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

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Urgent: Be a Voice For The Voiceless

Please use this opportunity to speak up for animals.

i) biotechnology

The APC’s biotechnology consultation exercise is the most urgent. Although the deadline for responses is Monday 31 January, we have found that, in practice, the Government will still accept responses a few weeks after the deadline. In any case, it never does any harm to express your opinions to the Government.

The APC says it "has formulated some specific questions on which it would be grateful for your comments, though it would of course be very helpful to hear of any other points you would like to make." If you would like a copy of the letter, it is available on the APC’s website at www.apc.gov.uk, or contact us and we can send or fax you a copy. Please send your comments to APC, Room 978, 50 Queen Anne’s Gate, London, SW1H 9AT, or by email to apc.secretariat@homeoffice.gsi.gov.uk - mark your correspondence "biotechnology consultation."

Click here for our response to Emerging Biotechnologies and the Animals (Scientific Procedures) Act 1986.

ii) openness

The Government is currently trying to decide how to apply its Freedom of Information Act to the matter of animal experiments, and the APC is looking to advice on this. Having briefly discussed the pros and cons of openness, the APC suggests five options ranging from complete openness through to a continuation of the present arrangement. We intend to recommend complete openness, which is Option A, and we urge you to do the same.

A copy of the letter is available on the APC website at www.apc.gov.uk or we can send you a paper copy on request.

The deadline in this instance is a little less demanding, being Friday 10 March. Send your comments to the same snail or e-mail address as above, marking them "Openness" on this occasion. See the appendix below for ‘Our view on secrecy and animal experiments.’

iii) operation of the act

The Home Office’s consultation draft is not so obviously open to an anti-vivisectionist critique. The Home Office states: "Please note that this is primarily a manual for working under the Act and is not intended to be a general treatise about the use of animals in scientific procedures." It is certainly not our intention to legitimise vivisection by making recommendations on a more efficient running of the Act.

However, these kinds of exercises allow us to show that the Act is unworkable, and that therefore there can be no practical way of regulating vivisection. This kind of approach is known as an immanent critique, and it’s a powerful argumentative approach because you state that, even if we accept certain basic premises of the Home Office’s position (in this case the letter of the law) for the sake of argument, when we consider the issue of animal experiments in the context of the workings of the Act, a case can be made for a ban on the practice. Even on the Home Office’s own terms, vivisection should be banned!

This is an approach which has worked out very well in our responses to xenotransplantation consultation exercises. It does take time and effort to develop these kinds of arguments, but the benefits of studying these issues in-depth are numerous!

The consultation draft is on the Home Office’s website at www.homeoffice.gov.uk/ccpd/abcu.htm or phone 0171 273 3777 for a paper copy to be sent to you. You’ll need to get a move on with this one though - the deadline is 11 February. Your comments should be addressed to Martin Walsh, Animal Procedures Section, Room 977, Home Office, 50 Queen Anne’s Gate, London, SW1H 9AT.

So get writing, and good luck! Please email us to let us know how you got on, or for any advice or help with these or other matters.

"Voice..." appendix (i): Our View on Openness: Our view on secrecy and animal experiments

The APC lists eight aspects of the Government’s administration of the A(SP)A that would be affected by freedom of information, ranging from the details of applications to the Home Office to conduct experiments on animals, to the files of the Inspectorate that is charged with advising whether the applications should be approved and monitoring compliance with regulations.

The APC suggests five options regarding the amount of information regarding animal experiments that should be made available to the public. Uncaged Campaigns believes that option A, which states: "Full information is made available about all the above matters", is the only justifiable approach to take. This option is the least secretive.

There are a number of compelling reasons why this option, which would allow full public scrutiny, should be adopted.

There are currently 21 Inspectors to monitor 2.6 million animal experiments every year. Furthermore, the Inspectorate is also supposed to do the bulk of the work in processing and examining roughly one thousand different vivisection project applications every year. It is practically impossible for the Inspectorate to carry out this work effectively.

The Inspectorate itself is largely comprised of individuals with direct experience of experimenting on animals and/or individuals who support the practice. This is like getting the fox to guard the chicken shed. There is deep mistrust of the Inspectorate’s willingness to question whether vivisection procedures are likely to lead to public benefit. Furthermore, those who closely watch these matters believe that the Inspectorate does not take the suffering of animals seriously.

The only direct evidence of the Inspectorate’s work has come from undercover investigations of vivisection laboratories. On every occasion, breaches of the A(SP)A were not noticed by Inspectors, who simply didn’t do their job in terms of inspecting animal facilities and the treatment of animals. In effect, vivisection laboratories are laws unto themselves. Increased public awareness of vivisection could make it more likely that an improved level of scrutiny would be achieved.

Secrecy surrounding animal experiments goes back many years, and predates any direct action from animal rights advocates. The Government has always advised vivisection laboratories to be as secretive as possible because if the public really knew what happened in these places then there would be even greater pressure to control and ultimately end the practice. The Government has traditionally promoted vivisection by helping those who conduct it to be shielded from public attention. It has adopted this approach because the scientific community is a very powerful lobby that has fiercely defended their privilege to conduct research without interference from the general public and without regard to the consequences. This arrogance is very widespread and based upon a view of the public that sees us as ignorant and inferior to research scientists.

We firmly believe that excuses for the maintenance of secrecy based on claims that scientists would be threatened by "violent extremists" are bogus. The extent of the threat of violence is massively exaggerated (to the best of our knowledge, no vivisector has even been substantially injured, never mind hospitalised or killed). Furthermore, details about vivisectors and vivisection laboratories are already available in scientific journals: if there was a realistic prospect of a violent attack being organised, then a sufficiently motivated attacker could find the information they required. Secrecy keeps the public ignorant, it does not protect scientists.

We seek complete freedom of information because we believe that an informed public debate will cast grave doubts on the ethics of vivisection, both in terms of cruelty to animals, and also the intrinsically misleading nature of animal research - experiments on animals tell us about those animals in those conditions, not about humans as we go about our lives. Vivisectors want to keep the public ignorant because it allows them to carry on regardless.

Furthermore, whatever one’s initial view about animal experiments, freedom of information is an essential requirement for a political system to be democratic. In a democratic society, it is the public that should decide whether animal experiments should take place, not a small clique of self-serving researchers working for profit-seeking biotechnology corporations.

"Voice..." appendix (ii):  Comments on Draft Home Office Guidance on the Operation of the Animals (Scientific Procedures) Act 1986.

Dear Mr Walsh

While acknowledging that the Draft necessarily does not address the fundamental question of the ethical acceptability of animal experimentation, it is important for us to register, briefly, our deep and sincere opposition to the UK Government's continued acquiescence to coercive, non-consensual experimentation on animals. If human beings have the right not be treated in this way, then so should other sentient animals. Any discrimination in this respect is arbitrary and completely unjustifiable, and represents an abuse of the superior power of humans in relation to other animals.

Furthermore, from a scientific perspective, we would urge the Government to recognise the existence of fundamental obstacles to the application of results gained from laboratory experiments on non-human animals to the human condition. The notion that animal experiments can provide reliable information that can be applied confidently to humans is based on a profoundly flawed, oversimplistic and reductionist view of biological phenomena. The promulgation of this view gives an illusion of control and prediction over biological phenomena which is useful for profession and commercial interests who work in these fields to maintain their positions of authority and power but, in the overall scheme of things, is erroneous, pernicious and results in the violence and abuse towards animals exemplified by animal research.

Obviously, the preceding two paragraphs are merely the conclusions we have reached as the result of a great deal of education, information gathering and objective reflection. In passing, we remind the Government of the Labour Party's pre-election pledge to support a Royal Commission of Enquiry into the issue of vivisection. We strongly believe that the Government has a moral and democratic duty to fulfil this pledge by initiating some form of wide-ranging enquiry.

Having read through the Draft, Uncaged Campaigns believes that, for the most part, any significant short term improvements in the operation of the Act would require alterations to the Act itself. However, we have identified three areas of immediate concern - surplus animals, the Inspectorate and infringements - where we believe improvements should be made as a matter of urgency in order to eliminate some of the gravest flaws in the working of the Act. 

Surplus animals (e.g. para. 2.20)

Currently, the destruction of animals - usually surplus animals - by Schedule 1 methods is not classified as a regulated procedure. We regard this as unjustified for the following reasons. The Act is designed to protect animals who are likely to suffer pain, suffering, distress or lasting harm. We believe that it is quite indisputable that the incarceration and killing of animals constitute harms.

Keeping animals in laboratory conditions is, at the very least, potentially emotionally and psychologically harmful. To dispute this point would be to hold the view that non-human animals are little more than soft. fleshy machines, and would be to severely underestimate the mental complexity of all "protected" animals. Presumably, the Government's licensing of behavioural and psychological experiments on animals, including rodents, means that the Government believes that there is some degree of similarity between the experiences of humans and other animals. (Though we stress that the complex biological processes that underlie these experiences vary in subtle yet profound ways which fatally undermine the notion that non-humans are analogous models for humans.) Given the acknowledgement of this similarity, to ignore the potential for psychological harm for nonhumans under laboratory conditions is arbitrary.

Therefore, we recommend that the act of incarcerating any animal in a laboratory ought to be classified as a regulated procedure.

The killing of animals raises also constitutes a harm: indeed, it is the ultimate, irrevocable harm. Setting aside the issue of any suffering involved, it is widely accepted in ethics and philosophy that not all harms consist of subjective or experiential suffering. Therefore, painless murder is still murder, and constitutes a harm to the victim. To have a conception of oneself as a being with future plans that would be frustrated by one's untimely death is not a necessary condition for an individual's life to be of value to them. All "protected" animals strive to sustain and protect their own lives. To deny that these lives are valuable to their "owners" would necessitate the acknowledgement that, infants, certain mentally disabled people, and the senile, would have valueless lives. This, of course, is untrue, and therefore we should accept that the lives of sentient animals are valuable - in fact they are of ultimate value because all other values are dependent upon them, and therefore killing them constitutes the gravest harm possible.

The Draft consistently uses the term "humane killing". We regard this as a misleading oxymoron motivated by public relations rather than logic. The only possible situation where this term could be valid would be where an animal (including humans, perhaps, if they gave their consent) was euthanased because they were suffering from an overwhelmingly painful, untreatable and lethal condition - when their lives cease to be of value to themselves. Putting to death healthy animals simply because they are deemed surplus to requirements is not humane because it is not in their interests! It is violent and destructive.

Furthermore, in any case it is clear that not all killing of surplus animals is free from suffering. Rodents gassed at Charing Cross & Westminster Hospital, according to an undercover investigation carried out by the NAVS a few years ago, struggled to find air as they suffocated. We think that this was very likely to be an extremely terrifying and stressful experience for them.

The routine and unlicensed slaughter of millions of animals in UK laboratories fails to grant these individuals the rather spurious theoretical "protection" granted by the requirements of the cost/benefit analysis for "regulated procedures." Therefore, these killings are possibly the most morally repugnant aspect of whole practice of vivisection.

We recommend that the harms/costs inflicted upon these animals by being put to death demand that such proposed actions should be classified as regulated procedures requiring necessary licences and a cost/benefit justification. We believe that no such cost/benefit justification exists, and that therefore such destruction should be outlawed. Any complaints of inconvenience on behalf of those who experiment on animals cannot constitute legitimate complaints in this context because it is totally unjustifiable to allow such relatively trivial considerations to lead to the killing of animals.

If, for whatever reason, the Government does not concur with this recommendation, we urge that the Government, as a minimal step, publish figures in the annual statistics to record the number of surplus animals killed. That is the very least they, and the public interest, deserve.

Infringements (e.g. 2.41)

We are concerned at the rather feeble approach taken to infringements of the Act and the Codes of Practice. Most importantly, infringements in both instances may lead to increased suffering of animals.

We recommend that for the Act to be administered in a minimally effective and justifiable manner, breaches of licence conditions or Codes of Practice should be considered offences, warranting criminal prosecution. This is the least that is required if the Government is sincere about "protecting" animals.

The Inspectorate

The Inspectorate is spectacularly understaffed. 21 Inspectors are expected to:

  • scrutinise carefully approximately 1,000 new project licence application every year (this is a major task);
  • continually assess a further 3,000 projects to see if scientific or ethical developments change the cost/benefit assessment and thus the justifiability of the project;
  • inspect the conditions for several million animals (including the ones currently destined to be exterminated as surplus);
  • check that licence conditions are being adhered to for over 2.5 million procedures;
  • ensure that named persons and certificate holders are discharging their duties satisfactorily and legally;
  • advice the Home Secretary and other in the Home Office on wider areas of concern.

Our guess is that a quadrupling of the size of the Inspectorate may just begin to enforce the Act. We believe that it is completely unacceptable for the Government to be in a position where the means of executing an Act which deals with such an important area are so obviously and utterly inadequate.

We recommend that an audit be conducted as a matter of urgency in order to ascertain the necessary size on Inspectorate in order to permit enforcement of the Act.


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