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

ID: 
36
Personal Details
Organisation Name: 
Queensland Brain Institute
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?: 

In the Draft Code no mention is made of the obligatory inclusion of a veterinarian in animal surgeries or anaesthetisation. This has been raised as a question during the development of the Draft Code.  Inclusion of veterinarians in the design of experiments, oversight and administration of training, in addition to constituting Category A members of institutional animal ethics committees is acknowledged as appropriate.  Any mandatory direct inclusion of veterinarians for any surgeries, or anaesthetisation, of animals is considered to be impractical.  In a large institution, containing multiple laboratories and teaching facilities, there are too many instances of surgery for veterinarians to be attendant at all of them, i.e. there are not enough veterinarians to go around.  There are insufficient resources to comply with this constraint if included in the Code. If included in the Code it would produce significant delays in project completion and management and could lead to prolonged animal distress if veterinarian's are not available and researchers are not permitted to perform this work.

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?: 

Making Category E membership mandatory may impact our Institute significantly as at present attendance of the OIC of our animal house at AEC meetings is recommended but not mandatory.  This could cause an issue with obtaining a quorum of members for a meeting.  Furthermore, Educational institutions, including primary and high schools that may breed small reptiles, mammals or avian species would also require a teacher to act as a Category E member on an AEC.  This would be impractical for a number of schools, in particular schools located outside major city centres.  This is not clearly defined within the Code, nor the discussion documents.

Comment on specific Sections, clauses or sentences of the draft revised Code of Practice
Specific Comments: 
Section 2-Clauses 2.4.18 to 2.4.37

Necropsy (Section 2.4.37, Page 34): The definition of an appropriately qualified person is left open for interpretation when dealing with the necropsy of animal that underwent an unexpected death (see section 2.4.37 (Page 34). If this is defined by an AEC as a veterinarian only, as opposed to an experienced researcher, there will be considerable delays in determining the cause of death. For example, in some cases there is an obvious cause of death and this would not require a veterinarian to verify the cause of death.  In these situations a veterinarian should not be required.  In other cases, most researchers would welcome the opportunity to consult with a veterinarian on the cause of an unexpected death.

Section 2-Clauses 2.4.18 to 2.4.37

In Section 2.4.20 through to 2.4.22 (Page 32) the record keeping requirements for investigators are outlined. A number of statements are open ended, e.g. “any additional information requested by the AEC.”   An investigator who has complied with all AEC conditions of approval, could be delayed while the AEC requests records and information not listed previously in an approved application, or made public by the AEC.

Section 2-Clauses 2.4.18 to 2.4.37

Necropsy (Section 2.4.37, Page 34)

The definition of an appropriately qualified person is left open for interpretation when dealing with the necropsy of animal that underwent an unexpected death (see section 2.4.37 (Page 34). If this is defined by an AEC as a veterinarian only, as opposed to an experienced researcher, there will be considerable delays in determining the cause of death.  For example, in situations where the cause of death was obvious a veterinarian should not be required.  In other cases most researchers would appreciate veterinarian consultation to determine the cause of an unexpected death.

 

Section 5-Clauses 5.1 to 5.10

In Section 5.4 (Page 71) of the code irreconcilable differences between an AEC and an investigator may be brought before a governing body of the institution. However it then later states in the same section that the ultimate decision lies with the AEC and must not be overruled.  This is ambiguous, as it appears to create an appeal process, if the difference is serious enough, but then power reverts back to the AEC, nullifying the appeal process.

General Comments
General Comments: 

The Queensland Brain Institute is a research intensive institute committed to identifying the causes of neurological diseases and mental illnesses.  Our researchers rely on the use of animals for research into these diseases as well as our investigations into the basic function of the brain.  We submit that the importance of animal research to uncover brain development and function and the causes of disease is not underscored in the current draft code of practice.  It is essential that the importance of animal research to human health be made parmount in this document.  it is the sole purpose for why we use animals in our research.

A more specific comment regarding the use of small animals such as mice and zebrafish is that the draft code does not allow for more flexibility and a faster turn around in the approval of applications.  The code tries to cover all animal species and does not make allowances for animals with faster life-cylces.

Page reviewed: 1 March, 2013