House of Lords - Animals In Scientific Procedures

Select Committee on Animals In Scientific Procedures Report

CHAPTER 7: THE THREE RS: ALTERNATIVES TO ANIMAL EXPERIMENTS

7.1 The Three Rs — reduction, refinement, and replacement — form a framework for the minimisation of pain, suffering, distress and lasting harm in animal experiments. They are widely accepted as a guiding principle by the majority of scientists and many anti-vivisectionists.[168]

7.2 The Three Rs are often referred to collectively as "alternatives". Although this term is in current use, a number of witnesses said that it was misleading.[169] To the public, the term "alternative" suggests the replacement of an animal experiment, not simply a reduction in the number of animals used, or the refinement of an experimental protocol.

7.3 Some anti-vivisection groups were also unhappy with the concept of the Three Rs. Those who are fundamentally opposed to animal experiments consider that replacement is the only "R" worth arguing for.[170] Refinement and reduction, they argue, merely serve as a smokescreen to allow scientists to continue to experiment with animals. Other animal groups, however, such UFAW, argued that animal experiments are unlikely to stop completely for some considerable time. Given that situation, such groups maintain that animal welfare and animal rights groups should focus on practical matters of reducing pain and distress. They argue that there is considerable scope for minimising animal suffering, and the preoccupation with "replacement" is not to the ultimate benefit of the animals involved.

7.4 It is unrealistic to suppose that we can change the use of the word "alternatives". We do not consider however that the word "alternatives" should be replaced solely by the word "replacements". Both long-term and short-term gains in animal welfare are important — that is to say, effort should be made to find replacements, but also reductions and refinements.

7.5 In considering the question of the use of animals in scientific procedures, we have been persuaded that benefits do arise from animal experiments. We are not, however, persuaded that enough effort is always made to avoid the use of animals. We are similarly not persuaded that where this is not possible, sufficient effort is always made to minimise the number of animals used, and to minimise the pain and suffering inflicted on each animal.

7.6 The justification for the use of animals in scientific procedures hinges on such procedures being necessary. It is therefore important that all possible steps are taken to implement the Three Rs.

7.7 This is important for reasons of animal welfare. It is also important for reasons of good science. Replacement in vitro tests tend to produce less variable results than animal tests. Better welfare leads not only to more contented animals, but can make animals better models for human disease — a recent paper shows that "Environmentally enriched mice may actually mimic human disease more accurately".[171]

7.8 Public confidence that only necessary animal research is carried out relies in part on the effective development and use of the Three Rs. Equally, scientists who experiment on animals need an up-to-date understanding of ethology (how animals behave in their normal environment), including expressions of pain in particular species, in order to implement appropriate refinement techniques. Steps to minimise animal suffering need to be taken, and need to be seen to be taken. Only if efforts are continually being made to reduce, replace and refine animal experiments can scientists who rely on animal experimentation expect to gain and retain public confidence.

7.9 We recognise that, to date, most advances in the Three Rs have been made by scientists in the course of their work. We have also seen that most of those who work using animals take great care of them and are concerned for their welfare. Particularly following the introduction of the ERP, it seems to us that reduction, refinement and replacement techniques which have already been developed are implemented. The question remains as to who will take responsibility for developing new techniques in the Three Rs. Scientists have many pressures on their time, and on their budgets. Without any specific focus on their implementation we do not consider that the development of the Three Rs is likely to proceed at a satisfactory rate.

USE AND DEVELOPMENT OF THE THREE RS

7.10 Under the 1986 Act, no animal procedure can be licensed where there exists a "reasonably practicable method not entailing the use of protected animals".[172] The Act also requires researchers to incorporate reductions and refinements wherever possible.[173] Virtually all our written submissions made reference to the use and development of alternatives to animal experiments, and in particular to the Three Rs of reduction, refinement and replacement.

7.11 Scientists said that consideration of the Three Rs was an integral part of planning research using animals. The project licence form requires the applicant to demonstrate that the Three Rs have been considered. Funding bodies also require that non-animal methods receive due consideration.[174] Scientists said that replacements, reductions and refinements are continually developed by scientists themselves in the course of their work. They argued, as we have already noted (see para. 4.10), that scientists have made considerable progress in reducing the numbers of animals used.

7.12 Those opposed to vivisection, however, were highly sceptical that scientists took the Three Rs sufficiently seriously. They asserted that scientists enthusiastically endorsed the Three Rs as a way of ensuring that they were seen to be taking animal welfare seriously, even though, in practice, very few changes to standard animal research practice were ever made. Professor Balls, from the European Centre for the Validation of Alternative Methods said that the support for the Three Rs from the scientific community is "often rather shallow" (Q. 1451). Dr Goldberg, from Johns Hopkins University, said that scientists did not look for the Three Rs enough, as they had not been trained to do so (Q. 1532).

7.13 We welcome the progress which has already been made by the science community, but there seems to us to be scope for further work to develop methods involving the Three Rs. Many scientists have insufficient time to spend on the Three Rs, and we did not consider that there was a consistent consideration of them.[175] We also consider that there is inadequate recognition for the work of scientists in this field.[176]

7.14 Scientists are required by the Act to use existing replacement, reduction and refinement techniques, but even where existing Three Rs are incorporated into scientific thinking, there seems to be little onus on any individual to search actively for new ways to improve animal welfare. Moreover, while there may exist a financial incentive to develop replacements and reductions (in terms of reducing the costs of obtaining and keeping animals), there is less incentive to develop refinements.[177]

7.15 Refinements are often as simple as incorporating environmental enrichments into existing procedures. However, before such enrichments can be incorporated, more research needs to be undertaken to demonstrate that the enrichment (such as the provision of nesting material or toys in cages, or even solid cage bottoms) will not interfere with the results, and prevent comparison with existing data. The science community has had little incentive to undertake such research as its first concern is with the validity and reliability of its existing methods, and validation of new enrichment techniques costs money. Such studies are beginning to be done, especially as it is now coming to be recognised that enrichment techniques can improve the validity of animal experiments.[178] We consider that this sort of work needs more encouragement.

7.16 In May 2001, the MRC established a Centre for Best Practice for Animals in Research to develop and disseminate information and guidance on the Three Rs. This is a welcome beginning, but its focus is on animal welfare and good practice — it has no specific mandate to look for replacement alternatives. Currently, it is only available to holders of MRC grants. We consider that this idea should be built upon to create a new initiative.

CENTRE FOR THE THREE RS

7.17 We recognise that many new techniques related to the Three Rs have been developed by scientists in the course of their work. We consider that there is a need for further impetus to support and encourage them to be innovative. In taking evidence, we heard that there is very little support for the idea of an independent research laboratory which would itself develop new experimental or toxicological techniques related to the Three Rs. We recognise that research into the Three Rs needs to be integrated into traditional science. Only by embedding such research into existing scientific structures will the necessary expertise become available.

7.18 We recommend that a Centre for the Three Rs be set up, consisting of a small, administrative hub which co-ordinates research units embedded in existing centres of scientific excellence.

7.19 In making this specific recommendation we have been particularly influenced by our visit to the Center for Alternatives to Animal Testing (based at Johns Hopkins University in the United States), the evidence we received from ECVAM and the OECD, and the conference we held towards the end of our evidence gathering with representatives from industry, funding bodies, and animal welfare and rights groups.[179]

7.20 The form of this "Centre", a collection of small, devolved units, is crucial. We envisage that the administrative hub would be a portal to relevant databases, provide a forum for sharing information, help to prevent duplication of animal research, and possibly include a database of "negative results".[180] It might co-ordinate existing funding for the Three Rs which is already provided by Government, charities and industry. It should also be a resource for researchers to provide reliable, validated information on the Three Rs.[181] It could encourage and co-ordinate research on animal pain and cognition, and use the results of such research to provide better standards of accommodation and care. It could promote conferences, and act as a focal point for efforts to lobby appropriate international bodies.

7.21 The hub would co-ordinate small research groups with different specialisations incorporated into existing research centres at universities and medical schools. These small units would draw on existing expertise in research centres, and act as drivers to incorporate research into the Three Rs into the everyday business of research science. We consider, for example, that one such group should be sited in the MRC's own laboratories, in order to complement their excellent initiative of a Centre for Best Practice for Animals in Research.

7.22 The centre should be jointly funded by Government, charities and industry. As the NAVS observe, such a centre would also provide a respected and official focus for public charitable giving. The public might be surprised to learn that the Home Office budget dedicated to searching for the Three Rs in animal experiments is a meagre £280,000 per annum. Even the more optimistic figure, given by the Home Office, that across all departments the Government spend £2 million per annum (Q. 174), is small in comparison with the £6 billion spent annually on medicines by the Department of Health.

7.23 We recommend that the current Animal Procedures Committee research budget of £280,000 should be given to the Centre to disburse. We further recommend that the Centre should co-ordinate the Government spend on the Three Rs across all departments. A Centre would also require further funding from Government, industry, and animal welfare charities.

7.24 The obvious objection to the setting up of such a centre is cost. Costs do not exist in a vacuum, and we recognise that new money spent by Government on a centre for the Three Rs could otherwise be spent on new research. The argument can be characterised as, "Why should the Government spend considerable amounts of money on keeping a few activists happy when it should be funding a cure for cancer?".

7.25 The principal justification for such a centre is that all sides of the debate on animal procedures say that animals are highly imperfect models. It will be for the benefit of science, and ultimately of human health, if better methods of research and testing could be developed. Another reason has already been discussed — the justification for the use of animals is predicated on the elimination of unnecessary animal use. Public opinion in the UK is also only in favour of animal research where it is absolutely necessary and suffering is kept to a minimum.

7.26 We consider that a Centre will encourage more research into the Three Rs and build on the considerable amount of research which is already undertaken by the scientific community. We also consider that a Centre will demonstrate in the clearest way possible that steps really are being taken to minimise animal use, and minimise the infliction of "pain, suffering, distress or lasting harm".

OTHER WAYS TO PROMOTE THE THREE RS

7.27 We recommend that the following suggestions to promote the use and development of the Three Rs should also be considered.

7.28 Funding bodies should encourage applicants who propose using animals in their work to state what developments in the Three Rs each application incorporates.

7.29 Academic and professional journals should agree a standard set of keywords for articles relating to research on the Three Rs, so that relevant articles can more easily be found in databases.[182]

7.30 Journals should encourage contributors to include information on how the Three Rs are developed or used in their research. Given the limited space in journals, this information could be made available on the web.

168 See The Three Rs para. 1.12. Back

169 For example, Animal Aid (p. 2). Back

170 For example, the Dr Hadwen Trust (Q. 457). Back

171 Dr E. Hockly et al., "Environmental Enrichment Slows Disease Progression in R6/2 Huntington's Disease Mice", Annals of Neurology, 51 (2002), pp. 235-42, p. 235. The abstract of this paper is reprinted as part of the DoH's memorandum following their oral evidence. Back

172 Section 5(5)(a). Back

173 Section 5(5)(b). Back

174 Wellcome Trust (Q. 1427), and MRC and BBSRC (Q. 743). Back

175 Lord Winston said that scientists "may well have turned a blind eye many times to alternatives" and "that may be still happening in the use of animals". He continued, however, that it happened much less than it used to and that many organisations had changed their attitude (Q. 1866). The RSPCA also acknowledged that some organisations had responded well to developments in the Three Rs, but said that there was no "long-term, global, strategic commitment to replace animals" (p. 294). Back

176 See para. 4.12. Back

177 Dr Dexter from the Wellcome Trust noted that most of the funding applications received were for replacement (Q. 1422). Back

178 "Environmental enrichment" paper by Hockly et al. (see footnote 171). Back

179 The report of the conference's Working Group on a Centre for the Three Rs is in Appendix 4. Back