A resource to guide you letter writing

By Dr. Olivier Berreville, Humane Education Advisor to Progressive Non-animal Research Society


In addition to growing public and scientific opposition to the use of animals in research,there are requirements – under the Canadian Council on Animal Care (CCAC) – for institutions receiving public funding to refine and reduce their use of animals in research, including by minimizing animal suffering.

While minimizing animal suffering does apply to all levels of suffering (classified under the CCAC as ‘A’ (Experiments on most invertebrates or on live isolates), ‘B’ (Experiments which cause little or no discomfort or stress), ‘C’ (Experiments which cause minor stress or pain of short duration), ‘D’ (Experiments which cause moderate to severe distress or discomfort) and ‘E’ (Procedures which cause severe pain near, at, or above the pain tolerance threshold of un-anesthetized conscious animals), categories D and E (which cause severe suffering) are of the greatest concern.

Avoiding severe suffering will significantly reduce harm to animals. This will help fulfill CCAC’s requirements, reduce ethical concerns and improve the harm-benefit balance. It is also increasingly acknowledged that untreated pain or distress can lead to physiological alterations that increase data variability and the risk of confounding data.

It is time for Canada’s biomedical research institutions to move away from the categories of animal research which inflict severe distress and pain that is at, near, or above the pain tolerance threshold, and become a leader in the use of modern, scientific and humane approaches that are proving more effective and cost-efficient.

It is vital that we re-evaluate the use of animals in research at our institution, seek more effective ways of avoiding or minimizing all unnecessary pain and psychological distress experienced by animals and end experiments involving the highest levels of pain and distress to animals.

Suggested strategic plan to ending severe suffering at your institution:

PNARS proposes below a series of practical steps to enable each such institution to identify ways to reduce, avoid and ultimately end severe animal suffering.  A key principle of this process is an ‘audit’ of procedures to establish how well current refinement practices are working and to identify any areas where further refinement can be applied. Central to the success of such an initiative is also a receptive institutional culture and a robust and challenging ethical review process.

The suggested process is the following:

  1. Perform an in-house ‘severity audit’ of all protocols, procedures and ‘models’ through an independent third party to establish where the potential for severe suffering exists and what the actual severity is that is experienced by individual animals.
  • For procedures where severe suffering occurs, determine:
    • What proportion of animals in each protocol, procedure or ‘model’ experienced severe suffering
    • Why the procedure is used and what factors contribute to it being severe
    • What refinements are already in place, how effective these are and what potential exists for further application of the 3Rs
    • What are the scientific obstacles to ending severe suffering
  • Set out a plan to overcome issues and to end severe suffering using an alternative approach e.g.: Re-framing the research question to avoid a severe model; Using a mechanism-based approach rather than a disease-model approach; etc.
  • Give proper attention to the ethical and scientific requirement that animal research be disallowed wherever a valid alternative exists.

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