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Our comment on the recent Nuffield Report on 'The ethics of research involving animals' uncovers some glaring omissions and a disregard of Uncaged's unique submission. It also exposes the links between supposedly reputable scientific bodies, and front propaganda groups spreading misinformation about animal experiments...


The first issue to bear in mind is the context and background to the Nuffield report. All three backers of the Nuffield Council on Bioethics - the Medical Research Council, the Wellcome Trust and the Nuffield Foundation - conduct or publicly support and promote animal experimentation. They are all involved, directly or indirectly, with the so-called 'Coalition for Medical Progress', a pro-vivisection propaganda organisation that also includes notorious companies such as Huntingdon Life Sciences, Novartis etc. Whether or not there is any direct collusion between these interest groups, they are likely to share values and assumptions...

Click here to access the report on the Nuffield website.

The language used in the 'Background and introduction' section (pp. xvii-xviii) reflects the prejudices of Nuffield. In listing the groups who are supportive of animal research, the Report omits the most significant pro-vivisection voice - the pharmaceutical industry - thereby creating the false impression of a philanthropic coalition untainted by financial vested interest. It also presents pro-vivisection dogma as straightforward fact. For example:

  • 'the use of animals in research has made a substantial contribution to our understanding of biological processes, and that it has been responsible for many important biomedical discoveries'

  • 'in the UK animal research is strictly regulated...'

On the other hand, the position of vivisection critics, such as Uncaged, is presented much more sceptically and, unlike the pro-vivisection groups (who we know would like to abolish any effective scrutiny or restraint whatsoever on their activities) we are repeatedly described as 'absolutist'. The Nuffield report thus positions pro-vivisection groups as public-spirited, credible and reasonable, while our movement is labelled as extreme, questionable, anti-science and misanthropic.


Such an approach is typical of 'establishment' bodies who accept the perspectives of the powerful without question. Nonetheless, this commentary will not seek to highlight every point of difference between the Report and Uncaged's basic philosophical position. That would be an interesting academic exercise but would have little practical relevance in terms of policy and hence what happens to animals. What is more interesting is to explain the differences between Nuffield and the policy status quo, which reflects the extreme position of the pro-vivisection lobby as represented by insider organisations such as the Research Defence Society (RDS) and the Association of the British Pharmaceutical Industry (ABPI), together with their Government friends in the animal research policy community, particularly in the Home Office, but also in the Departments of Health and Trade & Industry. The fact that explicit and implicit criticisms of current practice are being made by a generally conservative group such as Nuffield, if anything, makes them particularly powerful.

Sadly, the presumption that animal experiments have, on the whole, benefited society runs through the Report. However, even within this biased framework, in its 'consensus statement' the Report does manage to make some useful points regarding a hypothetical past without animal experiments:

'... there may have been other options which could have produced acceptable levels of knowledge and healthcare... Alternatively, it is conceivable that equally good or better progress might have been achieved with other methods... It is sometimes assumed that to end animal research would be to end scientific and medical progress, but such generalisation is unhelpful.'

Although Uncaged rejects the underlying notion that animal experiments are an effective and scientifically valid research methodology, we welcome the fact that Nuffield is at least questioning the extreme and unsustainable propaganda pumped out in a coordinated fashion by groups such as the Research Defence Society (1), the Association of the British Pharmaceutical Industry, and the Government itself - that major medical advances have 'depended' on animal research, and that banning animal experiments would end medical progress.

The Nuffield group takes a typically one-sided approach to its consideration of the scientific validity of animal research, quoting extensively and uncritically from animal research proponents. However, it does at least admit the lack of evidence from systematic reviews to support pro-vivisection claims that animal research is scientifically valid. Uncaged and other critics of vivisection have long called for independent review of this question, and Nuffield concludes a review would be desirable, though it fails to specify a truly independent approach to such a crucial inquiry.

The Nuffield Report's reiteration of the 'desirability of a world without animal research' is also to be welcomed (despite its rather tentative and conditional approach to achieving such an aim). Once again, this undermines concerted efforts by the pro-vivisection lobby to present animal research as unproblematic and of no public concern. Indeed, Nuffield recommends that campaigning organisations, including pro-vivisection interests, should 'produce fair and balanced literature on this subject'. Unfortunately, the self-styled 'Coalition for Medical Progress' seem to have overlooked this. In their press release response, they claim that most animal experiments 'are little different from what happens in GP clinics and hospitals throughout the land' (2). We know the NHS isn't perfect, but we weren't aware that it was routine for patients to be experimented on, poisoned, diseased and mutilated against their will in ways that cause pain, suffering distress or lasting harm, and then sacrificed for tissue analysis! (3)


Not surprisingly, the established 'Three Rs' approach to tackling vivisection - Reduction, Refinement and Replacement - is strongly endorsed by the Nuffield group. Uncaged believes that the 'Three Rs' is ethically, politically and scientifically flawed. It is unethical and undemocratic because it makes saving animals from vivisection dependent on whether or not animal researchers deem 'alternative' methods to vivisection to be 'satisfactory'. It is unscientific because it unquestioningly adopts unvalidated and flawed animal tests and models as its benchmark. However, within that flawed framework, Nuffield has called for the 'Replacement' element to be a priority, and has called for a more rigorous, strategic and better funded approach to replacing vivisection methods. Given that the scientific establishment has merely paid lip-service to the very conservative Three Rs approach, the Nuffield recommendations could at least make a marginal difference to the scale of vivisection.


Nuffield does make some potentially useful recommendations related to the wider public debate about animal experiments. For instance, it states that the Home Office should supply retrospective information about the outcomes of experiments, including the suffering experienced by animals. The trouble is, how can we make sure that such information is accurate rather than a Home Office whitewash? Our 'Diaries of Despair' experience shows that the Home Office habitually lies about the real cruelty of vivisection.

Another potentially positive recommendation involves funding and supporting new ways of holding informed public debates. However, the pitfall here is that such fora could end up being mere talking shops that have no effect on the day-to-day reality of vivisection, which is carried out behind closed doors in the context of incestuous relationships between Inspectors and researchers.


Commenting on 'regulation', Nuffield makes the useful point (albeit tentatively) that having detailed regulations does not necessarily mean that it will have any impact on the ground. They also challenge the notion, advanced by pro-vivisection groups and the Government, that any international leadership by the UK in terms of banning more types of animal tests is pointless because it would simply export cruelty.

At the heart of the UK regulatory system is the so-called 'cost-benefit assessment'. As we told the Animal Procedures Committee in their consultation exercise on this subject, Uncaged believes that such an approach is not morally acceptable because it allows for the sacrifice of innocent individuals, and does so in an entirely speciesist fashion: it's always non-humans who are forced to bear the immediate 'costs' of such research. Furthermore, we don't believe that animal experiments can ever be truly beneficial.

However, the word 'benefit' in the term 'cost-benefit assessment' does not actually presume that positive benefits will be predicted by such an assessment. 'Cost-benefit assessment' is a broad technical term that is shorthand for a utilitarian calculation of a proposed action. Even the Home Office admits that 'potential disbenefits', such as ecological disturbances caused by GM animals, are a factor in a 'cost-benefit assessment' (though in practice the Home Office ignores the huge range of dangers of animal testing). The 'cost-benefit assessment' leaves enormous discretion for whoever conducts it and if we were in Government we would potentially have the legal power to stop all animal experiments without changing current legislation!

So, given that the cost-benefit assessment is the current reality, and the scope for positive change that it provides, it was interesting to see what the Nuffield group had to say about it. Unfortunately, Nuffield do not attempt a review of the application of the cost-benefit assessment. Indeed, under the section that purports to discuss the regulatory system in practice (paragraphs 13.8-13.31), Nuffield merely describes the letter of the law, not what happens in practice. This is a shock, given that Uncaged submitted huge amounts of unique information regarding the reality of policy implementation, including the Diaries of Despair report on Imutran's xenotransplantation research and leaked regulatory documents from the Home Office. This was documentation that we disclosed following our legal victory on public interest grounds: that they revealed official misconduct in relation to the application of laws and regulations.


In terms of making a direct and immediate impact on animal experimentation in Britain, recommendations on policy and regulation are the most relevant and effective contribution that Nuffield could have made. Unfortunately, despite Uncaged's best efforts, Nuffield appears to have swept this issue under the carpet. Even the House of Lords Committee noted concerns about the bias of the Home Office Inspectorate. But Nuffield has been infected by Whitehall's 'infallibility syndrome'. They make the absurd claim that the Home Office administers the law 'to avoid possible conflicts of interest' (paragraph 13.20), as if the Home Office was hermetically sealed from the rest of Government and the vivisection industry. In fact this claim is exactly the same line Uncaged has been given by a Home Office civil servant involved in the Imutran cover-up. If Nuffield had any expert on public policy or political science on their working group, such an embarrassingly naïve assertion could have been avoided.

Nuffield ignores the Government's own admission that most of the Inspectors have previous involvement in animal experiments. They ignore the fact that since the early 1880s, the Home Office has had close and exclusive relationships with animal research interests. They ignore the fact that the recent Pharmaceutical Industry Competitiveness Task Force, which was centred in the Department of Health (mission: to sponsor the drug industry) and drew upon Department of Trade and Industry white papers (mission: to maximise corporate profits), essentially issued orders to the Home Office that further watered down animal research regulation. Basically, they ignore the facts.


  1. e.g. The RDS claims: 'Antibiotics, anaesthetics, vaccines, insulin for diabetes, open heart surgery, kidney dialysis and transplants, treatments for asthma, leukaemia and high blood pressure... these are just some of the major medical advances that have depended on the use of animals in medical research and testing... it would be extremely difficult to develop new medical treatments and cures without the use of animals. So animal research must continue if we are to solve serious medical problems like cancer, heart disease, Alzheimer's disease, AIDS, cystic fibrosis, multiple sclerosis, and malaria.' www.rds-online.org.uk/pages/home.asp?i_ToolbarID=8&i_PageID=94 (accessed 7 June 2005)
  2. www.medicalprogress.org/news/newsarchive.cfm?news_id=323 (accessed 14 June 2005)
  3. The Nuffield Report (p. xix) itself admits that 'All research in the UK has the potential to cause pain suffering distress or lasting harm to the animals used. Most animals are killed at the end of the experiment'.

Dan Lyons, Uncaged Campaigns 21.07.05


Uncaged 1993-2012: This is the archived website of Uncaged. All information correct at the time of archiving - November 2012.