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

ID: 
78
Personal Details
Organisation Name: 
AMREP AEC Governance & Policy Committee
C. Additional Information
Please identify the best term to describe the Organisation: 
Biomedical research institute / organisation
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
5. Should the document include specific guidance regarding the responsibilities of Veterinarians and Animal Welfare Officers?: 

The AMREP AEC GAP Committee strongly believes that it is impractical to require a veterinarian to be always involved in the conduct of surgical procedures and anaesthesia. Many institutes have well trained scientific staff capable of performing surgery and anaesthesia. We believe that as long as the approving AEC has confidence in the skills of the staff nominated as performing the procedures and anaesthesia then attendance of a veterinarian is not needed. Veterinary staff should be involved in the oversight of a care program and may provide training and supervision as required. There are insufficient veterinarians to perform the thousands of procedures undertaken in research and the majority would have fewer skills than those undertaking the procedures currently

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? : 

The AMREP AEC GAP Committee believes that approval duration should not be limited per se. If an experiment or series of experiments run for a number of years and this is described in the AEC submission there is no reason for an arbitrary time limit. The annual report provides protection and a review point in case ethical and best practice has changed over the period. It is important that the AEC retains the ability to determine such factors on a case-by-case basis.

Comment on specific Sections, clauses or sentences of the draft revised Code of Practice
Specific Comments: 
Section 2-Clauses 2.1.1 to 2.1.19

2.1.2 Institutions must ensure through an Animal Ethics Committee (AEC) constituted and functioning in accordance with Section 2.2 and 2.3 and directly responsible to the governing body of the institution, that all activities involving the care and use of animals comply with the Code.

 

2.2.3 The Institution must ensure that the AEC is directly responsible to the governing body of the institution(s) for which it acts.

 

The AMREP AEC GAP Committee supervises two AECs that provide services to multiple licence holders, including a public hospital, two medical research institutes and a university.  Direct responsibility to so many governing councils is impractical. The governing councils should have power to delegate appropriately.

2.1.6 Institutions must promote compliance with this Code by

(ii) nominating a senior individual from the institution to oversee compliance with the Code

 

The AMREP AEC GAP Committee supervises two AECs that provide services to multiple licence holders, including a public hospital, two MRIs and a university.  The requirement to nominate a senior individual from every institute seems unnecessary. Delegation between parties should be allowable.

 

2.1.7 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.

 

It is important that AECs and the related governance functions receive adequate resources. A lot can change in three years. We suggest the alternative of the institution submitting an annual resource support plan that promotes, among other things, achievement of the 3Rs. The plan would be prepared after extensive consultation with the AEC through the chairperson.

Section 6-Introductory paragraph

The AMREP AEC GAP Committee supports an external review; however believes that such a review in Victoria should form part of oversight by the Bureau of Animal Welfare and not constitute an additional exercise.

General Comments
General Comments: 

The comments made in this submission only refer to issues deemed of particular relevance to the AMREP AEC Governance and Policy Committee. Individual institutes and individuals from AMREP will make separate submissions as appropriate. Many elements of the draft code have cost implications for governance and research with questionable links to improvement in animal welfare. Greater cost pressures on researchers through chronic underfunding of research infrastructure may lead to ‘cutting corners’ that could impact on animal welfare. The new code should focus on directing resources to animal care and the 3Rs rather than meeting increasing costs of compliance.

Page reviewed: 1 March, 2013