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

ID: 
63
Personal Details
Organisation Name: 
Florey Neuroscience Institutes AEC
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.
Specific issues requiring particular consideration
1. Does the document clearly and concisely set out governing principles?: 

Yes

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

No comment

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

Yes

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?: 

No comment

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

While not stated in the new draft, the NHMRC has raised a serious question in point #5 of the discussion document, namely:

“Should the document include specific guidance regarding the responsibilities of Veterinarians and Animal Welfare Officers? Should the document include a requirement for direct veterinary involvement in the oversight of a veterinary care program and research involving animals including, for example, the conduct of procedures such as anaesthesia and surgery?”

On behalf of the Florey Neuroscience Institutes Animal Ethics Committee I would like to reiterate that our AEC operates with veterinary oversight of all procedures. Indeed, we typically have two qualified veterinarians at each AEC meeting, and the Institute has a consultant vet available on-call if/when necessary. We believe our system is robust and facilitates medical research with a strong emphasis on animal welfare. However, we do not recommend that veterinarians need to be present during anaesthesia and surgery protocols.

We have adopted the principle that if a new and/or complex procedure is being developed, then we may determine that direct veterinary oversight occurs to confirm that the correct procedures are in place. Subsequently, the veterinarian advises the AEC that they are happy for the individuals to undertake the given procedure(s). In addition, we also require that new investigators are trained in anaesthetic and surgical procedures by nominated experts (not necessarily veterinarians though). This latter point is of critical importance, since a scientist who has been performing complex surgery for an extended period of time is usually more skilled than a veterinarian with the specific procedures.

Accordingly, we would be strongly against any measure that would increase the degree of veterinary oversight in circumstances where this would hamper the progress of medical research and also dramatically increase the cost of such research. Nevertheless, as indicated above, we are cognizant of the key role played by veterinarians within an AEC.

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.: 

No comment

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)?: 

Yes

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?: 

No comment

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)? : 

No comment

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?: 

No comment

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? : 

No comment

Page reviewed: 1 March, 2013