Problems with ethics committees

Ask any institution or company whether they use animals in research and their response will nearly always say that all animals are treated humanely and their use is subject to approval by an animal ethics committee which contains an animal welfare rep. The presence of animal ethics committees, and in particular inclusion of a category C member (animal welfare representative) can therefore be seen to promote a ‘clean' image of the research industry to the public as an assurance that the care and use of animals is sanctioned by those with a concern for their welfare and/or rights. While it might be considered necessary to retain a system that monitors and polices the use of animals in research, the system is far from flawless. In particular, our continued efforts to refine experiments may be detracting our efforts to reduce and replace animals by actively seeking alternatives. Overseas studies of the ethics committee system and discussions with Australian AEC members have revealed serious concerns and raise questions as to whether this system is doing more damage than good. It therefore begs the question of whether we should be trying to resolve these problems or whether we should be re-evaluating the entire system, including our attitudes and approach to the use of animals in research. Thank you for the opportunity to present the views of AAHR here today. For those of you who are not familiar with the Australian Association for Humane Research, we are a non-profit organization that was formed back in October 1979 and until the last 18 months was based in Sydney. I’m going to be upfront and confess to you all that we are an abolitionist organization. But don’t worry. I haven’t brought along any protestors, no placards and I certainly won’t be wearing my black balaclava. That’s not how we work. We oppose the use of animals in research on both ethical and scientific grounds, but we do this by working with researchers, institutions and funding bodies to encourage the use of more humane, scientifically-valid non-animal methods. As part of an abolitionist organization I have not served on an ethics committee. The issues that I’ll be presenting have therefore been derived from a variety of sources, including overseas studies, discussions with AEC members and some examples taken from our own work. I do acknowledge and respect the motives of animal welfarists who participate in the process, and appreciate their willingness to become involved in a system they may not necessarily agree with, but consider that their involvement and input may have a positive impact on the welfare of individual animals that are the unconsenting subjects in the system. General Perceptions: Ask any institution or company whether they use animals in research and their response will nearly always say that all animals are treated humanely and their use is subject to approval by an animal ethics committee. I have personally received this standard response from multinational corporations that test their products on animals, from local councils that send pound animals to research institutions and from funding bodies ARC (Australian Research Council) and NHMRC (National Health & Medical Research Council) when I recently challenged their justification of funding vision experiments on marmosets. The presence of animal ethics committees, and in particular inclusion of a category C member (animal welfare representative), is often used by researchers to promote a ‘clean' image of the research industry to the public as an assurance that the care and use of animals is sanctioned by those with a concern for their welfare and/or rights. However many category C persons serving on an ethics committee are opposed to the use of animals in research. Their presence is to ensure that the animals are protected as much as possible but can only do so within the scope of the Code of Practice. “Ethics Committees, however, do not tend to question the ‘ethics' underlying experiments, they simply refine experiments. In this way they can be seen to justify experimentation.”(Category C member, name withheld.) Does the existence of AECs and in particular “Category Cs” really provide assurance that animals do not suffer? Ethics committees operate within the constraints of the code. If we look at some extracts of the code we find the following: “The scientific validity of animal models of human disease rests in part on how closely a given model resembles a particular disease, which may include the animals experiencing the attendant pain or distress of the human disease state” (3.3.43). The nature of many forms of medical research means that animals will suffer pain and distress from the invasive procedures as well as the effects of many drugs. For example, during research into arthritis the research animals would need to experience the arthritic pain associated with the condition. They may also suffer any adverse reactions the drugs may cause such as vomiting, seizures, stroke etc. This has been reiterated by The ethics of research involving animals, Nuffield Council on Bioethics. “..post-operative pain can be controlled by pain relieving medicines, but sometimes they may interfere with experiments on pain and may not be given.” The report also states: “Regulation can act as an emotional screen between the researcher and an animal, possibly encouraging researchers to believe that simply to conform to regulations is to act in a moral way.” “We conclude that some form of regulation is necessary for good moral practice, but that it is crucial to be aware that it may not be sufficient.” While the general public are often misled into believing that ethics committees protect animals from pain and suffering, clearly the existence of legislation, codes of practise and ethics committees can only protect animals to a certain degree but certainly do not guarantee there is no suffering. Failure to exercise ALL the 3R’s? We are all aware that the 3R’s serve as complementary rules of thumb to reduce overall suffering and form the framework of the animal ethics system. At conferences I have attended there has been quite some focus on refinement but very little on reduction and specifically on replacement. My first attendance at the BAW Scientific Procedures Seminar was two years ago when one of the speakers asked the floor whether there was anyone present that would like to see animal experiments banned. I was shocked that only two of us raised our hands at that time. I had assumed that as “Category Cs” there would have been a large number of people present that would 1 Australian code of practice for the care and use of animals for scientific purposes. 7 Edition 2004. 2 The ethics of research involving animals, Nuffield Council on Bioethics, 2005, p.137 3 Ibid p.XIX 4 Ibid p.XXIV be looking toward reducing and ultimately eliminating the use of animals for such purposes. This, I believe, should be the ultimate goal of everyone, but particularly of animal welfare representatives. Even according to William Russell, who co-authored of The 3R’s in 1959 (and who sadly passed away just recently), “Refinement is never enough, and we should always seek further reduction and, if possible, replacement... Replacement is always a satisfactory answer.” It’s absolutely essential that we ask the question, “Can the aims of the research be achieved in ways that do not involve animals?” And “Will the scientific outcome of this research justify the lives it will take and the suffering it will cause?” In many cases you will find that it will not. The House of Lords Select Committee 2002 has said: “We are not, however, persuaded that enough effort is always made to avoid the use of animals. We are similarly not persuaded that where this is possible, sufficient effort is always made to minimize the number of animals used, and to minimize the pain and suffering inflicted on each animal.” As a local example of the failure to implement replacement, AAHR became aware of the mouse bioassay being used to test water toxicity after algal blooms. The painful test involves intraperitoneal injection (into the abdomen) of the water sample and if 2/3 or 3/3 mice deaths occur within 24 hours then it is determined that toxins are present. The immediate effects on the mice can include them becoming rapidly subdued, unresponsive with bluish extremities and cold to the touch. They can display disorientation, paralysis of hind limbs, breathing difficulties and a violent jumping reaction. These can occur within 30 minutes of injection. No anaesthesia is used and death usually occurs within 5 hours from heart failure. The mouse bioassay has been criticized for a number of reasons, including inconsistency, its dubious relevance to human hazard and the suffering it causes to laboratory animals. Our research found that most water authorities use alternatives to the mouse bioassay – mostly high performance liquid chromatography (HPLC) so we now question why this particular water authority continued to use the mouse bioassay when an alternative method of testing not only exists, but provides a more accurate diagnosis? Clearly there was not enough effort put into replacement. As a further example, a speaker at the most recent ANZCCART conference discussed the use of animals in teaching and justified their use by suggesting that it enthuses students to learn more. If we did a cost/benefit analysis, can we honestly say that enthusing students is sufficient justification for taking away the lives of sentient beings particularly when there are other (perhaps a little less stimulating) ways to achieve the desired outcome? Do we really place such little value on the lives of those animals that we dispose of them, not in the pursuit of knowledge, but merely to pass on knowledge to others? Teaching is an area in which we CAN replace animals and yet they are still being used. I recently corresponded with the Department of Anatomy and Cell Biology at