As previously discussed in “Colorado Poised to Eliminate Animal Agriculture” this proposed referendum, while clearly intended to eliminate all animal agriculture and related industries in Colorado, is fraught with ambiguities.

Take, for example, the definition of the lifespan of a “chicken” purportedly living for eight years.

Attorneys will recall the basis of a case used by law professors teaching contracts and commercial law in which the definition of what “chicken” means was the basis of the lawsuit.  Frigaliment Importing Co. v. B.N.S. Intern. Sales Corp., 190 F.Supp. 116 (S.D.N.Y. 1960) begins with this question:

The issue is, what is chicken? Plaintiff says ‘chicken’ means a young chicken, suitable for broiling and frying.  Defendant says ‘chicken’ means any bird of that genus that meets contract specifications on weight and quality, including what it calls ‘stewing chicken’ and plaintiff pejoratively terms ‘fowl’.

If “chicken” means a young chicken, suitable for broiling and frying, then its normal life span would be approximately 35 to 49 days.

To make it even more ambiguous this is how USDA describes various forms of chicken:

The age of chickens used for meat can vary from 6 weeks to 1 ½ years old. Chickens labeled as ‘Broiler-fryers’ are young, tender chicken about 7 weeks old; ‘Roasters’ are older chicken, about 3 to 5 months old; ‘Capons’ are male chickens about 16 weeks to 8 months old; and ‘Stewing/Baking Hens’ are mature laying hens 10 months to 1 1/2 years old.

As reported by Dan Flynn in 2022 ballot measure could be “win or die” test for Colorado livestock industry published in Food Safety News, the National Western Stock Show, the Colorado Cattlemen’s Association, Colorado Livestock Association and Colorado Farm Bureau have joined forces to oppose the Initiative.

The criminalization of routine animal husbandry practices always angers farmers and ranchers and rightly so.  Those practices have been developed by animal scientists and agricultural extension agents to protect the animals from each other, predators, environmental hazards, infectious diseases, and also create safe work places for farmers and ranchers.

Unfortunately, Colorado is not the only state facing the threat to agriculture through a ballot initiative.  There is a proposed initiative under consideration in Oregon which is arguably even more egregious.  Look for discussion of that initiative in the near future.


As a veterinarian, if a pet-owner comes to you with questions or concerns about the safety of hemp or CBD infused pet products, are you prepared to navigate the conversation?

Practicing veterinarians are subject to the regulation of several entities, both state and federal, including the FDA, the DEA, and their respective state veterinary and pharmacy boards. Given the complexities of the laws regulating cannabis products at the federal and state levels, in addition to the independence that state boards have to control the intricacies of practice, it can be difficult for veterinarians to know what to say to pet owners, or if they can even say anything at all.

Meanwhile, the marketplace for cannabis pet products is exploding. Pet owners are left with a lot of purchasing options and questions about the safety, dosage, and effectiveness of these new products. While research about the safety and efficacy of cannabis pet products is ongoing, more robust, peer reviewed scientific evidence is needed to support labeling claims that such products prevent, mitigate, treat or cure a condition in animals. Under current FDA policy and regulations, such products would be considered an unapproved use of animal drug and veterinarians who administer, prescribe or recommend such products, including CBD products would be subject to disciplinary action.

While it may be clear that veterinarians cannot prescribe CBD pet products to clients, are there restrictions about what veterinarians can with their clients? In a crowded market, it seems natural that pet owners would turn to their veterinarians for guidance. A survey conducted by the Veterinary Information Network confirmed this; 63% of veterinarians surveyed said clients ask questions regarding cannabis pet products on a monthly, weekly, or daily basis.

While such discussions could arguably be protected under the First Amendment (see below), there has been guidance in some states (through regulation) whereby such discussions are expressly permitted or prohibited.

State Veterinary Medicine Boards

For example, since September 27, 2018, California prohibited the state veterinary medical board from disciplining or denying, revoking or suspending the license of a veterinarian for discussing the use of cannabis pet products with pet owners. In order to receive the protection of this legislation, there must be an existing veterinarian-client relationship, and the veterinarian must document the discussion in the patient’s medical records. That documentation must include evidence that the veterinarian discussed: the variability of cannabis products, that there is no oversight of product concentrations, and there is a lack of research and potential side effects that pets may experience. It is important to remember that this only protects the discussion; veterinarians are still currently prohibited from dispensing, administering or recommending cannabis products.

Similarly, Michigan recently amended the state Public Health Code to allow licensed veterinarians to consult with an animal owner on the use of marijuana or industrial hemp on the pet. Like California, Michigan’s update does not address actions beyond the “discussion” phase. However, on the other end of the spectrum, New Hampshire prohibits veterinarians from discussing cannabis use in pets with their clients. Veterinary boards from New Jersey and Pennsylvania have no published positions or policies on record.

Speech Regulation Concerns

Of additional concern are the potential implications of state veterinary boards’ regulation of professional speech. Generally, regulations of professional conduct that are part of a state’s licensing scheme are acceptable; however, the regulation of professional speech is much more complex. Currently, regulations of the practice of medicine that incidentally burden speech are given some level of deference and subject only to intermediate scrutiny when challenged under free speech theories. The explanation from the court in the recent case National Institute of Family and Life Advocates v. Becerra, 138 S. Ct. 1275 (2018) supports this concept. But the question remains, are the limitations on a veterinarian’s ability to discuss and recommend CBD pet products a permissible regulation of conduct, or do they cross the line into an unconstitutional regulation of professional speech? It is possible to have more concrete guidance soon; the well-known 5th Circuit Hines II case has been reversed and remanded for the district court to make a more thorough evaluation of the professional speech versus conduct concept.

In the coming months, especially as the cannabis market continues to develop, it will be important to monitor your state veterinary board’s policies and state regulations on the matter. It is likely that existing regulations, policies, and options for pet owners will continue to grow and develop with the cannabis pet product market.

To learn more about the regulation of hemp, hemp derivatives, and CBD in animal products, click here.

To learn more about labeling considerations for cannabis pet products, click here.

A referendum that would eliminate animal agriculture in Colorado has passed the initial challenges and has been approved for the collection of citizen signatures.

Colorado State Ballot Initiative titled “Protect Animals from Unnecessary Suffering and Exploitation” would amend the State criminal animal cruelty statute to:

  1. define “’Natural Lifespan’ for the following species . . . : a cow lives to 20 years, a chicken lives to 8 years, a turkey lives to 10 years, a duck lives to 6 years, a pig lives to 15 years, a sheep lives to 15 years, a rabbit lives to 6 years” and prohibit slaughter of those animals unless the animal has lived one quarter of their natural lifespan, and
  2. amend prohibitions of sexual acts with an animal to include: “any intrusion or penetration, however slight, with an object or part of a person’s body into an animal’s anus or genitals.”

The problems with the first set of amendments as written drafted to eliminate animal agriculture in its entirety, would fail to does so for the following reasons:

A “cow” is a female bovine that has had more than one calf.  A “heifer” is a female bovine older than a “calf.”  When she has her first calf, she is called a “first calf heifer.”

A calf; heifer; first calf heifer; bull; bob calf; veal calf; steer; slaughter heifer, bull, steer, cow are all defined in various state and federal laws which separates them from “cows” and would therefore be exempt from this law, if passed.

There are similar exemptions for broilers and lambs.

The lifespan for “pigs,” which are neonatal swine, is plainly wrong, so there should be no impact on swine slaughter if properly interpreted and enforced.

Issues with the amendments to prohibitions of sexual acts with an animal (including companion animals) include the following, some of which others have already identified:

  1. artificial insemination;
  2. pregnancy diagnosis by intra anal examination;
  3. castration; and
  4. spay.

While there is an exception for procedures that facilitate animal health that may provide exception for spay/neuter of dogs and cats, such exceptions may be more difficult to obtain for livestock (including horses).

In addition to these issues, if this referendum is actually passed, there appears to be numerous commerce clause, supremacy clause, due process, and takings clause arguments that could be claimed based on federal and state law.

Hopefully, media campaigns will be mounted by farmers, ranchers and trade associations that will prevail.

If not, legal action is warranted.

With the passing of the 2018 Farm Bill, the market for cannabis pet products has rapidly grown. As a result, broad-reaching marketing campaigns highlighting the available products and the claimed benefits have become much more prevalent. In response to the prevalence of these campaigns, the FDA and FTC have had to increase efforts to monitor and eliminate products with improper or misleading labels to protect pet owners. The FDA enforces laws that prohibit marketing and sales of misbranded and adulterated drugs and food, while the FTC focuses on eliminating any misleading or deceptive marketing practices. As part of the effort to curb inappropriately labeled cannabis pet products, the FDA has sent out several warning letters to companies that are producing, labeling and selling these products, often advising them that the identified product is an unapproved new animal drug. Warning letter language often states that the offending product is a:

“new animal drug, as defined by section 201(v) of the FD&C Act, 21 U.S.C. 321(v), because it is not generally recognized among experts qualified by scientific training and experience to evaluate the safety and effectiveness of animal drugs, as safe and effective for use under the conditions prescribed, recommended, or suggested in the labeling. To be legally marketed, a new animal drug must have an approved new animal drug application, conditionally approved new animal drug application, or index listing under sections 512, 571, and 572 of the FD&C Act, 21 U.S.C. 360b, 360ccc, and 360ccc-l.”

Companies that receive warning letters from the FDA must take “prompt” legal action to correct the identified violations, and are subsequently warned that failure to make a corrective change could result in additional legal action. The FTC has not currently sent independent warning letters to companies producing cannabis pet products. However, the FDA and FTC have issued several joint warning letters to cannabis pet product companies who are producing misleading and inappropriately labeled products.

Some states are independently regulating the cannabis and hemp space when it comes to pet products. For example, Florida currently permits pet food and pet treats to contain hemp (manufactured for both traditional and specialty pets). However, the product must not contain more than 0.3% tetrahydrocannabinol. Florida has also made labeling compliance in the hemp and animal product space user-friendly; the state has published a labeling checklist that clearly outlines the requirements. Now, businesses know what is required of them, and consumers know what they should be looking for.

What are the Current Risks?

Given the enormous amount of cannabis pet products in the marketplace, it can be hard to decide which one to select, or if you should select one at all, even if the labels seem to include a lot of information. Consulting with your veterinarian is advised, though they may be uncomfortable providing such advice, based on federal and/or state restrictions.

Other Concerns

There have been reports that pets that have consumed cannabis products intended for human consumption have become sick. Reported clinical signs include vomiting, dizziness, digestive complications, low blood pressure and dry mouth. Those risks become increasingly serious when pets consume cannabis products that contain dangerous additives (for pets) such as chocolate or raisins.

It is best practice to always research and examine any pet products before purchasing, especially when they contain cannabis. There are several national advocacy associations that also provide guidance and policy updates on the latest standards for animal feed. The Association of American Feed Control Officials (AAFCO) and National Animal Supplement Council (NASC) are two sources that can be referenced to help guide decisions about pet products.

To read about the regulation of hemp, hemp derivatives and CBD in animal products, click here.


If you are trying to navigate the space where hemp products intersects with animal products, it can be unclear as to which authority to turn to for guidance. In the United States, FDA, FTC, DEA and USDA share governance over the cannabis and hemp animal product industry, including regulations on labeling, distribution, growing, and sales. Understanding these intersecting laws and agency policies can help companies navigate this evolving marketplace.

The Food and Drug Administration (FDA)

Whether derived from marijuana or hemp, FDA considers CBD products to be drugs if intended for use (including advertisements) in the diagnosis, cure, mitigation, treatment or prevention of disease and/or intended to affect the structure or any function of the body. FDA considers products containing CBD marketed as animal food to be adulterated animal foods and are therefore prohibited pursuant to Section 301(II) of the FD&C Act, 21 U.S.C. 331(II), since the FDA found no evidence that the substance was marketed in food before the drug was approved (has not been approved for use in animals), or before the substantial clinical investigations involving the drug has been instituted. FDA would not consider CBD to be a “food additive” since it has not been generally recognized as safe (GRAS) among qualified experts under the conditions of its intended use, or unless the substance meets a listed exception.

FDA uses warning letters and enforcement actions to control how and what products are put into the marketplace. Failure to comply could result in product seizures, injunctions or civil and criminal penalties. In a 2019 FDA presentation, the agency highlighted its policy interests in regulating cannabis products. Among top priorities, the FDA is focused on both protecting the public from harmful or fraudulent products and encouraging scientific research in order to protect “the integrity of the conventional food supply.”

As an example, FDA has issued warning letters to several companies that produce cannabis pet products. These letters inform the companies of their violations, which typically are related to unfounded advertisements that the cannabis product can cure or treat a disease, which the FDA does not permit. Failure to make the appropriate changes after receipt of a warning letter could result in additional legal action.

The Federal Trade Commission (FTC)

The FTC regulates product advertisements to ensure that consumers are not being misled with false claims on product labels. Its regulating authority also permits it to freeze assets, seek temporary restraining orders, or institute civil litigation against companies or brands that engage in deceptive marketing practices. The FTC has sent warning letters to companies producing CBD infused products that state it is illegal to “advertise that a product can prevent, treat, or cure” a disease without the proper “competent and reliable scientific evidence.”

The Drug Enforcement Administration (DEA)

The DEA is responsible for overseeing the manufacturing, distribution, and advertising of controlled substances. Although the 2018 Farm Bill (see below) removed hemp from the definition of marijuana, marijuana remains a Schedule I controlled substance and the DEA continues to regulate it as such. The DEA has the authority to inspect products, issue warning letters, or enforce compliance with controlled substance regulations by issuing criminal or civil penalties.

Currently, the DEA does not give Schedule I clearance to health care practitioners, a category which includes veterinarians. As a result, veterinarians have no authority under the DEA to prescribe or recommend cannabis products. Doing so could subject them to DEA prosecution.

The United States Department of Agriculture (USDA)

Finally, the catalyst for the hemp product explosion – The 2018 Farm Bill. The Farm Bill is a package of legislation that is passed every 5 years. It shapes the programs, priorities and budgets for the USDA and its related entities. The 2018 Farm Bill removed hemp from the definition of marijuana and established the ability for states to work with the USDA to coordinate their own hemp production framework.

Current Status

Even though there have been many recent updates to hemp production and product regulation, there has not been much movement when it comes to changes on the cannabis pet products side. The FDA has not approved hemp or any hemp derivatives for use in any animal food, including animal treats. Furthermore, veterinarians who administer, prescribe or recommend CBD products with the intent to prevent, mitigate, treat or cure a condition in animals are utilizing the products as drugs. The FDA considers this to be unapproved animal drug use, subjecting the prescribing veterinarian to disciplinary action.

There are additional concerns that stem from the cannabis pet products industry. Check back for two additional blog posts that explore labeling concerns, potential side effects, current research efforts, and the regulation of cannabis pet products on an individual veterinarian basis.


In a case arising out of a series of cattle sales gone wrong, Fox Rothschild attorneys John Haggerty, Jim Clark and Jeremy Lacks recently obtained a summary judgment award of more than $740,000 for two central Pennsylvania cattle farms.

From December 2016 to July 2017, our clients, Nicholas Farms and Hottle Livestock, sold hundreds of cattle to an upstate New York cattle dealer called CAV Farms through its agent and middleman, Michael Rogers. CAV Farms, which is owned and operated by Jeffrey Snider, resold the cattle as processed beef to online grocer Fresh Direct for a substantial profit. Our clients received only a fraction of what they were owed on these cattle sales. When confronted, Snider claimed that his business partner—Rogers—had carried out the transactions without his knowledge or approval as part of a fraudulent scheme. Around the same time, Rogers, who was riddled with debts and facing a variety of criminal charges, disappeared.

We filed suit against Snider, CAV and a related entity in the Middle District of Pennsylvania in August 2018 alleging violations of the federal Packers & Stockyards Act, which protects livestock sellers by requiring full payment within two days of a sale, along with breach of contract and various equitable claims. Following two years of discovery, including a protracted, months-long effort to compel Rogers’ deposition (after he initially refused to testify based on the Fifth Amendment), we moved for summary judgment in September 2020.

On March 9, 2021, Judge Matthew Brann issued a 27-page opinion granting our Motion and entered judgment in our favor as to the Packers & Stockyards Act and breach of contract claims. Judge Brann criticized defendants’ legal arguments and cast doubt on their attempts to distance themselves from Rogers. At the outset, he summed up the case by noting that, having agreed to buy our clients’ cattle through Rogers, defendants “shorted Plaintiffs, refusing to pay, and claimed that Rogers was a ne’er do well, actually in the midst of defrauding Defendants through a sort of cattle-shifting Ponzi scheme.” Judge Brann dismissed this theory as unsupported by the record evidence.

On the key legal issues, Judge Brann found that the defendants were “dealers” for purposes of the Packers & Stockyards Act and that Rogers had carried out the transactions with defendants’ implied authority as their agent. Judge Brann further found that Snider was individually liable for the acts of the corporate entities he controlled under both the Packers & Stockyards Act and the doctrine of “piercing the corporate veil.” Judge Brann found that veil-piercing was appropriate in light of undisputed evidence of: (i) Snider’s domination of the corporate entities; (ii) the closely held nature of corporate entities; (iii) the absence of any corporate formalities; (iv) Snider’s commingling of corporate and personal funds; and (v) Snider’s “careful effort” to liquidate the entities’ assets and render them judgment-proof after Fresh Direct severed ties with defendants.

In all, Judge Brann awarded our clients over $743,000 to compensate them for their cattle, including prejudgment interest at a rate of 9% dating back to 2017.

A clearly misguided bill, S3402, was recently introduced in the New Jersey Senate that would prohibit veterinarians from euthanasia of animals suffering fatal disease or injuries for seven days if a cat or dog, having been seized by a law enforcement officer, places that animal in the care of a licensed veterinarian.  Specifically the bill states,

whenever a certified animal control officer, municipal humane law enforcement officer, county humane law enforcement officer, or other law enforcement officer seizes a cat or dog which the officer places in the care of a licensed veterinarian, veterinary hospital, or other establishment providing veterinary care to sick or injured animals because the officer believes the cat or dog is sick or injured and outside of the control of an owner, the licensed veterinarian, veterinary hospital, or other establishment providing veterinary care to sick or injured animals that receives the cat or dog shall hold the cat or dog and care for it for at least seven days.

The bill requires notification of the pets owner, if possible, but only permits euthanasia by a licensed veterinarian after seven days if the “animal is beyond recovery as determined by a licensed veterinarian.”  Such prohibition would necessarily require veterinarians, who diagnose incurable and painful conditions in such animals before the seven-day hold period, to keep those animals alive and suffering.  That cannot be the intended result of this bill, but sadly, that is how it is currently written.

Also, veterinarians would be required to provide care without reimbursement unless “the owner of the cat or dog is identified and the cat or dog is reclaimed by its owner.”  If the dog or cat is treated and survives and is sent to an animal shelter or animal rescue organization, the veterinarian would not be required to be reimbursed for such treatment.

To remedy these fatal issues with this bill, amendments should be introduced that (1) permits a licensed veterinarian to perform euthanasia when it is clear that the dog or cat would suffer terribly from a fatal condition if required to be kept alive for seven days; and (2) requires payment for veterinary services rendered from the jurisdiction placing that pet in the care of the veterinarian, if the pet is not reclaimed by its owner.


For those who do not receive notifications directly from USDA APHIS, please note that the agency has just announced that it has removed its Self-Reporting Incentive Program, included in the Animal Welfare Act Inspection Guide and published in Tech Note titled, “Incentives for Identifying, Reporting, Correcting, and Preventing Noncompliance with the Animal Welfare Act.”

The reason provided for this changes is that the guidance and program “is no longer representative of the current agency policy for documenting Animal Welfare Act non-compliances.”

The agency has come under scrutiny for the implementation of this policy which was implemented without promulgation of a proposed regulation pursuant to the Administrative Procedures Act.  It is unclear whether such scrutiny resulted in or contributed to this action.

The agency continues to offer assistance to licensees and registrants via its inspectors if a potential noncompliance issue is identified.

This change does not impact biomedical research facilities’ requirements to report to the Office of Laboratory Animal Welfare (OLAW) which enforces laws pursuant to the Public Health Service (PHS) Policy on Humane Care and Use of Laboratory Animal for the National Institutes of Health.

Well known animal rights activist, New York Assemblymember L. Rosenthal, has introduced a bill that seemingly runs afoul of federal law, that among other permissible shipments, allows the shipment of certain poultry through the mail, under specifically prescribed conditions. The language of the proposed bill would ban these and other federally lawful practices,

      Section 1. The agriculture and markets law is amended by adding a new section 382 to read as follows:

  •            382. Prohibition of the shipping of live animals by postal mail.

It shall be unlawful for any person, firm, partnership or corporation to mail or offer for mailing a live animal by postal mail into or within the state of New York or from the state of New York to points outside the state of New York. As used in this section, “live animal” shall mean any mammal, bird, reptile, or amphibian.  “Postal mail” shall mean mail that is processed and delivered by the United States postal service or other mail carrier.  A person, firm, partnership or corporation shall be considered to have mailed or offered for mailing a live animal in violation of this section when such person, firm, partnership or corporation causes such live animal and applicable postage or shipping fee to be physically placed in the possession of the United States postal service or other mail carrier.

As provided on an USPS website (see here ) the following animals are legally permitted to be shipped by mail, with certain requirements:

526 Mailable Live Animals

526.1 General

Some animals are mailable under proper conditions. See the specific instructions as noted for the following kinds of animals:

Live bees, 526.2 and Exhibit 526.21.

Live, day–old poultry, 526.3 and Exhibit 526.33.

Live adult birds, 526.4.

Live scorpions (only under limited circumstances), 526.5 and Exhibit 526.5.

Other small, harmless, cold–blooded animals, 526.6 and Exhibit 526.6.

The law requires USPS and shippers to provide for care of animals before and during shipment, and prohibits postal workers from rejecting a shipment if animals are properly protected.  It seems likely that the proposed bill, if challenged under the Supremacy clause of the Constitution of the United States, would be considered invalid.

GUEST COLUMNIST | Orlando Sentinel


More than 32 million doses of coronavirus vaccine have been administered in the United States, according to Feb. 3 data from the Centers for Disease Control and Prevention.

Many more are on the way. Pharmaceutical manufacturers are churning out hundreds of millions of doses. And just last month, Dr. Anthony Fauci, the director of the National Institute of Allergy and Infectious Diseases, said that the Food and Drug Administration could soon approve two more vaccine candidates.

This massive vaccination campaign is happening less than a year after health officials confirmed the first known case of the virus on U.S. soil. Now, we’re moving toward overcoming the pandemic. For that, we can thank animal research.

Consider how these vaccines came to be. The two vaccines currently authorized for use in the United States — developed by Moderna and a partnership between Pfizer and German firm BioNTech — were first determined effective in rhesus macaques. Humans share 93% of their DNA with these monkeys.

The next round of vaccines also has its roots in research in monkeys. Maryland-based Novavax, whose shot is in phase 3 clinical trials in humans, reported in July that the mice and non-human primates that received its vaccine developed an immune response after the first dose.

British drug firm AstraZeneca’s vaccine, which just received authorization in the United Kingdom, first proved itself in preclinical trials in monkeys at the University of Oxford. The vaccine candidate Johnson & Johnson developed — which, in contrast to the others, only requires one dose — is the product of research in rhesus macaques, too.

These latter two vaccines inject recipients with an adenovirus containing DNA with instructions for building the spike protein that rings the coronavirus. A person’s cells then start building that spike protein, which primes the immune system to produce antibodies that can neutralize the coronavirus and mark it for destruction.

Researchers have been investigating adenovirus vaccines in nonhuman primates for years in hopes of developing an easily modifiable template for fighting just about any pathogen. European regulators approved Johnson & Johnson’s adenovirus vaccine against Ebola in July. Work on adenovirus vaccines that would inoculate against HIV, influenza, and several other viruses is underway.

The vaccines developed by Moderna and the Pfizer-BioNTech team utilize a different approach. They build on the work of two University of Pennsylvania scientists who discovered over two decades ago that messenger RNA-based vaccines could initiate the creation of disease-fighting proteins in mice.

These mRNA vaccines introduce a sequence of mRNA that codes for a disease-specific antigen into the body’s cells. Once the body produces this foreign antigen, the immune system recognizes it and produces antibodies against it.

This technology has implications for many diseases beyond COVID-19. Scientists are developing mRNA-based Zika and flu vaccines.

BioNTech is also working on an mRNA vaccine against multiple sclerosis, which afflicts 2.3 million people worldwide. Existing treatments for MS suppress the immune system and consequently leave patients vulnerable to infection. The new mRNA technology targets specific MS-related proteins without compromising normal immune function.

The early returns are promising. The vaccine successfully alleviated symptoms in sick mice and prevented progression in those showing early signs of the disease.

Some critics of animal research have wondered how scientists could have developed the COVID-19 vaccine in less than a year when previous vaccines took decades to bring to market. Was it possible to skip some of the stages that have historically required animals in order to speed things up?

Hardly. Scientists conducted the basic research that’s at the foundation of every COVID-19 vaccine in animals.

After the pandemic hit, researchers first tested vaccine candidates for safety and some indication of efficacy in animal models. Then, with the permission of regulators, they tested the candidates for efficacy simultaneously in humans and animals.

It’s remarkable that scientists have been able to develop effective vaccines for COVID-19 within months. Animal research was instrumental in that effort — and will be behind the next miracle medical science brings about.


Matthew R. Bailey is president of the Foundation for Biomedical Research, a Washington, D.C.-based nonprofit that promotes ethical animal research.