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

Personal Details
First Name: 
Last Name: 
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
1. Does the document clearly and concisely set out governing principles?: 


2. Are the terms “should’ and “must” used appropriately in the document?: 

This questions will keep lawyers happy, fat and in fast cars for decades.

3. Does the document clearly and concisely set out, and correctly attribute, responsibilities of all parties involved?: 


4. Does the document provide all relevant parties with sufficient practical guidance on the application of principles of Code of Practice in terms of their responsibilities?: 


5. Should the document include specific guidance regarding the responsibilities of Veterinarians and Animal Welfare Officers?: 

Specific guidance is always useful as it removes debate. However, veterinarians are not exclusive in their ability to understand and make judgements on animal welfare, and many are poorly trained outside of livestock and companion animals. Mandating veterinary supervision of certain procedures would be detrimental to animal welfare where unusual animals (for example fish) are used. Cost is another issue here. veterinarians are expensive. I strongly believe that mandating veterinary involvement will encourage non-compliance (cheating and under-reporting) and drive some research underground or overseas simply for financial reasons. It is important to remember that this Code is about animal welfare, not personal enrichment of professionals. Compliance should be encouraged by making the legislation sufficiently flexible and cost-effective that it is easy and desirable for people to comply and conduct the animal research and teaching here, where welfare and ethics standards are high.

6. As a principles-based document, the impact of the revised Code of Practice may be lost if too much detail is included. Comment is therefore specifically sought on whether there is sufficient balance between principles and detailed guidance.: 

The natural tendancy of committees, regardless of the forum, is to over-think and over-complicate. Lack of detailed guidance can exarcebate this considerably by giving committees flexibility to flex their muscles on trivial matters whilst losing sight of the over-arching principles and purpose of their existence. I would be in favour of careful attention detail in the Code as a way of depowring committees to a point wher they must retain focus.

8. Do you believe the title of this document should be amended to reflect the focus of the Code of Practice on ethical principles and best-practice guidance, and to more clearly indicate the scope of the Code of Practice?: 

The title is adequate

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?: 

Making issues such as this 'mandatory' is a difficult area. For some institutions compliance may be relatively straightforward in terms of achieving a cohort for each AEC. However, for other organisations it may prove difficult, or so onerous as to stifle the ethical review process. I don't think this is an outcome that anyone on any side of the debate wants. It would be better to include guidance on selection of a cohort from a pool of members from differing backgrounds, allowing felixibility in the final make up of any AEC for a particular round thereby improving timely and appropriately balanced review of proposals.

11. Should the document include a guide regarding the longest duration of approval granted by an Animal Ethics Committee (AEC) for a project before submission of a new application is required? : 


Page reviewed: 1 March, 2013