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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.
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.
Specific issues requiring particular consideration
1. Does the document clearly and concisely set out governing principles?: 

Yes, I believe the governing principles are repeated and clearly outlined.

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

Yes, I believe they are.

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

Yes, this is a positive and sensible approach to the presentation of the Code which delineates different parties responsibilities.

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?: 

Yes. Perhaps some definition to describe 'good practice' and 'best practice' as these are used in different contexts within the text would be helpful.

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

Yes, I believe veterinarians should be responsible for oversighting veterinary care programs in scientific activities.

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.: 

I believe the balance between principles and detailed guidance exists in this draft.

7. Is there clear connection between the Code of Practice and the NHMRC Guidelines to promote the wellbeing of animals used for scientific purposes: The assessment and alleviation of pain and distress in research animals (2008) (Wellbeing Guidelines)?: 

Yes, I believe the NHMRC Guidelines are refered to sufficiently

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?: 

Yes, I believe a change to the title to explicity specify its coverage of science, research and teaching is warranted and appropriate.

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)? : 

As a matter of principle I believe that it is appropriate to include ethical consideration of the use of invertebrates or other animals not included in the definition. However the recommendation to take this into account is appropriate until a knowledge of the treatment of invertebrates is more widely known, and their sentience is better understood, and so the practical implications of broadening the definition can be better assessed.

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?: 

I think category E should be a mandatory inclusion to the Animal Ethics Committee. This would mean animal care staff would be exposed to the whole decision making process, and allow a animal care representative to have a formal opportunity to raise concerns or issues as it will directly affect their workload and they may have direct experience with certain species or experiments that could bear on the AEC decision. This also strengthens the continuity of respect for the animals at all levels of decision making.

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? : 

Yes, I think an approval should be time-limited. However that time should be reasonable and may vary depending on the time period planned for the experiment. Generally speaking I would consider a 5 year period appropriate, subject to submission of annual reporting requirements and no adverse incidents that might otherwise require shortening of an approval period. Extended or longitudinal studies, say 25 years, if they exist, should need a formal review period to assess contemporary matters. I believe it would be important that approved research projects should not be changed unless there is a significant change in a contemporary body of information or expert opinions that indicate that continuation of the study without taking into account the new evidence might invalidate the outcomes of the study.

Comment on specific Sections, clauses or sentences of the draft revised Code of Practice
Specific Comments: 
Section 2-Clauses 2.1.1 to 2.1.19


2.1.12 has a typo."Institutions must ensure the conduct (insert)OF  an external review ...."

Section 3-Clauses 3.2.1 to 3.2.12

Typo. 3.2.1  capitalise 'All aspects of animal care....'

Page reviewed: 1 March, 2013