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Government proposals threaten to increase suffering in animal experiments
Uncaged is deeply concerned that the UK Government is proposing to weaken animal welfare protection and independent oversight of animal experimentation. The proposals have emerged in draft regulations recently published by the Home Office, which are intended to implement the new European Union Directive on animal experimentation. Despite the controversial nature of animal experiments, the regulations are due to be driven through Parliament this autumn with minimal debate.
Under pressure for Uncaged and other animal advocates, the Home Office has reversed its previous intention to allow experiments on stray cats and dogs, and permit new-born puppies and kittens to be clubbed to death. While welcome, these are in reality relatively peripheral measures.
However, the draft rules - scheduled to be laid before Parliament on 15 October 2012 - reveal that the Home Office has largely ignored the core submissions by animal protection groups, which propose transparency, accountability and progress towards the ultimate elimination of painful and harmful animal experimentation - the aim stated in the text of the new Directive.
Instead the Home Office’s proposals reflect a one-sided position, whose effect is to:
- Advance the interests of animal researchers in industry and academia over animal welfare and public opinion: i.e. it further weakens the democratic legitimacy of animal research regulation
- Weaken independent oversight of animal experimentation
- Weaken levels of protection for animals from pain, suffering, distress and lasting harm
Consequently, the actual impact of the draft regulations will be:
- Increases in absolute levels of animal pain, suffering, distress and death
- Weaker application of the 3Rs
- Poorer quality research and constraints on potential medical and public health advances
One of the most disturbing proposals, not previously flagged up by the Government, includes the repeal of the law requiring limits on the pain, suffering and distress caused to animals in experiments. Under the current law, each experiment has a ‘severity limit’  which defines the point at which researchers are supposed to stop the experiment in order to spare animals more intense pain.
However, although there is a requirement to classify the severity of each experiment, the Home Office has removed the legal duty to enforce this limit, opening the door for researchers to break their original classification declared in their licence applications. 
There is an absolute upper limit, which is supposed to prevent ‘severe and prolonged pain’. However, this is significantly undermined due to the high threshold the Government has adopted in order to satisfy research interests practising the most damaging and traumatic experiments.  This limit will make no difference to current levels of animal suffering, meaning that, for example, there will be no prohibition on procedures where death is the endpoint, leaving primates and other animals to suffer a slow and agonising death as a result of poisoning and/or organ failure, for example.
The Home Office is also set to water down the application of the 3Rs by omitting the Directive’s ban on animal tests if there is a scientifically-validated alternative.  Drug and chemical companies are unhappy that they will be prevented from doing animal tests that are deemed redundant in the EU, but are still required for the marketing of products by regressive regimes such as China and Russia.
Among other reductions in welfare protection and scientific assessment, the Home Office is also proposing:
- to allow industry domination of new national advisory committee by removing the legal requirement for animal welfare representation 
- to reject ethical input into the critical harm-benefit assessment of proposed animal research projects, rendering it a rubber-stamping exercise 
- to allow painful experiments to take place regardless of a harm-benefit assessment indicating that animal suffering is not justified 
- to maintain the absolute secrecy clause, despite broad expressions of support for its removal ; this would severely hinder accountability and facilitate illegal and unnecessary animal suffering
- to weaken controls on the use of neuromuscular blocking agents (NBAs) which render the animal immobile but still sentient and conscious 
Dr Dan Lyons, one of the UK’s leading experts on animal research policy, comments:
‘I’ve been carefully monitoring the progress of this new law for a number of years, and it is deeply disturbing that the Government has effectively ambushed the animals and their advocates with unheralded reductions in legal protection for animals and independent regulation. This will take us back to the pre-1986 position, removing what little restraint there was on the activities of animal researchers.
Acting on behalf of big business interests and extreme elements in academic bioscience, the Government has systematically misled Parliament and the public with talk of protecting animal welfare standards and promoting superior non-animal research methods, while strenuously seeking to achieve the opposite.’
WHAT YOU CAN DO
- Please write to your MP as a matter of urgency. Here’s a sample letter, but please do personalise the text. You can get hold of your MP’s details from www.writetothem.com.
- See Project Licence Conditions 6 and 8, and Personal Licence Condition 13, pp78-81 of the Guidance on Operation of the Animals (Scientific Procedures) Act 1986 (www.official-documents.gov.uk/document/hc9900/hc03/0321/0321.pdf)
- See Schedule 2A, Parts 2 & 3 of Tabulated draft regulations (www.homeoffice.gov.uk/publications/science-research-statistics/animals/transposition_of_eudirective/tabulated_aspa?view=Binary). The new draft regulations give the Home Secretary wide discretionary powers regarding conditions (See Condition 23), instead of specifically requiring the enforcement of severity limits.
- For example, certain types of pain experimentation.
- See Article 13 of Directive 2010/63/EU (http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:276:0033:0079:EN:PDF)
- See Sections 19-20 www.homeoffice.gov.uk/publications/science-research-statistics/animals/transposition_of_eudirective/tabulated_aspa?view=Binary
- See Section 5B(4) www.homeoffice.gov.uk/publications/science-research-statistics/animals/transposition_of_eudirective/tabulated_aspa?view=Binary
- Putting the requirement for a favourable harm benefit assessment (HBA) in Section 5B3 instead of 5B2 fails to transpose the requirement of the Directive as it appears to create a loophole where a project can be licensed without a favourable HBA.
- See Section 24 www.homeoffice.gov.uk/publications/science-research-statistics/animals/transposition_of_eudirective/tabulated_aspa?view=Binary
- See Section 17 of www.homeoffice.gov.uk/publications/science-research-statistics/animals/transposition_of_eudirective/tabulated_aspa?view=Binary. This clause proposes to allow researchers to decide how much anaesthetic to administer, whereas current laws (and the Directive) require the Home Secretary to ensure adequate anaesthesia.
Uncaged Campaigns 14.09.12