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BUAV submission to the UK government regarding EU animal testing Directive

22/09/2011

It is a critical time for animals in UK laboratories as the legislation governing the use of animals in research is undergoing the first major review since it came into force in 1986. Following the adoption of EU Directive 2010/63/EU, the UK has until 2013 to implement new regulations into its legislation. 

The BUAV opposes all animal experiments, and we believe that the Directive is a missed opportunity to impose much stricter conditions. We also do not believe that legislation on animal experiments in the UK is in any way satisfactory. However, the transposition is both an important opportunity and the BUAV has submitted an in-depth response to the Government, using our scientific expertise to fight for the strongest possible regulations on the use of animals. 

In some cases, current UK rules are stronger than the EU Directive, and the BUAV has urged the UK to stand firm in these cases, notably in maintaining or improving the current inspection of laboratories which is at risk of being cut by 90%, as well as preventing the introduction of more painful experiments and the ending of stricter rules regarding the use of cats, dogs and horses.

In other cases, the EU Directive offers tighter regulations or allows a range of interpretations, and the BUAV submission calls for the proper use of the cost:benefit test as well as the full use of alternatives, so that the Directive can be used to progress to the real reduction in animal experiments that the Government has said it wants to achieve.

Here is an overview of the BUAV’s key recommendations: 

URGES that all experiments:

a) Have their project licences published in full, except for the limits set by the Freedom of Information Act (to protect individual safety and commercial confidentiality)

b) Have retrospective assessments to assess whether the objectives were achieved and suffering limited to the extent set out in the licence

c) Have non-technical project summaries including details of the experiments to assist the public in assessing the process

URGES the UK to lead the way in banning the use of the offspring of wild-caught primates

URGES concrete commitments to fund and promote alternative methods as required under the new Directive, for example introducing a fee for project licences involving animals, with the proceeds used to support research into alternatives

URGES that the new regulations should make clear that the veterinarian responsible for supervising an establishment should have no conflict of interest – in a BUAV investigation which uncovered particularly bad practices, the veterinarian responsible also had close links with the establishment he was supervising

URGES the UK to implement the EU requirement to minimise severe suffering, in ways going beyond current UK practice

SUPPORTS tighter EU rules on research using non-human primates. limiting it to research related to “debilitating or potentially life-threatening clinical conditions in human beings”

SUPPORTS the UK ban on experiments on Great Apes, and urges that it be made permanent.

SUPPORTS the restrictions laid down by the EU on capturing wild animals for experiments

PROPOSES ways to avoid duplication of animal experiments, using and strengthening current UK practice

OPPOSES the massive reduction in inspections (by up to 90%) and the abolition of unannounced (“surprise” inspections), both of which are being considered by the Home Office

OPPOSES the removal of tighter regulations on the use of dogs, cats and horses

OPPOSES relaxation of rules on the marking of animals (EU proposal would allow painful marking practices)

OPPOSES relaxation of rules on experiments on endangered species

OPPOSES allowing the use of stray and feral animals, which could result in stolen or abandoned pets being used

OPPOSES allowing animals to be used for educational training or weakening the current UK ban on use for testing offensive weapons, alcohol or tobacco products

OPPOSES any relaxation of the rules on minimising pain and suffering through anaesthesia or analgesia

OPPOSES a relaxation of the ban on the re-use of animals who have already suffered through a severe test

OPPOSES allowing inhumane methods of killing, for example, the especially cruel method such as a blow to the head

OPPOSES allowing researchers themselves to change licence conditions if they think the changes are “not significant” – this judgment should not be left to experimenters

OPPOSES a “simplified” and “more local” scheme for issuing licences for experiments. We believe that the current system is already weak in practice and it would be weakened further by this approach

OPPOSES the UK seeking exemptions to allow possible future weakening of policy