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Australian code of practice for the care and use of animals for scientific purposes submission

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77
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Organisation Name: 
Australian Veterinary Association
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Online Written Submission
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General Comments
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General Comments
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 The Australian Veterinary Association

Submission on proposed revisions to the Australian code of practice for the care and use of animals for scientific purposes, 7th Edition (2004)

2 December 2011

 Introduction

The Australian Veterinary Association (AVA) is the national organisation representing veterinarians in Australia. Its 6500 members come from all fields within the veterinary profession. Clinical practitioners work with a range of species including companion animals, horses, farm animals such as cattle and sheep, laboratory animals and wildlife.

Animal welfare is central to the mission of the AVA and this is a primary focus of our members. The AVA has 21 special interest groups and the Australian Veterinarians for Animal Welfare and Ethics (AVAWE) special interest group is one of them. Members of this group have reviewed the proposed changes to the Australian code of practice in detail.

Internationally there is increasing recognition of the animal welfare benefits provided by veterinary professionals within the laboratory animal field.  The Guidelines for the veterinary care of laboratory animals: report of the FELASA/ECLAM/ESLAV Joint Working Group on Veterinary Care highlight methods of implementing best practice.  Veterinary degree training provides high quality knowledge of multi-species anatomy, pathology, microbiology, disease, surgery and medicine.  The Australian and New Zealand College of Veterinary Scientists (ANZCVS) provides postgraduate qualifications in this specific laboratory animal area, with Membership examinations in Medicine of Laboratory Animals obtainable after 3.5-4 years of veterinary experience and Fellowship exams (specialisation) in Welfare Science, Ethics and Law.  Veterinarians by law in Australia are required to complete a set number of points of continuing education so they stay at the forefront of knowledge in their chosen field.

Recommendations

Recent developments in Canada[i] and the European Union[ii] specify that a veterinarian or a suitably qualified expert[iii] must have responsibility for the animals used for scientific purposes. The new Australian code should reflect the principle that each establishment that breeds, supplies, or uses animals for scientific purposes must have a veterinarian with knowledge and competence in laboratory animal medicine to advise on well-being and provide veterinary treatment to the animals.

Section 2.1.9

ii.) “provision of adequate resources for appropriate education and training”

We suggest the following improvement:

provision of adequate resources for appropriate education and training which must be developed by the facility veterinarian

iv.) "ensuring the care and management of animals is under direction of suitably qualified personnel"

We suggest the following improvement:

"ensuring the care and management of animals is under direction of a registered veterinarian"

Section 1.15

We suggest the following improvement:

 (vi) ensure that a veterinarian is appointed to oversee a program of veterinary care, and provide advice on animal health, nutrition, anaesthesia, surgery, biosecurity, animal husbandry and other matters as specified in later section on the ‘Responsibilities of a veterinarian’.

After Section 1.19

We suggest the addition of:                                                     

Veterinarian

S1.20 A veterinarian, should have appropriate knowledge, expertise, competence and experience relevant to the health, care and welfare of the animals used.

S1.21 A veterinarian will be charged with advisory duties in relation to the health, wellbeing, treatment and use of the animals, including implementation of the 3Rs of Replacement, Reduction and Refinement; as well as provide training and take action to protect animals where there is concern for their health or welfare.

 

S1.22 A veterinarian will also provide veterinary advice to the AEC.

 

Section 2.1.6

We suggest the following replacement:

(ii) nominating a veterinarian from the institution to oversee compliance with the code (from the insee above and footnotes).

 

Section 2.1.7

We suggest the following addition:

S2.1.7 (viii) appointment of an officer with veterinary qualifications who is authorised by the AEC to ensure that projects are proceeding in compliance with the Code and the decisions of the AEC.

 

Section 2.6

We suggest the following addition (under responsibilities):

 

Responsibilities of veterinarians

  • provide clinical veterinary care and advice on the health, care and wellbeing of animals, contribute to the institutional triennial plan (S2.1.7 (iii) and other when required;
  • oversee a appropriate program of preventative veterinary care;
  • provide advice on health surveillance, diagnosis, treatment, control and management of potential pathogens and other diseases, including the management of disease outbreaks;
  • manage experimentally induced adverse events, whether expected or unexpected;
  • provide advice on anaesthesia, analgesia, surgery, asepsis and pre-, intra- and post-operative care and selection, supply and administration of drugs;
  • conduct routine inspections of animal facilities and observe animal use on a regular basis, and make recommendations for improvement, where appropriate;
  • be actively involved in management decisions relating to animal facility planning and design, and choice of facility equipment and infrastructure which may have potential impact on animal health and wellbeing;
  • be involved in the training and assessment of competence in procedures that may influence animal welfare; and
  • assist the AEC in the recommendation of new measures, policies or changes which enable continuing refinement in line with current best practice standards in the research animal field.

Section 2.4.25

(ii) “ensure the technical skills and competence of all people involved in animal care and use”

We suggest the following improvement:

“ensuring the technical skills and competence of all people involved in animal care and use which must be through training and assessment developed by the facility veterinarian

Section 2.4.37

"...necropsy is performed by a person with appropriate qualifications and/or experience and that the AEC is notified promptly."

We suggest the following improvement:

 "...necropsy should be performed by a veterinarian or someone who has been trained by a veterinarian and that the AEC is notified promptly."

Section 2.5.4

We suggest the following addition:

" Animal carers should undertake continuing education that is arranged for and may be delivered by the facility veterinarian.”

Sections 3.7.1-3.7.26 Anaesthesia, non-surgical procedures & surgical procedures

3.7.18 Personnel performing surgery must be competent to perform the procedure, or be under the direct supervision of a person competent to perform the procedure”

We suggest the following improvement and addition to all three sections:

Anaesthesia, surgery and non-surgical painful procedures must be performed only by personnel with appropriate training and experience and who are approved as competent by the AEC and facility veterinarian.

3.5 Humane killing and euthanasia of animals

Sections 3.7.29-3.7.38 Post-procedure care

We suggest the following addition to these:

“Training and assessment of post-procedure monitoring must be conducted by the facility veterinarian.”

Section 4.4.9

We suggest the following addition:

At secondary level, AEC approval is not required for the training and application of agricultural extension work practices to achieve competency-based outcomes in routine procedures if all of the following apply:

(i)     the animals are at their home property and the owner has provided consent; 

(ii)    the procedures would normally occur as part of routine management at that particular time;

(iii) the animals are subjected to no type or number of procedures additional to what would normally occur in routine management;

v) the animals are not subjected to surgical procedures, as defined by the relevant Veterinary Practice Act;

vi) each student is directly supervised by a trainer when performing an animal procedure; and

vii)the trainer is appropriately qualified and competent to carry out the procedure.

 

 

Section 4.4.15

We suggest the following additions:

 

At the tertiary level, AEC approval is not required for the training and application of agricultural extension work practices, or the training of students in veterinary science, veterinary nursing or animal technology to achieve competency-based outcomes in routine

procedures if all of the following apply:

 

(i) the animals are at their home property or a licensed veterinary facility and the owner has provided consent;

(ii) the procedures would normally occur as part of routine management or veterinary

clinical management of the animal in those particular circumstances;

(iii) the animals are subjected to no type or number of procedures additional to what would normally occur in routine management or veterinary clinical management of the animal;

v) each student is directly supervised by a trainer when performing an animal procedure; and

(iv) the trainer is appropriately qualified and competent to carry out the procedure, and in the case of veterinary procedures the trainer is a registered veterinarian.

 

[Competent = current best practice qualifications and, wherever possible appropriate experience in the role or task to be undertaken. Competence requires AEC approval and should be determined by the veterinarian. Determination of competence may include certified copy of awards, certified copy of supervisors report on skills and experience and/or assessment in task by veterinarian.]

 

Fates: Re-use and Rehoming

The new Australian code should reflect the provisions of EU Directive 2010/63/EU in relation to the re-use and rehoming of animals used for scientific purposes. The following addition should be included:

-          an animal already used in one or more procedures, when a different animal on which no procedure has previously been carried out could also be used, may only be reused in a new procedure provided that the following conditions are met:

(a) the actual severity of the previous procedures was not a category of invasiveness level 5;

(b) it is demonstrated that the animal’s general state of health and well-being has been fully restored;

(c) the further procedure is not a category of invasiveness level 5

(d) it is in accordance with veterinary advice, taking into account the lifetime experience of the animal.

-          At the end of a procedure, a decision to keep an animal alive shall be made by the AEC, taking into consideration an assessment of the animal’s health, its lifetime experience, as made by a veterinarian or by another competent person.

-          An animal shall be killed when it is likely to remain in significant pain, suffering, distress as determined by the AEC and veterinarian.

-          Where an animal is to be kept alive, it shall receive care and accommodation appropriate to its state of health.

 

 

 

The Australian Veterinary Association

December, 2011

 

 




[i] Canadian Association of Laboratory Animal Medicine Standards of Veterinary Care, Available: http://calam-acmal.org/pdfs/StandardsVetCare.pdf

[ii] EU Directive 2010/63/EU

[iii] Note, the Home Office UK stated in June 2011 that a “other suitably qualified person” is acceptable when no suitable veterinary surgeon is available and the "other suitably qualified person” has considerable, proven expertise relevant to the health and welfare of the particular types of protected animal held and the range of regulated procedures performed at the establishment.

Page reviewed: 1 March, 2013