13 / 11 / 2023
The first meeting of the new Animals in Science Policy Unit Animal Protection and Welfare Stakeholder Group took place last week, on 20th July, at the UK Home Office. The Policy Unit was created following the Animals in Science Regulation Unit’s Change Programme in an attempt to separate policy-based concerns that animal welfare groups have, such as changes we would like to see to the Animals (Scientific Procedure) Act 1986, and the direct regulatory concerns which should be the realm of the Animals in Science Regulation Unit, like whether establishments and project license holders are complying with the law.
A new, and key, part of the Policy Unit is its operation across government departments which is a distinct and positive move compared to previous governance structures. Many organisations, including FRAME, have had concerns about elements of the change programme, both in its purpose and how it’s been implemented. That said, providing a dedicated, staffed unit to take this big picture look at how animals are used in science across legislation (such as REACH and the Cosmetics act) which currently sits under a number of departments is to be applauded.
Many organisations such as RSPCA, Animal Free Research UK, Animal Aid, and the Humane Society were represented and invited to discuss the group’s draft charter for how it would operate, how members would provide input and feedback to the new Policy Unit, and its initial policy priorities. The tone and manner of the meeting were positive, with a focus on collaborative change.
A number of issues arose during our discussion that, from FRAME’s point of view, warrant further consideration. The first of these was the wording of the new Unit’s purpose. We had noted previously that from its inception the description of the Policy Unit’s function embedded the ongoing use of animals in science. The wording is as follows:
“The Policy Unit is convened to: Develop strategy and vision for the use of animals in science”
We think that “a vision for the use of animals in science” is incompatible with the aim and intention of the legislation for which the Policy Unit has responsibility. The Animals (Scientific Procedure) Act 1986 is predicated on a moral assumption that, as a society, we believe it is wrong to cause intentional suffering to animals (well, most animals anyway as the legislation defines protected species as any “living vertebrate other than humans and any living cephalopod”). The legislation, therefore, exists to specify exactly under which circumstances, and for what research and testing purposes, as a society we DO permit harm and suffering. This is why it is explicit in its requirement that the 3Rs are adhered to, with the replacement of animals being the first priority:
“the principle of replacement is the principle that, wherever possible, a scientifically satisfactory method or testing strategy not entailing the use of protected animals must be used instead of a regulated procedure;”
This is outlined more appropriately in other places within the documents about the Policy Unit, so we would like to see it reflected more accurately in the wording that is front and centre in describing the Unit’s purpose and function. We were delighted that the Policy Unit was open to accepting suggestions from the stakeholder group and will continue to push for this change.
The second issue of some concern is the separation of the regulated community from the animal welfare organisations. The new structure retains the separation that existed in the previous setup, but for policy-level discussions, it is more critical than ever that we can come together to discuss how to move UK science forward. We very much hope that a further mechanism for exchange between the regulated community and animal welfare groups will be developed.
Thirdly, the new structure centres the importance of the Animals in Science Committee, the independent body convened to provide advice to the Secretary of State on the Animals (Scientific Procedures) Act 1986, as a filtering mechanism for concerns and input from a range of groups including the regulated community, NC3Rs, and animal welfare groups. The Animals in Science Committee will then feed its resulting advice into the Policy Unit. It is unclear at present how this fits with the existing terms of reference of the Animals in Science Committee, with the ability of stakeholder groups to be directly heard, or if the committee even has the capacity to deliver this expanded remit with members expected to contribute only 10–15 hours to the role per year. Suffice to say there is a lot of change and review currently happening and we’ve yet to see exactly how it will all come together, but we hope that sufficient support will be put in place to enable the Animals in Science Committee to do its job effectively.
We were delighted to see that Section 24 and transparency is listed as one of the key initial priority areas for the Policy Unit’s work. FRAME believes that transparency around animal research is critical. We need to understand what research is still undertaken and why. Where do non-animal technologies not yet exist, or why are they considered scientifically unsatisfactory for particular questions? Are there areas where alternatives do exist but are not being used? Is this due to an unmet training need, or additional costs not being met by funders, or some other systemic reason? Without the ability to interrogate and understand in much more detail what is happening with the use of animals, it is much harder to move forward towards better science. For this transparency to happen it is crucial that all participants in the discussion around the use and ending of the use of animals in science engage in respectful debate. There are often many false assumptions made by those on both ‘sides’ and these are exacerbated when the lines of communication break down or are removed. We hope that we are at a point where it will be possible to move forward together. The new Policy Unit provides a fantastic opportunity to lead the way in this space, and we’re excited to see it up and running.