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

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E. Submission
Online Written Submission
Written Submission: 
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.
Comment on specific Sections, clauses or sentences of the draft revised Code of Practice
Specific Comments: 
Section 2-2.5 Introductory paragraphs

I am writing in reference to the request for comments on proposed changes to the Australian code of practice for the care and use of animals for scientific purposes (7th Edition 2004), and specifically with respect to the inquiry regarding a proposed clarification or expansion of the role for veterinarians in performance of experimental procedures. The request for comments that was sent to the public includes the following:

“Comment is invited on whether the document should include specific guidance regarding the

responsibilities of Animal Welfare Officers and veterinarians. Comment is also invited on whether

the document should include a requirement for some procedures such as anaesthesia and surgery to

be performed only by a veterinarian or under the direct supervision of a veterinarian.”


            As a researcher with over 15 years experience with animals in a number of settings, including in the biotechnology industry and in academic research laboratories in Australia, Europe, and the United States, I have had extensive experience with issues surrounding the planning, execution, and follow-on procedures associated with experiments involving vertebrate animals. These have included multiple types of recovery and non-recovery surgical procedures, as well as unexpected situations which have necessitated the involvement veterinarians and veterinary staff to aid in the resolution of complications or side effects resulting from these procedures. In all cases, veterinarians have been involved in the development and planning of studies and of specific experimental procedures, and have been available and accessible to the researchers involved in carrying out experiments, if needed. While I have had many productive interactions with veterinarians and have learned much in the way of specific techniques and pharmacological and anaesthetic regimes from them, I believe that requiring a veterinarian to perform or supervise procedures involving anaesthesia would impose an undue regulatory burden on biomedical research, and furthermore, would be untenable in practice. My specific concerns and reasons for arriving at this conclusion are described in detail below.


1) Requirement for a veterinarian to directly supervise or perform anaesthetic procedures would impose an undue regulatory burden on biomedical research-

            Research involving animals is already among the most tightly regulated occupational activities in developed nations, and in the academic and industrial communities is second only to experiments on human subjects in terms of the regulatory demands, record keeping requirements and capital investments required to sustain it. This is entirely appropriate, and it is completely reasonable to require that researchers obtain prior approval for experimental procedures, and demonstrate that they are properly trained and equipped to perform the experiments they propose. Veterinarians, veterinary staff, and members of the Institutional Ethics Committees are currently an integral part of this process, and in my experience are not in the least bit hesitant to raise issues or concerns with investigators in their purview with regard to ensuring that these conditions are met for all studies. Imposing the additional requirement that these already overworked and de facto volunteers commit further time and resources to being present during every experimental procedure involving anaesthesia would in effect prevent such studies from occurring at all. Furthermore, the positive effect that veterinary personnel exert on biomedical research is magnified when they act as trainers where needed, regulatory and procedural points of contact, and are available for consultation, rather than forcing them to divide their already stretched time between those activities and routine conduct of approved experiments.


2) Requirement for a veterinarian to directly supervise or perform anaesthetic procedures would be untenable in practice-

The [third party information removed] alone currently includes approximately 1740 investigators including 987 academic staff and 753 higher degree by research students (data from [third party information removed] website as of 7 November, 2011), the majority of whom are involved in research affected by the NHMRC Code of Practice. This number does not include research in other faculties or associated research institutes, and even a cursory attempt to estimate the number of accredited veterinarians that would be required to supervise or perform all ongoing and planned experiments involving anaesthesia, or to devise a logistical program which would allow currently employed/affiliated veterinarians to allocate their time effectively for this endeavour reveals the fundamentally unworkable nature of this proposal. There simply are not enough accredited veterinarians available to monitor or perform experimental surgeries on even a fraction of the ongoing projects at this single institution, to say nothing of other universities and institutes across Australia. Moreover, the nature of biomedical research often requires that procedures commence or extend outside of normal working hours, in order to maximise data collection and minimize the number of animals needed to obtain statistically and scientifically reliable data. It is both unreasonable and impractical to expect that accredited veterinarians, for whom research may represent only a small fraction of their professional responsibilities, commit to an effort of this magnitude, given the small marginal return on animal welfare which could be expected from such a change in policy.


3) Requirement for a veterinarian to directly supervise or perform anaesthetic procedures would yield limited benefits with respect to animal welfare, while imposing enormous cost in terms of lost research effort-

            Currently, researchers at all levels who are engaged in animal-related activities are required to undergo training and demonstrate competence on procedures in which they participate, and Chief Investigators on all approved research protocols are required to certify that personnel are properly trained and supervised, and to assume responsibility for the welfare of animals assigned to their protocols. The vast majority of these investigators possess multiple years of experience and have performed the associated procedures, including anaesthesia for restraint and surgery many times. Moreover, in cases where research involves exotic species or wildlife not normally encountered during veterinary training and certification, it is often the case that while a given investigator’s expertise may confined to the population on which his or her research is conducted, that person possesses deeper knowledge of the peculiarities of a model species or organism than a generalist veterinarian might be expected to have. This in no way minimises or invalidates the need for veterinary oversight of animal procedures, but rather indicates that by virtue of many repetitions and years of specialized procedural experience, a doctoral-level biomedical researcher could be reasonably expected to have mastered their experimental model past the point where constant monitoring, or indeed, ceding of practice to a qualified veterinarian who may have less actual practice time on a model species than the researcher, would yield a benefit to the subject animal’s welfare commensurate with the difficulty and cost of implementing such a requirement. This cost would extend not only to the researchers or institute in question, but would be imposed on the general public as a decrease or frank cessation of biomedical research output, which is a key contributor to the general health of Australia’s population, as well as to our strong reputation as an international leader in ethical biomedical research.


For the above reasons, I strongly urge the review panel to reject this proposal as a well-intended, but excessively burdensome and unenforceable requirement, and to maintain the current, effective, and high-value system for veterinary oversight of biomedical research in Australia. Please feel free to use any or all of the above considerations as you see fit, and to contact me should you require any additional information or clarification. Thank you in advance for your consideration of my recommendations.


Page reviewed: 1 March, 2013