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

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General Comments
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General Comments
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Most of our work is conducted on wild fishes both domestically and internationally. In general, veterinarians have limited (if any) training in handling fishes particularly in field conditions, therefore trained wildlife biologists with training in fish handling are better suited to conduct this work.  We agree that when researchers do not have experience with particular techniques/animals, they should receive training from appropriately experienced people, who in some cases would be veterinarians.  However, once wildlife researchers have the experience, there is no need to have a veterinarian present.  The animal ethics application process asks whether project participants have the required expertise, and if they do not, asks who will provide this training; thus the animal ethics application process ensures that researchers without the appropriate experience do not perform anesthesia and surgical procedures until they are trained.  Requiring a veterinarian to be present during procedures for which researchers are well trained and experienced has the potential to significantly impact on the research productivity of Australian biologists, and this would be particularly true for research involving field work in remote areas.  It is unrealistic to expect that veterinarians be trained to same Occupational Health and Safety levels as a marine wildlife biologist for example (i.e. scientific diver training).

The definition of “animal” should exclude animals at the early stage of their development (i.e. embryonic, fetal and larval forms), particularly larval fish and cephalopods such as octopus and squid. Much of the work of marine biologists and oceanographers that involves taking water or plankton samples tends to sample a huge diversity of organisms from a wide range of taxa. A large proportion of these can include animals at early stages in their development, that is in their embryonic, fetal and larval forms. But because of their small size (often requiring a microscope), the often large numbers (easily 1000’s) collected per sample (including huge numbers of non-vertebrate forms), and the time constraints researchers face in the field, it is often impossible to identify what has been collected until the samples are preserved and brought back to the laboratory to be examined at a later date. Indeed, because so little is known about most these marine organisms, including their identity, it often difficult to identify animals according to broad taxonomic groups. So it can be almost impossible to ensure that fish and cephalopods, for example, have been identified in a sample. Furthermore, many of these taxa have different stages of development and these differ among the different species and thus it is almost impossible to determine whether some of these stages are present in a sample. For example, some of the larval forms of fishes do not even look like a fish, but more like invertebrates – some have elaborate appendages and other structures used to maintain their buoyancy or to protect them from predation. There are no existing sampling methods to date than can separate out fishes and cephalopods larvae from water or plankton sampling devices. Therefore, it is important that fish and cephalopod larvae are excluded as this would halt a wide range of water sampling and plankton work and significantly impact on the research productivity of Australian biologists.

The problem with this proposal is that for an animal ethics committee to be quorate, one third of the members present at the meeting must be from categories C (people independent of the organization with interest in animal welfare and endorsement by an animal welfare organization) and D (people independent of the organization who have never used animals in research or teaching).  It is already very difficult for the university to find Category C and D members for its animal ethics committees given the large time commitment they must make to read all applications and be present at monthly meetings.  The more categories of membership there are for these committees, the more likely it is that the absence of particular C or D members will prevent meetings from achieving the necessary quorum, thus postponing consideration of applications to a subsequent meeting.


Page reviewed: 1 March, 2013