Letter from Chair of the Animals in Science Committee to Baroness Williams (accessible version)
Published 6 August 2020
Chair: Professor David Main
Secretary: Caroline Wheeler
14th Floor Lunar House
40 Wellesley Road, Croydon, CR9 2 BY
Email:[email protected]
ASC Secretariat tel: 07826877304
Animals in Science Committee – Commission of work (2018 – 2019)
As Chair of the Animals in Science Committee (ASC) I am writing to provide you with an update on progress on the work you commissioned in your letter of 13 July 2018.
1. Societal concerns
You asked the ASC to review working criteria used to identify issues of societal concern and provide advice that could be used by the Animal Scientific Regulation Unit (ASRU) to inform their work with project licences and referral categorisation, including licences that should be referred to the Committee. In assessing the working criteria, the ASC also identified other important ‘future’ areas for inclusion in the work programme, including increasing complexity of emerging scientific topics, for example, brain organoid development in vivo in animal host brains and reanimation of animal brain tissue in the context of animal sentience. These have the potential to influence society’s perception of, and therefore concern about, the use of animals in research.
To address this the ASC has created two subgroups of its members: the first will look specifically at the topics of brain organoids, reanimation and sentience in order to review the ethical and animal welfare issues involved, and to understand the implications for legal status under ASPA; the second subgroup will engage with the Home Office Science Futures Team to explore, as part of a futures capability workstream, how these issues may impact upon or affect the use of animals in science. Through these key workstreams, the ASC will explore how it can support the Home Office’s preparedness to respond to such issues as they may arise. The scope of this work has the potential to be significant, the ASC will work closely with stakeholders involved in the use of animals in research. This key workstream will continue into 2021, and I will write to you in the Autumn with details of progress made.
2. Licence Analysis
I am pleased to tell you that the ASC’s analysis of project licences from across a range of species and severity ratings, undertaken in order to gain a broader view of the licences received by ASRU, is now complete. I will shortly write to you to present the ASC’s Licence Analysis Report ahead of its publication on the ASC website.
3. Non-technical summaries (NTSs)
As part of its analysis of project licences, the ASC also undertook a review of the accompanying NTSs, identifying a number of problems with their quality. The ASC recognise this is not an issue unique to the United Kingdom, and the Licence Analysis Report contains recommendations to help address these shortcomings. The ASRU have also supplied the Committee with a selection of NTSs taken from their new electronic licensing system, for a comparative assessment against those NTSs already reviewed. As Animal Welfare Ethical Review Bodies (AWERBs) provide a key interface with applicants before the submission of licences to ASRU, this assessment project will form part of the 2020 work programme for the ASC AWERB Subgroup.
4. Non-animal alternatives – 3Rs
You asked the Committee to provide advice on how information on the 3Rs (Replacement, Reduction and Refinement) can be shared across the UK. The ASC AWERB Subgroup has built the AWERB Hub Network, a UK wide knowledge sharing mechanism for all AWERBs. The Hub Network enables the ASC to share a wide range of information with the Network’s membership, including on 3Rs issues. The AWERB Subgroup also host an annual hub workshop for Hub Chairs and, in 2018, held two roadshow events to which all AWERB members were invited; 3Rs issues are always topics of discussion at these events.
In 2018, the AWERB Subgroup also created a secure electronic knowledge sharing platform for AWERBs, called the AWERB Knowledge Hub. I am pleased to say this now has around 150 members and the Subgroup continues work to increase membership. This secure platform is used to share information directly from the ASC, but also between AWERB members, on wide ranging issues related to the role of AWERBs and animal welfare issues, including the 3Rs. Additionally, the AWERB Subgroup has developed a workstream for 2020 which it will use to further explore opportunities with AWERBs to share 3Rs principles.
5. Project Licence application processes in other jurisdictions.
I am pleased to tell you that, as requested and in conjunction with ASRU, the ASC prepared a submission in response Article 54(1) of the Directive 2010/63/EU, the European Commission’s survey on Member State Regulatory framework implementation. In considering the second strand of the ASC work programme, Comparison of Regulatory Systems around the world, further research revealed that this work had already been completed by several other bodies. On reflection the ASC felt no useful additional information could be provided to support the existing body of evidence and decided to close this work stream.
6. Project Licence referral
I am pleased to say that during the period of this Commission the ASC has provided advice and recommendations to ASRU on eleven project licences.
Future
Science research in all its forms, including research that involves animals, is complex, increasingly innovative and fast paced and involves organisations with interests broader than ASPA. I, and ASC members, continue to work closely with ASRU colleagues as this important area of policy develops in order to provide independent expert advice to help deliver Government’s key manifesto commitments. Our recent discussions with ASRU have included the ASC’s role in providing assurance on compliance with ASPA, and more widely, the roles of ASRU and the ASC, working with NC3Rs, as leaders in public policy beyond ASPA compliance.
I look forward to discussions about defining the future long-term work programme of the Committee, and to further developing our good working relationship with ASRU throughout 2020.
Professor David Main Chair of the ASC