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

Personal Details
First Name: 
Last Name: 
E. Submission
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. I believe that the constant reiteration of the importance of respect is a valuable change.

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


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

Yes, this is very clear.

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?: 


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

I am concerned about the introduction of specific guidance for veterinarians, particular the suggestion that veterinarian oversight could be mandatory for the use of anaesthetics. Veterinarians play an important role in the AEC and are obviously consulted ad hoc for specific welfare concerns. As a medical researcher, I have been trained to use isoflurane as well as ketamine/xylazine in a responsible and informed manner. To mandate veterinarian involvement in this process not only assumes that trained and educated researchers are unable to manage this part of a procedure (yet they are deemed skilled enough in the art to perform complex recovery surgeries and monitor animal welfare on a day to day basis) but it could result in an unfair economic burden on smaller research facilities. Who will pay for the provision of the veterinarian? How much supervision is enough? I perform non-recovery surgeries on up to 12 rats a day - would a vet be expected to sit with me for the entire day? What if other researchers in the facility also needed to perform surgery? What if an animal was found to require emergency surgery on a weekend. Would the animal have to sit and wait for the vet to arrive or would be be compelled to euthanase an animal that ordinarily would have been saved with minimal suffering?

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.: 

The balance of detail seemed appropriate.

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)?: 


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?: 

The title seems to encompass the aims of the Code adequately

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)? : 


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?: 

Our animal ethics committee already has a Category E member. This seems to be an important and valuable role but how will the requirement be managed where an AEC oversees more than one holding and breeding facility? This would necessitate a larger AEC committee with more Category C and D members needed to meet the minimum 1/3 proportion, creating administrative issues.

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? : 

Our AEC has a limit of 1 year approval with a maximum of 2 extensions, meaning that no project can exceed 3 years without submission of a completely new ethics application. This seems a reasonable compromise between administrative burden and the concern that some applications may become outdated. Incorporating a guide for such a requirement is appropriate in my view.

Page reviewed: 1 March, 2013