Vivien Pomfrey
BSc (Hons) (Open)
DipNatSci (Open)
MSc (Science) (Open)

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Comments on Draft Australian code of practice for the care and use of animals for scientific purposes

The final code (7th edition, dated 2004) can be downloaded from
Vivien Pomfrey can supply the draft on request; it is a pdf file of approximately 500 kb.


I am a medical science Masters student in the United Kingdom and hope that my comments are worthy of consideration.

Vivien Pomfrey


I commend you on your very detailed and thoughtful draft Code of Practice

I note that "The strategic intent of the NHMRC is to work with others for the health of all promoting informed debate...and applying research rigour."

I am one of the growing number of scientifically-aware people who believe that human health would benefit from the abandonment of the use of animals as models for human conditions, on the grounds that such animal use is intrinsically not rigorous. I also believe that being compelled to collude in harming animals during one's education is damaging to psychological health, causing empathic distress and/or desensitisation to suffering.

I will specify below, mostly in the order in which they are presented in the draft Code, clauses with which I strongly agree and those with which I do not agree, as well as making additional comments and suggestions.

Comments on Introduction

I strongly support the aim: "The Code emphasises the responsibilities of investigators, teachers and institutions using animals to...promote the development and use of techniques which replace animal use in scientific and teaching activities."

I strongly support the aim: "The Code emphasises the responsibilities of investigators, teachers and institutions using animals to...avoid pain or distress for each animal used in scientific and teaching activities."

I do not agree with the statement that "the use of animals continues to be essential in some areas of research if people are to benefit from advances in health care." This is an opinion and should not be stated as fact.

Comments on Definitions of terms

I advocate the addition of the words 'harm', harmful' and 'harming' to some clauses in order to distinguish between studies which have some detrimental effects on animals and those which do not. If these changes are adopted, the words will need to be defined in the glossary of definitions of terms. A suitable definition for 'harmful' in this context would be 'with the potential to cause physical or psychological injury or distress, including the killing of animals to provide tissue and the killing of animals after experiments or where surplus to scientific requirements.'

Comments on main body of Code

I strongly support Clause 1.1 which begins: "Scientific activities using animals may be performed only when they are essential..."

I strongly support Clause 1.8 which states: "Techniques which totally or partially replace the use of animals for scientific purposes must be sought and used wherever possible."

I strongly support Clause 1.11 which states: "Scientific activities involving the use of animals must not be repeated unnecessarily."

I would amend Clause 1.13 to read: "Overproduction of animals bred for scientific purposes and the killing of healthy animals should be avoided." Also see my comments on Clause 3.3.17.

I am opposed to Clause 1.15 which states: "The design and management of animal accommodation should meet species-specific needs where not precluded by the requirements of the project." My objection is that I do not agree that requirements of a project should be allowed to override animal welfare. If there is conflict, the project, not the animal accommodation, must be modified. This clause in fact conflicts with the next one:

1.16 "Animals should be transported, housed, fed, watered, handled and used under conditions that meet species(-)specific needs. The welfare of the animals must be a primary consideration in the provision of care which should be based on the behavioural and biological needs of the species." I support this clause.

I strongly support the first sentence of Clause 1.19 which states: "Projects should be designed to avoid pain or distress to animals." The second sentence, which reads: "If this is not possible, pain or distress must be minimised" should be qualified by a statement along the following lines: "It is only permissible to cause pain or distress, however minimal, when the project is for the purpose of producing a net benefit to the animal(s) concerned, e.g. therapy or humane population control.
The second sentence in the clause in fact conflicts with the earlier statement: "The Code emphasises the responsibilities of investigators, teachers and institutions using animals to...avoid pain or distress for each animal used in scientific and teaching activities." (my italics to emphasise difference between 'avoid' and 'minimise')

I strongly support the statement in Clause 1.20 that "investigators and teachers must assume that animals experience pain in a manner similar to humans." I would like to add 'overwhelming' in front of the word 'evidence' in the subsequent sentence: "Decisions regarding the animals' welfare must be based on this assumption unless there is evidence to the contrary."

Clause 1.21 states: "An animal with signs of pain or distress not predicted in the proposal, must have the pain or distress alleviated promptly. Alleviation of such pain or distress must take precedence over finishing a project. If prompt alleviation is not possible the animal must be euthanased without delay." I feel strongly that 'not predicted' should be deleted. It makes no difference to animal welfare whether the pain or distress is predicted or not, and should therefore make no difference to the human response to such pain or distress.

I am strongly opposed to Clause 1.25 which states: "Where it is established that anaesthetics or analgesics cannot be used to alleviate pain such as in certain toxicological or animal production studies or in animal models of disease, the planned endpoint of the project must be as early as feasible to avoid or minimise pain or distress to the animals." My grounds for objection are that the clause accepts the need/desirability for projects in these fields which cause non-alleviable pain, which I do not. Anaesthesia and/or analgesia must be used when required on animal welfare grounds.

Re Clause 1.27 which states: “Death as an end-point must be avoided whenever possible", I would like to see 'whenever possible' deleted, as I do not accept that animals should be deliberately exposed to potentially harmful situations or to be deliberately killed except for the purpose of alleviating their own suffering, or in self-defence where there is no feasible ethical alternative.

I do not understand the meaning of the 'orientation' of new Animal Ethics Committee (AEC) members in Clause 2.1.1 (viii), and therefore request that this be made clearer.

I strongly support Clause 2.1.1 (xi) which states: "(Institutions that use animals for scientific purposes must implement processes so that the governing body of the institution or its delegate is assured of compliance with the Code and relevant legislation. This must at least include)...establishing mechanisms to respond to enquiries or complaints concerning the use of animals within the institution and ensure that staff members and students may voice concerns without jeopardising their employment, careers or coursework..."

I would like students to be included in the remit of Clause 2.1.1 (xii) regarding "establishing and making known procedures for the fair resolution of disagreements between AEC members, between the AEC and teachers or investigators or between the AEC and the institution." In other words, procedures should be also established and made known for the fair resolution of disagreements between students and teachers or investigators or the AEC.

I strongly support Clause 2.2.1 where it states that "AECs must have terms of reference publicly available which include provisions to..." with regard to point (iv) "how AEC members are appointed, re-appointed or retired..." and point (v) on members declaring conflicts of interest.

I am concerned about Clause 2.2.1 (x) relating to the AEC being able to authorise emergency treatment or euthanasia, on the grounds that such emergency action must not be delayed by any requirement to consult the AEC. Perhaps this should be clarified.

I do not agree with the minimum number of AEC members specified in Clause 2.2.2 (four). This is too low to provide the necessary balance of views and range of expertise. I would like to state at this point that no institution should be permitted to carry out animal experiments if it cannot fulfil the full range of requirements in the Code, including all stipulations for an AEC.

There is also a serious omission in the categories from which members are to be selected: it is extremely important that at least one member is knowledgeable about non-animal methods in medical research and education. If no individual can be found who is an authority in both areas (there are significant differences between research and educational animal use, both in purpose and in the range of methodologies), two people will need to be appointed, one to fulfil each 'alternatives' remit.

Re Clause 2.2.5, the sentence: "It is preferable that the Chairperson is an additional appointment to Category A to D members" should be changed to: "It is essential that the Chairperson..." A chairperson of any body must be impartial, and committee members in this context are perhaps unlikely to be so. There must be a permanent non-voting chair who is accepted by all AEC members as impartial.

Clause 2.2.9 (ii) should be amended to ensure that person(s) with expertise in non-animal-harming 'alternatives' are present for the committee to be quorate (see my comments re Clause 2.2.2).

Clause 2.2.9 (iii): "the conduct of quorate AEC meetings in exceptional circumstances where a face-to-face meeting is not possible, for example through the use of video linking or teleconferencing" is unnecessarily technophobic. Educational institutions in particular should not automatically regard IT-based meetings as a last resort - they are often preferable with regard to convenience, cost and the environmental impact of travel. This can enable them to be held more frequently.

I am unhappy with Clause 2.2.9 (vii) re the AEC being required to establish and document procedures to "advance approval for the immediate use of animals should that be required for the diagnosis of unexplained and severe disease outbreaks or morbidity/mortality in animals or people."Animals should not be used to study disease in humans. In the case of an outbreak of disease in animals, animals of the species concerned should be studied and, where possible, treated, as with humans - not used.

Clause 2.2.13 about irreconcilable differences between the AEC and an investigator or teacher should be amended to include students, as in my suggestion for Clause 2.1.1 (xii).

I strongly support the recommendations in Clause 2.2.14 about the use of plain English and the provision of lay descriptions (perhaps 'translations' would be an appropriate term) or glossaries.

Re Clause 2.2.15 (iv), I am concerned that there is no mention in the document of ethical sourcing of animal tissue. Indeed, the whole document, by addressing research and educational animal use together, fails to stress the differences between types of animal use. I do not know the Australian legal situation but, in the UK, harmful experiments on live vertebrates and specified invertebrates are covered by legislation that requires the animals to be sourced from laboratories, but this is not the case for animals which are simply killed to provide tissue. ECVAM (one of the bodies referred to in your lists of information sources) recommends ethical sourcing for such tissue, as do a number of other organisations. Ethical sourcing means the use of tissue from animals which have not been deliberately bred and killed for reasons which are not for their own welfare. It can include animals which have died naturally or accidentally or been euthanased for humane reasons. Thus I would like to see some reference to the ethical sourcing of animal tissue (including that used to provide microscope slides, plastinated organs, etc.).

Re Clause 2.2.15 (x),

·         I do not agree with the causing of any suffering to animals if it is not for the net benefit of the individual animals concerned.
·         'Prolonged' in the context of restraint needs to be defined.
·         I do not consider that there is any justification for ?production of monoclonal antibodies by the ascites method; I understand that humane methods of producing these have been available for a long time.

Clause 2.2.16: I am not familiar with SOPs but feel that the requirement for review of these by the AEC every three years seems inadequate. I would suggest that annual review would be more appropriate.

Re Clause 2.2.20, I wonder whether there is scope for recommending wider consultation when it is difficult to reach consensus. This may reveal precedents for similar situations and help to guide decision-making, although precedents must not be automatically allowed to influence decisions directly.

Re Clause 2.2.21, promptness (of decision-making on approving proposals) must be of secondary importance to animal welfare considerations. Could this be explicitly stated in the Code?

I do not accept the need or desirability for the harmful types of animal research detailed in Clause 2.2.29.

Re Clause 2.2.30, I would prefer inspections of animal holding areas to be required to be more frequent than annually. At least some should be conducted without prior notification of the investigators, teachers or others involved in the projects or in animal care.

Re Clause 2.2.31, it is not clear whether the code has any legal standing and thus how breaches should be dealt with, for example whether 'remedial action' can include sanctions against persons committing the breach. Perhaps this is beyond the scope of the document, but clarification would be helpful.

I would like to see Clause 2.2.32: "Institutions should consider appointing an officer with veterinary or other appropriate qualifications who is authorised by the AEC to ensure that the projects are proceeding in compliance with the Code and the decisions of the AEC" changed to "Institutions must appoint an officer..." This officer must have no pecuniary interests which might bias his/her decisions.

Clause 2.2.34 states: "In cases of emergency before an animal is treated or killed, all reasonable steps must be taken to consult with the responsible investigator or teacher..." I consider that it is more important to seek urgent veterinary attention for the animal's benefit than to consult with experimenters. If a vet considers that suffering is severe the animal must be treated or euthanased promptly. It is the fault of the experimenters and their associates if an animal is suffering, which reduces the degree to which experimenters' needs should be met, and difficulty in contacting experimenters may indicate non-compliance with Clause 3.1.7 (see below). The only situation which I can envisage in which the experimenters should be consulted first is where records necessary to assess the animal's needs, for example records of what experimental procedure has been carried out, cannot be found. Clause 3.3.10 (see later) refers to the need for promptness in alleviating suffering during experiments, as does Clause 3.3.37, and the same criteria should apply here.

I am not sure whether annual progress reports, as recommended in Clause 2.2.35, are sufficient. Many projects are of short duration and thus I think that reports should be more frequent - at least four times a year, in keeping with the frequency of regular AEC meetings. Perhaps there is scope for variable intervals for progress reporting as with inspections (Clause 2.2.30), depending on a project's potential animal welfare implications; these could be decided by the AEC as part of their approvals of proposals and subject to revision in the light of events.

Clause 3.1.7 states: "Investigators and teachers must make arrangements so that they or other responsible persons can be contacted in the event of emergencies." See my comments on Clause 2.2.34 (above).

Clause 3.2.2: "...Where relevant, species and individual animals should be chosen on the basis that the proposed studies will result in the least pain or distress. In making this decision, investigators and teachers should consider all aspects of the biological nature of the animals, including their behavioural characteristics and their cognitive development" could perhaps be more specific, for example including reference to sentience, social needs and susceptibility to stress from captivity or handling.

Clause 3.3.4 reprises Clause 1.20 and I strongly support it.

Re Clause 3.3.5 (v): "The investigator or teacher must anticipate and take all possible steps to avoid or minimise pain and distress including...using anaesthetic, analgesic and tranquillising agents appropriate to the species and the scientific or educational aims", I would prefer 'and the scientific or educational aims' to be deleted. The clause relates to ethical rather than scientific issues, so the minimisation of pain and distress should not be compromised by issues not directly related to animal welfare.

Clause 3.3.7 states: "The use of local or general anaesthetics, analgesics or tranquillisers must be appropriate to the species, and should at least parallel their use in current medical or veterinary practice." I agree with this but would like to see account taken of two important differences between the treatment of humans and the treatment of other animals, namely that (a) the latter do not understand what is happening and (b) they tend to need to be restrained in order for treatment to be carried out. These have significant animal welfare implications in themselves, and need to be taken into account in relation to all procedures.

I would like to see clarification of part of Clause 3.3.9: "...Before commencing a project, investigators and teachers should condition animals to the project environment and procedures and the personnel involved with the project", viz. elucidation of appropriate, humane conditioning methods.

I agree strongly with Clause 3.3.10 which states: "If animals develop signs of severe pain or distress despite the precautions outlined above, the pain or distress must be alleviated promptly or they must be killed humanely and without delay. Alleviation of such pain or distress must take precedence over continuing or finishing the project."

There is apparent ambiguity or even contradiction in Clause 3.3.16: "Periods of prolonged restraint or confinement should be avoided. Where prolonged restraint or confinement of animals is proposed, such as housing livestock in metabolism cages, consideration must be given..." The first sentence appears to say that prolonged restraint or confinement are not to be permitted, whilst the second sentence makes the issue conditional. Clarification is required, for instance something along the lines of "Investigators and teachers must provide detailed justification for procedures involving prolonged restraint or confinement. The AEC will not approve such restraint or confinement if not fully convinced of its necessity and of its acceptability on animal welfare grounds."

Clause 3.3.17: see my comments on Clause 4.3.2

Clause 3.3.18: states: "When it is necessary to kill an animal, humane procedures must be used. These procedures must avoid pain or distress, be reliable and produce rapid loss of consciousness until death occurs. The procedures should also be compatible with the scientific or educational aims." This is another clause [also see my comments on Clause 3.3.5 (v)] where I think that scientific or educational aims should be deemed irrelevant, so would prefer the last sentence to be deleted.

Clause 3.3.20 states: "Animals should be killed in a quiet, clean environment, away from other animals where possible. Death must be established before disposal of the carcass. Re the word 'clean': an overly sterile environment, especially one smelling of disinfectant or other cleaning products, might be more stressful to an animal than a less-clean one which more closely matches its natural habitat. In many instances the animal may be in the field, and euthanasia in situ would be more humane. I would also prefer "Death must be established..." to be replaced with "Death must be confirmed by at least two competent persons..."

Re Clause 3.3.22: "Dependent neonates of animals being killed must also be killed or appropriate provision made for their care" I would prefer 'neonates' to be replaced with 'offspring', as many species require prolonged parental care for their physical, social, psychological and survival traits to develop normally.

Re Clause 3.3.24: "When animals die unexpectedly an autopsy should be performed by a person with appropriate qualifications and/or experience to determine(d) the cause of death. The AEC should be notified of unexplained morbidity or mortality during the project (See 3.1.10)", the reference to another clause appears to be erroneous: Clause 3.1.10 is about farming practices. Also I would add the word 'immediately' after 'The AEC should be notified'.

Clause 3.3.27 states: "Surgical procedures must be carried out under appropriate local or general anaesthesia." I would add that, if any pain or distress is likely to occur under local anaesthetic, including distress due to restraint, general anaesthesia should be used instead.

Clause 3.3.27 also states: "...Anaesthetic monitoring records should be kept as appropriate." Clarification of 'appropriate' would be desirable here. Record-keeping should be as thorough and meticulous as possible, and both predicted and unforeseen findings of all kinds should be published electronically and freely available. This can enable other investigators and educators to ascertain whether various kinds of knowledge already exist, thus potentially greatly reducing duplication.

Clause 3.3.28 states: "The choice and administration of anaesthetic, analgesic and tranquillising agents must be suitable for the species and the purpose of the project..." The purpose of a project should never take precedence over the welfare of an animal.

Clause 3.3.30 states: "When the animal is to recover from the anaesthetic, surgical procedures must conform to accepted standards in human and veterinary practice. Analgesics and tranquillisers must be used when required and should at least parallel their use in current medical and veterinary practice." My comments on Clause 3.3.7 are also pertinent here.

My comments on Clause 3.3.27 regarding publication also apply to records referred to in Clause 3.3.34. ALL records should also be available to the AEC on demand.

I agree strongly with Clause 3.3.37: "Any post-operative animal observed to be in a state of severe pain or distress which cannot be alleviated quickly must be killed humanely without delay."

I agree strongly with Clause 3.3.38 which states: "Surgical wounds must be inspected regularly for the progress of healing and any problems must be attended to immediately." However, this is an example of potential conflict between research aims and animal welfare, as some research is aimed at investigating wound healing, post-operative infection, etc. My own stance is that it is morally wrong to deliberately create adverse events or a risk of their occurrence, so I hope that AECs would automatically reject such research proposals.

Whilst I am opposed to the use of neuromuscular blocking agents on animals in an experimental, rather than therapeutic, context, I strongly support the recommendations in Clause 3.3.41 in the event of such experiments being approved.

I do not support the use of animals as models for human conditions (Clause 3.3.43). However, I agree strongly with the stipulation that "The use of painful, distressful or lingering death as an end-point...must be avoided" not just in the specific context cited but in all contexts.

Clause 3.3.44 contains conflicting statements, one declaring that "Painful or noxious stimuli should be avoided" - an absolute statement, and a subsequent phrase: " If their use is necessary..." which implies conditionality. This needs clarifying. My own stance is to support the former sentence in an absolute sense.

The clause also conflicts with the one to which it refers (3.3.71). Clause 3.3.44 states: "Severe deprivation of water, food, social interaction or sensory stimuli must not be used" whilst 3.3.71 states: "Projects involving the withholding or severe restriction of food or water must be designed to produce no continuing detrimental effect on the animal." Perhaps this conflict means that withholding or severe restriction of food or water is permissible for some kinds of experiment but not for behavioural studies. I am opposed to all deprivations referred to in Clause 3.3.44 for any context other than a therapeutic one, e.g. for pre-operative preparation.

I am completely opposed to the use of animals for toxicological studies (Clauses 3.3.45-48). This opposition is reinforced by the weakness of your Code of Practice in this area with regard to animal welfare, for example:

(a) Clause 3.3.46 states: "The end-point of toxicological studies must be as early as is compatible with reliable assessment of toxicity, and must minimise the extent of any pain or distress." (my italics) This conflicts with your introductory statement: "The Code emphasises the responsibilities of investigators, teachers and institutions using animals to...avoid pain or distress for each animal used in scientific and teaching activities." (my italics) I understand 'avoid' to be an absolute term.

(b) Clause 3.3.47 states: "Investigators must not allow the painful or distressful or lingering death of animals unless no other end-point is feasible and the goals of the project are the prevention, alleviation or cure of a life-threatening disease or situation in humans or animals."

There is, to my mind, no likely scenario which justifies deliberately causing an animal to suffer a painful or distressful or lingering death. In the case of drugs, animal findings correlate extremely poorly with human clinical findings, so do not provide guidance which might benefit human health. Misleading animal findings actually cause human health problems (for example hundreds of thousands of deaths from prescribed medicines every year). Beyond the arena of medicine, justification of causing animal suffering by deliberate acts is even more difficult - in my view impossible.

I do not accept any justification for administering infectious organisms to animals (Clause 3.3.52) unless it is for prophylactic or therapeutic purposes in the animals concerned, e.g. bacteria which may be anticarcinogenic or protect against the development of allergies.

My stance on Clauses 3.3.49 to 3.3.53 is the same as that for Clauses 3.3.45 to 3.3.48. If there is evidence from epidemiological, clinical, in vitro or in silico studies that a substance, physical entity (e.g. radiation) or micro-organism is likely to be hazardous, the precautionary principle should apply and it should not be used unless it is likely to provide very substantial benefits to society and can be used in a completely contained way. Animal testing of such substances, entities or micro-organisms is unjustifiable.

I oppose the premise in Clause 3.3.54 that it is acceptable to harm animals for the purposes of 'studying ways of improving the health or welfare of animals', just as I do not agree that it is acceptable to harm humans when studying ways of improving the health or welfare of humans, except where informed consent has been given by a competent individual.

Conditions such as 'injury, trauma, nutritional disorder, physical exertion, disease or environmental stress' can and should be studied using non-invasive imaging techniques, epidemiological, clinical, in vitro and in silico methods and human volunteer studies. Humans tend to be better subjects for imaging as they do not have to be forcibly immobilised and are able to discuss their condition.

I am concerned about the weakness of one of the listed conditions for acceptability, namely that: "(i) the principal aim of the project is to improve animal welfare or health" (my italics) and would like to see the word 'principal' removed on the grounds that it might otherwise be difficult to detect instances of investigators bending the truth in order to gain approval.

Again, severe end-points are conditionally allowed by the Code of Practice for this field of research (Clause 3.3.54 (v) refers), and I consider these unacceptable.

I am also opposed to the genetic modification of animals (Clauses 3.3.55-3.3.62). Clause 3.3.57 states: "In the proposal, the investigator must inform the AEC of any potential side effects of genetic manipulation that may have a negative impact on the welfare of the parent animal or their offspring..." This is rarely or never feasible: there have been and will continue to be many unforeseen outcomes from genetic modification, often with severe animal welfare repercussions. Clause 3.3.59 effectively acknowledges this fact when it states: "The breeding procedures used to establish a genetically modified animal colony, either from newly-created genetically modified animals or those from an outside source, should be considered as a scientific purpose, at least until detailed information regarding the phenotype of the animals and any adverse side effects of the genetic manipulation have been documented by the investigator and forwarded to the AEC." (my italics)

I do not accept any justification for "Proposals for the creation of genetically modified animals which are expected to suffer pain or distress" (Clause 3.3.58).

I am opposed to the cloning of animals (Clause 3.3.63) with the possible exception of that for the purpose of sustaining biodiversity where a species or strain is extinct or endangered and viable DNA is available. If a cloning proposal is approved, I would not accept any causing or tolerance of suffering in the animal(s) concerned.

I am opposed on moral grounds to the deliberate induction of tumours (Clauses 3.3.64-3.3.67) or any other pathological condition. If such experiments are permitted, I agree with the conditions in the Clause, but only with the addition of stipulations that the causing of pain or distress must be avoided and that treatment, analgesia or humane euthanasia must be provided if any pain or distress is observed.

Re Clauses 3.3.68-3.3.69: as stated in my comment on Clause 2.2.15(x), I do not consider that there is any justification for ?production of monoclonal antibodies by the ascites method; I understand that humane methods of producing these have been available for a long time. If such experiments are permitted, I agree with the conditions in the Clause.

Causing lesions to the central nervous system (Clause 3.3.70) is morally unacceptable to me unless it is for therapeutic purposes in the animal concerned.

Clause 3.3.71: see my comments on Clause 3.3.44. I am opposed on moral grounds to the withholding or severe restriction of food or water except where this is necessary for therapeutic reasons in the animal concerned.

Clause 3.3.76: I do not accept the need to subject animals to 'stimuli designed to produce pain'. Such research can be carried out on human volunteers and patients, a major advantage being that humans can report their own pain levels, whereas in non-human animals these can only be hypothesised from behavioural and/or physiological responses. If such experiments are permitted, I agree with the conditions in the Clause.

It is not clear whether clauses in Section 4 are particular to the Code of Practice or extracts from other legislature or guidelines, but I will continue to comment as before.

Re Clause 4.2.5: "Food and water must be provided when necessary" I would prefer a precautionary recommendation, as the Clause could be interpreted in a reactive context and reaction might come too late.  Thus I would recommend something along the lines of: "Food and water requirements must be anticipated and must be provided on a precautionary basis following consultation with a veterinary expert on the species concerned."

Clause 4.3.1: "When new animals are being admitted into animal holding areas, they should be held separately..." is problematic because it does not take into account the social and psychological needs of animals who were living in social groupings, including mothers and infants. Suggested amended wording: "When new animals are being admitted into animal holding areas, they should be held separately from animals already at the facility. New arrivals should not be separated from each other if they are fellow-members of social groups, and members of social species should not be kept in isolation unless a serious threat of cross-infection or intraspecific aggression is identified."

Also regarding Clause 4.3.1, the type(s) of qualification held by the 'qualified person' referred to should be clearly specified.

Clause 4.3.2 states that '...(animals) which do not adapt satisfactorily should not be kept.' There should be some reference here to what should be done with such animals, and also perhaps an addition to Clause 3.3.17 ("Upon completion of the project, animals must be returned promptly to normal husbandry conditions or their natural habitat if appropriate and permitted, or killed humanely where necessary") to cover such situations. I would advocate a careful return to an animal's natural habitat if it has been wild-caught. This needs to be carefully done since some species will tend to attack or otherwise reject an animal if it carries unfamiliar or disturbing smells, and animals must not be relocated in such a way that territories or food supplies are compromised. Expert help and guidance on releasing animals must be sought.
Healthy non-wild-caught animals should be found places in sanctuaries or caring homes. Euthanasia should only be a last resort, after the aforementioned solutions have been fully explored with the help of animal welfare organisations.
Re Clause 4.4.7, it should be borne in mind that many construction materials contain and/or emit synthetic chemicals of known or potential toxicity, so these should be avoided as far as is possible in the construction of facilities.

Re Clause 4.4.10: "The choice of detergents, disinfectants, deodorants and pesticides must avoid contamination of the animals’ environment and should be made in consultation with investigators and teachers", it is important to consult experts in toxicology as well: investigators and teachers will not necessarily have the required knowledge. In view of the extreme paucity of knowledge about the safety of many such products, I would like to see a recommendation to avoid the use of products containing synthetic chemicals as far as is possible and to choose instead natural products with a long history of safe use.

I do not agree with the condition 'unless other conditions are approved by the AEC for a particular project' in Clause 4.4.14: "Animals must be provided with environmental conditions which suit their behavioural and biological needs unless other conditions are approved by the AEC for a particular project" and would like to see this phrase deleted.

I agree strongly with Clause 4.4.19: "Animals must receive appropriate, uncontaminated and nutritionally adequate food of a quantity and composition that maintains normal growth of immature animals or normal weight of adult animals as well as the requirements of pregnancy or lactation." In view of the word 'must', there is conflict between this clause and Clause 4.4.22 which states: "Variations to these requirements as part of a project must receive prior AEC approval" and with Clause 3.3.71 which accepts the need for the withholding or severe restriction of food or water.

Clause 4.4.21, with which I strongly agree: "Clean, fresh drinking water should be available constantly as suitable for the species" also conflicts with Clause 3.3.71.

I do not agree with part of item (ii): 'provision of single housing for animals when it is appropriate...for the purpose of the...collection of samples' which is given as a factor 'to be taken into account' in Clause 4.4.23: "Animal accommodation should be designed and managed to meet species-specific needs...." Facilitation of the collection of samples is not sufficient justification for keeping a social animal in isolation.

I am also unhappy with factor (v) relating to the above clause: 'the need to clean the pen, cage or container'. Such 'needs' have led to appalling conditions for many farm animals, such as wire floors instead of solid surfaces with natural bedding. Animal welfare must take precedence over convenience for humans.

Factors (vii): 'requirements of the project' and (viii): 'the need to observe the animals readily' cause me similar concerns. I would like to see the addition of a point (ix): 'the need to give precedence to animal welfare over convenience for humans.'

Item (ii) of Clause 4.4.24: "Pens, cages and containers kept clean" fails to take account of the need of some species for mud, faeces to reingest, etc. Suggested modified version: "Pens, cages and containers kept in a state of cleanliness suitable for the needs of the species and individuals concerned."

Item (viii): 'be compatible with the behavioural needs of the species' does cover the above requirement but conflict between statements should be avoided.

Clause 4.4.25 also contains conflicting statements. "The number of animals in cages, pens or containers and the placement of these in rooms must enable social and environmental conditions for the species to be maintained" (my italics) is an imperative and absolute statement, so is incompatible with the subsequent sentence: "Where it is necessary to house individually animals of a species that normally exists in social groups, the impact and time of social isolation should be kept to a minimum." Such conflicts, which are rather numerous, point to a general need for more careful wording conventions, e.g. the addition of conditional clauses, commencing with 'except' or 'unless', to the main statements.

I would only accept the individual housing of social animals for reasons directly related to their own welfare [also see my comments on Clause 4.4.23(ii)].

There is potential for conflict within Clause 4.4.26: "Bedding and litter must be provided if appropriate to the species and should be...absorbent...and suitable for the particular scientific or educational aims..." There may be species which require non-absorbent bedding, and there is often likely to be conflict between the animals' bedding needs and 'the particular scientific or educational aims'. Thus perhaps this part of the Clause should read "Bedding and litter must be provided if appropriate to the species and should be...absorbent (if appropriate for the species)...and suitable for the particular scientific or educational aims as long as this does not conflict with the needs of the animals."

The second part of Clause 4.4.26: "Pregnant animals must be provided with nesting materials where appropriate" needs also to refer to animals with young, as nests are added to, refurbished and repaired following parturition in some species. It is also important that the appropriate materials are provided. Thus I recommend: "Pregnant and nursing animals must be provided with nesting materials as appropriate for their needs."

Clause 4.4.27 states: "The AEC, investigators and teachers should be informed in advance of planned changes to these conditions, since these may affect the welfare of the animals and the results of the scientific and teaching activities." I believe that the appropriate word, at least with regard to the AEC, would be 'consulted' rather than 'informed' in order to clarify that the AEC's approval is required before such changes can be made.

Clause 4.5.4 states: "The person-in-charge must ensure that ill or injured animals which are not assigned to approved projects are treated promptly and that animals which die unexpectedly are subjected to autopsy." I would like to see the addition of 'euthanased' to cover the needs of animals which cannot be treated, and a requirement to inform the AEC immediately of such morbidity or death and of the results of associated autopsies.

Clause 4.5.13 states: "Personnel employed in the care of animals should be instructed in how to recognise at an early stage changes in animal behaviour, performance and appearance." I would like to see reference to assessment on such knowledge and skills as part of the instruction, to ensure that the information has been absorbed.

Clause 5.1.7 (iii) states: "(The capture, holding, transport, handling and release of animals from their natural habitat must be in accordance with the following...) all materials and equipment used in the capture, holding, transport and manipulation of animals must be cleaned and maintained in a way that minimises the assessed risk of disease transmission."
My comments on Clauses 4.4.7 and 4.4.10 regarding construction and cleaning materials respectively also apply here.

Clause 5.2.3 (ix): "(If capture is to be by trapping, the proposal must include details of the suitability of the trapping technique for the species and how the traps will be managed to minimise the impact on both target and non-target species, taking into account issues such as...) construction of trap - conformation of the walls, lids, covers or grids" should include 'details of construction materials', for reasons given in my comments on Clause 4.4.7 and also for reasons of acoustics:  for example, some metal traps have acoustic properties which can cause great noise-related distress both when they are activated and during an animal's period of incarceration.

Clauses on non-trap capture methods should perhaps also include reference to chemical methods, such as the use of paralysing compounds. These should be declared unacceptable due to their propensity to cause distress, injury and death in both target and non-target species (unless there is already legislation which outlaws these methods).

Re Clause 5.3.2: "Wherever possible, the long-term and short-term consequences of capture, handling and restraint should be recorded", such records should be made freely available in electronic form to assist others working in such fields.

I fear potential conflict in Clause 5.4.1: "The time for which an animal is held should be minimal and consistent with the achievement of scientific or educational objectives" and would like to see an additional statement to the effect that animal welfare must take precedence over scientific or educational objectives.

Re Clause 5.4.5 "Animals should be released at the site of capture unless the AEC approves a proposal outlining reasons why an alternative site is preferred", the suitability of the capture site for release will depend partly on the duration of the animal's absence and whether the site can still support the animal in the light of any changes since it was removed, e.g. occupation by another animal or animals, food supply, etc. (also see my comments on Clause 4.3.2).

I would like to see the word 'limiting' in Clause 5.5.2 (ii): "Stress during transport should be minimised by...limiting exposure of animals to extremes of temperature, noise, visual disturbance and vibration" changed to 'minimising' or, better still, 'avoiding'.

Re Clause 5.6.1: "The method chosen to identify individual animals must be that which causes the least distress and the least interference with the normal functioning of the animal within the context of the scientific purpose" I would like to see either 'within the context of the scientific purpose' deleted or the following text (or similar) added: "Animal welfare needs must take precedence over the needs of experimenters." I would also like to see the following (or similar) text added: "Identification methods which interfere with animals' normal functioning will not be permitted if they have the potential to cause distress or to impair normal functioning following release. Methods which pose a hazard to other animals will not be permitted."
An example of the latter is a collar with an antenna which can damage the eyes of conspecifics during interactions such as grooming.

Re Clause 5.8 on voucher specimens, I would like to see included a statement that the killing of an animal in order for it to serve as a voucher specimen is unacceptable. The range of technological methods available for recording details about living species makes it unnecessary to take life in order to study it. Biochemical information can be obtained from taking samples without causing physical harm, and anatomical data can be acquired by using non-invasive imaging equipment including still and video cameras.

I would also like to see 'and freely' added to Clause 5.8.1 so that it reads: "Optimal use of voucher specimens requires that they become part of a publicly and freely accessible reference collection."
I disagree with Clause 5.9.2 which states: "The primary ethical considerations with studies of wildlife interaction are the degree of manipulation required to set up the interaction and the effect of the observer(s) on the interaction." In my view these are issues of scientific rigour rather than of ethics, and the main ethical consideration is the degree of suffering which may be incurred by an animal as a result of human manipulation of a situation. For example, rendering a prey animal more vulnerable to a predator in such a way that it is aware of its impending fate for a prolonged period is unacceptable. Another example would be the deliberate reduction of food supply which might lead to starvation and/or intraspecific aggression. In both cases it is the suffering which should be the prime cause for concern, not the degree of manipulation or the effect of the observer(s). Another important ethical consideration would be the ecological effect of human intervention, such as a reduction in biodiversity, especially that due to an adverse impact on an endangered species or population, although this may only be an issue in a small minority of studies.

I am very pleased to note that Clause 5.10.1 states: "All of the principles set out in this Code apply equally to animals considered to be pests."

Most situations where animals are considered to be 'pests' are the consequence of ill-advised human actions. Therefore I consider that the AEC should require, before considering proposals for lethal 'pest control', evidence of attempts to minimise conflict between the culpable (human) species and the non-culpable ('pest') species through changes in human activities. Following maximal effort to reduce conflict by such means, the AEC should require a thorough investigation into non-harmful methods of reducing populations of 'pest' species and/or of relocating them to where conflict is less likely. Animal welfare must be given high priority at all times.

I welcome the statement in Section 6 that "...all parts of this Code, including the principles of the 3Rs, are applicable to teaching activities in schools and tertiary institutions."

I fully support Clause 6.1.1 which states: "Animals are not to be used for teaching activities unless there are no suitable alternatives for achieving the educational objectives."
The AEC should rigorously examine any educational objectives claimed to require the potentially physically or psychologically harmful use of animals, in order to ascertain whether they are reasonable and necessary. Where such an educational objective is not deemed by the AEC to be reasonable and necessary, harmful animal use should not be permitted. This may also require consultation with the institution.

I strongly support Clause 6.1.3 which states: "Students should be given the opportunity to discuss the ethical, social and scientific issues involved in the use of animals for scientific purposes. Students should be made aware of this Code and relevant state legislation. Where students use animals as part of their training, the relevant curricula should include material on such issues." I would add: "Teachers and students should be made aware of the range of non-animal-harming methods available and of findings regarding their efficacy as teaching tools. Advantage should be taken of alternatives loan services such as those provided by the Humane Society International and InterNICHE, and students should be enabled to try out such alternatives under teachers' supervision prior to deciding whether to use these or animal methods."

I strongly support Clause 6.1.4: "The use of non-animal models to achieve educational outcomes is still evolving and therefore should be kept under constant review. The institution will therefore need to establish mechanisms to respond to enquiries or complaints concerning the use of animals within the institution and ensure that staff members and students may voice their concerns without jeopardising their employment, careers, or coursework." I would add: "Students should be permitted to use non-animal-harming alternatives without jeopardising their employment, careers, or coursework."

To Clause 6.2.4: "Teachers must keep a record of the number of students involved and the number of animals used in each activity and the welfare outcomes" I would add: "Teachers must keep a record of the number of students who use animal-harming and non-animal-harming methods along with anonymised findings of their respective academic performances, which should be made freely available in electronic form (e.g. the Internet)."

Clause 6.4.6: "A school or group of schools may request AEC approval to repeat a particular activity with different animals, students, times and locations" is ambiguous with regard to types of animal.  For purposes of clarity, I would recommend a change of wording to "A school or group of schools may request AEC approval to repeat a particular activity with different animals of the same species, age and gender, different students, different times and/or different locations." Alternatively the clarification could be included in condition (i), which would then read: " teachers must not vary any aspect of the project, including the species, age and gender of animals, without AEC approval and..."

The section on teaching omits reference to animals killed to provide tissue for use by students. This practice should be replaced by ethical sourcing [see my comments on Clause 2.2.15(iv)].

I commend you on your long, detailed and diverse lists of sources of information, loan programs and organisations, but would recommend inclusion of the following in your list of publications on alternatives to the use of animals:

Balcombe, J. (2000) The Use of Animals in Higher Education: Problems, Alternatives & Recommendations, The Humane Society of the United States, Washington, USA

Langley, G. (1989) Animal Experimentation: the Consensus Changes, Macmillan Press, Basingstoke and London, United Kingdom

Langley, G., Harding, G., Hawkins, P., Jones, A., Newman, C., Swithenby, S., Thompson, D., Tofts, P. and Walsh, V. (2000) Volunteer Studies Replacing Animal Experiments in Brain Research: Report and Recommendations of a Volunteers in Research and Testing Workshop, Alternatives to Laboratory Animals (ATLA) vol. 28 pp. 315-331

I would also recommend inclusion of the following in your list of Alternatives websites:

Animalearn and
Dissection alternatives; 'myths' about dissection

Association of Veterinarians for Animal Rights (AVAR) Alternatives in Education Database:
American organisation: website covers wide range of ethical issues for vets

Dr Hadwen Trust:
UK Charity funding non-animal research. Alternatives details, current humane research

Lord Dowding Fund for Humane Research:
UK Charity funding non-animal research. Alternatives details, etc.

Medical Research Modernization Committee

Physicians Committee for Responsible Medicine

Pro Anima
Scientific arguments for non-animal research. Info in French and English

Psychologists for the Ethical Treatment of Animals (PSYETA)
American-based organisation; website features student experiences, evidence linking cruelty to animals with violence against humans, alternatives list, etc.

and the following database to be added to your database list:

CONVINCE Database (Consortium of North American Veterinary Interactive New Concept: Education)
promotes interactive video, CD, and hypermedia programs for veterinary medical education
I should also point out that there is an error in the website address given for InterNICHE - it should be

Please do not hesitate to contact me if anything is unclear or if I may be able to contribute further to discussions.

Vivien Pomfrey BSc (Hons) (Open) Dip. Nat. Sci. (Open)

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