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Replacements to animal research aren’t being prioritised, report shows

Written by Amy Beale, Head of Policy & Programmes

A recent UK report confirms what FRAME has been highlighting for many years – the legal requirement to only conduct animal research if there are no viable alternatives is not happening reliably or robustly, despite a legal requirement to do so. This is an issue FRAME continues to raise and address in our work to facilitate the development and uptake of alternatives. 

FRAME is calling on the UK government to prove its commitment to the replacement of animals in research by: 

  • A commitment across all Government departments to replace animal research.  
  • Funders to ensure replacement is thoroughly and demonstrably addressed in grant applications and review processes.  
  • Strengthening replacement requirements in existing licence applications by the Home Office with clear expectations, examples and case studies to demonstrate how to research and evaluate replacement options. Increased scrutiny of replacement opportunities prior to licence approval by the Home Office. 
  • More information on replacement from licence applications to be made publicly available through the Non-Technical Summary. This will highlight gaps in replacement opportunities. 

In February 2023, an independent report evaluating the implementation of the 3Rs  via existing regulatory frameworks was published by the UK-based National Centre for 3Rs  (NC3Rs). The report collates evidence from interviews with multiple animal research stakeholders. It states that the legal requirement of replacing the use of animals with a scientifically satisfactory alternative where available is not being appropriately monitored or met at any of these existing ethical or scientific review checkpoints 

This is unacceptable and must be addressed to avoid unnecessary animal use.  

Read more on the FRAME view below or read the full report here: The role of review and regulatory approvals processes for animal research in supporting implementation of the 3Rs ( 

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More on the report

Under UK legislation governing the use of animals in research, there are various points at which a project involving animals undergoes scrutiny and review: by research funders, members of the research organisation and the government: 

  • Researcher plans project and proposes research method requiring regulated procedures on animals. 
  • Funder reviews and assesses projects being submitted for grants. 
  • Review at the research establishment by the Animal Welfare Ethical Review Body (AWERB). 
  • Governance check by Home Office Inspector prior to licenses for animal research being granted. 

At each point, relevant individuals or panels review the planned research including the proposed experimental method and design, but assessing whether animals should be used and to what extent the the replacement requirements of the 3Rs have been explored and implemented is overlooked at fundamental stages.

Scientists decide whether they should use animals in their projects at an early stage of research planning. Once projects are funded researchers then apply for licences to conduct animal research. In the application they must justify their decision to use animals by describing how they have explored and considered any non-animal alternatives. These justifications are evaluated by AWERBs and the Home Office. These reviewers however, are unlikely to have detailed knowledge of appropriate replacement opportunities across multiple research fields.  

The report emphasises that Home Office and AWERB reviewers sometimes assume the assessment of whether animal use could be replaced has already been thoroughly addressed by both the researcher when planning the project, and by the funder’s review processes. This is often not the case.  

Funders are normally the first point at which proposed projects undergo external peer review to assess the scientific value and whether the research is worth funding, but funders are not subject to the same legal requirement to enforce the 3Rs. The report confirms that the question ‘can we answer this research question without animals’ therefore receives little or no scrutiny at this point. This will also be influenced by the experience and knowledge of the panel.  

The UK public has a growing interest in learning about the work being done to develop and implement alternatives to animals. Many organisations, including FRAME, have been calling for an overarching commitment from the government to replacing animal research for some time. 

Strengthening current systems to more rigorously meet legal replacement requirements of the 3Rs must be an immediate priority within this and review panels at all levels must have access to tools, training and expertise to help assess replacement opportunities.

This report demonstrates that the replacement element of the 3Rs principles is widely not met as intended, despite a legal obligation to do so. Meanwhile the government continues to defend existing regulatory systems for animal research by referring to the robustness of the implementation of the 3Rs and multiple review checkpoints in the regulatory system. This is clearly failing. When we consider that the UK Government is planning to spend nearly £40 billion on research and development between 2022 and 2025 which will include animal research, this should be a matter of public concern.  

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