We review the Home Office's records and assess trends and actions Our comments are coloured by experience of commercial practices with consequent issues common to DEFRA and the Home Office. We seek corresponding consistency and rigour at the higher level with the minimum of exclusions arising from differences of species or purpose.
We draw to your attention the responsibilities of DEFRA, the Meat Hygiene Service, and the Food Standards Agency in the origins, traceability, transportation, breeding and rearing, methods of culling, “humane” killing and disposal, for which statistics of cruelty are not kept or are not easily available to the public: DOAs (dead on arrival) are significant indicators whether the animals are destined for a slaughterhouse or for a laboratory.
Further, birds kept for the production of fertile eggs in the manufacture of vaccines must be kept in cages which will need special consideration when European initiatives in replacing such systems come into force.
Two factors are arising for consolidation and comparison with information reported from procedures included in the Home Office statistics.
DEFRA’s efforts at launching an integrated Act of animal welfare regulations, coupled with the many exercises in research and genetics ensuing upon the BSE and foot-and-mouth epidemics and outbreaks of other viral diseases, are yielding data on culls, mortality, production and fertility investigations and the measured consequences derived in veterinary and medical contexts from experimentation and monitoring. With or without artificial insemination the effects of breeding tricks in terms of dystokia, metabolic disorders, and yields and output have been reported and are available for collation and comparison against the results obtained by GM technology. Data are also available for collation on factors involved in feeding trials in breeds of athletic animals such as horses and dogs, especially greyhounds, and in endocrinological disturbances measured in yields, calving intervals, and fecundity and fertility in cattle. Sheep have received similar attention.
Collation of statistics must also anticipate the effects of the European Union’s REACH program, in which test for “safety” are proposed for exposures to as many as 30,000 commonly-experienced chemicals. We can find no proposals for batteries of tests for these purposes nor for the involvement of animals nor for the form in which they would be exposed to the challenges. It is time now for analyses of existing statistics and translation for all parties to assess in contemplation or rejection of the REACH program.
There follow answers to your questions:
A. We concur with the objectives identified, as the foregoing observations indicate. Restriction on the use of wild-caught animals must be powerfully enforced on grounds grounds of unsuitability due to aggravated distress, variability and transmission of exotic infections.
B. No exemptions from the Home Office Statistics on GM animals should be permitted.
C. The competence of veterinarians and animal behaviourists is at the moment inadequate to remove any of these constructed beings from the provisions of the Act.
D. The New Zealand gradings of manipulations are useful, except that no procedures in the C and X categories should be permitted. (The definition of C – “manipulations that cause severe stress or pain which cannot be alleviated because of needs to achieve the purpose of experiment. Suffering is probable” – is inadequate: unalleviated stress or pain connotes suffering).
E. Our foregoing remarks deal with this question and the need for traceability. The MHS has had to admit that foetal calves may be “born” when the cow is slaughtered and that death may occur by drowning rather than by the accepted methods of bleeding out or electrocution adopted in slaughterhouses (which are, anyway, unlikely to rate as “humane” for animals covered under the Home Office’s regulations.
F. Full descriptions of species should be published, but summaries might use generic terms, with references to comprehensive data in annexes. In addition, conservation efforts should not have to compete with the demands of dubious procedures, and the use of endangered species should not be permitted.
G. Our earlier remarks deal with sources of animals and the purposes for their use, as well as with the risks of double-counting. Indistinct divisions (e.g. of “biological” and “medical” purport) must be avoided and indications of significance in specific diseases must entertain the possibility of relevance to other disorders in a family the research might comprehend. The regulations must include plans for the nursing of recovering animals and definition of means of “immediately” killing “by a humane method”.
H. An edited version should be available, as well as annexes of detailed data and footnotes. The edited version should include a commentary. Analyses in the style of the MHS’s would be valuable, e.g. with data for individual institutions and WASs (i.e. welfare assessment scores analogous to the MHS’s HASs – hygiene assessment scores). The information must also include reports on prosecutions and miscarriages of control and accidents and face the full force of an open debate on the contentious issues the public must face, in the hope that all factions can contribute their best for the welfare of the animals caught in the workings of ugly science. The openness we call for should allow local councils visits by representatives they nominate to premises used for scientific procedures on animals, as well as those used for breeding and rearing such animals (and similar local rights could be applied to farming units and slaughterhouses). It is not difficult these days for unauthorised entry and reporting to be achieved and, regrettably, to come upon abuses and cruelty that all the might of official controls and masses of statistics had failed to prevent. Advocates of the 3 Rs must be invited to on-site assessments of the resort to painful procedures and into constructive debate in alternatives that would allay avoidable local misgivings over suspect evils.
I. Records should be included in the Home Office statistics of experiments and test on animals commissioned in countries outside the UK by British companies and institutions. The details should include names of authorising bodies and the degree of control and compliance with Home Office regulations.