Counting the Cost Again: the 2019 Numbers

The numbers for UK animal-research procedures completed during 2019 have now been published by the Home Office. The total was a little over 3.4 million, a fall of 3% on the previous year. That means that there has been a modest decline in the total every year since 2015, tending to correct the brisk upward tendency which began after the year 2001, when the number was 2.62 million. We’re now back at any rate to pre-2010 levels. In fact, 2019’s total is, as the Home Office text says, “the lowest number of procedures since 2007”.

Back in 2001, that 2.62 million number was the lowest total since the 1986 Act had been passed, the lowest in fact since the mid-1950s. The notable fact was modestly presented in that year’s report as the first of fourteen ‘main points’ in ordinary black type, after eleven pages of general introductory matter. By contrast, this year’s achievement appears in a special box of ‘key results’ on page one, a three-colour affair enriched with graphics of various kinds, the numbers being set in eye-catching 36 point type. Why not? It makes navigation of the essential information that much easier. But of course it also quite changes the reading experience. The feeling you get is that the Home Office, rather than merely allowing you to know all this, as in earlier days, actually wants you to know: wants you to know that the numbers have gone down, certainly, but also, it seems, that 57% of the procedures were made for the purpose of ‘basic research’ – not obviously a point to boast about, but getting the same vibrant treatment in that text-box. The remainder of the report is laid out in a similarly easy-read style.

No doubt it’s partly the ‘Concordat effect’ that we’re seeing, and have been seeing gradually over the last few years of these government reports: the fashion, that is, for a more bullish PR, which celebrates rather than apologises for animal research, cleverly extolling at the same time both its claimed great achievements and the promise to do as little of it as possible. It’s also, I suspect, a response to the two-yearly Ipsos Mori surveys of attitudes to animal research (the next one is or was due this year: see notes below for previous ones). These surveys habitually find that respondents consider themselves ill-informed about animal research and regard the institutions that practice or supervise it as secretive and untrustworthy. “Come See Our World!” is how the promotional organisation Americans for Medical Progress title their digital introduction to the wonders of animal research. It’s a slogan which the Home Office now seems to have adopted too.

Here, anyway, are a few points about that world, as it was in 2019.

Regulatory testing:

This is probably the most unsavoury class of procedure, conducted to satisfy national or international laws of one kind or another. It continues to make up about one quarter of all the experimental (as opposed to GA animal-breeding) work. It’s the industrial end of animal research, involving the mass through-put of animals in standard testing regimes. The products and devices being tested include medical therapies, but also pesticides and other lethal products, and the techniques used for testing them still include, astonishingly, the ruthless LD50 AND LC50 tests. Accordingly this category of research is consistently the worst for animal suffering. In other experimental work, about 4% of the procedures are usually counted as ‘severe’; in 2019, the rate for regulatory testing was 10.8%. We are told (on page 14) that ‘severe’ procedures are those which cause “a major departure from the animal’s usual state of health and well-being”. Since all sixteen of the “eye irritation/corrosion” procedures conducted on rabbits in 2019 were classified as ‘mild’, and there is an intermediate category ‘moderate’, we can form some idea of how major that departure has to be.

Moreover, it’s in regulatory testing that the largest numbers of specially protected animal species appear (“animal species appear”! you see how numbers and tables push the mind towards abstractions): for instance, 3002 dogs (85% of the year’s total) and 2426 monkeys (71% of the total). Not that mice aren’t the most numerous species here as elsewhere: 437,124 of them were used in 2019.

Protection of the natural environment:

Most classes of animal research have shared to a greater or lesser degree in the reduction of numbers last year; even the breeding of GA animals, which has been mainly responsible for the increase since 2001, shrank by that same 3%. One class which noticeably did not shrink was ‘Protection of the natural environment’. This accounted for 13,074 animals in 2018, but for 29,343 in 2019. The animals included 5821 horses and “other ungulates”, 898 birds, and 22,079 fishes. It’s a category of research distinct (at least for statistical purposes) from regulatory testing and from general toxicology. The primary purpose is to understand the health implications of pollutants in the environment, but a common associated aim is the conservation of species and ecosystems: looking after animals, then!

An article about this sort of research, published in the journal Disease Models and Mechanisms earlier this year, conceded that epidemiology, the comparative study of whole populations, “can provide strong statistical inference linking chemical exposure to disease.” But that’s not enough; to understand the ‘mechanism’ of the harm being done, it has to be animal research. In fact the article is titled ‘Casting a wide net: use of diverse model organisms to advance toxicology’. You’ll notice the ambivalence of that last word: what’s to be advanced is both our understanding of poisons, and the scientific discipline called toxicology. This latter aim is the real subject of the article, whose authors wish “to shift the perception of toxicology as an applied science to that of a basic science” and thereby to “enrich the field”. This, they believe, can best be done by relying less on mice and rats, and resolving instead to “utilize diverse model systems”, especially fish (so “casting a wide net” turns out to be a sort of pun; don’t forget that science can be fun!). After all, they say, “The tree of life is vast”; why confine ourselves to “a few distinct branches”?

It’s a classic instance of scientistic thinking: calling in big science to fix the effects, while leaving the causes untouched. (We see it happening also in the case of Covid-19.) More to the point here, the article reminds us that there are always strong professional interests bound up in the growth (and resistant to the contraction) of any branch of scientific research, including those that use animals. That jump to 29,343 will have been good for some.

Roadmaps to nowhere:

Yet in fact both these classes of animal research, regulatory testing and protection of the environment, as well as toxicology more generally, should be especially amenable to non-animal technologies. That was indeed the main aim of a project set up in 2015 with the publication of a document entitled A non-animal technologies roadmap for the UK: advancing predictive biology. It was a collaboration between various government-sponsored agencies (including the National Centre for the 3Rs), academia, and industry, whose purpose was to promote the development and marketing of ‘NATs’ (surely a good sign that it seemed worth abbreviating ‘non-animal technologies’). The thinking was frankly commercial (further evidence of real purposefulness, sad to say): “The market potential is huge”, said the ‘Executive summary’. Correspondingly, the stated objections to animal testing were pragmatic, not ethical: its failure to predict for humans had “far-reaching implications, from wasted resources . . . to large financial losses”. As the trendy word ‘roadmap’ implies, this was a programme for the future rather than a survey; it was described in business-speak as “stretching towards a 2030 vision”.

Since we’re a third of the way along that road now, you’d expect the toxicology numbers to be showing some effect; you’d at least expect them not to have grown. But then I can find no surviving trace of the NATs project among all the other ‘roadmap’ projects boosting themselves online. What’s happened to it? The NC3Rs makes the document available on its web-site, but seems to have said nothing further about it since the day of publication. Another of the collaborating agencies, the Medical Research Council, makes no mention of it at all. More eloquently, the Medical Research Council’s laboratories were second only to the huge Francis Crick Institute as users of animals in research in 2019 (Oxford University came third).

That abandoned roadmap was part of an official programme of reform devised during the period of the Coalition government in the UK – largely the effect of having, however briefly, a minister in charge of animals in science who really wished to get them out: Norman Baker. Two other substantial publications had set out the aims of the programme and the progress being made: in 2014 there was Working to reduce the use of animals in research, and this was followed a year later, as promised in its text, by a review of progress titled Delivery Report. In fact the promise had been to publish such reviews “regularly thereafter”. But no others have appeared.

The number of animals used in 2015 was 4.14 million, the largest number since the 1986 act came into force. There’s been a 17% reduction since that high point – a return, as mentioned, to 2007 levels. Perhaps we must regard that much progress as the finished legacy of the Coalition programme, and now we’re left again with optimistic reassurances and pious references to the 3Rs. God knows there was nothing radical about that programme, but it had serious intention. To have let it lapse is a shameful delinquency.


Notes and references:

The report for 2019 and the separate tables of numbers can be accessed from this page: .

The Ipsos Mori surveys for 2016 and 2018 are reviewed in this blog here:

The Americans for Medical Progress digital tour of animal research was briefly reviewed in this blog here:

Among the various responses to the statistics, the one from Fund for the Replacement of Animals in Medical Experiments is especially authoritative. It talks about the Coalition publications, which were also touched on in this blog when Norman Baker was the subject, here:

The article ‘Casting a wide net: use of diverse model organisms to advance toxicology’ was published in April of this year, and can be read here:

These are the three Coalition documents discussed above:

Working to reduce the use of animals in research (2014: quoted above from p.9):

Working to reduce the use of animals in scientific research: Delivery Report (2015):

A non-animal technologies roadmap for the UK: advancing predictive biology (2015: quoted at pp. 4 & 6):

Counting the Animals again

The Home Office has now published its Annual Statistics of Scientific Procedures on Living Animals, Great Britain for 2018. Here is VERO’s selective summary of the numbers and species, alongside those of 2017 (which seem to have been slightly revised since they were published last year), with some comments to follow:

 Species  Number used in 2018  Number used in 2017
 Mice   2,568,197    2,781,685
 Fish   454,340    514,059
 Rats   177,904    241,544
 Domestic fowl   141,069    125,280
 Sheep    53,672    47,499
 Guinea Pigs    6,445    22,560
 Horses    10,424    10,600
 Rabbits    11,159    10,362
 Dogs    4,481     3,847
 Non-human primates    3,127     2,962
 Other species    89,099     28,975
 Total:   3,519,917   3,789,373

Direction of travel: You may notice that there has been a fall of about 7% in the numbers since last year. You certainly will notice it if you read the Home Office report itself, since the point is made twice in the first four pages, as is also the fact that this is the lowest number since 2007 (a fact highlighted in attractive purple each time). There has been a fall in each of the last three years, so perhaps it is now possible to detect a real and very welcome downwards trend after years of more or less steady increase. Still, there is a long way to go (to go back), for even this 2018 number is about 34% greater than the number recorded in 2001.

Particular species: There has been a fall in numbers for most species, but you’ll see that two of those which have special protection under the 1986 Act have not enjoyed a share in it: dogs and non-human primates. The sad thing is that these animals are mainly used in so-called ‘regulatory testing’, the most patently unpleasant category of research, and one which has always had the worst severity ratings: this year, 12.5% of the procedures were classified as ‘severe’ (i.e. the top pain rating), compared to about 2% of the procedures for ‘basic’ research. Dogs (which mercifully don’t appear in the ‘severe’ category this year) and primates are used primarily for the testing of human and veterinary ‘medical products’, by the method called ‘repeated dose toxicity’. Other animals in this category of research may be required to test industrial chemicals, biocides, animal feeds (this, we’re told, is “for the safety of target animals, workers and environment”, so God knows what these feeds contain), and an unspecified ‘other’, in which again both dogs and primates feature.

The testing methods used on the less-protected animals still include the notorious LD50 and LC50 tests, as well as unspecified ‘other lethal methods’. That word ‘other’ acquires a sinister character in these records, but “other lethal” is an illogical category anyway, since all or nearly all this laboriously counted work is lethal in the not-so-long run for the animals, even when they are not killed by the product itself.

The 10,000 or so procedures on horses recorded in this Home Office report (up 19% since 2009) appear likewise mainly in this ‘regulatory’ category, although in fact the horses are being used not for testing but for the routine production of blood derivatives. You can see some of the uses to which this blood is put being advertised on the web-site of TCS Biosciences (“your partner: For Life”). In the USA, these uses include the keeping of farmed sows regularly in heat, by means of ‘Pregnant Mare Serum Gonadotropin’. I mention this as one stray and disgusting instance of the way that animal research serves and therefore promotes high-tech animal farming. Scientists often compare the animal costs of their work favourably with the suffering and death-rate in agriculture; it’s a defence they have been using ever since they discovered that vivisection required defending. But the distinction is altogether disingenuous: farming as now practised would not have been possible, let alone profitable, without the steady support of laboratory science.

Democracy at work, or not: The 1986 Animals (Scientific Procedures) Act requires the Home Office to “publish and lay before Parliament” these annual statistics in order that the people, acting through their representatives, can knowingly assent to them. In practice this assent is assumed rather than annually petitioned for. Some challenges there are, of course. ‘Early Day Motions’ may be tabled, in which MPs express their dissent: at present there is one such (EDM 66), signed by 63 MPs and calling for “a thorough, properly moderated public scientific debate on the misleading and costly practice of trying to apply results from animal experiments to human patients.” Or questions may be put to ministers; for instance, on 3 September 2018, the excellent (and vegan) MP Kerry McCarthy asked about the increased use of horses for blood collection, as mentioned above. Much more rarely there are dedicated debates, the most recent of them on 5 February 2013, held in Westminster Hall and simply titled ‘Animal Experiments’.

But the lack of a proper departmental home and a dedicated minister for all animal subjects means that no great momentum is ever created out of these haphazard initiatives. Animal research alone is dealt with in fragments by at least three major departments: the Home Office, the Department for Business, Energy and Industrial Strategy, and the Department of Health and Social Care. It’s a situation tragi-comically reflected in the name of the Home Office agency responsible for putting out these annual statistics: the Fire, Licensing and Public Order Analysis Unit.

In the absence of sustained parliamentary fuss, these statistics and the exploitation of animals which they dimly shadow have come to seem like a sort of natural or at least sociological phenomenon, rather than a deliberate moral choice. The Home Office report itself sets the style for that way of viewing them. Surveying the variations in numbers over the years since 1987, it provides this helpful explanation: “The number of procedures carried out on living animals is determined by several factors, including the focus of scientific and medical endeavours, the economic climate and global trends in new technologies or fields of research.” No one’s really in charge, then; we’re all just bystanders. And it then becomes reasonable to take the view noted in this blog when last year’s statistics were published: that is, that big numbers are actually an indication that all’s well in UK life-science research – or, as one promotional organisation has said this time round, “Year-to-year numbers are thus best seen as a reflection of the current health of UK bioscience investment and will fluctuate year-on-year.”

Fluctuate! We’re a very long way here not just from the pains of the animals whom these statistics are nominally about, but also from the moral purpose clearly though imperfectly put into political effect in the 1986 Act and the 2010 European Directive. For them, downward was the desired and proper direction, not an accident of economics.

Well, it’s true that counting animals is not the essence of animal rights, but falling numbers are emphatically better than rising numbers, and if the present trend in that direction is to be kept going we need to remind our political representatives (even at this least propitious of political times) to keep the subject controversial. Many MPs really do mind about animals, and even more of them know that their constituents do. To illustrate as much, here is an MP speaking about animal research back in 1971, at the high point of vivisection numbers in the UK, just preceding the long fall towards 2001: “I know that the object is to preserve human life; but it does make me wonder whether a human race that can take such morally degrading practices in its stride is really worth preserving.”  OU primate

Yes, that’s the proper context in which to view and debate these annual statistics.




Notes and references:

The Annual Statistics can be found here (the quotation comes from p.5):

The tables of data are now published separately, and are linked here:

Information about the farming of horses for blood comes from this web-site:

A transcript of the Westminster Hall debate can be read here:

The parliamentary briefing document, titled Animal Experiment Statistics, was published on 25 April: a summary of it is available here, with a link to the full pdf version provided at the end:

The quotation about “year-to-year numbers” is from the Speaking of Research web-site here:

Unfortunately I don’t know who the last-mentioned MP was: he or she is quoted without name or reference by Desmond Morris in his book Intimate Behaviour (Jonathan Cape, 1971), p.183.

The photograph of a rhesus macaque monkey in Oxford University’s Biomedical Sciences Building, probably himself long since an annual statistic, is used by courtesy of the university’s Public Affairs Office.


The Many and the One

The Home Office has now published statistics for the animal research done in Great Britain during 2017 (not the UK, because Northern Ireland publishes its own modest contribution to the scene separately).

Very little has changed since 2016 for these statistics to record (see the chart below), but there’s a notable innovation in the look of them. There are now three or four distinct colours, instead of the old black, white, and grey; the former tables and columns have been supplemented with graphs of zig-zagging lines in tonic blues; helpful comment and explanation appear in tinted text-boxes. In short the document has been designed to engage and even impress the reader, rather than merely to provide, with implicit apology, unwelcome information. This suggests the influence, perhaps even the direct advice, of Understanding Animal Research and its PR project, the Concordat on Openness on Animal Research. And UAR’s director, Wendy Jarrett, makes a comment on the statistics which reflects this new way of seeing them: not as a regretted cost, certainly not as a “necessary evil” (when was that phrase last used?), but as an index of achievement:

Animal research continues to play a vital part in the development of modern treatments and medicines. While the numbers of procedures may vary from year to year, we should be proud of the important contribution that the UK makes to scientific and medical advancement worldwide.

Here, anyway, is VERO’s summary of the numbers and species, alongside those of 2016, with some comments to follow:

 Species  Number used in 2016  Number used in 2017
 Mice   2,866,435    2,781,685
 Fish   535,819    514,059
 Rats   249,389    241,544
 Domestic fowl   139,860    125,280
 Sheep    48,095    47,499
 Guinea Pigs    26,186    22,560
 Horses    8,948    10,600
 Rabbits    15,431    10,362
 Dogs    4,932    2,496
 Non-human primates    3,569    2,215
 Other species    38,059    31,073
 Total:    3,936,723    3,789,373

Direction of travel:

For the second year in a row, there has been a welcome fall in the total number of animals used, this time a fall of slightly less than 4%. Nothing can be deduced from this; as the Home Office puts it “any clear trend for recent years is as yet difficult to determine.” However, there is a very clear trend for the century so far: a rise of nearly 45% since 2001’s 2.62 million. Nor is the prospect good. If the UK were to leave the European Union without making terms to remain a partner in REACH (Registration, Evaluation, Authorization and restriction of Chemicals – a bad enough system already), it might have to create its own testing regime, duplicating what is done collaboratively in the rest of the EU. Or rather, it apparently would have to. A government minister truculently told a House of Lords committee  earlier this month, when asked about this possible secession from REACH, “if that required animal testing, that would require animal testing.”

The term ‘procedure’:

Viewing the Home Office’s annual pageantry of numbers, so eloquent of orderly record-keeping and nothing if not factual, the dazzled reader must keep in mind that the basic unit, the regulated ‘procedure’, is itself an unknown quantity. A helpful hint to this effect is provided in one of those text-boxes, where ‘procedures’ in the plural is defined in the singular, a confusion of number which characterizes all official documents when dealing with this point, for very good reason.

Those horses, for instance. You’ll notice that they’re one of the few species in greater demand this last year. Mainly, it seems, they’re made to yield blood products for use in medical diagnosis and other scientific analysis. What: just the once each? Of course not: it’s really their career, and that would be the right term for what is asked of all these animals. Some animals may eventually retire, as perhaps the horses do: much more commonly, the end of their part in the project coincides with the end of their life. (This is something which the statistics ought to record, but in fact they say nothing about death.) Either way, the term ‘procedure’, with its suggestion of a single experience, is a misleading fiction, and therefore so are all these numbers.

Classifying the pain:

Actually the statistics do say something about death. Being found dead in your cage after a ‘procedure’ is one of the indicators for a ‘severe’ classification, we’re told. Others include needing help to eat and drink (to survive, in short). It may be that the statistics for each of the four main levels of suffering – sub-threshold, mild, moderate, severe – really are informative. They seem to change very little from year to year (the Home Office notices this), but I don’t know what that implies.

About 5% of procedures (not including GM breeding) are said to have imposed ‘severe’ suffering on the animals involved (95,025 of them) during 2017. So-called ‘regulatory testing’ (tests required by law in the EU or the UK, or beyond) takes a disproportionately high part in this category. Of its 505,000 or so procedures, 10% or more were considered severe. That’s no surprise, since this class of work includes toxicity-testing (195,000 procedures), and the Home Office statistics show that for this purpose the LD50 and LC50 tests – identifying the Lethal Dose or Lethal Concentration that kills half the animals – are still in use.

Numbers and individuals:

How much does anyone really learn from these numbers? No doubt they provide a rough knowledge of the scale of animal research, and which species and which purposes are tending upward and which down. But it is rough knowledge. Not just the basic term ‘procedure’ is opaque: the classifications of research are uninformative. Thus, one cat, of the 198 cats dealt with in 2017 (190 in 2016), suffered pain in the category ‘severe’. The purpose of the research in question was ‘animal diseases and disorders’. That’s all that there’s space to tell us. And how dependable even that much is may be deduced from the ‘Revisions’ to previous years’ statistics attached at the end. Here we find, for instance, that 5,930 sheep and 1700 horses which had appeared under ‘protection of the environment’ (itself a sinister enough category) were in fact engaged in ‘routine production – blood products’. It’s not so much that a mistake has been made – easily enough done in the stress of all this bureaucracy. More sobering is how little an outsider can make of the difference.

Animal protection groups quite reasonably tend to call the annual statistics ‘shocking’. I would say instead ‘stupefying’. Seeing these great phalanxes of animals moved around in their graphs, columns, tables, and other formations simply dulls the imagination. In fact, to re-iterate other posts in this blog (and the whole annual performance is after all a wretched re-iteration), these statistics are a variety of euphemism. Certainly they’re much better than secrecy, but they take the mind off the subject of individual suffering, which is the one thing that matters. Just occasionally, in the smaller numbers, momentary illuminations are offered as to what we’re really seeing: that one cat, for instance, needing help to eat or drink, suffering pains which “a person would find difficult to tolerate” (Home Office guidance on the ‘severe’ category), or perhaps being found mercifully dead in the cage.

By way of final re-iteration, I shall re-append the picture of the Oxford University OU primatemacaque monkey: suggested caption, ‘Waiting for the End’.


Notes and references:

The Home Office’s publication, Annual Statistics of Scientific Procedures on Living Animals, Great Britain 2017 can be read here:

I should add that a much more informative annual account of animal research is provided in the Non-Technical Summaries (i.e. of proposed research), also published by the Home Office. There is more about the NTS in the VERO blog here:

Wendy Jarrett’s comment, and Understanding Animal Research’s response in general, can be read on their web-site here:

The government minister who spoke to the House of Lords EU Energy and Environment Sub-Committee was Therese Coffey MP, at a session on 18 July of this year.

The complete Home Office guidance to ‘severity’ is provided in Advisory notes on recording and reporting the actual severity of regulated procedures, 2014, especially pp.12-13.


Brothers and Cousins

Statistics of the animal research done in Britain during 2016 have now been published. They show a decrease of about 5% or 206,000 in the annual total of ‘procedures’ (down, but not very far down, to 3.94 million). The Home Office press release announcing the statistics was headed with that notable news – notable not so much because the achievement is very great (after all, the 2015 figure had been the highest number of ‘procedures’ ever recorded), but because it represents only the second time in about fifteen years that the numbers have not gone up. And the total in 2016 is still larger than it was in 1986, when the present Animals (Scientific Procedures) Act was introduced with the aim and expectation (for a time actually realised) of pushing the numbers steadily down.

Now is a good moment to recall that aim, because the European Union’s Directive 2010/63, which has been co-ordinating the laws on animal research in all 28 member states, is about to be revised. Although the U.K. will probably not belong to the Union by the time any revisions come into effect, its own practice will certainly be influenced by them. In fact, because science is an internationally collaborative business, published in international journals, the rules and standards established in the Union are certain to have some influence in all countries where animals are used in research.

Article 58 of the Directive requires the European Commission (the E.U.’s executive) to “review” its contents no later than 10 November 2017. In doing so, the Commission must take into account “advancements in the development of alternative methods not entailing the use of animals, in particular of non-human primates”. Specifying OU primateprimates in this way, the Directive’s authors no doubt had in mind a ‘declaration’ which the European Parliament had adopted back in 2007, urging the Commission “to establish a timetable for replacing the use of all primates in scientific experiments with alternatives”. Anyway, by way of limbering up for the review, the Commission asked one of its advisory committees, the Science Committee on Health, Environmental and Emerging Risks (SCHEER), to set up a Working Group to study and report on “the need for non-human primates in biomedical research, production and testing of products and devices”. Under this same title, with its ready-made implication that such a need really does exist, SCHEER accordingly published its conclusions (formally an ‘Opinion’) a few weeks ago. These conclusions, on such an especially controversial aspect of animal research, may be taken as indicative of what animals have to hope for from the coming review.

We’re deep inside the E.U. machine here: a working group reporting to a standing committee commissioned to advise the executive on the revision of a parliamentary directive setting the parameters for (and here we at last come out into the open) actual laws in the 28 member states. And the advice itself frequently does have a machine-generated feel to it, of truth made out of words rather than real things, and all the more conveniently incontrovertible for that. “It is indeed important to consider the limitations of the NHP when choosing which species to use in a drug-safety test: the use of an appropriate species or combination of species/models is essential to obtaining the most reliable and translatable information.”[p.63] Has anything been said here that isn’t necessarily true? Is anyone arguing, for instance, that an inappropriate species would produce more reliable information? This key word ‘appropriate’, with its built-in wisdom, is much used in the authors’ proposals: “appropriate training”“appropriate standards”, and of course “appropriate use of NHPs”.

Another such passe-partout word is ‘robust’: the authors variously recommend “robust scrutiny”, “robust peer review procedures”, “robust study design”, and so on. One wonders why scientists hadn’t thought of the great merits of robustness before. Anyway, everything will surely be better in this robust and appropriate new world.

But not very much better. Distinctly this is a technical account of the subject: how to make things as they are work properly (the machine again). There are some good suggestions to that end, certainly. For instance the authors recognize, as one of the barriers to progress in animal-free research, the weight of professional habit and institutionalized practice; they advise that training courses for animal researchers should include “non-animal technologies”, so that transition is easier and more acceptable [p.64]. Also I must concede that, for all the tautologies and self-evident truths, there’s a 12-page bibliography to back up what the committee says. But the rationale for all this attention, why it matters whether there’s a ‘need’ for NHPs in science or not – in short, the morality of it – is almost untouched. Two pages (out of 66 in the main text) make a hurried tour of the topic, though it is of course alluded to from time to time elsewhere. But then all members of the Working Group were scientists. Accordingly, the section headed ‘Minority Opinion’, which looks rather promising in the table of contents with the whole of page 23 to itself, proves, when one reaches it, to be blank, apart from the word “None”.

The committee recognises, as a political fact, that “polls of the European public repeatedly show low levels of acceptance of the use of NHPs in research” [p.24]. Approval for the use of NHPs in the U.K., for instance, was about 17% when last canvassed (see, in this blog, ‘Animal Pains and Human Attitudes: the new Ipsos Mori survey’, 26 September 2016). However, there is at least “greater acceptance of animal research where animal use and suffering are minimised in line with the 3Rs principle” [i.e. Replacement, Reduction, Refinement: p.25]. This is no doubt true, although it’s a somewhat disingenuous way of putting things: where acceptance has not been ‘great’ in the first place, it shouldn’t really be said to become “greater”. And I suspect that approval would actually have been even lower if the respondents had known, as this SCHEER report records, that nearly three quarters of ‘procedures’ conducted on NHPs in the E.U. are for “regulatory use and routine production” [p.15].

What these quotations illustrate is how the “3Rs principle” is seen by scientists as a sort of ethical machine labouring away to turn expediency into good conduct, rather as the “invisible hand” of the free market was supposed by Adam Smith to convert self-interested actions into social good. In this capacity, it’s expected to satisfy or at least placate opponents of animal research. That it does not do so, and that the whole managerial attitude to “ethical considerations” understates their seriousness, is evident in the consultation document which is published alongside the SCHEER report (but which came before it in time, of course).

I must say that this 234-page consultation document is conspicuous proof at least of the diligence and fair-mindedness of the committee, which here records in the left-hand column, and replies to in the right, hundreds of queries and comments. It wasn’t in the committee’s remit to deal with ethics except as a general premise, but at least the moral passion is now allowed printed expression in raw, ungentrified form: “cruel”, “inhuman”, “abhorrent”, “nearest cousins”, “brothers”, “freedom”. True, the committee makes little attempt to address this sort of complaint (there being plenty of other more strictly scientific representations). “Stop this insane abuse!!” says one contribution (well yes, two exclamation marks, but then, as the great Aneurin Bevan used to say, “In public life, those who would change things must shout to be heard”). To such, the committee can only reply with a slightly pompous set formula: “This is a personal opinion. The comment does not provide any suggestions for improvements of the scientific basis of the SCHEER preliminary Opinion and/or any scientific evidence.” Still, such remonstrations, earnest and unscientific, are at least recorded here. Thank you to those who did speak up with this authentic human indignation.

When it issued its previous ‘opinion’ on animal research, just prior to the making of the 2010 Directive, this same science committee was called SCHER. The second ‘E’, recently added, stands for ‘emerging’, and refers to novel or reappearing infectious diseases. It’s an ominous alteration for NHPs, because this is one of the areas of research in which the committee, so far from sketching out a diminution in their use, foresees an increase. NHPs, so SCHEER claims, “provide essential models for understanding and combatting (re)emerging infectious pathogens.” Thus, for recent research into whooping cough, “a new baboon model was developed” [p.47]. That rather euphemistic phrase actually means that research was conducted, for the first time, on juvenile baboons (from two to six months old): the opposite of the 3Rs, then. SCHEER justifies such retrogressions by speaking of “realistic dangers” [p.47]. Danger, which might properly be seen as a test and validation of our ethics, is evidently expected to frighten them away. And after all, even the great apes (gorillas, chimpanzees, orangutans, bonobos), whom the E.U. Directive in principle protects absolutely from scientific exploitation, may be used “in relation to an unexpected outbreak of a life-threatening or debilitating clinical condition in human beings” [Article 55.2].

So, shall a timetable be drawn up for ending the use of NHPs in European research, as the E.U. Parliament was dreaming ten years ago? SCHEER’s 12,000 word answer resembles the one being given in a famous Saul Steinberg cartoon from 1961. A well-fed manager of some sort, comfortably leaning back at his desk, addresses a petitioner with a mass of words, illegible but obviously full of patronizing civilities and bureaucratic reassurances. The words coalesce, above the petitioner’s head, into a giant ‘NO’.


Notes and references:

The 2016 statistics can be viewed here:

These new statistics record about 3,600 procedures using NHPs. The SCHEER report uses the all-E.U. figure of 8898, which was the total in 2014. Note that the Home Office numbers don’t include Northern Ireland: i.e. they cover animal research in Great Britain rather than the U.K.

The 2007 Declaration of the European Parliament on primates in scientific experiments is published online at

The SCHEER report is at

The results of the public consultation are published at

Aneurin Bevan is quoted in Michael Foot, Loyalists and Loners, Collins, 1987, p.36. Among other political achievements, Bevan was the Minister of Health from 1945 to 1951, therefore the man responsible for establishing the U.K.’s National Health Service.

The photograph is of a rhesus macaque monkey in Oxford University’s Biomedical Sciences Building, and is used here by permission of the University’s Public Affairs Office.





Home Office statistics: numbers, words, and euphemisms

The Home Office has now published its statistical report on the animal research done in Great Britain (i.e. omitting Northern Ireland) during 2015. It shows that 4.14 million ‘procedures’ were completed last year. This is the largest number ever recorded under the 1986 Act, and tends to confirm that the promising drop in the numbers during 2014 (3.87 million) was the result of under-reporting in that year, rather than a sudden change of direction. The new system had just been introduced, whereby the research projects are counted when they finish rather than when they begin, and not everyone seems to have understood it. So the Home Office advises that the new figures should be compared with 2013 rather than 2014 (for VERO’s comment on the 2014 figures, see In that case, there has been a slight increase of 1% or 21 thousand in these ‘procedures’. This in turn means that the real numbers have been rising in every year since 2001, except 2009, which came after a notable jump the year before. During this whole period, the numbers have increased by about 58%.

This new Home Office report makes an exhaustive summary of every countable aspect of the nation’s work as vivisector in 2015. Its own two-page précis can be found at There are other useful and more critical summaries to be found on the web-sites of the Fund for the Replacement of Animals in Medical Experiments and Cruelty Free International. These notice, for instance, the rise in numbers of primates used in research (from 3,220 to 3,600), and the continuing use of dogs in toxicology studies, one of the most unpleasant areas of research. There’s also a review on the web-site of Understanding Animal Research, which is the promotional arm of the animal research industry. At the end of it the Chief Executive, Dr Wendy Jarrett, is quoted as saying “today’s statistics will help people to find out more about the reality of animal research in the 21st century.”

Yes, on the face of it the statistics ought to help in that way, but I doubt that they will help much. Quite apart from the varying interpretations which statistics notoriously allow, they address a part of the mind (the numerate) which is completely unrelated to the part where ethics or empathy live. What can one feel about this great torrent of numbers? It’s a crowd scene with no foreground. Every now and then, a detail will catch the dazzled attention. For instance, under the category ‘regulatory testing’ (p.49), the astonishing fact emerges that the LD50 and LC50 tests (= the Lethal Dose or Lethal Concentration that kills 50% of the test animals) are still in use. These true products of the mind as computer, giving a specious accuracy to toxicology tests at the cost of human decency, accounted for 8898 animals in 2015 (mice, rats, and fish).

Nearby, now that one’s eye is adjusted to such detail, it seems that something very like the Draize test (listed as “eye irritation/corrosion”) also survives: 173 rabbits went that way. But what: only 173? In most of the categories, that number would simply have disappeared in the ‘rounding down’ of untidy decimals (see User Guide to Annual Statistics, pp.9-10). On the other hand, you’d certainly hate to see the test done to a rabbit you knew, and you’d be quite properly liable to prosecution for cruelty if you did it yourself. And by the way, that’s a useful reminder that the Home Office is wrong to define the Animals (Scientific Procedures) Act in its preamble as “an animal protection measure” (p.5): the Act is also, and much more successfully, an animal-user’s protection measure.

Anyway, such details as the ones mentioned are generally invisible in the glare of the huge numbers. The whole dazzling parade of facts, so competently put together by the Home Office’s statisticians, is therefore a kind of euphemism, tending as much to hide as to show the “reality of animal research in the 21st century”.

A rather more informative source, and a necessary complement to the Annual Statistics, are the ‘non-technical summaries’ of proposed research which the Home Office also publishes (at There you can see the research in detail, admittedly as presented by its partisans, but in the format required by the Home Office, with answers to questions about purpose, method, the 3Rs, and so on. The animals appear in more comprehensible numbers (150 pigs, 200 chickens), and their kind is more accurately identified (crows, rainbow trout, opossums, voles). What happens to them is more or less picturable, and the scene can be bloody and squalid, even where no suffering is involved: “In parallel to in vivo experiments, we will also carry out in vitro experiments using sheep uteri and ovaries collected from an abattoir” [God, what have we become?]. You get some idea of how scientists may have judged the pain levels which are later to be recorded in the statistics: “The expected adverse effects are the development of skin wounds, inflammation and cancer. In most cases the severity will be mild. However, in some situations, such as tumour development, the severity will be moderate.” [Excellent! Cancer is evidently not as bad as we feared.]

And now, with these and other Home Office publications about animal research to hand, you begin to realize that the word ‘procedure’, the key word in the Animals (Scientific Procedures) Act (ASPA) and the one on which you have to rely if the statistics are to make any sense, is itself a euphemism. Having myself been misled by this word, I shall try to show what’s wrong with it.

For the purposes of the Act, a “regulated procedure” is defined (see the User Guide, p.10) as “any procedure applied to a protected animal for an experimental or other scientific purpose, or for any educational purpose, that may have the effect of causing an animal pain, suffering, distress or lasting harm equivalent to, or higher than, that caused by the introduction of a needle in accordance with good veterinary practice.” The breeding of a genetically altered (GA) animal is quite properly counted as one such procedure under the Act, and we’re told in the 2-page summary that about half of those 4.14 million procedures “related to the creation/breeding of genetically altered animals that were not used in further procedures.” That seems to make good sense. The breeding would be one procedure. Those GA animals for whom that turned out not to be a sufficient contribution to science would become part of other (“further”) procedures, counted as such.

But in fact we know that this isn’t what’s being done. It would mean that there’d be many more procedures than animals in the total count, whereas we’re specifically told that the two numbers are always more or less the same, and that in the rare cases where the number of procedures is higher than the number of animals used “this is due to a re-use of animals” (User Guide, p.9). ‘Re-use’ is a term always meaning ‘used in a different project of research’, which is actually by no means a common practice. And for this purpose, GA breeding apparently doesn’t count as a different project. So the real situation is this: animals which have undergone the GA procedure, and are then used in “further procedures”, still count for only one procedure each.

All right, but even apart from the GA question, ‘procedure’ has a very elastic meaning, which seems to include its own plural. It may just mean an injection, such as the one which is the model for what minimally constitutes a regulated procedure as defined in the Act. On the other hand, it can mean a whole “series of regulated procedures”: that’s the phrase which the Home Office Use, Keeping Alive, and Re-use Advice Note (p.9) uses when reviewing the experience of an animal during one research project, and advising on its suitability for ‘re-use’. The User Guide explains (also p.9): “Each procedure (which may consist of several stages) for a given purpose on an animal is counted as one returnable procedure.” ‘Procedure’, it emerges, is a collective noun, but what exactly it may have collected in any particular instance there’s no way at all of discovering from the statistics.

I don’t know whether I’ve been able to make things clear; probably not, because this key-word in ASPA is not used clearly and consistently even in the official documentation. To summarise, then. A ‘procedure’ is an animal’s whole career of procedures within one research project. If it’s a GA animal, that career will include the procedure which brought it into being, and may or may not include others. In short ‘procedure’ is a term so elastic as to be almost meaningless. The number 4.14 million, therefore, really means 4.14 million multiplied by an unknowable n.

This ambiguity must affect every aspect of the published statistics. For instance, the rule for deciding the painfulness or severity of a ‘procedure’ is that it should be put in the severest of the four classes (sub-threshold, mild, moderate, or severe) which it reaches at any point during the research. But you will see that the meaning of a severity class is itself obscured by the vagueness of the term ‘procedure’. A procedure classed as ‘severe’ may have been a brief torment constituting the whole of an animal’s part in modern science, or it may have entailed that ‘severe’ pain together with a succession of other ‘severe’ or ‘moderate’ or ‘mild’ interventions covering the full period of a research project. It makes a great difference to our understanding and (lest we forget) to the animal concerned, but the difference cannot be indicated in the Home Office statistics.

It’s no wonder, now I come to think of it, that Understanding Animal Research has been content to present the Home Office statistics on its web-site as the “reality” of animal research. In truth, they’re a mixture of understatement, euphemism, and unintelligibility. Despite all the varieties of show and tell that the animal research industry now agrees to, the essential secrecy remains. And I should say that outsiders will never really know what’s going on until we get the number of ‘procedures’ down to nought.



For Oxford University’s part in the 2015 numbers, see ‘Multitudes, multitudes’ in this blog (posted 24 April).

The Home Office’s Annual Statistics of Scientific Procedures on Living Animals, Great Britain 2015 can be seen at 

Its User Guide to Annual Statistics of Scientific Procedures on Living Animals  is at

Use, Keeping Alive and Re-use (dated October 2015) is at .

Other references are to be found on the relevant web-sites.