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.