IAVS releases statement on 2012 Irish Animal Experimentation statistics
The IAVS gives a cautious welcome to the drop in the number of animals used in experiments in Ireland in 2012 - 232,285 – a fall of 32,679 (12.3%) compared with 2011 (264,964). However, this very large number of animals is still much higher than Ireland’s historic standards, for example 64,378 in 2007.
Excessive delay in publication
The IAVS is concerned about the lengthy delay in publishing the statistics. It should not take over a year to go through what is a relatively simple process. Such a lengthy period of time elasped frustrates public accountability as any problems that arise in the statistics cannot be addressed in a timely manner.
6 Certificate Gs – severe, prolonged pain
For example, one of the most disturbing aspects of the statistics is that they reveal that the number of Certificate Gs, which permit the infliction of ‘severe pain that is likely to be prolonged’, issued by the Department of Health tripled to 6. These are highly controversial experiments raising issues of significant public interest. Yet they have effectively been going on in secret for up to a year, denying the public the opportunity to relay their objections to the Department of Health and Irish Medicines Board.
The IAVS’s concerns are exacerbated by the refusal of the Department of Health in late 2012 to publish anonymised licensing documents that would explain precisely how and why they decided to approve these extreme experiments. However, we are hopeful that the Irish Medicines Board will implement the new Directive’s requirements to publish meaningful information about these tests, which is essential for an informed public debate and democratic accountability.
Less animals but higher pain severity?
It is a major concern that the bulk of the 232,285 animals are being tested on in commercial establishments, indicating that financial considerations are overriding animal protection. For instance, the steep increases in recent years have been almost entirely down to extremely severe toxicity tests called Lethal Dose 50% for the sake of Botox and similar cosmetics products.
Given statements by Westport-based Allergan regarding their development of a non-animal test in 2012 to replace the traditional animal LD50 test, we were expecting a more substantial drop. One of the reasons this has not happened is the difficulties in persuading Allergan to agree to share their technology with other Botulinum toxin manufacturers. Unfortunately, narrow commercial considerations have caused thousands of innocent animals to suffer greatly for what is a trivial product.
Overall, the fall in the number of animals subjected to experiments is offset to some extent by the apparent increase in severity as evidence by the rise in number of Certificate Gs. Furthermore, there was an increase in the number of rats (+2,136 to 12,612), guinea pigs (+938 to 1,483), rabbits (+383 to 1,098), cats (+65 to 185), dogs (+224 to 697) and ‘other mammals’ (+275 to 755) who were subjected to experiments without any anaesthesia. Meanwhile the number of animals experimented on under full anaesthesia dropped from 25,698 to just 9,846. So the overall levels of animal harm (numbers multiplied by pain severity) would appear to be pretty constant. This is a matter of enormous ethical discomfort and demands a new more rigorous approach to regulation and the promotion of non-animal replacement test methods.
Setting aside issues around average severity, the IAVS does welcome the falls in animals used in in fundamental research and ‘education and training’. We regard these as among the most unnecessary and legally dubious experiments as any predicted benefits are inherently uncertain and/or trivial. We are also pleased to see a fall in the number of animals bred with genetic defects and mutations. Many of these animals will have been deliberately engineered to suffer from painful and debilitating diseases.
The small reduction - 29,689 to 28,706 - in the number of animals used at universities and colleges is also positive, but we strongly encourage these establishments to strive harder to achieve more significant steps both in terms of numbers of animals spared and bearing down on experimental severity.
The point of publishing statistics is to inform the public about how the Government is honouring its regulatory responsibilities in the field of animal research. It is therefore hugely frustrating to see significant proportions of experiments outside the informative categories and lumped under ‘other’ instead, as well as blatant miscategorisations.
For example, in Table 3 which covers toxicology experiments, virtually all of the 170,000 tests listed are listed as being for the sake of ‘other products’, when it is highly likely that most of these experiments are for cosmetic botulinum toxin products. Clearly these would be more accurately listed under column 3.6 which relates to cosmetics. This is tantamount to misinformation that provides a sanitised impression of the reality of animal experimentation in Ireland.
Table 3 is linked with Table 8, but here the same ‘botox’-type poisoning tests are now under the medicines category, which is even more misleading. The IAVS urges the Department of Health to recall the statistics and sort this mess out. A serious question mark has to be placed over the potential inaccuracy of returns supplied by animal research licence holders: have they provided false information to the Department of Health on occasions and hence committed an offence under Section 5E (1)(b) of the regulations in force at the time (SI 566 (2002))? We urge the Department of Health to initiate an investigation.