Ethics of Research involving animals
Appendix 5: Consultation with the public - continuation II
What is your view about ethical issues relating to the use of animals in research?
Many people responded to the Consultation with their view that the use of animals in research was unethical in principle. They observed that if animals were so like humans that results from animal experiments were valid for humans, then these similarities made it unethical to use
animals for experimentation. They felt that all living creatures should be given the same level of compassion because they believed animals and humans had the same moral status. A number of people compared the use of animals to the use of humans by other humans, such as abuses carried out by Nazis preceding and during the Second World War.
Some of the respondents felt that research involving animals was unethical because of their belief that the concept was scientifically flawed and actually caused a slowing of medical progress. A different argument was presented by others who felt that humans had a responsibility or duty of care and compassion for other species. Several of these respondents drew comparisons between research and the use of animals for food, pets, clothing and sport, which they also thought unacceptable and unethical. Some people considered that those who denied that animals suffer should be considered as dangerous because their arguments could be used to deny that other groups of humans suffer.
For many people who responded to the Consultation, welfare and the prevention of suffering were paramount, independent of the question of whether the animals possessed ‘higher’ mental states or cognitive capacities. However, others thought that self-awareness and cognitive ability were more significant, because suffering could be connected to being able to recollect events of the past and anticipate the future. Some were concerned that researchers did not recognise symptoms of pain, or that observation of animal behaviour was not a reliable means of assessing suffering. These respondents believed that, based on their personal experience, many species were capable of complex thoughts and emotions. There was consensus that there should be increased research into welfare, suffering and awareness.
Contrary to these viewpoints, many other respondents considered that there was a moral duty to undertake research to alleviate human suffering and to improve quality of life. They accepted that if research involved animals, then it was ethical to use them for this purpose. In the view of many respondents, the acceptability of a particular type of research depended on the purpose. For others it was the level of suffering that constituted the overriding factor in deciding whether research should or should not be carried out. The majority of these commentators also drew distinctions between the use of different species, noting that most people practise some ‘speciesism’ in their daily lives.
Some people favourably compared animal research to animals used for other purposes or even those living in the wild. It was felt that ethical considerations should be consistent. One respondent believed that it was important not to be too anthropomorphic about what we conceive as quality of life for other animals. Others felt that animals did not have the capacity to act rationally as moral agents and could therefore not have ‘rights’.
What is your view about the UK regulations on research involving animals in the UK?
The regulations which govern animal research were clearly important to the majority of respondents. Views on the current UK regulations were divided, with many arguments being expressed. Views ranged from those who considered that regulations were overly prescriptive to those who thought that they were insufficiently strict and therefore ineffective. Within this spectrum were others who believed the regulations to be appropriate as they stand. It was widely held that the UK regulations were stricter than those in other countries.
Some thought that the nature of the care procedures at individual establishments were more important than the role of the Home Office Inspectorate. One respondent wished to point out that violations of the regulations have rarely led to prosecutions for staff in research establishments. There was the suggestion that licence applications should be assessed by an independent panel, not composed of members of the government or civil service. The Inspectorate, which consisted of 25 inspectors in 2003, was felt by some to be insufficiently staffed. It was suggested that if the number of inspectors were increased, then more unannounced visits to research establishments could take place.
Some respondents considered that simplification and flexibility of project licences would be beneficial for animal welfare. These respondents, often involved in animal research, believed the regulations to be strict and thorough and sometimes overly bureaucratic. They felt that any further tightening of the legislation would stifle research, slow down progress, increase costs and could drive researchers away from the UK.
The development of the Ethical Review Process in the previous six years was highlighted. One respondent felt that the lay member on ethical review panels had limited involvement, although others felt that lay members frequently made valuable contributions. Some noted that the Animal Procedures Committee had made recommendations regarding improvements to regulation; and suggested that these be implemented.2
Some respondents considered the concept of the cost-benefit assessment to be flawed because costs to animals were not given due weight. The regulations state that research involving animals should only be undertaken in the absence of alternatives. However, some people alleged that this limitation could not be adhered to until further research into alternatives was conducted, as alternatives may be possible but have simply not been developed. The regulations also rely on assessments made in advance of experimentation; many respondents questioned how researchers could make welfare assessments in advance and felt that evaluations should be made before, during and after procedures are applied.
A core concern was how the regulations related to genetically modified (GM) animals. Some took the view that they were inadequate and had been written before the advent of new technologies which have resulted in the creation of GM animals. It was pointed out that current Home Office statistics included GM animals kept to maintain breeding colonies. This meant that the statistics misrepresent the proportion of rodents as compared with other animals used in actual scientific procedures. Others felt the status quo should prevail, and licences should be required for all GM breeding.
The Home Office system of classification for procedures was criticised by some respondents who questioned the use of the term ‘moderate’ for certain research carried out on primates. They argued that a ‘substantial’ procedure could be hidden within a ‘moderate’ project. In addition, some people objected to the fact that the terminal sedation of an animal could be termed ‘unclassified’.
It was suggested that greater effort could be made to harmonise regulations regarding animal research in different countries, at least across the EU. A number of respondents considered that there was insufficient protection for people and institutions involved in animal research and would like to see regulation introduced to overcome this. There were particular concerns about violent extremists.
Footnotes2 Animal Procedures Committee (2003) Review of the cost-benefit assessment in the use of animals in research (London: HO).