Guidance for Animal Ethics Committees

Ethics committees are the only real level at which the validity and justification of the research can be challenged, and it is imperative that they are used for maximum impact. This page provides some useful information for those serving on animal ethics committees. It may also be of value to animal care staff and research integrity officers.  

For resources relevant to researchers interested in replacing animals in research, please view the for researchers page.

Serving on an animal ethics committee is a huge responsibility. The use of animals in science is embedded in culture and practice, as well as education and regulation, and questioning its validity or necessity may be met with resistance. Whilst individuals working or volunteering in the animal industry may have the best intentions towards the minimising of harm to animal, sometimes external forces come into play which obstruct these intentions. From the information HRA receives, these pressures may include; bullying, social pressure, lack of knowledge surrounding non-animal models, ignorance of the law and regulations, and the impact of hierarchies within institutions.

humane research

Below are some tips and resources to aid animal ethics committee members  to best serve the interests of both animals and the validity of research.

  • Make sure you are well-versed on the NHMRC Code for the care and use of animals for scientific purposes. Whilst it needs to be strengthened, it does provide a framework to prevent the worse exploitation of laboratory animals 
  • If you have a grievance as an AEC member, refer to the AEC operating procedures, which should be publicly available. There should be a complaints/grievance policy outlined which you can follow, which according to the Code, ensures fair, prompt, timely, effective, confidential processes that accord with procedural fairness, the principles of natural justice and protection of whistleblowers
  • If you need to escalate your concerns, you can contact the State department responsible for regulating animal research (for example, in Victoria, Animal Welfare Victoria).
  • If you live in NSW, you can refer complaints to the Animal Research Review Panel. There is no such body in other states or territories
  • If you feel a research institution has insufficiently handled a breach, contact the Australian Research Integrity Committee (ARIC)
    The ARIC undertakes reviews of institutional processes used to manage and investigate potential breaches of the Australian Code for the Responsible Conduct of Research.
  • If you are a category C member and were nominated by an animal welfare organisation, you can ask them for advice
  • If you don’t understand a research proposal you can ask that it be rewritten in plainer language, request more information from investigators
  • HRA has webpages on Australian Regulations and Replacing Animal Models you can refer to
  • HRA has a collation of Australian non-animal case studies you can refer to
  • The HRA report ‘Better Ways to do Research’ is a good resource for all Animal Ethics Committees
  • The  Australian & New Zealand Council for the Care of Animals in Research and Teaching (ANZCCART) has a number of resources relating to animal care and ethics
  • The Australian and New Zealand Lab Animal Association (ANZLAA) has a range of resources relating to animal welfare, the 3Rs and ethics
  • Ask to participate in any training. AEC training in now mandatory in Victoria, but if you find the mandatory training insufficient, request more and consider ComPass, a free online course provided by ANZCCART which covers the Australian Code and NZ Guide and welfare issues relating to animal use in research and teaching.
  • The UK National Centre for the 3Rs has some useful resources
  • Whilst based on UK legislation, there are some useful information sheets for AEC produced by RSPCA UK
  • RSPCA UK also has a useful Animal Welfare and Ethical Review Body Engagement Pack
  • There are specific journals your institution can subscribe to with a focus on non-animal methods, such Alternatives to Laboratory Animals and Alternatives to Animal Experimentation (ALTEX)
  • There are several databases of alternative research methods, including https://www.piscltd.org.uk/alternatives/ and https://www.nat-database.org/
  • Watch this useful video from FRAME on searching for alternatives 
  • Suggest that the research is pre-registered to avoid duplication, address publication bias  and improve research rigour– there is not an Australian registry but projects can be registered internationally via www.preclinicaltrials.eu and www.animalstudyregistry.org
  • Use your experience to input into consultations into legislative reviews, or updates of the NHMRC Code 

Questioning research – moving beyond alternatives

It is important to note that conducting biomedical research without animals is not simply a case of looking for a direct replacement for an animal model, as explained in this article by the UK organisation Fund for the Replacement of Animals in Medical Experiments. It is about experimental design focuses on the desired outcome and challenging faulty logic. A like-for-like replacement is not always possible, and if that is what an AEC is seeking, not finding, then using as a justification for animal use, this is a flawed approach.

Additionally, human behaviours that can be a root cause of diseases are not represented in animal models. If resources are invested in prevention or enhanced treatment regimes, we may understand human disease better and be less reliant on study for disease biomarkers using animals. 

You can use your influence as a driver for change to push for specific detail on the method and deliverables expected from the research applicant as justification for the animal model selection. A recent study showed that the current choice of a specific animal model seems to be based on traditional acceptance and standard responses rather than robust substantiation for the choice of an animal model. You may find that researchers consistently justify animal research on the grounds that an entire biological system is needed. Non-animal models may lack the integration and longevity of an intact organism. They are designed to stimulate human biology up to a certain level or organization and complexity. However, despite the current limitations, a whole living rat does not represent a whole living human.

Rejecting animal research proposals

As non-animal methods of research evolve, there will be increasing opportunities to reject animal based research. With the advances in such methods, regulatory pressure to phase-out animal methods may follow. For example, the Dutch government has committed to a phase out of toxicology tests for chemicals, food ingredients, pesticides, veterinary medicines, and vaccines by 2025. Their Transition Program for Innovation without the use of Animals sets out the means to achieve this through collaboration between the science, health care, government and business community.

In you are overseeing regulatory science, there are validated non-animal methods that must be used in place of animals

A publication reviewer or editor may request that results be validated in animal models. You can urge your AEC to refuse this request and offer justification for the reason for refusal. 

Rejecting animal research may challenge the investigator, but this challenge can result in innovative new methods of research that may never have been considered. 

A thesis by Dr Anne van Veens provides some real-life examples of alternative methods adopted for various reasons in place of animals, all of which worked in practice.

Example 1: Ageing Research & Caloric restrictions.

Due to budget cuts, the researchers used pre-op human patients in place of mice

Example 2: Research into chrome’s disease using primates was rejected by the animal ethics committee, with led to a literature review showing that human research would be superior.

Example 3: An institute was earmarked to be a leader in animal housing and laboratory animal science. When vaccine development was moved to another facility, the institute took the opportunity to become a leader in alternatives development and policy.

The thesis provides hope that regardless of the rationale behind selecting non-animal methods, researchers can and should be adaptive and consider non-animal methods as the first option, with the overall outcome being better science.

Find out more by watching this interview with the thesis author.

Update of the NHMRC Code

The Australian code for the care and use of animals for scientific purposes was last amended in 2013 and a review is overdue based on scientific progress, state legislation changes and increasing public expectations of accountability.  You can contact the NHMRC to request that the Code be reviewed. 

Confidential Reporting

HRA welcomes open communication with anyone involved in the animal research industry, whether that be a question, complaint you wish to see investigated, or insider report.  Please contact us, or you can use the below form for anonymous contact. Complete confidence will be granted in either case. You may attach an image or document with your message. Date and location details would be useful to accompany any footage or images. 

Such information builds HRA’s intelligence of the animal research industry and may prompt further investigation by HRA.

Please note, despite the option to remain anonymous, we would need to be able to have a confidential chat with you if you are seeking a formal complaint to be lodged, a matter of concern to be pursued, and/or footage/images to be shared by HRA. Otherwise, we would be limited in our ability to progress such matters. Please also note that HRA complies with all relevant state and territory legislation in this regard.

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