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

ID: 
68
Personal Details
Organisation Name: 
ANZCCART
C. Additional Information
Please identify the best term to describe the Organisation: 
Other
E. Submission
Types: 
Online Written Submission
Written Submission: 
Specific issues requiring particular consideration
After consultation with stakeholders during the initial phases of this review, specific issues have been identified as requiring particular consideration. Your comment is invited on these issues.
Comment on specific Sections, clauses or sentences of draft revised Code of Practice
Select if you wish to provide comment on specific Section, clauses or sentences within the draft revised Code of Practice.
General Comments
Select if you wish to make general comments about the draft revised Code of Practice.
Specific issues requiring particular consideration
1. Does the document clearly and concisely set out governing principles?: 

It was generally agreed that these principles have been outlined clearly, but some concern about the degree of repetition in this draft version was raised and that would suggest that it could be more concise.  The main concern here being that it makes the document “less readable” that earlier versions.  Specifically, there was some concern about the degree of repetition in this draft version was raised and that would suggest that it could be more concise.  The main concern here being that it makes the document “less readable” that earlier versions. 

 Some specific comments are given below:

 I disagree with requiring that people “respect” animals. The Macquarie Dictionary defines “respect” as

  1. a particular detail or point in phrases preceded by “in
  2. relation or reference  to in phrases preceded by “in:” or “with
  3. esteem or deferential regard felt or shown
  4. deferential, respectful, or friendly compliments
  5. to hold in esteem or honour
  6. to treat with consideration; refrain from interfering with.

I think we can require people to care for animals, to treat them appropriately and to minimise adverse impacts on them but I don’t think “respect” is the right term.

 The document is not concise. It is repetitive and difficult to read. I am concerned that this might mean that the people who need to read it won’t bother.

2. Are the terms “should’ and “must” used appropriately in the document?: 

As a general rule, there was a high level of agreement that these terms had been used appropriately.  There are however a few sections where the use of these terms will need to be reviewed.  For example:  In Section 1.35(i), the use of ‘must’ appears to be contradictory to Section 1.35(v) as such work could not be done.  

 Several other specific suggestions in this area have also been made, but rather than list them all here, they have been noted in the accompanying table which covers all issues raised by our members by paragraph number in the Draft Code. 

3. Does the document clearly and concisely set out, and correctly attribute, responsibilities of all parties involved?: 

Once again, there was strong agreement that this has been achieved with some minor exceptions.   For example:

There has been a clear intent to make sure everyone involved with the use of animals is prepared to bear the responsibility, but it might reasonably be asked if as a result, the lines have not become a little blurred.  Traditionally, it has been the CI (or equivalent) has been required to accept the ultimate responsibility for the animals and their welfare.  Has this changed?  We now have the governing body of the institution being responsible (2.1.1), the school principal (4.2.2) and of course all investigators (1.18, 2.4.2 & 2.4.7).  If anything goes wrong, who is THE person that is ultimately responsible??

4. Does the document provide all relevant parties with sufficient practical guidance on the application of principles of Code of Practice in terms of their responsibilities?: 

Most people felt that this new draft does provide sufficient practical guidance, although again the point was made that repetition did make it more difficult to read and extract that information. 

 One specific and potentially quite important exception to this opinion was however noted by some respondents who noted the loss of paragraph 2.2.22 from the 7th Edition with regret:-  

We would prefer more practical guidance on making decisions when there is no consensus among members of the AEC.   Section 2.2.22 in the 7th edition of the Code was helpful in this regard. This clause has been removed.

5. Should the document include specific guidance regarding the responsibilities of Veterinarians and Animal Welfare Officers?: 

This was a question which prompted some debate and a range of opinions.  Some felt that this was the domain of the institution and others felt that it would vary with the nature of work conducted within each particular institution, for example:-

 “No. Whether or not a veterinarian or an Animal Welfare Officer is required, and what they do if they are required, depends on the institution and the type of work being undertaken. Precise definition of the roles risks omitting some aspect which may be important in some situations or including functions which are irrelevant in others.”

 Others were clearly of the view that it is vital that the role of the AWO in particular is given greater importance and support within the Code.  Some submissions clearly expressed a desire to see a role on the AEC mandated as a part of the job description for every AWO that included full voting rights (noting that AECs generally do not vote).  It was also suggested that the Code should empower the AWO to act (ie treat animals) as and when required without having to seek specific authority to do so from the relevant CI or AEC Chair – both of whom can be difficult to contact in an emergency. 

 One example comment in this regard is:-

“I currently have no authority for emergency intervention and must seek permission from the Chair (who is an “Adjunct” and only present 2 days a week), the Deputy Chair or the PVC(R).  I would like the AWO to be vested with more authority in the legislation

(a) to treat animals,

(b) to attend AEC meetings (even as a non-voting member).  This may require the AWO not to be included in the “head count” for the ratio of Cat C/D members as the AWO is non-voting.

(c ) to attend facility inspections with the AEC members.”

 There seemed to be a strong desire among those who particularly addressed this question, to ensure that the appointment of an AWO is never seen as a token gesture. 

When it came to te question of direct veterinary oversight, the definition of a veterinarian was also raised by some with a view to seeking greater clarification.  One particularly clear example is given below:

“Cat A member on the committee needs to be a registered practicing vet to ensure they are undergoing continuing education and thus keeping their skills and advice up to date ( in Victoria you can hold non practicing registration).”

The question of who should be performing experimental surgeries and related procedures was also raised in light of this question and the greater emphasis placed on demonstrable competency that is integral to this document.  It may also relate to the fact that this has clearly been the subject of some debate recently, particularly in Queensland. 

 It was apparent from the each of the responses specifically focussing on this question, that they were all submitted by Veterinarians and it was interesting to note that none expressed the view that all such procedures should only be performed by Veterinarians.   There was however a strong consensus view expressed that there should be a greater role for Veterinarians / AWOs in assessing / monitoring the competency and technique of those investigators that are performing at this level.  One of the stronger expressions of such views is given below:-

 “I understand many researchers have the skills to perform surgeries but I think the vets/ or AWOs should have direct involvement - to assess competence and aseptic technique.  If external researchers (experts) are being brought into the institution specifically to perform the surgery, the AEC should give approval based on a video of the surgery being performed.” 

 A number of submissions did point out that the AEC does obviously have the right (obligation?) to make direct Veterinary involvement with any project a condition of approval in situations where it may be required – including cases where the investigators may not have the requisite skills available within their group.  Equally, the important point was made by others (also Veterinarians) that it is not always practical or possible to get a vet to participate in research projects to this extent.  Two particularly interesting comments in this regard were:

 “No. Direct involvement of a vet may be an impossible requirement (eg field work).”

 “The vet on the AEC or the AEC itself,  can already recommend that all surgery is done by a vet if the specific circumstances warrant it.”

6. As a principles-based document, the impact of the revised Code of Practice may be lost if too much detail is included. Comment is therefore specifically sought on whether there is sufficient balance between principles and detailed guidance.: 

A number of respondents felt that there is too much detail and too much repetition.  Some also suggested that a lot of the content belongs in guidelines, not in the Code itself.

7. Is there clear connection between the Code of Practice and the NHMRC Guidelines to promote the wellbeing of animals used for scientific purposes: The assessment and alleviation of pain and distress in research animals (2008) (Wellbeing Guidelines)?: 

Some felt that this was fairly clear, while others would have preferred to see more direct references to such documents.  This does of course raise the potential issue of ensuring that such references remain current. 

 One particularly lucid comment was:

 “There is a clear link if the reader knows the content of the guidelines.  I think every website which published the Code should also publish the guidelines, the guide to the external review and have links to appropriate websites. The Code itself should reference these documents and state where and how they can be obtained.”

8. Do you believe the title of this document should be amended to reflect the focus of the Code of Practice on ethical principles and best-practice guidance, and to more clearly indicate the scope of the Code of Practice?: 

Surprisingly, not one respondent addressed the question of the title being more reflective of “ethical principles and best practice”.  Everyone who responded to this question focussed on the second part of the question with unanimous* agreement that there should be some acknowledgement of the relevance of the Code to the use of animals in teaching. 

 It was generally felt that the current title might result in those who do not consider themselves to be scientists, choosing to operate independently of the Code and some felt that this perception would be further exacerbated by the fact that it is clearly an NHMRC publication – leading to the false belief  that it only applies to medical researchers. 

 All respondents to this question made it clear that education or teaching should be incorporated into the title.  Regrettably only a portion of respondents included specific suggestions and of those put forward, some were less descriptive and so have not been included.  Some of potentially suitable suggestions are listed below.  The fact that most respondents did not address this question may indicate a greater degree of satisfaction with the current title than anything more descriptive, but this is just speculation. 

 “The Australian Code of Practice for the Care and Use of Animals in Research and Teaching” (x9)

“The Australian Code of Practice for the Care and Use of Animals in Research and Education” (x4)

“The Australian Code of Practice for the Care and Use of Animals for Scientific Purposes including Research and Teaching” (x1)

“The Australian Code of Practice for the Care and Use of Animals in Science and Education” (x1)

 The important point highlighted in many submissions was the Code now emphasizes the principles for teaching activities involved in Primary, Secondary and Tertiary Education, so the term “Education” or “teaching” needs to be included with Scientific Purpose.    This would ensure that animal use in art classes for example (where there may be less relevant expertise available than in a science class) would clearly be included rather than excluded.  Equally, some might argue that some forms of wildlife survey work or observations studies are not always seen as ‘science’ but it would be far more difficult to argue a case for them not being seen as ‘research’. 

 *One regionally relevant submission made the point that in South Australia, the Code only applies if animals are being used for research or for the teaching of science. This respondent suggested that from the South Australian perspective, it would be good if this were reflected in the title but did acknowledge that such a change would most likely, not be acceptable in other jurisdictions.

9. Is “animal” appropriately defined? Should the definition account for animals at the early stage of their development (i.e. embryonic, fetal and larval forms)? : 

Since the definition of “animal” varies from State to State, it is essential to have a clear definition which can be applied in a consistent manner across the Country.  With the possible exception of a few submissions that referred to the fact that fish are not recognised as animals in some regions of Australia (but did not question their incorporation into the definition in the Code), this definition met with universal support. 

The area which was seen by some as being a bit more contentious was the developmental stage at which animals should be regarded as sensate and come under the Code.  This part of the definition did attract a lot of comment, but in all honesty none of them really argued against the definition in the Code.  All of them focused on the science and essentially showed how an applicant should argue a case for inclusion or exclusion of a larval / foetal form before an AEC.  Each one took a more critical look at when animals become conscious / sensate without considering how this had been covered in the Code, so it may be reasonable to conclude that these comments are more supportive of the current wording than critical of it. 

 

For the sake of openness and transparency, a representative sample of comments received on this topic are provided below.  In this context, “representative” means that duplicate comments have not been included. 

 

“Inclusion of foetuses

I think the time when a foetus is protected by the Code should coincide with the time that it is sufficiently developed to be conscious and feel pain and distress.”

 “According to David Mellor’s presentation at the 2007 ANZCCART Conference held in Melbourne: ‘If we adopt the conservative assumption that conscious wakefulness cannot occur postnatally any earlier than the age at which REM-non-REM differentiation is first evident (i.e. when critical neural connections are made between the thalamus and cerebral cortex), such neurologically immature young normally would not be able to perceive any sensory inputs, including those transmitted in pain pathways, earlier than about 4 days of age in the rabbit, about 7 days in the cat, about 10 days in the rat and mouse, and, possibly depending on the breed, earlier than about 4 to 14 days in the dog (see Ellingson and Rose, 1970). Likewise in pigeon chicks: EEG silence is evident during the first 3 days after hatching, and then there is a slow evolution of the EEG to more mature forms between days 6 and 14 (Ellingson and Rose, 1970).’”

 “In reference to marsupials, this paper also says that These observations suggest that in-pouch tammar wallaby joeys are not able to perceive by the senses or exhibit consciousness, and therefore cannot suffer, during at least the first 120 days after birth, and possibly not until about 150 days.”

 “And in reference to animals which are neurologically well developed at birth: “The newborns in this category include lambs, kids, bovine calves, fawns, foals, piglets and guinea-pig pups (Ellingson and Rose, 1970; Mellor and Gregory, 2003; Mellor and Stafford, 2004; Lee et al., 2005; Mellor et al., 2005; Mellor and Diesch, 2006, 2007). Most published information refers to fetal and newborn lambs and human infants, but sufficient is known about the other species for some cautious inferences to be made about them as well.”

 “Using REM-non-REM differentiation and the establishment of thalamic-cortical connections as primary criteria, the fetal brains of animals that are neurologically mature at birth develop the capacity to support conscious awareness after about 80% of pregnancy has elapsed.”

 “The stage of gestation at which foetal pain should be considered should reflect the time at which the animal is physiologically capable of consciousness. Perhaps refer this issue to David Mellor to determine if his position has changed.”

 Scope of the term animal

The South Australian legislation does not include fish and invertebrates. From the South Australian perspective, it would be more appropriate for the Code to address vertebrates only.  (ANZCCART Note:- Last time we checked, fish were vertebrates so is this just a less obvious way of including them?)

10.Comment is sought regarding the proposal for a Category E membership category for an Animal Ethics Committee to be mandatory for institutions that have or maintain animal breeding or holding facilities. How would the proposed changes work for your AEC?: 

This change has generated quite a bit of comment – as expected.  It has been very interesting to review the feedback we received about this as it would seem that it is generally strongly in favour of the change, but frequently then goes on to question the relevance of it for “our AEC”.  While I have received no dissenting feedback from larger tertiary & research institutions (where the presence of animal breeding or holding facilities puts the matter beyond question), various schools and school related AECs as well as those affiliated with State Government DPI’s and alike have frequently questioned the relevance of Category E members in their situation.  There have also been a few comments about the effects such appointments will have on meeting quora, the relative balance between internal and external AEC members etc. – all of which I felt were addressed within the Code.  However, the fact that these questions have been put forward may indicate that these sections are not clear enough. 

 This is mandated in South Australia for all animal ethics committees. In this context, there have been no difficulties implementing the appointment of such members.  The Category E members all provide extremely useful input to the committees and are invaluable. This has therefore been seen by most respondents as a definite improvement on the current version of the code.

 NOTE:

One respondent interpreted the second part of this question “How would these proposed changes outlined in Section 2.2 work for your Animal Ethics Committee (Animal Ethics Committee)?”in a broader context and included the following rather important perspective:-

An important concern has also been raised with respect to the process of decision making by an AEC.  In previous versions of the Code, there has been a strong emphasis on decision by consensus, but where this cannot be achieved after all the appropriate steps, cooling off periods etc have been tried, there has been provision for a vote to resolve the question(s) (2.2.22 in 7th Edn).  It would seem from 2.3.7 that there is no longer the provision to resolve a deadlock by voting.  While this was not the main issues brought to our attention, the loss of the advice about what steps should be taken along the way to help resolve a deadlocked decision is a source of some concern. 

11. Should the document include a guide regarding the longest duration of approval granted by an Animal Ethics Committee (AEC) for a project before submission of a new application is required? : 

Responses to this question were rather variable and covered the full range of ideals (I suspect largely guided by personal or professional experiences).  Some respondents clearly felt that it would be most appropriate to link the duration of approval to major project milestones such as the tenure of a grant, thereby opening the way to gain approval for up to six years in the first instance for applicants seeking a five year grant.  Others felt that anything over two years (the extent of each appointment to their AEC) would be impractical as members might be asked to approve extensions or modifications to projects they have not seen,  A substantial proportion of responses indicated a high degree of comfort with the more traditional three year limit, but even within this group there was significant variation when it came to questions about time extensions (number and duration requested) etc.  Nobody made mention of the fact that all approvals are still subject to annual review and renewal – irrespective of the duration of initial approval, and this is potentially disappointing, 

 The final and perhaps most sensible collection of responses did not seek to mandate the duration of projects, but took a more creative approach as exemplified by the following response:-

“No, in my view this is a matter for the animal ethics committees to consider in the context of the application, impact on animals and the funding arrangements. Funding providers may be reluctant to fund (for example) a three year research project if AEC approval were only for two years.”

Comment on specific Sections, clauses or sentences of the draft revised Code of Practice
Specific Comments: 
Definitions

These should be presented in alphabetical order so for example, Animal would be listed before animal wellbeing, animal welfare, animal ethics committee, animal carer, etc. 

Consideration of foetuses and eggs should coincide with their physical ability to feel pain and distress, not be an arbitrary decision.

This should be defined and should not be limited to a veterinarian – particularly with respect to schools.

The common English meaning of livestock does not include fish.  I think animals in aquaculture have such difference needs to production animals they should be in a separate section.

A lot of institutions use the term “minor modification”. This reflects the intent of this provision very well. The definition is a change which does not alter the scientific question or educational objective being sought. This is widely considered to be a better definition than animal impact – which can be harder to judge.

Section 1-Introductory paragraph

 If there is one area we could suggest might be further improved, it would be the introductory section.  As we have gone through the submissions we have received as a part of this process, it has become increasingly clear that many people have failed to understand that the Code is really a document that sets the parameters for and empowers an AEC to make decisions on behalf of the community that are consistent with both the law and what we term “best practice”.  The Code is not and cannot be a global rule book that covers every event because the highly diverse range of activities, locations, situations and people involved with the use of animals in research and teaching means that any attempt to achieve this would result in a tome rivalling (if not exceeding) the World Book encyclopaedia. 

 So, if we could make one suggestion to improve the Code and everyone’s understanding of what it is trying to achieve, it would be the inclusion of some clear “guiding principles” statements in the introductory section.  These might include ideals like:-

 This Code provides a framework for the operation of every Australian AEC and recognises that each AEC will face quite unique and occasionally difficult decisions.  This is why the membership of every AEC is designed to be as inclusive as possible of different perspectives and such a high level of importance is placed on both holding meetings in person and ensuring that a quorum of members is present.  While the Code cannot offer a ruling on every question, it does provide you with the framework and guidance required to enable each AEC to make an appropriate and justifiable decision. 

 Researchers, teachers and AEC members must always remember that the use of animals for any purpose is a privilege that can be both awarded and revoked by the AEC.  It is not a right.

Section 1-Clauses 1.1 to 1.5

“Respect” implies veneration. Animals must be managed, provided with appropriate care etc but a requirement to venerate them is inappropriate.

Section 1-Clauses 1.6 to 1.19

1.6 (ii)

Remove the word “all”. It is superfluous

1.6 (iv)

Change “involves the minimal negative impact” to “minimises negative impacts” for simplicity

1.12

Investigators must use scientific and educational methods that accord with current best practice.

  • How do you define or decide “Best Practice”?  Without a clear standard for best practice this could be open to interpretation.
  • Comment: The reference to the Three R’s has been removed. 

1.13 and repeated

The 3R’s are important but they are repeated far too often.

Section 1-Clauses 1.24 to 1.29

1.24

Each project must use no more than the minimum number of animals necessary to achieve the scientific or educational aims and to satisfy good statistical design. The use of too few animals may invalidate the experimental result and result in wastage of animals.

  • Sometimes researchers do not know what is the minimum number of animals required to conduct a project and animal use may result in fewer animals being used than approved. 
  • Suggest that wording be amended to “Each project must aim to use the…”.  This would accommodate wildlife  and fish studies when numbers being surveyed are probably unknown.

1.28

Refers to sharing of tissues and tissue banks.  We suggest that might be expended to include all biological samples e.g. blood/sera.

Section 1-Clauses 1.30 to 1.35

1.32

“Recognized good standards of practice” – another term which needs a guiding document to refer to.

1.33

The revised version places a high importance on “competence” but offers no guidance about how this should be determined or by whom.  Some guidance here might be helpful.

1.3.4 (iv)

‘regularly observe and assess animal’- this could mean weekly or monthly. Need more definition.? Add in “ as appropriate for the species and the procedures being undertaken.”

1.34(v)

 (v)  Change “take prompt action to treat animals with signs of pain and/or distress not anticipated in applications to the AEC” to “take prompt action to treat animals with signs of pain and/or distress unless the pain or distress is essential to the protocol and has been specifically approved in the application to the AEC”.

1.3.4 (vii)

(vii) “Provide prompt notification to the AEC” Please specify a time period e.g within one working day or should this be added into the institution policy. 

1.35

Needs additional clause relating to fate of the animal at the end of the project.

(i)

Clause 1.35 (iv) “best practice” is not defined and should be based on “evidence” for the species and animal use situation.

1.35 (iv) scientific and educational methods used must accord with current best practice.

  • How do you define / decide “Best Practice”? 

 (v) I hate the term “best practice”.  I am frequently unable to do use “best practice treatments” either because they do interfere with the research protocol or the researcher is concerned about creating a variable.  An example is the suturing of a cut.  This does not interfere with the research protocol but creates a variable therefore the researcher insists on the much slower and more labour intensive process of healing.

1.35 (i)

Two issues were raised with regard to this paragraph:

(a)     Wellbeing to many researchers means only freedom from pain and distress. Symptoms such as lethargy and nausea are debilitating but do not fall into the pain and distress category. How can we include these wider but still important symptoms of wellness?

(b)      Clause 1.35 (i) Uses the word must and contradicts the later part of the clause (v) where is says “Some experiments cannot be designed to ensure animal wellbeing as the treatments imposed may themselves test the ability of the animal to cope or perform under different conditions and result in different levels of well being.” See above comments around what “well being” implies.  If projects must be designed to ensure animal well being then clause (v) is redundant.  These types of projects cannot occur as they cannot be designed to meet the requirements of part (i) of this clause.  It is suggested that words such as “as far as possible” or some other qualification could be considered.  The alternative is to separate these types of experiments from others in terms of the obligatory requirements under the code.

Section 2-Clauses 2.1.1 to 2.1.19

2.1.6 (ii)

Institutions must promote compliance with this Code by:

(ii)  nominating a senior individual from the institution to oversee compliance with the Code and must be at a senior level with authority.

  • Define “Senior individual” 
  • Further clarification is required. Is this person intended to perform a Quality Assurance Role or is this the responsibility of the Licence Nominee (as in the case in Victoria) or a Compliance Manager?
  • What are the implications for organisations that oversee more than one institution/facility?

2.1.6 (iii)

(iii) the word “evidence” is used but has not been defined (see earlier comments). “good practice” has not been defined and is inconsistent with “best practice” page 10. Good practice may not be best practice and vice versa. These terms need much clearer definition and needs linkage to “evidence” of physiological and behavioural requirements for the species and use situation, and/or reference to codes of practice related to the species.

2.1.6 (iv)

  (iv) What are suitably qualified and experienced personnel ?  This needs to be linked to AEC approved personnel and some definition of acceptable qualifications and levels of experience.

2.1.7 (ii)

Some institutions have asked why the terms of reference of the AEC must be publicly available.  This has also led to others asking the question If it MUST be available, HOW should it be made available to the public?  This has been a particular issue for some smaller organizations that do not have full public access to their web site for example.  With this in mind, would the word “should” be more appropriate here?

2.1.7(iii)

Institutions must ensure and support the effective operation of the AEC by:

(iii) providing the AEC with an institutional triennial plan for the implementation and resourcing of institutional responsibilities, including goals and strategies for achieving the 3Rs. The institution should, on an annual basis, review its triennial plan, and provide a report to the AEC on outcomes against the plan.

An annual review of an institutions triennial plan and providing a report to the AEC on outcomes against the plan could be cumbersome and may divert the AEC’s attention and resources from its primary duty of the well-being of animals.

How will this fit in with the differences between organisations and their planning processes?  e.g. Govt organisation vs private organisation

2.1.7 (viii)

This section relating to the compulsory appointment of a qualified veterinarian as the AWO in each institution resulted in a lot of comment – both for and against the proposal.  Most feedback received from large, tertiary level institutions (Universities, Research Institutes and alike) seemed to be largely supportive of this idea (although some were more qualified in their support than others), while submissions received from smaller organizations and schools in particular were quite emphatic that the costs of such an appointment would be prohibitive.  In a number of cases relating to schools, there was a suggestion that an existing member of staff be appointed to take on such  a role, in a way that might be compared with other roles in the school such as fire warden, etc.  Typical responses along these lines, are provided below:

 “The increasing trend among Universities in particular to appoint an Animal Welfare Officer (AWO) has been very positive, but we are not sure that such appointments will be practical in all situations and consider the example of schools as being pertinent here.” 

 “I prefer the requirement to have access to veterinary advice and assistance. It is not always necessary to employ a vet (eg schools)”

 “appointment of an officer with veterinary, or other appropriate, qualifications who is authorised by the AEC to ensure that projects are proceeding in compliance with the Code and the decisions of the AEC.

  • Define “appropriate qualifications”.
  • Is this a duplication of the role stated at 2.16 (ii)?
  • How will this be manageable for Institutions that have multiple sites across a wide locality?

 If this role is to oversee compliance, why is it necessary for this person to be a Veterinarian or a person with other appropriate qualifications?”

  “This could be addressed by encouraging these institutions to appoint an AWO Just as they do an OHS Officer or Floor Warden”

 “The (State name) Independent Schools  AEC is of the opinion that schools cannot be expected to appoint an outside authority such as a veterinarian.  We wish to have more information as to what is meant by appropriate qualifications?  It may be better to suggest schools appoint an 'officer' to perform this function from within the school itself.”

 “Would this be resolved by use of different wording – for example use similar wording to that used at 2.1.6(ii) nominating a senior individual from the institution to oversee compliance with the Code, so this could become ….. “appoint a senior member of the school staff to oversee compliance with the Code.”  This circumvents any need or perceived need to specifically employ a veterinarian or other additional person to fill this role, but does require the school to ensure that a member of staff does take on the important task of overseeing animal use.”

 As indicated, a number of submissions from research institutions and Universities were very supportive of this idea and in some cases (which might be associated with existing AWOs) wanted to use this clause to strengthen the role of the AWO.  For example: 

 “The AWO officer should be appointed to every institution which houses and or breeds animals for experimental use hence schools would be exempt. The AWO should at least attend AEC meetings if not be a member (non Voting) of the AEC.”

 “AWO’s should not report to the Facility as conflicts of interest can arise (as in my case- it is not possible to report an issue involving the facility manager when I report to them directly. AWOs should report to the Licence Holder or Nominee or director of Research Services?)”

2.1.9 (ii)

 “certification of competence by AEC”  is good but include a process where skills are acquired during a project – so that the successful attainment of skills is reported back to the AEC (during a specified period?)  Specify regularity at which AEC should monitor competence where necessary. e.g. quarterly.

2.1.9 (iii)

Refer to document which describes “Good practice” such as “the Guidelines”

2.1.9 (iv)

If Vet service is required at an Institution – they should be a member of the AEC and be able to review a protocol before it goes to the AEC as they may have more specialized knowledge of the research team and their skills than the Cat A member on the committee.

2.1.9 (viii)

The purpose of the Code is not occupational health and safety so I don’t think this should be included.

OH & S – add in “best practice” e.g Q fever vaccination is in a guideline at my institution and is not compulsory.

 It is important to include this as it is often the only way to ensure that appropriate safety measures are in place.

2.1.11

It should be up to the institution whether the annual report and external review report are made publicly available. This requirement may detract from the frankness of those reports.

2.1.13 (iv)

The word “work” needs stricter definition and should be restricted to “activities that may impact on animals or animal management or requirements”.  It should not preclude planning or project preparations that do not impact on the animals.

1.1.13   (vi) & (vii)

 

 

 

 

 

 

 

 

 We applaud the concept of ensuring free communication between multiple AECs involved with the administration of a single project.  However, the concept of having AECs formalizing arrangements for oversight of collaborative projects does raise some issues.  For example: Letter of understanding signed by the Chair on behalf of the organization.  What happens if the Chair is independent of the institution?  Will they have the (legal) authority to enter into such agreements on behalf of the institution?

 For projects to be conducted at more than one institution, procedures must be in place to ensure that:

(vii)  letters of understanding are signed by AEC chairpersons on behalf of their respective institutions to  formalise the arrangement.

  • This requirement could have legal ramifications for an institution. The AEC Chair may not necessarily be the person responsible for signing legal documents on behalf of their institution.
  • Organisational governance differs between organisations.  The Chair although senior within the Institution may not have this degree of delegation.
  • This section needs to be amended to reflect that Institutions should have letters of Understanding.

2.1.13 & 2.1.14

Clause 2.1.13. and 2.1.14. These clauses should recognise the need to reduce duplication across institutions, AECs and for PIs. There are an increasing number of national and international collaborations with respect to research and AECs should be required to develop processes for acceptance, reviewing and approval of project applications from other AECs without the requirement for re-writing of proposals into their own formats except for where additional

information is required for decision making purposes.

2.1.15

 Investigators employed by Australian Institutions who wish to use animals overseas must ensure they obtain approval from their AEC for such use.

  • Clarification is required for obtaining approval for “their” AEC for use of animals, i.e. does this mean the overseas AEC or the Australian AEC?

2.1.15 – 2.1.18

Overseas Work: As they apply to work conducted off-shore, statements within this section cannot be deemed enforceable.  We would therefore suggest that these paragraphs need to all be written as “should” rather than “must” statements.  The imperative here is that the authors of the Code need to be mindful of the multitude of situations and circumstances that may be involved with work conducted overseas – particularly with respect to location.  Such work might be conducted under closely controlled circumstances in a laboratory while based in a country with similar rules and regulations to those in force in Australia.  Equally, it may involve field studies or wildlife survey work while researchers are based in a remote part of a third world country and well away from any form of reputable authority. 

Specifically, with regard to 2.1.15, the practicalities, and legalities, of enforcing Australian standards in overseas countries would be questionable.  We suggest that this might be qualified by a statement to the effect that compliance with the standards set by the Code be subject to compliance with all local laws.  This would protect researchers from difficult situations such as a requirement to carry and use some pharmaceutical products in Countries where the possession of such agents may be illegal (as per 2.1.18). 

2.1.18

While I agree that Australians working overseas should comply with the Code, there is no extra-jurisdictional application so I don’t think this can be a must.

Section 2-Clauses 2.2.1 to 2.2.11

2.2.3

If the AEC is directly responsible to the governing body for which it acts, does this limit or potentially remove any level of independence of the AEC?

2.2.4

The Institution must ensure that the AEC membership will allow the committee to fulfill its terms of reference. For institutions that operate or maintain animal facilities, the AEC must comprise at least five persons, one from each of the five categories of membership (A, B, C, D, E). For institutions that do not operate or maintain animal facilities, the AEC must comprise at least four persons, one from each of four categories of membership (A, B, C, D) (see 2.2.14).

  • The appointment of a Category E member may have ramifications on the AEC’s ability to maintain a quorum balance with Category C and D members.
  • How can this be achieved for institutions with facilities at multiple sites?  A suitable person for a Category E role may not have oversight of all facilities; therefore this would require the appointment of multiple Category E members?
  • If the Category E member is listed on an AEC project application then they must declare a conflict of interest and cannot be involved in the discussion, therefore the AEC may not be able to consider the application as they will not have a full quorum.
  • Many AEC’s struggle to co-opt suitable Category C and D members to their Committees.  The mandatory requirement for a Category E may cause problems for AECs to maintain a quorum at meetings if this is a “Must”
  • Although the value of a Category E member is acknowledged, and where workable, to enable AEC’s to operate with a quorum this role should remain optional.

2.2.5

Clause may be warranted around payments to AEC members or AECs for services rendered such that payments should be sufficient to cover costs including sitting fees. They should not be large or generate profit in such a way that payments may create conflict of interest in the consideration for proposals. 

2.2.7

I can see no benefit in the terms of reference, particularly in such detail, being available to the public. The institution should make this decision rather than have it mandated.

 Publically available: what does this mean?  On the Web or provided on request?

 TOR publically available and include the composition of the AEC: this should not include the names of AEC members if they do not wish their names to be published.  This can be a particularly important consideration in smaller communities and potentially stifle AEC effectiveness.

 Protecting AEC members from backlash from Investigators is still inadequate, it stifles AEC effectiveness, especially in small communities.

2.2.11

The wording is convoluted and rather legalistic. Simplify if possible.

Section 2-Clauses 2.2.12 to 2.2.25

2.2.15

(i) Category A member – should they be registered to practice as a vet or just registered as a vet (retiree but not practicing).  How is “current experience defined?

 Cat C – Can we allow Veterinarians who can demonstrate an active role in animal welfare in their work be exempt from being active members of animal welfare organizations?

2.2.15 (ii)

Category B – a suitably qualified person with substantial and recent (i.e. within the last three years) experience in the use of animals for scientific purposes relevant to the institution.  The experience must entail possession of a higher degree in research or equivalent experience.  If the business of the AEC relates to the use of animals for teaching only, a teacher with substantial and current experience may be appointed.

  • “Recent experience” needs to be defined.  Does this refer to recent as in hands on or recent in a position of supervision?
  • “Substantial and current experience” is very general and needs to be defined.
  • The inclusion of “within the last three years”  excludes individuals with long experience in animal research who remain informed about procedures and techniques but may not be directly involved with animal experimentation in the past three years.

2.2.15 (v)

Category E – a person employed by the institution with responsibility for the routine care of animals.

  • The description of the Category E member is very general –what is the intended purpose of the Category E member to the AEC?

 2.2.15 - it seems it will be mandatory to have a Cat E if the institution has animal facilities, and DPI does, so I think we must expand to accommodate the additional member?  This has been talked about for some time, and Cat E's permitted but their membership not mandatory.  It will doubtless be helpful to have the extra expertise/input.  But how does one decide who?

 I welcome the change in committee membership to include a Category E member. This is a change sought by so many at ANZCCART some years ago. It does, however, present a problem in that our committee receives submissions from several institutions, each different in its operation.

 As much as the number on committee will increase I can see no alternative at this stage other than to include Category E members from each of the institutions.

2.2.19

The Chairperson should be an additional appointment to Category A to E members.  Does this mean a committee must be 5 +/- an E?  This is not consistent with earlier sections.

 I don’t think the Chair should be permitted to act as extra category member and have a vote. They should only be a facilitator at meetings. The AWO should be a non voting member and the 1/3 rule for cat D & C should only apply as 1/3 of voting members.  Thus appointing an AWO as a member would not interfere with the 1/3 rule and require more Cat C & D members to be appointed.

 The Chairperson should either hold a senior position in the institution or, if an external appointee, must be given a commitment by the institution to provide the necessary support and authority to carry out the role.  The Chairperson should be an additional appointment to Category A to E members.

  • The appointment of a Chairperson in addition to Category A to E members could cause membership unbalance or quorum issues.

2.2.20

The chairperson must also chair the meetings or in his/her absence, arrange for another member to do so.

In past versions of the Code there has been provision to allow members present to elect  / appoint an acting chairperson to cover the absence of the AEC Chairperson.  Noting that such an appointment would need to be consistent with the principle that dictates that any member present at an AEC meeting can only act in one guise – ie cannot simultaneously serve as a member of more than one category. 

 Would it be simpler to direct every AEC to also appoint a Deputy Chair to cover such absence(s).

2.2.20 (ii)

The Chairperson must:

(ii) oversee the development and promulgation of all written procedures relating to the operation of the AEC to ensure that the AEC and the institution comply with the Code.

The request to have the Chairperson oversee the development and promulgation of all written procedures could be administratively problematic for the individual and in particular, burdens the Chairperson with responsibilities pertaining to the Institution, particularly in the situation when the Chair is an external appointment to the AEC.

2.2.21

The Chair should not generally act as a category member whilst Chairing the meeting.

 The Chair should only be allowed  to fill the role of a Category X member under exceptional circumstances (if at all) where the meeting would not be quorate if the Chair did not also act as an appropriate category member – bearing in mind the need to ensure that the Chair does fulfil the requirement for that category of  membership.  

2.2.24

A person with a conflict of interest may be able to provide very useful insight into the review and deliberations of the committee (eg the principal investigator for a protocol under consideration). I think they could be present for the discussion but not for the decision making process of the committee.

The AEC must develop procedures for the management of conflicts of interest involving members, expert advisors and all persona attending meetings.  Any person with a conflict of interest regarding an activity or project must remove themselves from the review and deliberations of the AEC.

  • Does this mean that the person declaring a conflict of interest must leave the room or can they remain present without being involved in the deliberations? Clarification on “must remove” is required.
Section 2-Clauses 2.2.26 to 2.2.51

2.2.33

In determining the duration of approval for individual projects, AECs should take into account the number of years for which the project is funded, any milestones or stages outlined in the project and any Deeds of Agreement between the institution and the funding bodies.

  • Should there be a maximum time period stated that projects can be approved for?  AECs/Institutions currently set the maximum timeframes that approval can be granted.
  • Within the AEC application information on milestones or funding agreements between institutions and funding bodies are not provided.  The AECs purpose is to determine the ethical use of animals.

2.2.34

We suggest the additions of the following: “including presentation of project proposals by the CI.”

2.2.35

Decisions should be communicated in writing within 10 working days. Or the AEC should indicate the specified time limit on a decision.

2.2.38

Investigators are people too and their rights should be protected. This clause should also include consideration of human welfare and safety and the responsibility of institutions to provide adequate support to PIs. Thus grievance processes must also include experienced and senior persons that were independent of the AEC process or investigator. (i.e. have not been involved in AEC process that is being reviewed).

2.2.39

This clause should include that the governing body of an institution for review of due process must also include experienced and senior persons that were independent of the AEC process or investigator. (i.e. have not been involved in AEC process that is being reviewed).

2.2.40

Add (v) a register of all AEC approved SOPs acceptable for use by investigators.

2.2.43

The word “evidence” is used and should be defined.

2.2.44

Standard Operating Procedures.  Reference to standard operating procedures (SOPs) can facilitate the preparation of applications, but make it more difficult for the AEC to apply rigour to the evaluation of Procedures.  SOP’s should only be referred to under the following conditions:

(iii) SOPs lapse and cannot be used if not reviewed by the AEC within three years.

  • Reviewing SOPs can be an extremely time consuming process for AECs.  Many SOPs remain current regardless of the time between reviewing.  To state that SOPs cannot be used if not reviewed by the AEC within three years is impractical.  A statement that incorporates a review on a basis to be determined by individual AECs would be more appropriate.

 Clause 2.2.44. (iv) SOPS must be available to AEC members and investigators.

2.2.46 (iv)

Include a list of adverse events which have occurred during the project in the annual report.

2.2.47

2.2.47 During the planning of projects, investigators must give particular consideration to activities that are of special ethical concern because of the potential risks to animal well-being and hence require special justification.  These include:

(iii) Re-use and repeated use of animals

  • How is the criteria for re-use and repeated use of animals applied?

2.2.48

Suggest this clause is called Unexpected Adverse Event report. This clause must be crystal clear on whether reports are required for all adverse events, only unexpected adverse events or both. To reduce unnecessary paper work and reporting requirements on projects particularly for extensive agriculture projects, reports on unexpected adverse events only should be required. In other words adverse events foreshadowed in the application and not related to experimental procedures should not need to be reported. See definitions page 3.

Section 2-Clauses 2.3.4 to 2.3.9

2.3.5 (iii)

Remove “any” and replace with “an”  (ANZCCART Note:  Possibly either wording would work)

2.3.7

It would seem from 2.3.7 that there is no longer the provision to resolve a deadlock by voting.  While this was not the main issues brought to our attention, the loss of the advice about what steps should be taken along the way to help resolve a deadlocked decision is a source of some concern. 

Section 2-Clauses 2.3.10 to 2.3.16

Header section above 2.3.10

Monitoring and animal care and use

The AEC monitors animal care and use activities by the inspection of animal housing and laboratories and/or in the review of records and reports

  • Animal housing and laboratories should be replaced with Animal Facilites.  Refer to definition of Animal Facilities

2.3.10

Definition of what is considered “regular” is required.

2.3.12

The requirement to inspect ALL animal hosing and laboratory areas annually is excessive especially for field work and for schools

2.3.15

2.3.15    The AEC must ensure that when detected, activities that are in breach of the Code cease immediately, remedial action is initiated and the requisite reporting occurs.

  • This should automatically apply in major breaches that effect animal welfare.  However, is this appropriate in the case of minor incidences (no adverse welfare effects) of non compliance with the Code? 
  • The degree of non-compliance needs to be defined. 
  • Section 5. of the Code,  Complaints and non-compliance require AEC’s to have procedures for addressing complaints and non compliance therefore this should be covered within the individual AEC’s procedures for dealing with incidences of non-compliance.

 The “cessation of activities immediately” could harm animals and or reduce animal welfare in many projects. Some assessment of the activity and the type of breach of the code is required so that an informed remedial action is taken that also considers the welfare of the animals as the highest priority. An immediate cessation of activity may actually cause more harm than the breach of the code and under some circumstances could result in cruelty or mortalities to the animals concerned. This clause must be revised to consider the safe cessation of activity with due respect given to the welfare of the animals.

Section 2-Clauses 2.4.1 to 2.4.9

2.4.2

This clause is equally applicable to the AEC and it’s members and the institution. The clause could be repeated in the responsibilities for both, see section 2.3 and 2.1.

2.4.4

Environmental enrichment should be mentioned here.

2.4.7

Investigators may act as animal careers during this period provided that they are appropriately trained.

 Remove the words “propose to” in the first sentence.  Investigators should not be responsible for all matters to related to well being of animals prior to the start date of the approved proposal or activity.  Therefore proposing to use animals in an activity should not mean taking responsibility at this point in time.

2.4.8

This section should also include a requirement that AEC approval must be obtained before animals are purchased or bred. 

 2.4.8 Investigators must:

(i) ensure that all persons involved in the use of animals undertake and accept their role and responsibilities in the project. For students undertaking research activities that use animals, this responsibility rests with the student’s supervisor.

  • The statement contradicts itself e.g. ensure that all persons involved understand and accept their role and responsibilities, then states that students responsibilities rest with the students supervisor.
Section 2-Clauses 2.4.10 to 2.4.14

2.4.13 (viii)

Response should not be confined to disease – also to ill-thrift, injury, etc, Change to “respond appropriately to observations”

 The section should also include a statement to the effect that an approved emergency response plan should be in place.

 Overall this section deals with minimizing the negative impacts but provides little direction in improving positive outcomes such as environmental enrichment.

 When an animal is used in isolation, thought should be given to including a second animal as a companion to reduce the negative impacts.

 Would it also be advisable to consult with the AWO /veterinarian before submitting an application to the AEC.

2.4.14

Before submitting an application to the AEC, investigators must ensure that all persons involved in the care and management of animals understand and accept their role and its relationship to that of other personnel involved with the proposed project and have agreed to participate

  • Who does this refer to? 
  • Should this statement relate more to all persons involved in the project?
  • Staff are generally allocated to work on a project and not given the opportunity to decide if they are willing to participate.
Section 2-Clauses 2.4.15 to 2.4.17

2.4.17 (vii)

Is it worth requiring phenotype reports of genetically modified animals in this list?

2.4.17 (viii)

Investigators must provide the following information in the application:

(viii) assessment of the potential negative  impact on animal wellbeing for the duration of the project including:

  (b) identification of all circumstances that are likely to have a negative impact on the wellbeing of an animal and  how such an impact will be minimised.  Experimental and non-experimental factors must be addressed.

  • Clarification on what is meant by “all circumstances” is required, particularly in relation to non-experimental factors.  If this statement was included  in the Code, researchers involved in  Agricultural research projects that utilise animals on farm would need to identify potential negatives impact such as bush fire and flood, extreme weather events, algal blooms, predation (foxes, wild dogs, birds of prey, crows), chemical residues etc.   These circumstances are unpredictable and not in the control of the researcher.
  • The wording under section 3.2.1 (xii) of the current Code is more appropriate.

 (viii) (a) the clause should recognise extensive agricultural research situations where animals may be treated as groups.

 (viii) (b) It is impossible to identify all circumstances that are likely to have negative impact. If this was the case there would be no unexpected adverse events. It is only possible to indentify expected circumstances that have negative impact. It is suggested that all is replaced with expected.

2.4.17 (xi)

 (a). based on the current clause 1.35 these types of experiments cannot occur. Additionally the clause now adds “severe” adverse effects.  Given the vague and circular definitions of adverse event it will be very subjective to judge “severe”.

Section 2-Clauses 2.4.18 to 2.4.37

2.4.19 (v)

Can we specify the meaning of ‘prompt’. E.g. within 1 working day.

2.4.21

Should the monitoring records be kept in the facility where the animals are kept so the AWO or veterinarian can access the records at any time to monitor the welfare of the animals. As stated currently it implies the AEC will be given access if they specifically request to see the records.  Records should be present at all times for inspection.

 Monitoring records agreed with the AEC should be based on the physiological and behavioural requirements for the species and animal use situation. The monitoring methods should be fit for purpose and the method and frequency should minimise impact on well being from the monitoring itself.

2.4.22

Monitoring records should include date, timing and description of animal well being relevant to the method of monitoring which should be based on the physiological and behavioural requirements of the species and animal use situation.  The frequency of monitoring and methods should not need to be repeated in the monitoring records as it has already been detailed in the proposal and collection of the timing, dates and wellbeing descriptions should be sufficient to test compliance against the agreed frequency and method.

 The acceptability of different types of records should be defined. (E.g. electronic, hand written, hard copy check lists.).

2.4.28

It is possible for animals to have a condition requiring treatment such as a wound which does not fall into the categories of “pain” or “distress”. How do we ensure that the researcher is required to provide “best practice” treatment to these animals?  [On a number of occasions now I have been required to provide animals with less than optimal treatments as the researcher claims it will either introduce a “variable” or the treatment interferes with the protocol e.g. carprofen in antibody production.]   Can we legislate to ensure the AWO or veterinarian makes the final decision regarding suitable treatment. The role of the AWO needs to be given more authority to be effective.

2.4.29

 “Standards of good practice” should be defined and based on recognised codes of practice for the species. This clause also uses the word “evidence”.  This requires definition.

2.4.31 & 2.4.32

Nice to have this included so animals don’t sit around for months without being used however can we make this more specific.  If the project is approved for 3 years these sentences will not stop the practice of ordering animals months and months before they are needed. 

2.4.35

This clause should be include reference to intellectual property rights that may reside in collected tissues from and experiment that may prevent sharing of tissues. The same could be said for data and genetic information.

2.4.37

When an animal dies unexpectedly, or is humanely killed due to unforseen complications, investigators should ensure that a necropsy is performed by a person with appropriate qualifications and/or experience and that the AEC is notified promptly.

  • Need to define “should ensure”, does this mean “Must”?
  • Need to define “promptly”.

 This clause needs to differentiate between deaths or euthanasia due to expected adverse events or unexpected adverse events. See definitions. It needs to be clear whether all deaths require necropsy or just unexpected deaths or both. In some projects it is possible to foreshadow deaths due to expected occurrences. For example it is expected that some ewes will suffer lambing difficulty under extensive grazing experiments. Despite care and intervention some lambs will die or have reduced viability at birth as a result and therefore require euthanasia. Under this clause is this unexpected or unforseen and will it require a necropsy?

 Also what is “prompt”?

The AEC should specify the timeliness of reporting and this should relate specifically to the proposal and the physiological and behavioural requirements of the animal and the use situation. Some consideration needs to be given to the level of “promptness” required for unexpected adverse events that are emergencies because they have a large welfare impact affecting multiple animals versus low level expected adverse events only affecting individuals occasionally.

 Please specify the meaning of “prompt” to number of a specific number of working days

Section 2-Clauses 2.4.38

2.4.38 (ii)

What is “prompt”? How is this defined? The AEC should specify the timeliness of reporting and this should relate specifically to the proposal and the physiological and behavioural requirements of the animal and the use situation. Some consideration needs to be given to the level of “promptness” required for unexpected adverse events that are emergencies because they have a large welfare impact affecting multiple animals versus low level expected adverse events only affecting individuals occasionally.

2.4.38 (iii)

Final report on the outcomes should include how the study will improve scientific knowledge and path to impact. e.g. publication of results.

2.4.38 (iv) & (v)

Subsection (iv) is identical to subsection (v). Presumably a typo

2.4.38 (v) Is a repeat of part (iv) above and should be deleted.

Section 2-Clauses 2.4.39 to 2.4.47

2.4.41

Use of privately owned animals:  this section should be reviewed with the context of a researcher going on board a live export ship or monitoring cattle/sheep as they are loaded onto a live export ship.

2.4.43

“Project” should be “Projects”

 Toxicological studies:  Include a stronger statement that although animal testing may be required as the ultimate test of safety and efficacy a full range of in vitro tests must be used prior to the use of animals; animals should be seen as the last test after all appropriate in vitro tests have approved successful.

 Question: - Could a similar statement be made for behavioural studies and the power of supplementing with theoretical models to assist with the 3R’s prior to experimenting on animals?

2.4.44

I feel insufficient is said about the significant negative aspects of cloning.  At the very least a clear indication of negative outcomes should be given; nothing is mentioned here in this paragraph.  

2.4.45

Change to “Xenotransplantaion must be conducted in accordance with relevant legislation and should be undertaken in accordance with guidelines” Compliance with legislation is not optional

2.4.47 (iv)

Prolonged restraint and confinement: consider the use of a companion animal. 

 Provide detailed behavioural data on change of behaviour if no companion is provided.

 Consider making “assessed regularly” a specific period of time because ‘regularly’ could mean once a month or once a year!

2.4.47 (v)

 

The requirements stipulated for nonhuman primates are identical to those for any other animal. The clause is therefore meaningless as it stands.

Section 2-2.5 Introductory paragraphs

2.5

Responsibilities of animal carers

Does this section need to include those involved in capture?

 In situations where investigators are acting as carers, there should again be a proviso that they are appropriately trained to take on this role. 

Section 2-Clauses 2.5.4 to 2.5.22

2.5.4 (iv)

Refer to earlier comments on definitions for “good practice” and “evidence”.

2.5.5 (i)

MONITORING - I think more frequently than 'at least daily' is required.  I think it should be at least twice a day, or dependent on the needs of the animals (perhaps that's the bit that should be added).  If an animal is checked at, say 4pm one day and something occurs to cause them to suffer in the intervening 24 hours, there could be a lengthy period of suffering.

“At least Daily” monitoring is fairly loose and a lot can happen in a day with a sick animal, should a greater frequency be specified?

 The “monitoring and assessment of animals at least daily” is unnecessary for extensive livestock situations and much greater than currently required if managed under current codes of practice such as might be used when following clause 2.5.4. (iv). Furthermore daily monitoring pre-judges the behavioural and physiological needs of the animal and assumes that the monitoring and assessment itself and its frequency has no negative impacts on animal wellbeing. This is unlikely to be the case in different situations and for different species and sub-classes of animal. The level of monitoring should be equivalent to that required under the codes of practice for the species and be based on evidence of the physiological and behavioural requirements for the species with reference to their physiological status and housing/environmental situation.

2.5.5 (iv)

Animal facility manager responsible for ensuring all permits in place- AQIS, OGTR, Wildlife etc.  This puts a big responsibility on the individual knowing the origin etc of all material.  This is of particular concern to livestock and wildlife situations where different AQIS requirements exist compared to lab animals.

2.5.6

Should include that, unless there is a compelling reason why not, all research animals should be held in a central animal holding facility not in individual laboratories.

 

2.5.8

Humane intervention. As a veterinarian I do not have the authority at my institution to perform urgent euthanasia or provide any treatment to an animal– I must consult with the Chair of the AEC or the PVC(R) if I cannot contact researcher or the researcher and I do not agree on the treatment required.  In this paragraph the authority to intervene is given to the animal carer.  Can we have a similar statement somewhere for the AWO or veterinarian? 

Also I think we need to specify a time frame for the researcher to make a decision about treatment or I am the only person who has a researcher taking 3 to 6 hours to confirm that I can treat the animal?

2.5.13

The clause needs to recognise limitations that may be imposed by intellectual property arrangements.

2.5.14

2.5.14 Persons supervising the care, husbandry and health of animals and Biosecurity in facilities must be competent and hold appropriate veterinary qualifications, training and/or experience.

  • This will not be feasible in most institutions.
  • Request remove “hold appropriate veterinary qualifications”

2.5.15

This section needs to recognise that some researchers take more of an animal management role than others who leave it to the animal house staff.

2.5.15 (iv)

This responsibility rests primarily with the researcher

2.5.15 (v)

This responsibility rests primarily with the researcher

2.5.15 (vi)

Ensure the training of all staff:  is this limited to animal facility staff or all staff?

2.5.18 (i)

Veterinary supervision is required but not necessarily always direct supervision.

2.5.18

Animals for which they are responsible: should this relate to all animals in the facility?  This is an important difference as technically, once animals are allocated to a project, the CI assumes ultimate responsibility for those animals and their welfare.

2.5.19

Should there be a requirement or recommendation for sentinel animals?

2.5.21 (ii)

Protective clothing should be expanded to include protective clothing and equipment

2.5.21 & 2.5.22

This clause should be repeated for the responsibilities of institutions in section 2.1. with respect to obligations surrounding OH&S for investigators. Particularly with respect to the provision of resources to achieve these outcomes.

Section 3-Clauses 3.1.1 to 3.1.8

3.1.1

Change “irrespective of the source of the animals” to “irrespective of the source or fate of the animals”

3.1.2

All circumstances with the potential to have an adverse impact on the wellbeing of an animal must be identified and any potential impact minimised, including through the application of the principles of Replacement, Reduction and Refinement (the 3 Rs).

  • Clarification on what is meant by “all circumstances” is required, particularly in relation to non-experimental factors.  If this statement was included  in the Code, researchers involved in  Agricultural research projects that utilise animals on farm would need to identify potential negatives impact such as bush fire and flood, extreme weather events, algal blooms, predation (foxes, wild dogs, birds of prey, crows), chemical residues etc.   These circumstances are unpredictable and not in the control of the researcher.
  • There is no previous reference to the “3Rs” in the draft Code.  If it is not referred to in Section 1, where an explanation of Replacement, Reduction and Refinement are provided.  Why refer to it here?

 It is impossible to identify all circumstances with potential for negative impact.  This needs to be qualified based on expectations for the species requirement.

3.1.6

Refer to early comments on defintions for “good practice” and “evidence”.

Section 3-Clauses 3.2.1 to 3.2.12

3.2.1

It is impossible to indentify all aspects of animal care and use that could have a negative impact on well being. For example it may not be known what the long term impacts or side effects are of a chemical treatment for an animal even though it may be acceptable to administer under current veterinary practice.

Section 3-Clauses 3.3.1 to 3.3.44

3.3.3

Provision of veterinary care and advice.  Should it be compulsory to have a vet or AWO employed on site or just have a vet on call?

3.3.8

(Just above 3.3.8) include species as one of the factors which determines the extent of distress

3.3.16

Could also add age, weight and sex to this list

3.3.18 – 3.3.22

Conditions matching the current 4.4.4 are contained in the sum of 3.3.18 + 3.3.22.  Social and behavioural needs are mentioned in 3.3.18, although not specifically directed to animals in outdoor enclosures.  This could be helped by the addition of 'also' in 3.3.22,  i.e. Animals held outdoors must also be provided with …..

3.3.22

Animals held outdoors must be protected from adverse environmental conditions and predation and where appropriate, provided with access to adequate shelter, food and water.

  • It is disappointing to see that the reference to outdoor housing has been reduced.  The wording under section 4.4.4 of the current code is far more appropriate.
  • The Code needs to provide an expanded section on Outdoor housing as per the sections for Indoor facilities, Pens, cages and containers. 
  • The Code needs to take into account Agricultural research projects that utilise animals on farm and incorporate principles for this area of research.

3.3.27

Grammatically incorrect. “Indoor facilities must have effective ventilation is essential for the comfort …”

3.3.31

Suggest adding ' chemicals used must not be obnoxious to animals in the holding facilities' (to that effect), although there is some reference to this in 3.3.28, above.

3.3.32

Somewhere I would like a recommendation that all rats, unless there is a compelling reason not to do so, are housed in high top cages. Also that cages containing weaner rodents must be designed to prevent their escape or injury (which dome rat cages don’t)

3.3.32 (viii)

Suggest cages, pens etc. should (viii) provide for the behavioural needs of the species.  (rather than 'be compatible' with..)

3.3.41

Somewhere in this section I would like something that toe clipping isn’t acceptable unless there is a clear argument for its necessity

3.3.43

"Invasive identification procedures, if they prove necessary, …."

Section 3-Clauses 3.5.1 to 3.5.11

3.5

3.5 Humane Killing

  • The “NHMRC Guidelines to promote the wellbeing of  animals used for scientific purposes the assessment and alleviation of  pain and distress in research animals” states:

When are humane Killing and Euthanasia used?

The key difference between humane killing and euthanasia is the reason that the animal is being killed.

Humane killing is used:

•  at the end of studies to provide tissues for scientific purposes

•  when animals are no longer used for breeding

•  when stock are not required (eg unsuitable for particular research purpose).

Euthanasia refers to circumstances where:

•  pain, distress or suffering are likely to exceed designated levels and cannot be alleviated promptly (see Section 1.21 of the Code)

•  the health or wellbeing of the animal is grounds for concern.

The draft Code does not refer to euthanasia only Humane Killing.  Given the above definition of Humane Killing and Euthanasia, a reference to Euthanasia should be included in the Code.

3.5.9

See the definition of “animal”. Im not sure that the requirement to ensure death of eggs embryos and foetuses is necessary unless they are mature enough to be conscious of pain or distress.

3.5.11

This should recognise limitations on such practice based on intellectual property restrictions.

Section 3-Clauses 3.7.1 to 3.7.11

3.7.3

If there is a scientific basis for the assertion that “foetuses have comparable requirements for anaesthesia and analgesia as adult animals of the same species” it should be stated.

Section 3-Clauses 3.7.18 to 3.7.26

3.7.26

Uses the term “experimentation” for the first time I think. Change to research for consistency

3.7.18 – 3.7.26

Surgical procedures

  • “Surgical Procedure” needs to be defined
Section 3-Clauses 3.7.29 to 3.7.38

3.7.32

add at end of para "… or be counterproductive for the individual.  

3.7.36

A requirement for “skilled and specialised attention” doesn’t mean anything

3.7.38

Again, this doesn’t really add anything to the requirements already stated.

Section 3-Clauses 3.7.44 to 3.7.55

3.7.44

The potential for negative impacts in the process of cloning is included here, but only in terms of Cloning involving GE.  The debilitating and often lethal outcomes for cloned animals and the dam are not referred to in the reference to non-GE cloning (above).  I think they should be.  (One could perhaps also say this about 'disease models' and 'indication of tumours' although at least in these cases pain/distress is implied and directly or indirectly dealt with.)

 Similar applies to Xeno, although this is dealt with variously in 3 Animal Wellbeing, e.g. application of anaesthesia/analgesia and other measures to reduce pain/rejection.  However, such measures are not applicable in Cloning.  More is needed.

Section 4-Introductory paragraphs

ANZCCART NOTE:  This section elicited a lot of comment from the pre-tertiary education sector.  It was very clear from all submissions received that there was a lot of concern about the disparity between what was included in this draft and what has become increasingly common practice within this sector.  I think it is fair to suggest that the NSW system of devolving responsibility (within the limits of prior AEC Approvals) to school principals and teachers, is being progressively adopted across the Country and there is great concern about both real and perceived differences between this draft Code and that system.  This has been reflected in numerous comments received – a representative sample of which are included in comments pertaining to this section. 

  

This section should be reviewed to ensure that it is not going to conflict with the system of devolved responsibility that has been initially implemented by the NSW Act and Education sector and is being progressively adopted in other States and Territories.  Having established a system that carries appropriate controls and accountability, it would be unwise to over ride it with a system that is unwieldy and potentially unworkable. 

 A major issue for schools has been that the existing code fails to adequately recognize the unique nature of the use of animals in teaching and learning in primary and secondary schools and requires schools to comply with all parts of the code. This has not changed. (Section 4 introduction; “All parts of the Code are applicable to the care and use of animals for any teaching activity”)

 In the existing code, references to schools appear as an afterthought to the major attention paid to the use of animals in tertiary studies and high level research and intervention with the potential for significant distress and trauma to animals.

 Primary schools and the middle years of secondary schools have particularly low level interaction and interventions with animals and the requirement of these schools to comply with the detailed application requirements of section 2.4.17 (as stated in section 4.5.1) is inappropriate and unnecessarily burdensome on schools and the AEC.

 Based on the NSW schools’ AEC model of variable responsibility between the school Principal and the AEC, the [third party information removed] AEC has developed a simple process to assist schools to be compliant with the existing Code while removing the unnecessary administrative burden. This process recognizes that there is a level of responsibility of the school Principal to approve certain low level impact engagement with animals in the classroom such as a pet budgie, rabbit, axolotl or mouse and the engagement of external agencies for demonstrations with animals off site or the use of animals from the Nature Education Centre. This process would now appear not to be acceptable under the new draft Code. It was hoped that this work would be recognized in some way in the new Code by recognizing the differences between schools and research institutions.

 All the comments and feedback from the sector during the consultation process appears to have been ignored in this redrafting.

 There is confusion of definitions in the use of “teaching organizations” (Section2), “teaching institutions” (section 4.2) and “schools”. The introduction to 4.2 seems to imply that while tertiary teaching institutions are covered in 2.1 and 2.2, section 4 has addition compliance requirements (for the primary and secondary schools) that are not necessary compliance requirements in higher learning institutions. This confusion of terms must be addressed.

 The requirements of section 4 for all schools to meet all parts of the Code, creates confusion as to whether schools are “institutions” under the terms of Section 2. If schools are indeed “institutions” the governance arrangements and responsibilities of school Boards for the governance of schools in the non-Government sector would suggest that the existing cross sector AEC arrangements will not meet the requirements of the Code and that schools must individually establish an AEC. This must be clarified.

 Section 4.2.2 changes the acceptable existing code section 6.4.2 to state that “the head of the school is ultimately responsible for all teaching activities involving animals being conducted in compliance with the Code.” This revised statement again reveals a lack of understanding of the governance structures of the Independent and Catholic schools (and probably State schools) as to where ultimate responsibility lies, usually with a school Board or Council or in the case of State schools with the Minister through the Director General. This draft clause is unacceptable in its present form.

 While section 4.2.2 places “ultimate responsibility” on the Head of the school, section 4.3 creates confusion by specifying that “teachers” are responsible for a number of matters. Teachers are required to act within the policies and the directives of the school and school Principal as determined by the school Board. Section 4.3 does not appear to recognize this or the delegated authority of the Principal to teachers.

 While it is reasonable to expect that teachers will abide by the Code the draft Code now has imposed significantly higher demands on teachers than their tertiary research counterparts and removes the opportunity for the Principal to approve certain low level interactions with animals as referred to above and as agreed by the AEC.

 The language of section 4 uses terms such as ‘Teachers must ensure...’ This needs to be modified to a more sensible and practical statement such as ‘...take all reasonable steps...’

 We also note that the teachers in a Tertiary teaching course are not required to keep records of numbers of students and animals in activities as are teachers in primary and secondary school (s4.4.5 and s4.4.10). Given the likely high level interaction at tertiary teaching versus primary and secondary schools this is an unfair and unnecessary imposition on schools and the apparent unfair additional burden on school teachers should be justified before this can be accepted.

 This draft Code is a step backwards for the use and management of animals in primary and secondary schools because of the greatly increased bureaucratic burden being imposed on schools that are consistently demonstrating good practice with animals in the school environment. There is a disturbing lack of understanding of schools, their governance and management in the manner in which this Code is drafted.

 We believe that there is a significant and unnecessary increased burden on schools to report and seek approvals through the AEC that will have the unintended consequence of less rather than greater compliance. The [third party information removed] AEC believes that it has improved compliance by more sensible and reasonable administrative processes for schools introduced in 2010.

 We urge the NHMRC to give appropriate recognition of the work that has been done by the school sectors’ AECs in SA, NSW and other States in reconsideration and redrafting of the sections of the Code that relate to primary and secondary schools.

 Re Teaching activity - I recall there was quite some discussion about this.  I think you are right that education should be included e.g. not all aspects of agricultural education are science based.  However, it may be meant to be understood i.e. implied.  Have a look at the definition of 'teaching activity' on p. 64, that has specific reference to the 'animals in teaching' section - 'education' is mentioned.  If 'education' is added to the initial definition, it may become too broad an interpretation.  See what others think.  I can only think of 'science' based courses e.g. animal and veterinary science, or 'agriculture' that would refer the use of animals to an AEC - which they must do if the activity relates to the curriculum.  However this would mean that 'agriculture' would be the missing term rather than 'education'?  (and we should not forget wildlife studies, but they are generally science-based)  Thinking of the Schools AEC that I am on, the applications come from (quasi) science, or agricultural classes - or occasionally in relation to indeterminate lessons from primary schools!

 Some additional specific questions have been raised in this section.  These include the following:

 1.    Is it necessary for a Schools AEC to include a Category E member when this role is either filled by a teacher or someone working under their direct supervision?

2.     Should there be a blanket ban on the demonstration of humane killing at all levels of secondary education or could this potentially be approved by an AEC under specific conditions?

Section 4-Clauses 4.2.1 to 4.2.5

4.2.3 (ii)

The requirement for a school policy committee and/or animal welfare officer is excessive. Schools have a “focus person” which is sufficient

4.2.3 (ii)

The need for a school policy committee and/or animal welfare officer is unrealistic. Appointment of an Animal Ethics “focus person” is appropriate

4.2.3 (iii) and 4.2.4

The AEC should be developing SOPs rather then each individual school developing guidelines

4.2.3 (v)

I think this could be better worded.  I believe what is meant here is any necessary additional or 'in service' type of training that teachers may need that becomes evident from points (i) - (iv) and in relation to animal 'use' within the school, including their responsibilities under the Code.

Section 4-Clauses 4.3.1 to 4.3.8

4.3.3 (i)

This must allow for the SOP approval system used in SA, NSW and WA

The system of “Pre-approval” (being conditional on the strict adherence to methods and details provided and confirmation within the school itself) as practiced in NSW for many years is being progressively implemented in other States to great effect.  As the standard model of individual application and approval by the AEC has proven unworkable in schools, this system of controlled but devolved responsibility should be encouraged and formally recognised in this section.  This should include reference to the published approvals that form the basis of Category 1 – 3 work.

Section 4-Clauses 4.4.1 to 4.4.5

4.4.2

I think this should be amended to " … legitimate, curriculum linked educational aims …"

 Should there be a blanket ban on the demonstration of humane killing at all levels of secondary education or could this potentially be approved by an AEC under specific conditions? It would be our opinion that none of the objectives at secondary level would require demonstration of humane killing, and a blanket ban should exist.  Given it is not approved to euthanase in front of other animals it is difficult to see any circumstance that would make it appropriate to euthanase in front of students.

4.4.2 (iv)

The issue of external sponsorship should be at the discretion of the school, not prohibited by the Code.

4.4.11

Agree that humane killing must not be undertaken as a demonstration for students – but when it is necessary, it cannot be delayed to avoid students either.

4.4.5

There seems to be a perception among some of the more sceptical (or realistic) members of schools AECs that the inclusion of 4.4.5 is merely setting the Code up for failure as they believe that if this requires anything more detailed than the standard maintenance of class rolls, it will not be done.  Accordingly, they question the value of its inclusion. 

Section 4-Clauses 4.4.6 to 4.4.11

4.4.6

Should there be a blanket ban on the demonstration of humane killing at all levels of secondary education or could this potentially be approved by an AEC under specific conditions? It would be our opinion that none of the objectives at secondary level would require demonstration of humane killing, and a blanket ban should exist.  Given it is not approved to euthanase in front of other animals it is difficult to see any circumstance that would make it appropriate to euthanase in front of students.

4.4.9

“This has some definition issues that need to be clarified otherwise interpretation is very difficult and open to diverse opinion.  What exactly is meant by agricultural extension work?  Is it off school, on farm experience or is it on school extension of the learning outcomes?  What is meant by home property?  Is this a privately owned farm or does it relate to stock held on school grounds?  There is no definition of routine procedures and a more detailed definition of routine husbandry is required.  It may be that there are procedures that are not appropriate to teach. Subsection (ii) and (iii) seem to pretty much cover the same thing.  A clear definition of a 'competent trainer' is necessary?  Does this mean a specific qualification, years of experience or something else?  This needs to be very clear cut or will be open to interpretation and not terribly useful.”

Section 4-Clauses 4.4.12 to 4.4.17

4.4.15

ANZCCART Note:  This paragraph is not new and has been a part of the 7th Edition.  However, it did attract a lot more interest than expected and it was interesting to note that virtually all of the 7 respondents that commented on this section raised virtually identical questions. 

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 on their home property or a licensed veterinary facility

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

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

(iv) the trainer is competent to carry out the procedure

  • Clarification is required for how many students this applies to. 
    • Is this limited to one student?
    • What is the ruling in the case of multiple students?  Multiple students learning to undertake a procedure although a routine management practice in a teaching situation involving multiple students cannot be considered a standard practice. 
    • Further clarification is also required for agricultural extension work.  Where an Extension Officers is demonstration a routine management procedure in a one-on-one situation this is clear, however it is unclear if this applies in a group situation. 
    • The above guidelines leave this area of teaching and extension open to interpretation and needs tighter guidelines.

 “This clause is open to interpretation with regard to training courses on farms around agricultural practices. Some currently AEC approved courses would appear to no longer require approval.”

 “This has some definition issues that need to be clarified otherwise interpretation is very difficult and open to diverse opinion.  What exactly is meant by agricultural extension work?  Is it off school, on farm experience or is it on school extension of the learning outcomes?  What is meant by home property?  Is this a privately owned farm or does it relate to stock held on school grounds?  There is no definition of routine procedures and a more detailed definition of routine husbandry is required.  It may be that there are procedures that are not appropriate to teach. Subsection (ii) and (iii) seem to pretty much cover the same thing.  A clear definition of a 'competent trainer' is necessary?  Does this mean a specific qualification, years of experience or something else?  This needs to be very clear cut or will be open to interpretation and not terribly useful.”

Section 5-Clauses 5.1 to 5.10

5.1 (ii)

These procedures should include codes of conduct surrounding handling of grievances and should include the use of senior and experienced persons independent of the AEC and AEC process in the review. It should not be allowed for members of the AEC to be solely responsible for conducting a review of its processes.

5.4

The AEC must refer irreconcilable differences between it and an investigator to the governing body of the institution for review of the due process.  The ultimate decision after such a review lies with the AEC and must not be overruled.

  • What is the purpose of the governing body review – when would it be used?
  • “The ultimate decision after such review lies with the AEC and must not be overruled”.  If this is the case, why have the review?

 In South Australia an irreconcilable difference between an AEC and researcher is resolved by the Minister and the Minister can overrule an AEC decision

5.5

A serious breach could be one which has no animal welfare implications (eg a change in the location of the research without AEC notification). In this case, the work does not have to be immediately. It must cease if animal welfare is compromised

5.7

The AEC is not a disciplinary committee. It should refer any non-compliance to the institution for appropriate action.

Section 6-Clauses 6.1.1 to 6.1.2

6.3.7

Should not require the AEC to publish the external review report otherwise the reports will be worded in a more careful and less informative manner.

General Comments
General Comments: 

After considering the draft version of the Code, ANZCCART along with our Australian based members and affiliates have formulated the following opinions and submit them for consideration by the relevant individuals, committees and code writing groups.  Being a broad and representative sample of AEC members, researchers, teachers, institutional administrators, veterinarians, animal welfare supporters, government officials and members of the general public, there are a number of areas where the opinions have varied.  In such cases, we have tried to indicate both the diversity of opinion and (where possible) the majority view. 

 Overall, we are very supportive of the changes that have been made to the Code.  Clearly, there has been a great deal of effort devoted to making the Code clearer and easier to work with for all involved.  As a group, we would like to express our sincere thanks to all who have been involved with this process. 

Format of this Submission:

 This submission has been prepared as a collation of comments received from ANZCCART staff and the Board, as well as the broader membership of ANZCCART – defined as members of the ANZCCART Council along with regular attendees of ANZCCART conferences and events.  The aims behind preparing a response in this way were firstly, to encourage participation in this important process but also to offer the various individuals or groups that are associated with ANZCCART the opportunity to participate in an honest, frank, yet anonymous way. 

 In this submission, we have tried to both address the specific questions asked by the NHMRC in the Public Consultation Questions and also the Questions within the Technical Discussion Paper that were part of the Public Consultation Pack.  We have then discussed some of the broader issues in a series of statements and finally addressed a number of specific issues that were raised by our members and affiliates in an accompanying table set out by paragraph number within the Draft Code. 

 As this submission is based on the feedback received from over 40 sources, the perspectives portrayed are many and varied.  While ANZCCART would not necessarily agree with or support every one of the statements included in this submission, we consider it vital to ensure that all submissions received are included in this submission.  Accordingly, we have worked hard to ensure that the specific statements cited in each section do truly represent all opinions offered.  We have not however included every statement as in many cases, the opinions offered were virtually identical in terms of both sentiment and the wording used.  

 General Comments on the Draft Code

ANZCCART is a strong supporter of the Australian Code of Practice for the Care and Use of Animals for Scientific Purposes and we would like to thank everyone that has played a role in the revision of the Code for their efforts and for producing what we are sure will become an excellent replacement for the 7th Edition. 

Overall, the tenure of comments about the draft Code were strongly supportive and in typically Australian fashion, the comments contained in this document are largely critical as we do tend to accept the good parts of things like this and focus more on the problems or perceived problems. 

If there is one area we could suggest might be further improved, it would be the introductory section.  As we have gone through the submissions we have received as a part of this process, it has become increasingly clear that many people have failed to understand that the Code is really a document that sets the parameters for and empowers an AEC to make decisions on behalf of the community that are consistent with both the law and what we term “best practice”.  The Code is not and cannot be a global rule book that covers every event because the highly diverse range of activities, locations, situations and people involved with the use of animals in research and teaching means that any attempt to achieve this would result in a tome rivalling (if not exceeding) the World Book encyclopaedia. 

 So, if we could make one suggestion to improve the Code and everyone’s understanding of what it is trying to achieve, it would be the inclusion of some clear “guiding principles” statements in the introductory section.  These might include ideals like:-

 This Code provides a framework for the operation of every Australian AEC and recognises that each AEC will face quite unique and occasionally difficult decisions.  This is why the membership of every AEC is designed to be as inclusive as possible of different perspectives and such a high level of importance is placed on both holding meetings in person and ensuring that a quorum of members is present.  While the Code cannot offer a ruling on every question, it does provide you with the framework and guidance required to enable each AEC to make an appropriate and justifiable decision. 

 Researchers, teachers and AEC members must always remember that the use of animals for any purpose is a privilege that can be both awarded and revoked by the AEC.  It is not a right.

Page reviewed: 1 March, 2013