Farm Animal Welfare
Council
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Farm Animal Welfare
Council |
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The following is the text of a letter sent to the Head of Research Policy and International Division in the Ministry of Agriculture Fisheries and Food (MAFF), on 26 September 2000MAFF POLICY STATEMENT ON THE USE OF ANIMALS IN RESEARCH Thank you, for your letter of 4 May to Judy MacArthur Clark, Chairman of FAWC, enclosing a first draft of MAFF’s policy statement on the use of animals in research. I am grateful to you for extending the deadline for comments on this document. FAWC welcomes the production of a statement of MAFF’s policies on the use of animals in research. The draft policy statement appears impressive but FAWC has a number of concerns regarding how, in practical terms, this policy will be applied. The following comments refer to the sub headings under section 8 of the document. The Animals (Scientific Procedure) Act 1986Reference is made to "highest standards of animal husbandry and welfare". FAWC would like this to be clarified and believes that MAFF should encourage grant holders to strive to exceed the Home Office Codes of Practice which set out the minimum acceptable standards. The 3 RsFAWC would like to know what "fully committed to the implementation of the 3Rs" means in practical terms. We are concerned that progress often seems to be made on developing the 3Rs but information is not always shared. Funding bodies such as MAFF are centrally placed to be able to collate information about the application of the 3Rs in research programmes and share this with relevant grant holders. Assessment of research proposalsAgain, FAWC would like to know what "great care is taken to ensure the implementation of the 3Rs" actually means in practical terms. Does MAFF have any process in place for the ongoing/retrospective review or evaluations of the benefits versus harms to animals of the research programme it funds, other than those assessments carried out by the home office and ethical review panels? Alternatives to using animals and data sharingFAWC would be interested to know how MAFF encourages data sharing between contractors, particularly in a climate of powerful competitiveness between research groups. FAWCAgain, we should like to know how MAFF "ensures its research contractors are aware of the five freedoms…and that these are applied wherever possible." MAFF Research and Development not covered by the Animals (Scientific Procedure) Act 1986 We would suggest substituting ‘FAWC advice’ for ‘the FAWC code’ in the last sentence. Policy on GM animal researchFAWC would appreciate greater explanation of this policy. For example would MAFF consider funding research into the production of transgenic disease resistant farm animals? FAWC is still awaiting a response from the Minister to its 1998 report on Implications of Cloning for the Welfare of Farmed Livestock which might help throw light on this policy. MAFF Scientific AgenciesFAWC supports the sentiment of this proposal but would like to know how staff are actually made aware of animal welfare issues and best practices. Ethical Review ProcessFAWC believes that it is important to have a wide range of people involved in ERPs in order to avoid the situation of scientists only being judged by other scientists.
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