UK Bioscience sector submission of supplementary evidence to the HoL

In May 2009, the UK Bioscience sector submitted written evidence to the House of Lords European Union Committee, Sub–Committee D (Environment and Agriculture), on the revision of Directive 86/609 on the protection of animals used for scientific purposes. Since that time a number of new developments arose, including the oral evidence sessions and emerging conclusions of the inquiry; meetings between the UK Bioscience sector and the Commission; developments in the Council Working Group and the publication of the full Prognos impact assessment on the Commission website.

As a result of these developments, in September 2009, the UK Bioscience sector prepared a submission of supplementary evidence to the committee. The submission encompasses the views of a number of organisations, including umbrella organisations, that represent academia, industry, SMEs, charities and other research funders in the United Kingdom, all of which will be directly affected by the revision of the Directive.

Organisations supporting this submission:

  • Association of Medical Research Charities (AMRC)
  • BioIndustry Association (BIA)
  • Biotechnology and Biological Sciences Research Council (BBSRC)
  • Institute of Animal Technology (IAT)
  • Laboratory Animals Breeders Association (LABA)
  • Laboratory Animals Science Association (LASA)
  • Medical Research Council (MRC)
  • Society of Biology (SoB) (Bioscience Federation and Institute of Biology)
  • The Academy of Medical Sciences (AMS)
  • The Association of the British Pharmaceutical Industry (ABPI)
  • Understanding Animal Research (UAR)
  • Wellcome Trust

The submission covered the following issues:

  • Public opinion: Calling for a regulatory system that takes into account the fact that there is strong evidence that the public supports balanced regulation
  • International competition: Calling for a revised directive that would not lock the EU into an uncompetitive position
  • Severity classification: Welcoming, along with animal welfare groups, the Commission setting up a workshop to determine appropriate severity classification system for the Directive
  • Care and accommodation standards: Calling for recognition from the Lords of the need for flexible derogations in cases where there is no measurable animal welfare benefit from prescriptive “standards”
  • Restrictions to research on non-human primates: Calling for more clarity on proposed restrictions on the use of NHPs that would facilitate important research whilst excluding unnecessary use of NHPs
  • Animals bred for use in procedures (Article 10): Raising concerns over moving to only F2+ NHPs
  • Authorisation of decisions: Welcoming the Committee’s call for a ‘smooth and timely authorisation procedure’ while calling for specific proposals to incorporate proportionality into the Directive in order to ensure this
  • Alternative Methods: Highlighting that animals are only used when necessary, alongside other methods as appropriate which demonstrates the scientific community’s commitment to developing and using replacement and reduction techniques

 

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