Tag Archives: animal welfare act

USDA Statistics for Animals Used in Research in 2012

In 2011 the USDA stopped publishing its animal research statistics on the Animal and Plant Health Inspection Service (APHIS) website (with the last full stats being 2010). We have recently received the 2012 statistics for animals used in research under the Animal Welfare Act. Overall the number of animals used in research fell by 16% since 2010, falling over 180,000  from over 1.1 million (2010) to just over 950,000 (2012).

Click to Enlarge

Click to Enlarge

These statistics do not include all animals as most mice, rats, and fish are not covered by the Animal Welfare Act – though they are still covered by other regulations that protect animal welfare.

We can see that rodents (guinea pigs, hamsters and other rodents) and rabbits together account for 67.3% of all research animals, with cats, dogs and primates accounting for 16% of research. In the UK, where mice, rats, fish and birds are counted in the annual statistics, over 98% of research is on rodents, birds and fish. Across the EU, which measures animal use slightly differently, 93% of research is on species not counted under the Animal Welfare Act. We would expect similar patterns to be true in the US – although there are no statistics to confirm this.

Click to Enlarge

Click to Enlarge

If we look at the changes between the 2010 and 2012 statistics we can see a drop in the number of animals of most species between 2010 and 2012, with only pigs and cats going against the trend. Most notably the number of non-human primates has fallen by 9.5%, with an even larger drop in the number of rabbits (11.1% drop).

Animals used in research 2010 vs 2012

It is unclear whether the 16% drop represents a clear downward trend for the numbers of animals used in research, or is simply annual variability, though it would fit in a general downward trend in the US statistics since the mid 1980s. It is also likely that, similar to the UK, a move towards using more genetically altered mice has reduce the numbers of other animals used (those counted by the USDA under the Animal Welfare Act).

Speaking of Research

New UK Animal Research Law is a Victory for Animals and Scientists

As the science correspondent of a top UK newspaper said to me earlier this year “Call me cynical, but there are very few things that kill a story quite like having “EU Directive” in the title.”

He was referring of course to the snappily-titled “Directive 2010/63/EU of the European Parliament and of the Council of 22 September 2010 on the Protection of Animals Used for Scientific Purposes” which was transposed into UK law in December 2012. This is how the various EU countries are doing as regards implementation:

Adapted from the excellent http://animaltestingperspectives.org/transposition

Adapted from the excellent http://animaltestingperspectives.org/transposition (Click to enlarge)

In December 2012, the UK’s House of Commons Statutory Instruments committee unanimously approved the amendments to the Animals (Scientific Procedures) Act, 1986 which harmonised UK laws on animal research with the new EU Directive 2010/63. All that remains is for the Home Office to develop supplementary guidance which will clarify specific aspects of the regulations.

The changes, as far as UK science is concerned, are minimal partly because the UK was allowed to keep its standards where they were higher, for instance granting special protection to dogs, cats, primates and equidae. We continue to have a similarly equipped inspectorate, and it appears we will have a similar ethical review process, but these are the sort of details currently being hammered out in the post-legislation guidance.

Another reason for this similarity is the fact the UK has been at the forefront of developing the new legislation, bringing the rest of Europe up to the UK’s standards of animal welfare, whilst harmonising legislative differences and dispensing with some of the red tape that had built up over 30 years that wasted time without improving animal welfare.

Some animal rights and abolitionist organisations continue to fret that regulations will somehow be substantially reduced as the guidance is developed over the next several months but if anything the risks run the other way, with unnecessary red tape in the form of data duplication, or the inclusion of details that benefit only campaigning groups which thrive on the misrepresentation of biological research.

There is also a rather flippant suggestion that project licences should be published, with personal or commercial information redacted, which appears to misunderstand the fact that the triangulation even of redacted information with published materials and the known specialisms of different researchers or research facilities make identifying individuals a moment’s work.

This has serious security, legal and commercial ramifications for some researchers and the institutions charged with protecting their health and safety. That said, it should be possible to release more information to the public in the future, if the project licenses are correctly designed and the ground rules set in a certain way, but once again it is researchers, not campaigning groups, leading the way in finding a practicable solution.

This approach is also in line with the Declaration of Openness signed by over forty leading research institutions and funders. Openness is something UK scientists hope will help to reassure the public, as they may come to see the true costs and the true benefits of research for themselves, not through the distorting filter of campaigning groups.

Nevertheless, the de facto changes to UK regulation of animal research are small – the UK has a system, it certainly works well for animals and it should remain so. The Directive is an important step in bringing many European countries towards the high laboratory animal welfare standards that exist in the UK. Although the Directive does not match the UK’s strict animal welfare laws in every area, the UK will retain its higher standards in all areas where they exist.

Moreover, in many cases scientists have objectives in common with animal welfare groups. Scientists want a well-financed inspectorate: they speed up project approvals and help with legal compliance. Scientists want clean, happy animals: they make better test subjects, and the meme of the “mad scientist” torturing animals is, after all, the construction of a fevered imagination – a foul-tasting cocktail of H.G. Wells, Frankenstein and internet footage of rare and atypical abuses.

Of course, anti-research groups will still push to gain more influence over the ethical review process, such as via Animal Welfare and Ethical Review Bodies (AWERBs), which will preview project licenses, as happens now, at a local level. Abolitionists want to sit on these boards so they can more easily dig up campaigning material and have started describing the current system as a “cosy box ticking exercise” or similar, as usual implying a dark conspiracy where there is none in order to wangle a seat at the table, despite lacking credibility, understanding or perspective.

They may be disappointed; however, since another change taking place from 2014 will be the retrospective assessment of suffering. For years, project licence holders have overestimated the suffering an experiment may engender in order to avoid accidentally exceeding the terms of their project licence. The abolitionists have then dined out on the millions of examples of suffering they think they’ve identified, when in fact they have once again misunderstood what they are reading. From 2014 onwards however they might just find themselves having to vet three and a half million procedures that are no more severe than temporary discomfort or a blood draw: hardly the grim picture of torture suggested by their literature.

Speaking of Research will continue to keep you updated on developments to the EU Directive and its implementation across Europe.

Speaking of Research

An Open Letter to the Laboratory Animal Veterinary Community and Research Institution Administration

The decades following passage of the U.S. Animal Welfare Act in the 1960s are marked with wide-ranging and significant changes to the administration, oversight, and responsibility for daily operations of institutions engaged in laboratory animal research. The intent of the legislation, and the central purpose of the accompanying and continuing changes, is to best ensure the welfare of animals in research.

This goal encompasses all aspects of laboratory animal care— their participation in ethical scientific studies, their humane treatment during daily care and maintenance, and their receipt of the highest standard of clinical care. Do scientists engaged in animal research perform all of these duties?  No. In fact, by law, it is not scientists who have the ultimate responsibility for oversight of all issues involved in animal welfare, but the attending veterinarian and institutional officials.

In practice, there are a range of individuals who share in the responsibility to provide for animal welfare. Many different types of expertise are needed to provide the best management of a laboratory animal research facility. Scientists working with animals have expertise in the topic their research addresses, in the activities that research requires, and in use of animals in research. Depending on their research area, background, and training they may have tremendous depth and breadth of knowledge about the animals’ behavior, psychology, physiology, and other systems. But it takes more than this to accomplish all that is needed to maintain an animal research program.

Animal research programs always include veterinary staff to provide the animals with clinical care. They typically also include animal care staff to provide daily husbandry; behavioral management staff to provide environmental enrichment and animal training; and facility management staff who work with engineers and others to maintain clean and safe environments for the animals. In addition to facility management, clinical care, and daily husbandry there are also divisions of personnel charged with evaluation and oversight of the research, including the Institutional Animal Care and Use Committee, associated staff, and compliance officers. Oversight for the entirety of the animal research program typically rests at the level of university administration.

In sum, the number of individuals and divisions now involved in ensuring laboratory animals’ welfare and humane treatment in ethical scientific studies extends far beyond the scientists most identified with animal research.  What does this mean? It means that there is a great deal of shared responsibility for both successes and the occasional failures in the conduct of laboratory animal science.  It also means that any discussion of continued improvements in the daily activities that affect animal welfare, as well as changes in policies that govern the conduct of animal research, should benefit from teamwork among these different stakeholders.

A Veterinary Technician works with rodents

A huge number of people are involved in animal welfare in laboratories

Finally, it should mean that in public dialogue the voices of scientists and research advocates are routinely joined by laboratory animal veterinarians, university officials, and others who play important roles in laboratory animal research.  This is true even when that research is controversial and has the potential to elicit attention from animal rights activists. All too often, however, few of these voices are raised when the public eye is turned to issues of concern in animal facilities. Rather, in place of thoughtful answers to questions raised by a range of parties—by the press, by animal rights activists, by other scientists, by USDA reports— what is often offered are generic statements that contribute little to understanding of the events and the context in which they occurred. For example, in response to virtually any type of incident, an institution’s response might be along the lines of:  “We follow all regulations and hold animal welfare in highest regard and priority…”

It is long past the time that our community should have abandoned this approach and required more from each of its members and divisions.  To accept anything less is a mistake.  Absence of accurate information, accompanied by the failure of institutions and their representatives to engage in public dialogue, only further erodes public trust.

The intent of the AWA, subsequent legislation and policies, accreditation programs, revisions of guidelines, and continued increases in regulatory oversight is to ensure the best animal welfare and humane treatment possible.  In the rare cases where the apparatuses put in place to achieve this goal fail, sometimes from accident or human error, two things must happen.  First, it is contingent upon all of those involved to immediately work together to identify the reason for the failure and ways to minimize the possibility that it occurs again.  Second, those ultimately responsible for oversight should provide the public with accurate information, explanation, and opportunity for discussion.  At the very least, they should be able to articulate the rationale and their support for the research programs and their contribution to scientific and medical progress.

Are we suggesting that attending veterinarians and institutional officials open their doors for daily chats with animal rights activists?  No, but we do believe that addressing legitimate public concerns and questions about their animal research programs are among the key obligations of those charged with oversight and conduct of those programs.

While scientists can address questions about the scientific side of animal research, we need the laboratory animal care and veterinary staff to provide their expertise in service of addressing public questions about clinical care and husbandry.  If they do not, it will be no surprise if the public view of animal research is disproportionately colored by the relatively rare adverse events and the misrepresentations of animal rights activists. Many believe that it is possible—and perhaps acceptable—to ignore this part of reality in order to focus on more immediate demands for time, energy, and resources. Consider, however, that a fundamental part of the AWA, accreditation, regulation, and professional obligation is actually to ensure communication with the public that supports animal research.  Thus, it is our entire community who share a primary obligation to engage in the dialogue that surrounds us.

Speaking of Research Committee

Compliance at Work

One of the core principles at SR is that animal research should be conducted with the utmost care, responsibility and respect towards the animals.  All personnel involved in animal research should strictly follow the pertinent guidelines, regulations and laws.  Unfortunately, as in all human endeavors, there are isolated individuals who sometimes fail to adhere to established principles. The compliance system exists to detect such instances and take corrective action.

Recently, the USDA confirmed that an individual researcher at the University of Rochester was in violation of the Animal Welfare Act. The University was the first to discover the problem, reporting it to the USDA (the institution in charge of ensuring that the Animal Welfare Act is implemented), who confirmed the findings of non-compliance. The USDA were quick to identify the violations and publish the results, publicly, on their website.  This is an example of the compliance system at work.

As expected, animal rights groups, such as SAEN (warning: AR website), have used this opportunity to attack animal research, promising to “Expos[e] the truth to wipe out animal experimentation”. However, there are two important facts to consider:

  1. This was an isolated incident; and
  2. the system in place to deal with such incidents, responded appropriately.

We say the system responded appropriately in citing the University because the facts that are apparent about this case strongly indicate that this was an unacceptable deviation from established norms for the care and use of non-human primates in biomedical research laboratories.

With very few exceptions (for example, the need to restrict food in advance of anesthesia), monkeys must be fed every single day, with no exceptions or mistakes being permissible. What is worse, deprivation of food for multiple, consecutive days certainly produces profound distress in an animal that should have been identified by the combination of researchers, veterinary care providers and animal husbandry staff who were supposed to be carefully monitoring these animals every day. These animals were failed by the people who were responsible for their health and well-being. We hope that the Institutional Animal Care and Use Committee that supervises these research activities have taken comprehensive measures to ensure that an event like this never happens again.

Speaking of Research must condemn the actions the researcher in question.  Such behavior undermines the hard work that the rest of the animal research community does to ensure the highest standards of animal welfare. Furthermore, we commend the USDA and the University of Rochester for the actions they have taken to ensure that such violations do not occur ever again.

The success of our training, accreditation and compliance systems is not only measured by their ability to detect and correct isolated violations, but also in preventing them from occurring in the first place.   Here, we believe it is imperative to recognize the tens of thousands of persons that conduct their research with the utmost care, responsibility and respect towards the animals.

The Human or the Mouse? Would You Flip a Coin?

On March 8th I debated Prof. Gary Francione at Rutgers.

It was an interesting, heated but civil debate, with a somewhat anticipated outcome.

In a few words, we have profound, irreconcilable differences.

There is a deep, fundamental gap between the views of the vast majority of the public and anyone whose moral theory declares permissible to flip a coin in order to decide who to save in a burning house, a human or a mouse.

And this is exactly what Prof. Francione and a handful of his followers (about 5 out of 120 members in the audience) were prepared to do .  Of course, they are right.  They are right in that this is precisely what Prof. Francione’s theory of animal rights demands them to do.  Why?  Because the theory considers the mouse and the human as both sentient beings that deserve exactly the same level of moral consideration.

The root of our differences can be traced down to his position that there are no morally relevant characteristics that would make the loss of life for the human any different than the loss of life for the mouse.  Prof. Francione view is that the same things are at stake.

Here, of course, he stands against the philosophical current:

For example, Peter Singer recognizes that

to take the life of a being who has been hoping, planning and working for some future goal is to deprive that being of the fulfillment of those efforts; to take the life of a being with a mental capacity below the level needed to grasp that one is a being with a future — much less make plans for the future — cannot involve this particular kind of loss.”

Ortega y Gasset explained that

Human life is the execution of an aspiration — a life’s plan.  Human life is a process that cannot be reduced to mere living by satisfying our immediate biological needs.  Humans are not content with living, they need to live well and realize their ambitions.”

and this, of course, is a relevant reason why animal and human interest in life are not similar.

Tom Regan agrees when he writes

“[…] the harm that death is, is a function if the opportunities for satisfaction it forecloses, and no reasonable person would deny that the death of any […] human would be a greater prima facie loss, and thus a greater prima facie harm, that would be true in the case [of] a dog”

In my opening remarks, I presented reasons for why we must reject the animal rights view, which equates the moral status of all sentient beings.  I did this by giving examples of how applying the theory to various scenarios would lead us to behave in ways that conflict with our moral intuitions.  I argued that once we reject this extreme view, all we are only left with theories based on the notion of unequal moral status between animals and normal humans (such as the two-tier or sliding scale model of moral status).  All of these theories allow animal experimentation to various degrees.

I explained how researchers view very concrete situations as being comparable to the burning house scenario, such as porcine heart-valve replacement surgery, the polio epidemic or the AIDS epidemic in Africa.

I explained also why I believe we have obligations to other living beings, but that these obligations do not imply that animals have rights, as they cannot behave as autonomous, rational moral agents in a community of equals.   This, of course, is a point made by Carl Cohen in various occasions.

Unfortunately, there was no effort on Prof. Francione’s part to pinpoint the flaws in my reasoning.  One of the virtues of his theory is that it is extremely simply to understand, extremely simple to apply, and the consequences are straightforward.   My main point was that the consequences of the theory are in direct conflict with the moral intuition of the vast majority of the public and we must reject it.

Instead, his attacks on animal research amounted to a potpourri of classic mischaracterizations by animal right activists of the actual science, our true intentions, and personal ethics, all of which are difficult to address in a few minutes in a debate.

For example, I pointed out to the use of primates in the development of the polio vaccine that has helped to nearly eradicated the disease from the face of the planet and will continue to save lives for generations to come.  The benefits are unmeasurable.  He responded that animals were not truly needed in the development of the vaccine, in direct contradiction to statements by Dr. Albert Sabin.

I noted that there is vast scientific consensus (92% agreement) from both scientists and physicians alike on the necessity of animal research to advance medical science and knowledge.  He countered that, on this matter, the jury is still out.

He criticized the scientific community for not including mice and rats in the animal welfare act (AWA), but his true position was exposed when he declared the AWA “not worth the paper on which it is written”.   Let us be clear: there are no amendments to the AWA whatsoever that would make the research ethical in the view of animal rights activists.

He criticized me for not being vegan, while it is evident that even if all scientists were to become vegan tomorrow the research would still be viewed as unethical in their eyes.  (Incidentally, I think the ethics of animal food can be defended, but this is an entirely different topic and debate).

I clarified that I am opposed to the use of animals for the development of yet another lipstick, but that there is an obvious need to ensure that any chemicals we bring to our homes are safe to humans and animals alike.  I also noted this is not the type of toxicology work done at our universities.

During our mutual questioning I asked him if his education campaign to break the cycle of “supply and demand” of animal food also extended to the benefits generated by animal research, such as vaccines.  In other words, was he willing to ask the population at large to stop vaccinating their children?

He responded that in fact he would not vaccinate his children (he has none, although he did not say if his dogs are vaccinated), and later he clarified his opposition to vaccination rests not only for ethical but other reasons, which he never explained.  I expressed my dismay at his anti-vaccination position.

Many of the questions directed at me by the audience dealt with the question of moral status of animals and humans.  I explained that I do not claim the moral status of all humans is above the moral status of all animals.  A number of questions regarding marginal cases ensued.   I think this can be a productive and interesting discussion to have in society, but it is only a discussion that is possible once we accept the unequal moral status of animals and normal humans.   Clearly, it is not a discussion that is even theoretically possible within the framework of animal rights theory that equates the moral status of all sentient beings.

I had a nice and frank conversation with Prof. Francione prior to the debate.  As he correctly judged, our positions are “miles apart”.  My perception is that he is a good man, with noble intentions, but philosophically he is as wrong as anyone can be.

Both Prof. Francione and I agreed on one thing: the debate was a good example of how passionate but respectful discourse is possible on controversial issues in our society.  I want to publicly thank him for his invitation to debate.

Prof. Francione and I will share a video of the entire event once it is ready.

Dario Ringach

Speaking of Regulations

Regulations of research has always been an important issue for animal welfarists (as opposed to animal rights activists who start on a fundamentally different set of assumptions). Many people do not realize that there are strict protocols that monitor and regulate research. For this reason we have created a new page dedicated to the regulations surrounding the use of animals in laboratories. This covers the role of the Institutional Official, the Attending Veterinarian, the Institutional Animal Care and Use Committee (IACUC), and other regulatory requirements.

Some activists suggest that because the animal welfare act does not cover mice and rats, that 95% of research is essentially unregulated. This could not be further from the truth, and the regulations page will help explain how the various institutional frameworks fit together to ensure the highest standards of care to all animals – be it mouse or monkey.

We hope to continue to further expand this section in the future.

Regards

Tom Holder