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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.
Specific issues requiring particular consideration
5. Should the document include specific guidance regarding the responsibilities of Veterinarians and Animal Welfare Officers?: 

Of particular concern is Point 5 of the specific comments which raises the question of “whether some procedures such as anaesthesia and surgery should be performed only by a veterinarian or under the direct supervision of a veterinarian.”  I suggest that broad oversight of a vet at the central level of an AEC or in training programs but not in day-to-day experimentation. In many cases the researcher has more expertise than a vet in a procedure specific to the project.  The system of checks and balances in the code already ensures oversight of projects and that appropriatley qualified personnel are used in the project. Therefore the need for a vet for direct supervision is unnecessary, would overload the system and cause biomedical resaerch to grind to a halt. 

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)? : 

The 2004 and 2011 Code both include a generic statement about different stages of development as follows: 

"Animals at early stages in their development, that is in their embryonic, fetal and larval forms, can experience pain and distress but this occurs at different stages of development in different species and thus decisions as to their welfare should, where possible, be based on evidence of their neurobiological development. As a guide, when embryos, fetuses and larval forms have progressed beyond half the gestation or incubation period of the relevant species, or they become capable of independent feeding, the potential for the experience of pain or distress should be taken into account."

This statement is wise and provides for various possibilities in different species however it does not specifically provide advice to the AEC or researcher as to how such animals deemed to not experience pain or distress should be dealt with. There should be a final and very specific statement that the "AEC need only approve welfare arrangements for animals in their embryonic, fetal and larval forms that are deemed to experience pain or distress".  Such a statement as in section 3.3.77 of the 2004 code, but specifically in regard to this developmental issue, would provide clear direction to the AEC and researcher.

In the 2004 code there were specific guidelines on “Fetal and Embryonic Experimentation” (page 3). Subsection 3.3.77 stated “Eggs must be destroyed before hatching, unless hatching is a requirement of the project. The AEC must approve arrangements made for hatchlings.” This statement provided clear guidance to the AEC on their need to approve experimentation for post-hatching animals.  This guideline removed the administrative burden on both researchers and the AEC for projects involving embryos without a nervous system or with a nervous system too immature for awareness or pain perception.  This guideline also recognized the need to exempt monitoring biological events (such as pre-hatching spontaneous miscarriages, failed impregnation, and non-viable pre-hatching embryos) which would be financially prohibitive, laborious and which would provide no meaningful animal welfare benefits. This guideline alleviated unnecessary monitoring and reporting of pre-hatching embryos in species such as amphibians and fish where observational and interventional experiments (such as fertilisation rates, growth rates, and analysis of gene expression) are conducted on hundreds to thousands of pre-hatching embryos in a single experiment.  Due to the high egg production statistical approaches are needed to estimate pre-hatching embryo numbers and experimental effects rather than counting of the whole population.  

Unfortunately the 2011 Draft Code does not provide any clear statements about “Fetal and embryonic experimentation” which has the potential to lead to unnecessary burdens on the research and administration community. It is recommended that the 2011 Code reincorporate the 2004 guidelines on “Fetal and Embryonic Experimentation” and in particular section 3.3.77.


Page reviewed: 1 March, 2013