The amended Animals (Scientific Procedures) Act 1986 (ASPA) came into force on 1 January 2013, in compliance with the requirements of Directive 2010/63/EU on the protection of animals used for scientific purposes, amid a flood of rhetoric about the uniquely high standards of laboratory animal care and use in the UK.
A few weeks later, the British Union for the Abolition of Vivisection (BUAV) sent Imperial College London a dossier containing allegations about what were claimed to be a wide range of infringements of the ASPA at the College. The Home Office, which is the government department responsible for the administration of the ASPA, immediately began an enquiry, and Imperial College, to its great credit, set up its own enquiry, by an independent committee, under the chairmanship of Professor Steve Brown, Director of the Medical Research Council’s Mammalian Genetics Unit at Harwell.
The remit of the committee was “not to investigate the specific allegations made by the BUAV”, but “to undertake a broad and detailed examination of all aspects of animal experimentation at the College facilities”. The committee interviewed a wide range of personnel, obtained a large number of documents, and visited the facility that was the focus of the BUAV’s allegations, and concentrated its deliberations on four areas: a) the Animal Welfare and Ethical Review Body (AWERB) process; b) the operations of the Central Biomedical Services (CBS); c) training and competency assessment; and d)culture, leadership and management.
On 10 December 2013, the committee produced a severely critical 38-page report,1 in which it concluded that the College’s animal research facilities are understaffed, under-resourced, and operating without adequate systems for training, supervision, management and ethical review.
The AWERB process was considered to be “not fit for purpose” and in need of “wholesale reform”, and required “a new senior administrative appointment … to manage the process”. The committee found the facilities to be “well equipped”, with “a high quality of animal husbandry”, but there was room for considerable improvement “in terms of operational structures and standards, communication and working practices, as well as the mechanisms for reporting animal welfare concerns”, which would “have a substantive impact upon animal welfare and the Three Rs”. However, “the provision for training, supervision and competency assessment” was “ad hoc”, with “little evidence of effective mechanisms for sharing information and best practice”. They found “a strong emphasis on process and procedural issues to the detriment of focus on improvements in the Three Rs”, with “relatively limited opportunities for interactions that bring together and promote ideas and developments for the Three Rs between diverse groups”, and that, “overall, a culture of whole teams working together was lacking”.
The committee made 33 recommendations, and emphasised the need for “a clear restatement of the key role of the Named Veterinary Surgeon (NVS) and the Named Animal Care and Welfare Officer in animal welfare and the Three Rs, along with a clear route for escalation of concerns to the AWERB”. Again to its credit, the College “accepted all the recommendations”, admitted that there was “significant scope for improvement”, and said that it “will now move quickly to implement the recommendations”.2 The need for this investigation leads to two important questions. First, why was such a situation allowed to develop at Imperial College, one of the world’s most prestigious universities? Why were the Certificate Holder, the senior academics, the project and personal licence holders, the NVS, the Home Office Inspector and others, not performing their duties up to even the minimal standards required of them?
The second question, is that: if this situation could be allowed to develop at Imperial College, in what other institutions do similar problems exist and are similarly low standards considered acceptable? Professor Paul Flecknell, a member of the committee and director of the research animal facilities at Newcastle University, said that, while the report was specific to Imperial College, “every institution will pick up something we’ve said and think, ‘we should take more note of that’ ”.3 The Home Office, and the equivalent authorities in other countries, should insist that they do just that.
1 Anon. (2013). Independent Investigation into Animal Research at Imperial College London, 38pp. London, UK: Imperial College. Available at: http://brownreportinfo/wp-content/uploads/2013/12/Brown-Report-Final-EMBARGOED-0001GMT-10-12-132.pdf.
2 Jones, J-P. (2013). Imperial responds to animal research investigation report. London, UK: Imperial College. Available at: http://www3.imperial.ac.uk/newsandeventspggrp/imperialcollege/newssummary/news_9-12-2013-18-21-18.
3 Cressey, D. (2013). Report slams university’s animal research. Nature News, 10 December 2013. Available at: http://www.nature.com/news/report-slams-universitys-animal-research-1.14329.