Refining IACUC Protocols to Minimize Animal Pain and Distress

By Dr. Zubair Khalid, DVM, MS, PhD ·

Refining IACUC Protocols to Minimize Animal Pain and Distress

Key Takeaways

  • Prospective Severity Classification is Crucial: Assigning specific severity categories (mild, moderate, severe) to each distinct procedure within a protocol before approval is essential for identifying and addressing potential pain and distress. This classification must account for the expected intensity and duration of pain or distress, and protocols should include criteria for upgrading classification based on clinical observations.
  • Multimodal Analgesia and Rescue Criteria are Paramount: For procedures expected to cause pain, a comprehensive analgesic plan is required, detailing drug class, route, and timing. Crucially, this plan must include explicit, objective criteria for administering rescue analgesia when pain scores exceed predefined thresholds, preventing undertreatment.
  • Humane Endpoints Must Be Prospectively Defined and Validated: Establishing objective, measurable humane endpoints before study initiation is critical for preventing prolonged suffering. These criteria should be a combination of parameters (e.g., tumor size, body condition score, weight loss) and validated through pilot studies to ensure they are neither too lenient nor too strict.
  • Distinguishing Pain from Distress Requires Targeted Interventions: Pain, a sensory and emotional experience from tissue damage, requires analgesics, while distress, a broader state of maladaptive responses to stressors, may necessitate environmental modifications, social housing adjustments, or refined handling techniques. Protocols must address both.
  • Pilot Studies Validate Refinements and Inform Severity: Small pilot cohorts are vital for testing the efficacy of proposed pain and distress reduction strategies (e.g., analgesic regimens, handling techniques) and for generating data to justify refinements and potentially lower the initial severity classification of a procedure.
  • Documentation and Monitoring Drive Continuous Improvement: Detailed recording of implemented refinements, welfare outcomes, and monitoring data is essential for future protocol iterations and IACUC review. Monitoring frequency should be scaled to anticipated severity and procedure phase, utilizing objective parameters with defined intervention thresholds.

This article provides practical strategies for veterinary researchers who design, review, or revise Institutional Animal Care and Use Committee (IACUC) protocols with the explicit goal of reducing pain and distress in research animals. It serves investigators preparing new submissions, attending veterinarians evaluating proposed procedures, and IACUC members who must distinguish meaningful refinement from cosmetic changes. The clinical question at the center is direct: which specific modifications to housing, handling, procedural technique, anesthesia, analgesia, and endpoint criteria produce measurable welfare gains without compromising scientific validity?

The framework throughout is the refinement arm of the 3Rs, applied at the level of protocol design instead of institutional policy. Regulatory compliance is addressed only where it intersects with clinical judgment. The emphasis falls on decision criteria, monitoring parameters, and named failure modes that a veterinary researcher can apply across species, from laboratory rodents to wild mammals studied in the field.

At a Glance

ParameterConsiderationReference Point
Refinement definitionAny modification that reduces pain, distress, or lasting harm without undermining study objectivesNC3Rs refinement guidance
Severity classificationAssign prospective severity categories to each procedure before approvalGuide for the Care and Use of Laboratory Animals
Pain management planMust include drug class, route, timing, and rescue criteriaAVMA professional practice resources
Endpoint criteriaDefine humane endpoints prospectively, not after morbidity appearsGuide for the Care and Use of Laboratory Animals
Wild mammal protocolsField capture, marking, and transport require species-specific refinementAmerican Society of Mammalogists guidelines
Monitoring frequencyScale to anticipated severity and procedure phaseNC3Rs refinement guidance
Pilot dataUse small cohorts to validate refinement before full study launchNC3Rs refinement guidance
DocumentationRecord refinements and welfare outcomes for future protocol iterationsGuide for the Care and Use of Laboratory Animals

The Scientific Basis for Refinement

Refinement rests on the premise that pain and distress are measurable biological states with identifiable physiological, behavioral, and neuroendocrine correlates. A protocol that does not define these correlates cannot meaningfully claim to minimize suffering. The attending veterinarian's role is to translate clinical assessment skills into objective, repeatable criteria that research staff can apply consistently.

The Guide for the Care and Use of Laboratory Animals establishes the institutional expectation that protocols address pain and distress as scientific variables, also ethical obligations. Pain influences physiology, behavior, and experimental outcomes. A stressed animal produces different endocrine profiles, altered immune responses, and variable pharmacokinetics. Refinement therefore protects data quality as much as animal welfare.

Distinguishing Pain from Distress

Pain is a sensory and emotional experience associated with actual or potential tissue damage. Distress is a broader state in which an animal cannot adapt to stressors and shows maladaptive physiological or behavioral responses. The two frequently coexist but require different interventions. Pain responds to analgesics and local anesthetics. Distress may require environmental modification, social housing changes, or refinement of handling techniques.

The American Society of Mammalogists guidelines emphasize this distinction for wild mammals, where capture and restraint can produce distress independent of any painful procedure. A protocol that addresses analgesia but ignores capture-related distress has not achieved refinement.

Severity Classification as a Refinement Tool

Prospective severity classification forces the investigator to think through each procedure phase before it occurs. The Guide for the Care and Use of Laboratory Animals describes a framework in which procedures are assigned to categories ranging from mild to severe based on the expected intensity and duration of pain or distress.

The classification should be applied to each distinct procedure within a protocol, not to the study as a whole. A survival surgery with postoperative analgesia may be moderate while the subsequent blood collection is mild. Assigning a single severity score to the entire study obscures where refinement is most needed.

Where Classification Fails

Classification systems fail when they are applied retrospectively or when they describe the procedure as intended instead of as performed. A laparotomy classified as moderate becomes severe if postoperative analgesia is inadequate or if the animal does not resume normal behavior within the expected window. The protocol must include criteria for upgrading severity classification when clinical observations warrant it.

Refinement Across the Protocol Lifecycle

Refinement opportunities exist at every stage, from animal acquisition through study completion. The NC3Rs refinement guidance organizes these opportunities into practical categories that map directly onto protocol sections.

Animal Acquisition and Acclimation

Transport and relocation are among the most distressing events in a research animal's life. The protocol should specify an acclimation period that matches the species and the magnitude of the environmental change. Social species should be transported and housed with familiar conspecifics where the study design permits. The American Society of Mammalogists guidelines note that wild mammals may require extended acclimation before handling procedures are initiated, and that some species never habituate to captivity.

Handling and Restraint

Handling refinement reduces distress before any procedure begins. Positive reinforcement training, tunnel handling for rodents, and minimal restraint for rabbits are techniques that reduce stress hormone responses and improve cooperation. The protocol should specify the handling method and the training plan for personnel. Restraint duration should be justified and minimized, with explicit criteria for when restraint will be terminated.

Procedural Technique

Surgical technique refinement includes smaller incisions, atraumatic tissue handling, and appropriate suture materials. Nonsurgical refinements include using the least invasive blood collection route that meets study needs, applying topical anesthetics before venipuncture, and warming animals before tail vein injection to reduce struggling.

The Role of Pilot Studies

Pilot studies serve a dual refinement function. They allow the investigator to test whether a proposed refinement actually reduces pain or distress, and they generate the preliminary data needed to justify the refinement to the IACUC. A pilot cohort of three to five animals can reveal whether a new analgesic regimen provides adequate coverage, whether a handling technique produces measurable stress reduction, or whether a humane endpoint is being reached earlier than predicted.

The NC3Rs refinement guidance encourages investigators to use pilot data to refine endpoints, analgesic protocols, and monitoring schedules before the full study begins. Pilot data should be reported to the IACUC as part of the protocol review process, particularly when the pilot suggests that the original severity classification was inaccurate.

Analgesic Planning and Multimodal Strategies

Analgesic planning should begin at protocol conception, not after the procedure. The severity classification assigned to a procedure dictates the minimum analgesic expectation, but the reverse also applies: a well-designed analgesic plan can lower the severity classification of an otherwise painful intervention. This bidirectional relationship is the core of refinement-oriented protocol design.

The first decision point is whether the procedure is expected to produce pain at all. Procedures that do not involve tissue injury, such as brief handling or noninvasive imaging, may require no analgesics. Procedures involving incision, inflammation, visceral manipulation, or orthopedic intervention require a plan that addresses both incisional and visceral pain components. The Guide for the Care and Use of Laboratory Animals states that the selection of analgesics should be based on the species, the procedure, and the expected duration and intensity of pain, and that the plan must be documented in the protocol.

Multimodal analgesia is the default expectation for moderate to severe procedures. Combining an opioid with a nonsteroidal anti-inflammatory drug (NSAID) and a local anesthetic block addresses different pain pathways and reduces the required dose of any single agent. The protocol language should specify the drug class, route, timing relative to the procedure, and the criteria for additional rescue analgesia. Rescue criteria are the most commonly omitted element. A protocol that states "buprenorphine q8-12h" without defining what observation triggers an unscheduled dose leaves the clinical team without a decision framework.

Local and regional anesthesia deserves explicit protocol language. For procedures where a nerve block or local infiltration is anatomically feasible, the protocol should name the block technique, the maximum number of blocks per animal, and the method for confirming block efficacy before the surgical incision begins. The MSD Veterinary Manual provides species-specific guidance on local anesthetic techniques and their contraindications, which is particularly relevant when adapting a protocol across species.

The analgesic plan must include a tapering or discontinuation strategy. Abrupt cessation of opioids after several days of use can produce withdrawal-associated distress that confounds study endpoints. The protocol should state the duration of analgesic coverage relative to the expected pain duration, not a fixed number of doses.

Refining Surgical and Postsurgical Protocols

Surgical protocols are the highest-yield targets for refinement because they combine multiple pain sources: skin incision, muscle retraction, visceral manipulation, and postoperative inflammation. The protocol should specify the surgical approach, also the procedure name. For example, a laparotomy protocol that specifies a midline incision, the use of atraumatic retractors, and moistened laparotomy sponges for tissue protection gives the surgical team concrete guidance that reduces tissue trauma.

Aseptic technique is a refinement measure, also an infection control measure. Surgical site infection prolongs pain and distress and can invalidate study data. The protocol should specify the skin preparation sequence, the surgeon's hand hygiene and sterile attire requirements, and the sterility maintenance plan for instruments. The AVMA professional practice resources include guidance on perioperative care standards that can be adapted into protocol language.

Postsurgical monitoring frequency should be matched to the risk period. The highest-risk period for pain and complications is the first 12 to 24 hours after recovery from anesthesia. The protocol should specify a monitoring schedule that includes at least one assessment during the immediate recovery period, followed by a defined schedule that can be escalated if the animal's score crosses a threshold. The monitoring parameters and their thresholds are discussed in the next section.

Wound care is a refinement opportunity that is frequently under-specified. The protocol should state the expected appearance of the surgical site at each postoperative day, the signs that warrant veterinary intervention, and the plan for suture or staple removal. For species that may self-traumatize the incision, the protocol should specify the type of protective device, such as an Elizabethan collar or body wrap, and the criteria for its use.

Monitoring Parameters and Scoring Systems

A monitoring system is only useful if it produces a decision. The protocol should define the parameters to be assessed, the frequency of assessment, and the score at which intervention is triggered. A simple three-tier system works well: green (within expected range, continue routine monitoring), yellow (mild deviation, increase monitoring frequency and consider intervention), and red (severe deviation, immediate veterinary intervention).

The table below summarizes commonly used monitoring parameters, what each detects, and the intervention threshold logic.

ParameterWhat It DetectsTypical Yellow ThresholdTypical Red Threshold
Body weight changeDehydration, reduced food intake, disease progression5-10% loss from baseline>15% loss or rapid loss over 24 hours
Food and water intakePain, nausea, stress, inability to access resourcesReduced intake for 24 hoursNo intake for 24 hours or >50% reduction for 48 hours
Activity and posturePain, depression, neurologic compromiseReduced activity, hunched postureImmobility, recumbency, inability to rise
Grooming behaviorPain, stress, dermatologic diseaseUnkempt coat, reduced groomingSelf-trauma, barbering, alopecia
Facial expression and vocalizationAcute pain, distressGrimace score above species baselineContinuous vocalization, severe grimace
Respiratory rate and effortPain, respiratory disease, anesthetic complicationsMild tachypneaDyspnea, open-mouth breathing
Heart rate and mucous membrane colorCardiovascular compromise, pain, shockMild tachycardia, pale membranesSevere tachycardia or bradycardia, cyanosis
Fecal and urine outputGastrointestinal stasis, renal function, obstructionReduced output for 24 hoursNo output for 48 hours or evidence of obstruction

The thresholds in this table are starting points, not universal standards. The protocol should establish baseline values for each animal or cohort before the procedure, because a 10% weight loss may be trivial in an obese animal but critical in a cachectic one. The NC3Rs refinement resources provide species-specific guidance on welfare assessment and scoring that can be adapted to individual protocols.

The monitoring plan must specify who performs the assessments and how inter-observer reliability is maintained. A single trained observer is preferable for consistency, but if multiple observers are required, the protocol should include a training and calibration step. The assessment form should be part of the protocol appendix, with space for the score, the observer's initials, and the time of assessment.

Refining Experimental Endpoints

Endpoint refinement is the most consequential refinement decision because it determines the maximum pain and distress an animal will experience. The protocol should define the humane endpoint prospectively, with objective criteria that do not rely on a single observer's judgment. The criteria should be specific enough that any trained observer would reach the same decision.

The endpoint criteria should include a combination of parameters, not a single measure. For example, a tumor study endpoint might be "tumor diameter exceeds 20 mm, or tumor ulceration with discharge, or body condition score drops below 2, or the animal loses more than 15% of baseline body weight." The use of "or" is important: an animal meeting any single criterion is euthanized, not an animal meeting all criteria.

The protocol should distinguish between the humane endpoint and the experimental endpoint. The experimental endpoint is the point at which study data are complete. The humane endpoint is the point at which the animal's welfare is compromised. These may coincide, but when they do not, the humane endpoint takes precedence. The protocol should state this explicitly.

Endpoint criteria must be validated during the pilot phase. A pilot study that tests the endpoint criteria on a small cohort can reveal whether the criteria are too strict, leading to unnecessary euthanasia, or too lenient, allowing animals to experience avoidable distress. The American Society of Mammalogists guidelines for wild mammals emphasize that endpoint criteria should be developed in consultation with a veterinarian and should account for species-specific biology, which is particularly relevant for wild species where baseline parameters may differ from laboratory-adapted strains.

Protocol Language That Enables Refinement

The wording of a protocol determines what the clinical team is permitted to do. Vague language creates ambiguity, overly restrictive language prevents appropriate intervention. The protocol should use language that grants clinical discretion within defined boundaries.

Effective protocol language uses conditional structures. Instead of "administer buprenorphine for 48 hours," write "administer buprenorphine for a minimum of 48 hours, and continue beyond 48 hours if the pain score exceeds the yellow threshold." This gives the clinical team authority to extend analgesia without requiring a protocol amendment.

The protocol should include a standing order for rescue analgesia. This is a pre-approved intervention that the clinical team can administer without contacting the attending veterinarian, provided the triggering criteria are met. The rescue order should specify the drug, dose, route, and the conditions under which it is administered. It should also specify the follow-up action, such as "notify the attending veterinarian within 4 hours of rescue administration."

The protocol should include a section for unexpected findings. This section should state that any observation not consistent with the expected postoperative course, such as neurologic signs, hemorrhage, or wound dehiscence, requires immediate veterinary consultation and may result in early euthanasia. This language protects the animal without requiring the clinical team to make a judgment call about whether a complication is "bad enough" to warrant intervention.

Finally, the protocol should include a mechanism for refinement during the study. A line such as "the attending veterinarian may modify the analgesic plan, monitoring frequency, or endpoint criteria based on clinical findings, with notification to the IACUC at the next review" allows real-time refinement while maintaining oversight. This provision is consistent with the Guide for the Care and Use of Laboratory Animals, which expects the veterinarian to have authority to intervene in the welfare of any animal in the facility.

Recognized Failure Modes and Early Detection

Refinement failures typically present through predictable patterns. The most common is silent deterioration, where an animal meets humane endpoint criteria on paper but the scoring system is applied too infrequently or at times when clinical signs are masked. A second pattern is scoring fatigue, where observers habituate to abnormal posture, reduced grooming, or mild dehydration and recalibrate their baseline to an unacceptable standard. A third is analgesic underdosing driven by fear of respiratory depression or ileus, particularly in rodents and rabbits, where subtle pain behaviors are mistaken for sedation.

Early detection depends on scheduled, time-anchored assessments instead of ad hoc checks. Observations should be tied to procedure-specific time points, such as 2, 6, 12, and 24 hours after surgery, then daily until the animal returns to baseline. The Guide for the Care and Use of Laboratory Animals emphasizes that the veterinarian must define the monitoring schedule and that the schedule must be proportionate to procedure severity. For wild mammals, the American Society of Mammalogists guidelines note that capture and marking procedures require species-specific monitoring because stress responses differ markedly from laboratory-adapted strains.

A reliable early warning sign is deviation from an individual baseline, not deviation from a species norm. Weight loss of 10% in a well-conditioned adult may be trivial, while the same loss in a juvenile or a debilitated animal signals decompensation. Body weight, food and water intake, fecal output, and spontaneous locomotion should be tracked as continuous variables, with alarm thresholds set before the study begins.

Common Errors and Corrective Actions

Less experienced personnel most often err in three areas. First, they score pain and distress as a single category, conflating a painful surgical site with systemic distress from dehydration or sepsis. The corrective action is to use separate scoring domains for pain, hydration, nutrition, and behavior, each with its own intervention trigger. Second, they delay analgesia until pain is obvious, when the goal is pre-emptive and scheduled administration. Third, they treat the scoring sheet as documentation instead of a decision tool, recording scores without acting on them.

Students and trainees frequently misidentify normal species behavior as distress. Nocturnal rodents resting during the day are not moribund. Rabbits sitting quietly with ears back may be thermoregulating, not in pain. The corrective action is supervised, side-by-side assessment with an experienced clinician until inter-observer reliability is acceptable. The NC3Rs resources on refinement provide practical checklists for recognizing pain behaviors across common laboratory species.

ObservationLikely causeDiscriminating check
Hunched posture, piloerectionPain, cold, or systemic illnessResponse to analgesia trial, ambient temperature, hydration status
Reduced food intake, weight lossPain, stress, or dental/ gastrointestinal diseaseExamine oral cavity, assess fecal output, check analgesic coverage
Self-trauma or wound interferenceInadequate analgesia or bandage irritationInspect surgical site, evaluate analgesic duration and dose
Aggression or vocalisation on handlingPain on restraint or learned aversionObserve response to gentle handling, assess analgesic adequacy
Lethargy with normal vital signsSedation, hypoglycemia, or early sepsisBlood glucose, temperature, reassess analgesic regimen

Limitations of the Evidence Base

The evidence for specific refinement strategies is uneven. Analgesic efficacy data are robust for common laboratory species such as rats, mice, and rabbits, but sparse for many wild species, reptiles, and production animals used in research. The MSD Veterinary Manual provides species-specific pharmacology, yet for many non-traditional species the clinician must extrapolate from closely related taxa with explicit acknowledgment of uncertainty. The American Society of Mammalogists guidelines acknowledge that field conditions impose constraints, such as inability to monitor continuously or to provide postoperative warmth, that require protocol-specific risk assessment.

Expert opinion differs on several points. Some clinicians advocate scheduled analgesic administration regardless of observed pain, while others prefer rescue analgesia triggered by scoring thresholds. The former risks unnecessary drug exposure, the latter risks undertreatment in stoic species. Similarly, the value of environmental enrichment as a distress-reduction tool is accepted broadly, but its interaction with experimental variables is contested, particularly in neuroscience and behavioral studies where enrichment may alter baseline physiology.

Referral, Consultation, and Escalation

Referral is warranted when an animal fails to respond to first-line analgesic and supportive care, when pain is refractory or escalating despite multimodal therapy, or when the clinical picture suggests a complication outside the research team's expertise. The attending veterinarian must have authority to intervene without protocol amendment, and the Guide for the Care and Use of Laboratory Animals is explicit that veterinary care takes precedence over study objectives.

Specialist consultation is appropriate for species with unusual anatomy or physiology, for complex surgical procedures, and for behavioral distress that does not respond to standard environmental modification. Laboratory animal medicine specialists, wildlife veterinarians, and anesthesiologists each bring distinct expertise. The AVMA practice resources offer guidance on professional obligations when animal welfare concerns arise.

Regulatory reporting is required when an animal experiences unanticipated pain or distress, when a protocol deviation causes harm, or when a humane endpoint fails. The WOAH terrestrial animal health standards address welfare obligations in research and teaching contexts, and institutional policies define the reporting pathway. The threshold for reporting is not the occurrence of pain, which is anticipated in many protocols, but the occurrence of pain or distress that exceeds what the protocol described and approved.

Frequently Asked Questions

How do I refine a protocol when the ideal equipment or analgesics are unavailable?

Prioritize refinements by welfare impact and feasibility. When a specific drug or device is unavailable, consult the MSD Veterinary Manual for species-appropriate alternatives within the same drug class or mechanism. For example, if a preferred opioid is unavailable, a different opioid with comparable duration and receptor profile may suffice, provided the attending veterinarian approves the substitution. For equipment, consider whether a manual technique can achieve the same outcome with less distress, such as using a well-designed restraint device instead of chemical immobilisation. Document the limitation and the alternative in the protocol. The Guide for the Care and Use of Laboratory Animals requires that veterinary staff have authority over animal care decisions, so escalate persistent shortages through that channel instead of accepting suboptimal care silently.

What refinements matter most for wild mammals studied in the field?

Field studies present constraints that laboratory protocols do not. Capture methods, handling duration, and marking techniques often dominate the welfare profile. The American Society of Mammalogists guidelines for wild mammal research specify that trap checks must occur at intervals appropriate to the species and environmental conditions, and that anesthesia protocols must account for thermoregulatory and metabolic changes during capture. Refinement priorities include pre-screening trap sites to reduce capture of non-target species, using traps that minimize injury, and limiting handling time to the minimum needed for data collection. For marking, choose the least invasive method that meets study objectives. Pilot data on capture-related stress responses, such as corticosteroid levels or heart rate, can guide protocol adjustments before full-scale deployment.

How should I document refinement decisions in protocol records?

Record the rationale, also the decision. For each refinement, note the welfare problem identified, the options considered, the evidence or clinical judgment supporting the chosen approach, and the outcome measures used to verify improvement. The NC3Rs guidance on refinement recommends that protocols describe refinements in measurable terms, such as specific score thresholds that trigger intervention. Include dates of protocol amendments and the names of personnel who approved them. When a refinement fails to produce the expected welfare benefit, document that too, as it prevents repetition of ineffective strategies. This record also supports retrospective review when the IACUC evaluates whether the protocol achieved its refinement goals.

How do refinement strategies differ between rodents and larger species like swine or nonhuman primates?

Body size, social structure, and husbandry requirements change the practical emphasis. For rodents, refinements often focus on environmental enrichment, group housing compatibility, and minimally invasive sampling techniques. For swine, analgesic protocols, surgical technique, and postsurgical monitoring dominate because of the frequency of survival surgery. Nonhuman primates require attention to psychological distress, social housing, and training for voluntary cooperation with procedures. The Guide for the Care and Use of Laboratory Animals addresses species-specific housing and environmental needs, while the MSD Veterinary Manual provides pharmacological differences relevant to analgesic selection. Always verify that a refinement validated in one species transfers safely to another, as metabolic and behavioral differences can alter both efficacy and risk.

What do I do when a supervisor or collaborator resists protocol refinements?

Frame the discussion around data quality and study validity instead of welfare alone. Pain and distress introduce physiological variables, such as altered stress hormone levels and immune function, that can confound experimental results. Present the refinement as a method to reduce variability, which strengthens the scientific conclusions. The AVMA practice resources include guidance on professional communication and ethical obligations that support this conversation. If resistance persists, involve the attending veterinarian or the IACUC, as institutional policy typically requires that veterinary staff have authority to intervene when animal welfare is compromised. Document your concerns and the response in writing. Most resistance stems from perceived cost or delay, so prepare a brief analysis of time and resource implications before the meeting.

How can I reduce pain and distress when funding limits refinement options?

Low-cost refinements often yield substantial welfare gains. Adjusting cage density, providing simple nesting materials, and modifying handling technique require minimal expenditure. The NC3Rs resources include practical refinements that are inexpensive to implement, such as habituation to handling and optimizing injection routes. Prioritize refinements that address the most severe welfare issues first, using severity classification to rank interventions. For costly items, such as specialised housing or imaging equipment, consider sharing resources across protocols or institutions. Pilot studies can test a refinement on a small number of animals before committing resources to full implementation. When budget constraints prevent an ideal refinement, document the compromise and revisit it at protocol renewal, as priorities and funding may shift.

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This article is educational professional reference material for veterinary audiences. It is not a substitute for veterinary diagnosis, individual clinical judgment, current product labeling, or applicable regulatory requirements.