Your Christmas Reading Done for You

By way of confirmation that Christmas approaches, the facebook page of Understanding Animal Research (UAR) is counting down the days with a festive sequence based on ‘The Twelve Days of Christmas’: “On the nth day of Christmas researchers sent to me …” It’s true that the well-worn carol really refers to the days after the 25th, but this is light-hearted entertainment after all, and it helps to show that animal research can be fun – or promoting it can be, anyway! So with much jingling and stardust, a rat in a lab coat stands by a Christmas tree and gratefully receives such amusingly pertinent things as “approval by ethics committee” (the “partridge in a pear tree” equivalent) or “six knockout mice”.

Tearing oneself away from this merriment, there are more straight-faced things happening in the profession at this time of year. There’s the annual awards ceremony associated with UAR’s Concordat on Openness on Animal Research, and although that’s a sort of school prize-day that interests only the school itself, the Concordat’s annual report is published to coincide with it, and this document genuinely is a sign of the times worth attending to. Then, in the wider world of animal research, there’s the annual report from the Animals in Science Regulation Unit (ASRU), the organisation responsible for licensing, inspecting, and policing such work. This report too has just been published, though it actually reviews 2017. And more portentous still, a parliamentary ‘statutory instrument’ has now been issued which will disjoin the UK’s law – the Animals (Scientific Procedures) Act 1986 – from that of the EU, with which it has been harmonized since 2012.

VERO has perused all these and some other newly published texts, and here is a view of what they amount to. Do your best to attend: this jungle of words is where millions of animals have to live, however briefly.

First, a stray and very specific publication from the Home Office, short-titled Additional Statistics. Here, we are finally told how many animals die in labs without ever appearing in the statistics of ‘procedures’. These are the animals (mostly mice, but also rats and fish, plus an undeclared 2% “other”) who have been bred but found unnecessary or unsuitable and therefore killed, or been used for tissue collection only, or been kept as ‘sentinels’ to test for infections circulating in the neighbourhood. Or they have simply died by mistake (i.e. human mistake: see the ASRU report below). The total of these animals in 2017 was 1,810,091. Therefore the total of all animals used in Great Britain’s laboratories last year, as the Home Office now declares, was about 5.53 million.

This is surely a very important addition to the statistics hitherto provided. The law, and accordingly perhaps the scientists themselves, don’t rate death very highly as a harm, compared to suffering. Death is therefore not classified as a ‘procedure’ even when (as is usually the case) it’s deliberately inflicted, nor does it require a licensed person to effect it, and it hasn’t until now been made part of any official count. But a public survey carried out by Ipsos MORI in 2013 showed very clearly that non-professionals think differently: “they saw death as the most serious harm which could be done to an animal . . . participants felt the public should know more about how many animals are killed.” That now they do know more is the result of the European Directive 2010/63 which governs animal research in all member states, and which requires this information to be issued once very five years. (The Directive was transposed into UK law in 2012, so 2017 is the first result of this provision). Why every five years, I don’t know. Nor does anyone seem to know (a more important uncertainty) whether the requirement will lapse in the UK after Brexit, assuming that Brexit occurs.

That brings us to another recent publication, The Animals (Scientific Procedures) Act 1986 (EU Exit) Regulations 2018, which specifies the alterations to UK law which will become necessary “on exit day”. Despite the resoundingly bureaucratic title, these alterations are surprisingly few; they take up hardly half a page of detailed adjustments. And indeed the much longer Explanatory Memorandum which accompanies them states emphatically that the changes “are the minimum necessary”. A convincing illustration: under the heading ‘Matters of special interest to the Committees on the UK’s exit from the European Union’ (a warning of difficulty or controversy) is the statement “None”.

Of course, nothing is said in the Memorandum, or can be said yet, about the pressures which may come when UK bioscience has to make a more solitary effort to “retain competitiveness in global markets” (as the Head of ASRU dismally expresses it). But in the course of emphasizing that all existing standards of welfare and supervision will be maintained, the Explanatory Memorandum does provide one very specific and most important reassurance: “Implementation of the 3Rs (Replacement, Reduction and Refinement) will contribute to the final goal of full replacement of procedures on live animals for scientific and educational purposes as soon as it is scientifically possible to do so, which was an aim enshrined in Directive 2010/63/EU.”

Admittedly the ambition thus re-stated commits nobody to anything, and it leaves to scientists the decision as to when full replacement has become possible, but as far as I have seen it’s the first time that this goal has been formally re-stated, perhaps even been mentioned anywhere in animal research circles, since its original declaration in the Directive. Yet it’s what really makes sense of the 3Rs. They’re not there just to discourage waste of life and pain, important as that purpose is. Still less are they a sort of passport or alibi for research which might otherwise be suspected of moral frivolity or negligence. The 3Rs should act as a constant and uncomfortable reminder that this sort of work is due to end.

That is not at all the impression of them which one gets from the Concordat’s literature or activities. There they seem to be regarded more as a sort of correct dress for scientists when appearing before the public – for instance, on web-sites. Nowhere there or in any UAR material (but of course I haven’t seen it all) can I find any endorsement of that statement from the Directive. Rather the contrary, because the purpose of UAR, and in particular of its Concordat project, is to make a secure and welcoming place in the modern UK for vivisection: to entrench it, in short. The primary aim of the Concordat, as twice stated in the Annual Report just published, is to “support confidence and trust in the life-sciences sector.” The progress which is aimed at, then, is not a change in scientific practice or in momentum towards animal-free research, but a change in public attitudes to the thing as it is.

The Concordat’s awards event and its annual report have both been fully featured in this blog on earlier occasions (see notes below). I don’t find any substantial differences this year, except in the scale of the public ‘engagement’ organised by its signatories: open days, virtual tours of laboratories, science fairs, links with schools, and so on. Always there has been one essential PR principle driving these things: to gain control of the public’s awareness. The principle is implied in the 2018 Report thus: “There is now more information about the use of animals in research in the public domain than ever and, crucially, it is owned and presented by more and more of the organisations who are responsible for funding, staffing and carrying out the research.”

Owned and presented” most immediately by professionals in PR, of course, rather than by scientists themselves, who have other things to do. One signed-up university is quoted in the Report praising its own progress in this direction, and showing how it works: “Members of the marketing and communications team have been invited to tour facilities and to take pictures and prepare videos for dissemination to the public.” We saw one symptom of this way of managing things on Oxford University’s web-site earlier in the year, where a gross mis-statement can only have been allowed to get in and endure because the scientists themselves were not even reading it. Incidentally, that web-site is the first of the four examples of web-sites chosen in the Report “to illustrate good practice”. We’re told that “UAR periodically checks statements [the ones made by signatories on their web-sites] throughout the year to make sure they are active” (i.e. up to date), but it’s evidently looking for show rather than substance.

As habitually, this year’s Concordat Report acknowledges that being honest about “harms done to animals in research” is “an area of challenge” for most signatories, and they continue to shy away from it, in their texts and even more obviously in their pictures and videos. The Report itself makes a first very modest attempt to set an example in its own illustrations (a brain scan on rats, a pig lying on an operating table), though since there are no explanatory captions, these images are hardly more illuminating than the ubiquitous ‘library pictures’ which the report deprecates. And even the Concordat does not expect anyone to go public about the sort of lab-blunders which account for some of those Additional Statistics discussed above. For these we must turn to the Animals in Science Regulation Unit’s Annual Report 2017 (i.e. covering 2017).

ASRU’s report is an inclusive account of all its work during that year, including its licensing and inspection regime. The cases of ‘non-compliance’ which it had to discipline during the year are reviewed near the end, forty of them (compared to 45 last year, 55 in 2015: a promising sequence?). It’s a familiar record of failed communications, forgetfulness, under-staffing, lapsed attention, and occasionally real incompetence. The equivalent record for last year was treated in this blog at some length, and again there does not seem to have been any notable change. Mostly, of course, the victims of these errors were rodents: forgotten about at the week-end, overproduced in their thousands, cack-handedly half-killed. However, at least one possible contributor to that “other” category in the Additional Statistics (the 2% group) gets individual notice here:

A non-human primate . . . died when it became trapped between a restraint mechanism and a cage wall. Attempts by the Named Animal Care and Welfare Officer and other staff to resuscitate the animal were unsuccessful.

Here would indeed be an eloquent illustration to the relevant institution’s web-site. Even the brief text vividly evokes the unhappy scene.

But although one can learn a lot about laboratory life from the ASRU report – about the ordinary routines as well as the accidents – it shares with the Concordat’s more obviously  partisan survey the premise that animal research should be made to work acceptably in its given (= its best possible) form. No “final goal” is mentioned or even hinted at in the introductory blessing to ASRU’s account given by the relevant Home Office minister, Baroness Williams. (Her official title, just so we know how near the front of her mind animal welfare must be, is Minister of State for Countering Extremism.) Baroness Williams places animal research firmly in its commercial context: “The UK’s life science strategy is based on a vision of how the UK may exploit its current strengths to support strong economic growth in this sector.” However, strict regulation is important as well, and the minister’s prose takes a sort of zig-zag course between these two purposes: “As a regulator, the Home Office has an important role in balancing the need to enable innovation and research in the life sciences whilst maintaining public trust [the Concordat’s aim, remember] through a strong framework that has the necessary checks and balances.”  And so on.

Proponents of animal research like to talk about a ‘middle ground’ between the two extremes, which is where moderate and realistic persons can discuss and manage the practice. This is indeed where most of the texts discussed above would be supposed by their writers to be located. But there is no such ground: at least, not as they imagine it. For although abolition exists as a real possibility at one end, the other ‘extreme’, a free for all, cannot exist in the UK (or the EU) except as criminality. The real far limit in that direction is simply present practice, which should, as the “final goal” of the Directive makes clear, always be closing up towards abolition. All the texts reviewed here are concerned in one way or another to present animal research to the public. In so far as they fail to acknowledge and promote its character as a practice in required motion towards oblivion, they misrepresent its true legal status and help to protract its wrongs. Perhaps that’s their purpose. At any rate, I’ve saved you from the ordeal of reading them.

 

Notes and references:

The Home Office’s Additional Statistics, published 8 November, can be read here: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/754408/breeding-genotyping-animals-scientific-procedures-2017-hosb2718.pdf

The Ipsos MORI survey of 2013, Openness in Animal Research, was commissioned as part of the Concordat preliminaries, and can be found on their web-site at http://concordatopenness.org.uk/wp-content/uploads/2017/04/openness-in-animal-r.pdf. The quotation is from pp.34-5.

The Brexit regulations and the Explanatory Memorandum which goes with them, were first published on 1 October and are on the government’s web-site here: https://www.gov.uk/eu-withdrawal-act-2018-statutory-instruments/the-animals-scientific-procedures-act-1986-eu-exit-regulations-2018#sifting-committee-recommendation. The “final goal” is spoken of in paragraph 7.4.

The Concordat on Openness on Animal Research Annual Report 2018, ed. A.J.Williams and H.Hobson, is online here: http://concordatopenness.org.uk/wp-content/uploads/2018/11/Concordat-report-2018.pdf. Quotations are from pp. 48, 3, 22, 32-3, and 9. Last year’s Concordat report was featured in this blog on 18 December 2017: https://voiceforethicalresearchatoxford.wordpress.com/2017/12/18/advent-pr-style/ See also, from 18 December 2016, https://voiceforethicalresearchatoxford.wordpress.com/2016/12/18/prize-day-with-the-concordat-folk/

The mis-statement on Oxford University’s web-site is discussed in this blog on 8 June 2018 here: https://voiceforethicalresearchatoxford.wordpress.com/2018/06/08/on-the-trail-of-an-untruth/

ASRU’s Annual Report 2017, published on 3 December, can be read here: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/761083/Animals_in_Science_annual_report.pdf .  Quotations are taken from the Ministerial Foreword and the Foreword by the Head of ASRU, William Reynolds. The quotation about the non-human primate is from non-compliance case 2, on p.30. ASRU’s previous report is featured in this blog on 30 March 2018: https://voiceforethicalresearchatoxford.wordpress.com/2018/03/30/policing-the-lab/

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Policing the Lab

By way of putting its readers into the right mood to read about animals, the London Times heads a news item about misconduct in laboratories with the comic sci-fi title ‘Eek! Errant scientists breed city of rogue mice’ [26 March, p.3]. After a sentence of two in similarly facetious style, however, the item turns into a perfectly serious account (mainly a re-hash of a piece in the Sunday Telegraph the day before) of a research project which was licensed by the Home Office two or more years ago to breed up to 127,600 mice, but which by 2016 had accidentally bred well over twice that number. The unauthorised excess amounted to approximately the population of the City of York: hence the phrase “city of rogue mice”. But ‘rogue’ is hardly the right word, since the extra mice were neither wandering nor solitary; they were put to mass use in experiments just like the others, the difference being that their experiments were unlicensed, a sort of uncovenanted extra.

The Sunday Telegraph calls this “blunder” (if such it was) “the most alarming of dozens of non-compliance cases by labs across Britain, though the punishment for it was relatively slight: “a letter of written reprimand” sent to the establishment licence holder.

All of this information, as well as that last quoted phrase, comes from the Annual Report for 2016 just published by the Home Office’s Animals in Science Regulation Unit (with the admittedly rather sci-fi acronym ASRU). The report shows how British law on animal research has been administered and enforced, as well as other ways in which ASRU has been promoting what it regards as good practice in laboratories. We’re told, for instance, that ASRU “piloted a framework” to reduce waste of life in the breeding of genetically altered mice. That mixed metaphor, with its comical image of trammelled endeavour, is rather well suited to ASRU’s work as a whole. With its steadily shrinking inspectorate (‘full-time equivalent’ numbers of staff were 22.3 in 2009, 14.7 in 2016) having to supervise a rising number of ‘procedures’ (a few hundred thousand more in 2016 than in 2009) and even an increasing number of establishments doing them, ASRU must have a hard job keeping its framework airborne or afloat.

Accordingly it relies heavily on the scientists themselves to police their own scenery, and this upbeat report expresses confidence in their willingness and competence to do that. Their willingness isn’t easily estimated by an outsider. However, I see that a group of research scientists and animal-research institutions in the U.S.A., where regulation is very much slighter than in the U.K., has recently published proposals aimed at cutting down even that ”administrative burden on investigators”, and I suppose that many British scientists, with their greater “burden”, would be in sympathy.

As to competence, the report’s case-studies in non-compliance (45 of them) naturally give quite an unfavourable impression. Many of the cases are instances of absent-mindedness, confused responsibilities, carelessness in record-keeping, hurried work on a Friday evening, duties neglected over the week-end – the sorts of thing which are likely to occur in any office or institution, and are only remarkable in this context because non-human animals have to pay for them in suffering or lives.

Here, for instance, are the experiences of some mice which were being used as ‘models’ of diabetes. This case helpfully concentrates in one place, to an almost farcical degree, many of the characteristic errors and slapdash procedures shown in the others:

Two mice died unexpectedly. Appropriate action was not taken when three other mice showed adverse effects, which exceeded the severity controls specified in the project licence. A drug was also administered to eight mice without the appropriate project licence authority. The same licence holders performed unauthorised surgery on nine mice … They did not keep any contemporaneous records of the regulated procedures performed, and failed to label correctly the cages in which the animals were kept … The project licence holder failed to ensure that the project licence was available and its content made known to those personal licensees working under its authority. The project licence holder also agreed with them that they did not need to monitor the animals at the weekend. [Case 2]

Of course the mice in question have been lucky to receive this much of an inquest. In countries outside the European Union, mice in similarly wretched plight enjoy neither the public attention provided by ASRU’s reports, nor even the protective standards for their exploiters to fall so absurdly short of. It’s not in fact possible to know how much in this kind happens without being noticed or reported even in the U.K., but at least there’s a deterrent. All the licences involved in this particular case were revoked by ASRU, except the one held by the unnamed institution itself. The ‘establishment licence holder’ (referred to with scrupulous anonymity as “they”) received a letter of reprimand, the basic and commonest penalty in these cases.

Note how we’ve moved from thinking of a “city” of erroneous mice to concern for mice numbered in twos and threes. In other cases we read of “three rats”, “a mouse”, “one rat”, “18 chickens” and, in the previous year’s report, “a litter of ten mouse pups” (whom we’ll encounter again below). This very proper concern that ASRU has for individual animals must feel anomalous to the practitioners, when a research project may be counting animals in their tens of thousands, and a slip in record-keeping can let over 100,000 pass unnoticed. In such a setting, the animals must surely be regarded more as products than as individual lives, by the researchers if not by the animal care staff. Something of that is indeed suggested in the ASRU report. We hear of a registered dealer in dogs, who provides “high quality animals to meet their clients’ requirements”, of staff “unpacking a delivery of mice”, of other mice “surgically prepared with cranial windows and then exported to a collaborator in Germany”. “high quality animals” is a particularly miserable phrase.

There’s a comparable incongruity in the way ASRU thinks about death (also known by the sinister euphemism “endpoint”, but ASRU generally and honourably prefers the plain word ‘killing’). The omnipresence of death in the laboratory is clearly enough announced in the annual research statistics, since nearly all those millions of animals must have been killed during the year, to say nothing (and nothing is said) of others not used in ‘procedures’. Oxford University, for instance, must be dispatching over 600 ‘protected’ animals a day. To keep up with this work, more staff than just the licensees themselves have to be active in it, which may be partly why killing is not ordinarily counted as a licensed ‘procedure’. The Animals (Scientific Procedures) Act does, however, specify, in its Schedule 1, how the different animals should be dispatched. And a laboratory has to have a “Schedule 1 killing register” listing the personnel competent to perform executions, rather as offices, schools, etc., have lists of trained first-aid people with exactly the opposite function.

This is where those baby mice had their moment in the public light. An untrained person had

attempted to kill the mouse pups using a rising concentration of carbon dioxide, which is not an appropriate method of Schedule 1 killing … The pups were not properly killed and the following morning a number were found to be still alive in the waste disposal bag.

It’s a familiar enough discovery (“two rats were found alive inside a cosmetic-testing-animal-remainsclinical waste bin”, “a mouse that was supposed to have been killed by Schedule 1 killing … was observed to be breathing while the procedure was taking place”, and so on ), and again it reflects the very large numbers being continually hurried through into oblivion. Those pups, incidentally, will not re-appear in the 2017 statistics, because their breeding was not licensed, nor were they used for any procedure: they were simply another ‘accident’.

But although ASRU is rightly strict about ‘Schedule 1 killing’, it can hardly, in the circumstances, view death itself as a wrong. Suffering is ASRU’s concern; death, putting an end to that, is a sort of therapy, and many an offence is apparently mitigated by the delinquent’s swift resort to it. “After taking the blood samples [this by a Schedule 1 killer, not licensed to take blood], the birds were immediately humanely killed [that’s better].” “The second mouse had lost weight due to lack of feed and was immediately euthanased.” As the German poet Detlev von Liliencron writes at the end of a poem set among the graves in a churchyard, “Genesen” – they’ve made a complete recovery.

No doubt there’s logic and ethics of a sort in this. A mouse that was “at the scientific endpoint of a metastatic bone cancer study and was not immediately killed at the end of the study” would indeed have experienced “unnecessary pain, suffering or distress” [Case 32]. And accordingly, letting an animal die, as opposed to killing it, is one of the most serious of wrongs that ASRU recognises. It’s the theme of the one case in this report regarded as so serious that a separate write-up of it was published on ASRU’s web-pages as soon as the investigation was completed (in October 2017). The case concerned an animal (species for some reason kept anonymous) that had been taken from the wild for research but was subsequently found dead in its captivity. Even though this animal had been “assessed as very old” (for all the anonymities, these case-studies are often poignantly evocative), its death from natural causes, probably failure to eat, must have meant “avoidable suffering”: avoidable in the sense that the animal could have been killed earlier if its deteriorating condition had been noticed.

Nothing in utilitarianism, the ethical system on which British animal-research law is largely based, necessarily makes death a non-interest, as it seems to be viewed in the laboratory. On the contrary, some of utilitarianism’s earliest practical endeavours were aimed at putting a price on loss of life (admittedly human life). Anyway, that’s too big a question to attempt here. I would only insist that premature destruction is indeed a patent wrong against any animal life, even if not the greatest of possible wrongs, and that ASRU ought to recognise this more frankly in the case of the animals whom it oversees. It might make an easy start by ruling that their dead bodies should be described exactly as such, rather than as “carcases” (see, for instance, the Schedule 1 Code of Practice: “carcases should be disposed of on site by incineration or through a macerator.”) It’s a speciesist term which brings a habit of wrong attitude with it, and should be disused everywhere.

The next step would be to classify killing as a ‘procedure’ under the Act. This would probably make no difference to its frequency, but it would raise the acknowledged seriousness of the action. It would also bring into annual notice, if only as numbers, all those unused animals whose only part in the laboratory scene, or indeed in the world, is to be born and killed, like the pathetic ten mouse pups.

Published in the same week as the ASRU report was a research article in the American journal Science which described a study of circadian rhythms in the baboon, “a primate closely related to humans”. Over a 24-hour period, detailed changes of physiology were recorded every 2 hours. The study used 12 baboons (juvenile males imported from Kenya), and killed one at each interval in order to collect and study “64 different tissues and brain regions”. It’s all right, though, because baboons are “listed by the IUCN as a species of Least Concern.

On further thought, let’s not bother with those intermediate steps; let’s simply stop using and killing animals in laboratories. It’s a filthy business, not redeemable by regulations however humanely intended.

 

Notes and references:

The Animals in Science Regulation Unit’s Annual Report 2016 (a 53-page document) was published online by the Home Office on 12 March, and can be read here: https://www.gov.uk/government/publications/animals-in-science-regulation-unit-annual-report-2016  The case-studies appear as Annex 1, pp.36-48. The case of the mouse pups is Case 2 from the previous year’s report, to which there’s a link on the same web-page.

The case of the wild animal (briefly cited as Case 1 in the 2016 report) is described in the 11-page Report of ASRU Investigation into Compliance, published online here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/654177/asru_investigation_into_compliance_oct_2017.pdf

The proposals to reduce the “burden” of regulation in the U.S.A. were published in October 2017 as Reforming Animal Research Regulations: Workshop Recommendations to Reduce Regulatory Burden, and can be accessed here: http://www.faseb.org/Portals/2/PDFs/opa/2017/FASEB-Animal-Regulatory-Report-October2017.pdf

The Schedule 1 Code of Practice is from 1997, but I notice that it was withdrawn in 2016. It has not been specifically replaced, but the newer advice seems to use the word ‘cadaver’, a half-way improvement, so perhaps there has been a deliberate change here.

The poem by Detlev von Liliencron (1844-1909) is titled ‘Auf dem Kirchhofe’.

The baboon study, by Ludovic S. Mure et al, is titled ‘Diurnal transcriptome atlas of a primate across major neural and peripheral tissues’, and appears in the 16 March issue of Science at p.1232, then with its own pagination 1-9. Quotation is from p.1232 and from the ‘Supplementary Materials’ appendix to the article.

The photograph is by Brian Gunn.