Ethics of Research involving animals
Conclusions and recommendations: The context of the debate
15.21 Before we present the conclusions and recommendations, we must clarify two important points:
- Members of the Working Party who believe that research using animals is, on balance, justified, as well as those members who take the view that it poses a moral dilemma, find most research which is currently undertaken to be acceptable. They are cautious of any proposals that might undermine progress in basic and applied sciences which, they believe, in specific areas crucially depends on research involving animals. Other members who, within the spectrum of possible views, are closer to the abolitionist view, are implacably opposed to the use of sentient animals for any scientific or medical purposes, and assert that other methods must be used to ensure progress. They are equally cautious of any proposals that prolong or legitimise the infliction of pain and suffering on sentient animals. We emphasise that the recommendations that follow below, several of which aim to improve the conditions in which animals are used, should not be taken to imply the acquiescence of the latter group to animal experimentation. These members acknowledge that animals are currently subjected to experiments and believe that they need protection. While they continue to advocate that the recommendations should go further in specific areas, they accept them as steps in the right direction, without endorsing research involving animals in principle.
- Because of the diversity of views and beliefs within the Working Party, it has not been possible to achieve complete agreement on all of the recommendations by all members of the group. In our discussions, however, and in discussion with the Council, it became clear that in the context of a highly polarised debate it is crucial to make unambiguous recommendations in specific areas. While it is therefore not possible to attribute to all members of the group the conclusions and recommendations presented on any one issue, all members do accept the recommendations as valid contributions to the debate, clarifying further important implications of the more abstract thoughts presented in the consensus statement above. Nonetheless, on a few occasions it did not prove possible to identify positions that were acceptable to all members. In such instances we have tried to explain the reasons why some members could not agree with particular conclusions or recommendations. We hope that the descriptions of disagreement help to clarify the nature of the underlying dispute in a constructive way.
The context of the debate
General observations
15.22 Members of the research community who use animals in their work frequently refer to evidence from opinion polls to support their claim that most people support research on animals because of the benefits to humans. They take the view that more information on the benefits of research involving animals would help engender further support from the public. Those who are fundamentally opposed to research involving animals, and those who are primarily concerned about the pain and suffering it may cause, also use evidence from opinion polls to support their views. They often claim that most people would share their views if only they knew more about the welfare implications of research. While evidence from opinion polls should be treated with some caution (paragraph 1.16), many people would like more information on research involving animals, some asserting that it takes place in secret (see paragraph 2.19).
15.23 One response to this situation would be to improve transparency and openness, which should serve the interests of all the various parties concerned with issues raised by animal research. Freedom of information is crucial to informed debate in democratic pluralistic societies (paragraph 14.63). Increased openness and transparency should therefore be encouraged, subject to safeguards for confidentiality of proprietary information and assurances that the safety and security of those involved in animal experimentation will not be compromised. Such an approach would also be consistent with the requirements of the FoI Act (Box 13.4).
15.24 We therefore consider first how provision of information by the Home Office can be improved, especially in relation to the presentation of the Statistics, details about granted licences for research and the way the cost-benefit assessment is carried out. We then explore ways in which discussion between those involved in research and interested stakeholders can be improved; consider issues raised by the conduct of public debates on animal experimentation; and review the role of scientists, campaigning organisations and teachers in education and higher education. We also comment on the practice of using violence and intimidation as means of protest against animal research.
Provision of information by the Home Office
Statistical information about the number of animals used and the suffering involved
15.25 The Annual Statistics of Scientific Procedures on Animals, published by the Home Office, have an important role in providing information about animal experimentation. At the same time, there is wide agreement that the data are presented in ways that are not readily accessible to lay people, and that the presentation could be improved. In particular, the Statistics have been criticised for not providing clear answers to the following questions: (i) what is the nature, level and duration of pain, suffering and distress actually experienced by animals used in the different kinds of procedures? and (ii) how many animals are used in procedures and related activities?
15.26 It is not possible to answer the first question, because information about welfare implications is only provided prospectively, in the process of the licence application (see paragraph 13.14). By definition, it is not possible to know in advance how animals will be affected in practice, and data from separate interim or retrospective analyses are not reported publicly.
15.27 Information about the degree of pain and suffering can, in some sense, be inferred from the Statistics about the severity bands assigned to granted project licences. These are classified in one of three bands: mild, moderate or substantial (see Box 13.3). But over the five-year period of a project licence, a range of different protocols, themselves assigned different severity limits, may be carried out. It is questionable how meaningful it is to average out the different limits under one band, in order to provide the public with accurate information. For example, it may be the case that a project that contains ten mild protocols, each involving 10,000 animals, and one protocol with a substantial severity limit involving 50 animals, would still be classified as mild.3 Furthermore, it has also been suggested that the category of moderate protocols ‘appears to be something of a catchall, covering a wide range of the more invasive procedures’.4 We make the following observations.
15.28 Information about the suffering that animals involved in procedures experience in practice is unsatisfactory. We recommend that the Home Office should make retrospective information about the level of suffering involved during procedures publicly available. In gathering this information the Home Office should also obtain and make available, retrospectively, information about the extent to which the scientific objectives set out in applications have been achieved.
15.29 The terminology used to describe the severity of projects and individual protocols and procedures is not straightforward and therefore difficult for members of the public to understand. We recommend that the annual Statistics should provide case studies of projects and procedures that were categorised as unclassified, mild, moderate or substantial. Case studies should also include examples of animals used over extended periods of time and should describe not only their immediate involvement in research but also the range of factors that influenced their life experiences, such as the conditions of breeding, housing and handling (see paragraph 4.31).
15.30 The current system of severity banding for project licences and the severity limits for procedures should be reviewed, particularly the use of the moderate category which covers a wide range of different implications for animal welfare. For the general public, the category unclassified, which refers to protocols and procedures involving terminally anaesthetised animals, is too vague to be informative, and should be clarified.5
15.31 The Statistics give details about the total number of animals used for the first time in a year, and the total number of procedures initiated in that year (paragraph 13.27). As we have said, the term procedure refers to a wide range of activities, with very different implications for animal welfare which may arise from breeding, the withdrawal of blood, or experiments where death can be the endpoint. It is not straightforward to infer from the number of procedures undertaken how many animals have experienced what kind of pain, suffering or distress.
15.32 The humane killing of animals by means set out in Schedule 1 of the A(SP)A, for whatever purpose, is not itself a licensed procedure. Animals killed in this way are therefore not recorded in the Statistics. Many would argue that possession of a life is a morally relevant feature, and that it is therefore important to provide information about the number of animals that are killed humanely (paragraphs 3.47, 13.26 and 14.5).
15.33 We realise that the system of collecting data about the numbers of animals used in research is very complex and that care needs to be taken to avoid making existing administrative processes more onerous. Nevertheless, we think it highly desirable to present clearer information about how many animals of a particular species experience pain, suffering and distress, to what degree, and for how long. We therefore recommend that the Statistics be revised to provide this information, including details about the number of animals killed under A(SP)A Schedule 1.
15.34 Further thought is required to identify how changes could be made to improve information about the suffering and numbers of animals involved in research. We are aware that the APC,6 LASA and the RSPCA together with the Boyd Group7 are considering these issues at the time of writing. We hope that the Home Office will find our general observations useful in considering the reports from these groups.
Information about licensed research projects
15.35 There has been some discussion about whether or not, and if so to what degree, information about research projects that have been approved by the Home Office should be made available to the public. We note that, following an announcement by the Government in 2004,8 the Home Office has made available the first anonymised information in the form of Abstracts of Project Licences9 in January 2005. We welcome the principle of publishing more information, and the decision to make it available in a searchable and publicly accessible database in due course. We also note that the information provided in the first Abstracts varies in content, level of detail and style of presentation. We therefore recommend that the current form of presentation be reconsidered, to ensure that, as far as possible, meaningful information about the following categories is provided:
- the goals and predicted benefits of research;
- the probability of achieving these goals;
- the numbers and species of animals to be used, and an explanation of why they are needed at this stage in the project;
- what is likely to happen to the animals during the course of the project, including adverse effects from husbandry, supply, transport and procedures;
- what consideration has been given to the Three Rs to achieve all or part of the research objective(s), and how they have been applied;
- on what grounds possible alternatives have been rejected;
- source(s) of funding (i.e. public, private or both).
15.36 Members of the Working Party were unable to agree in which form this information should be provided. While there was a range of views, those at the two ends of the spectrum were as follows:
- Some members, concurring with the views of several animal protection groups, argue that full project licences should be made available, in which only the names of researchers, research facilities and commercially sensitive information have been removed. They believe that this step would be a correct interpretation of the FoI Act (see Box 13.4), and that any further editing of licences would reduce trust in the Home Office, which might otherwise be suspected of operating in non-transparent ways. They assert that access to full, anonymised licences is necessary to allow the public to gauge the extent of costs to animals, to allow review and challenge of the information and to comment on the way in which the cost-benefit assessment has been made.10
- Other members, noting that their view would be shared by most researchers using animals, consider that the current format is, in principle, suitable, although they would like to see less rather than more information made public. Hence, they wish to keep the new practice under close review. They argue that the legislative framework already requires assessment of the acceptability of research by the ERP and the Home Office, and that participation by the public in the regulatory system is not permitted. This system of assessment, together with the assessments made by the researchers themselves, and the funding bodies, is judged to be sufficient. The possibility of increased openness is viewed with scepticism because of fears about compromising accepted standards of confidentiality and commercial and academic competitiveness. Researchers using animals are also concerned that more detailed information about specific research projects could be used by militant activists to identify individuals and research facilities as potential targets.11 They also argue that the provision of information contained in full, anonymised project licences would not be intelligible and informative to the public, and that shorter summaries would therefore be more effective in providing the public with information next page
Footnotes3 Animals Procedures Committee (2003) Review of cost-benefit assessment in the use of animals in research, p44, available at:
http://www.apc.gov.uk/reference/costbenefit.pdf. Accessed on: 4 April 2005.
4 Animals Procedures Committee (2003) Review of cost-benefit assessment in the use of animals in research, p44, available at:
http://www.apc.gov.uk/reference/costbenefit.pdf. Accessed on: 4 April 2005.
5 We note that some explanation can be found in the Guidance notes on the A(SP)A (p32). However, it is unlikely that members
of the public will consult this document, and it is therefore important to clarify the terminology in appropriate places, for
example in the Statistics.
6 The APC’s Report will be available in 2005 at: http://www.apc.gov.uk/reference/reports.htm. See Animal Procedures Committee
(2004) Work Programme, available at: http://www.apc.gov.uk/aboutapc/workprog2004.htm. Accessed on: 21 April 2005.
7 See http://www.boyd-group.demon.co.uk, see also: The Boyd Group (2004) Categorising the severity of scientific procedures on animals - Summary and reports from three round-table discussions on the use of severity limits and bands in the UK, available at:
http://www.boyd-group.demon.co.uk/severity_report.pdf. Accessed on: 21 April 2005
8 Home Office (2004) Ministerial statement announcing the outcome of the review of section 24 of the Animals (Scientific
Procedures) Act 1986, 1 July 2004, available at: http://www.homeoffice.gov.uk/docs3/animalproc_wms_section24_040701.pdf.
Accessed on: 4 April 2005.