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

Personal Details
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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.
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?: 

This would greatly impede research. Research activities within the scope of this suggestion at remote locations and remote labs (e.g. Orpheus Island, Heron Island, One Tree Island, Lizard Island) would cease. Much of the new great advances in our understanding of the ecology of marine organisms has arisen though the application of new electronic tagging technologies. Who could afford to take, pay and feed a vet to accompany a research trip to the Wenlock River to tag critically endangered saw sharks? These data are vital to our effective management of their populations and those of many other marine animals with big eyes and complex nervous systems. These organisms subjected to threatening human impacts cannot be properly managed without these data. Species will be put at risk if this goes ahead and I do not think there is an ethical argument for that.  

For much of the work that we do on wild animals, we as researchers/professional zoologists usually have far more experience with working on these animals, and with the techniques that we usually carry out on these animals, than most veterinarians would have.  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 we 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.

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)? : 

If larval fishes are included in this definition then much of the vital work in oceanography and marine biology will be subject to the Act. Larval fishes are caught in plankton nets, continuous plankton recorders, plankton pumps, which are used to monitor the health of the world's oceans. Moreover the spatial and temporal patchiness of larval fishes (and other plankton) means that the investigator would have no ability to predict numbers to be used. Moreover, the identification of larval fishes is a highly specialised skill and few can do it accurately. We will not know how many we might catch and may not even know what species they area when we get them. Due to the massive mortality that is the norm in fish populations these animals would likely have died anyway. It is far more sensible in terms of fishes to include them under the act when they settle onto their habitat. That is they move from the water column (Larval stages) frequently become characteristically pigmented postlarvae and have a clear developmenta x habitat pathway to adulthood (this deals with the issue of the ethics of maintaining recruitment and ongoing ecosystem services - for example while a study involving teh capture of large numbers of parrotfish from a reef might be ethical in terms of the treatment of the animals removed, their removal might have very negative effects on the health of that coral reef). These fish are beginning to show more complex sensory integration through more complex behaviours and have the potential to contribute to adult populations. 

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?: 

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. 

General Comments
General Comments: 

Why not license us? Set up a Animal Researchers Board of Australia. Set up suitable training syllabi - presumably as part of a postgraduate degree. Use a Yellow and Red card system. Red card and your license is revoked (as it would be for a Vet or Medical Doctor). Two yellow cards and you have your license suspended. This would obviate all these committees and forms. Have awards for best new innovation in animal welfare. 

Page reviewed: 1 March, 2013