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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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Dear Professor Anderson,

RE: Public consultation on proposed revisions to the Australian code of practice for the care and use of animals for scientific purposes, 7th Edition (2004).

I am writing in regard to the public consultation on proposed revisions to the Australian code of practice for the care and use of animals for scientific purposes, 7th Edition (2004).

In particular, I would like to express my concern at item 5 of the discussion document: “Should the document include a requirement for direct veterinary involvement in the oversight of a veterinary care program and research involving animals including, for example, the conduct of procedures such as anaesthesia and surgery.” I advise you that the answer to this question should be a resounding no!

Apparently this issue was raised during the development of the consultation draft as requiring particular consideration. With respect, I suggest that those raising this issue are ill-informed and do not appreciate the extensive training and animal husbandry that is performed by researchers in their animal-based research.

I am an integrative pharmacologist, who has been working in the field since 1982. I am a former NHMRC Fellow (RD Wright Fellow; Research Fellow; Senior Research Fellow) and have had continuous funding from the NHMRC related to animal research since 1993. I am the author of more than 100 scientific publications, and I am also a former Chair and member of standing Animal Ethics Committees at Monash for 7 years. Therefore, I am well placed to comment on this discussion document, particularly since much of my work necessitates anaesthesia and surgical procedures on animals.

I raise 2 points below which clearly indicate why item 5 discussion point should be rejected:

1. Veterinarians are not the only individuals who have skills in anaesthesia and surgery of animals. Like many of my colleagues who have PhDs in animal-related disciplines (pharmacology, physiology, medicine etc), I have been specifically trained in procedures required for anaesthesia and surgery. I now provide such specific training to other staff members including postdocs and PhD students. Indeed, the current ethics guidelines mandate that anyone involved in such procedures receives such specific training. Thus, the current system ensures that all persons performing these procedures receive specific training and such techniques are performed with a high degree of proficiency. Indeed, I would argue that many procedures performed are beyond the competency of a veterinarian- unless they were specifically trained by the researcher!

2. If the requirement set out in item 5 were to come into effect, my research career, and the careers of many who have made significant contributions to the medical research effort in Australia, would be ended. There are simply not enough veterinarians to go around! The issue here, of course, is not my career, but the fact that a large segment of the medical research community in Australia would no longer be able to make the important contribution the make to our nation’s research effort. This proposition would kill the discipline of integrative physiology/pharmacology in this country overnight. The resultant cost to our nation’s health would be immeasurable.

In conclusion, I strongly urge you to reject the proposition set out in item 5 of the Discussion Document.

I cannot identify any anaesthetic or surgical practice in animal research that cannot be carried out to World Best Practice by animal researchers who are properly trained and who adhere to ethical guidelines.

 Yours sincerely


Robert Widdop PhD

[personal details removed]


Page reviewed: 1 March, 2013