https://petition.parliament.uk/petitions/611810
** URGENT CALL TO ACTION **
Vivisection Exposed are working with other groups to help make sure MPs are present at the debate for the above petition. We need your help!
It looks like the petition calling for a ban on commercial breeding for laboratories and to implement reform to approve & use NAMs will achieve the 100k signatures to be considered, once signatures are accepted again. This is a great achievement by everyone involved but there is still more to do!
Please email your MP to let them know about the petition and that you as one of their constituents support it. A template letter and accompanying notes are below, obviously feel fee to personalise how you wish, this is just a suggestion.
If a debate is timetabled we will be asking for a second letter to be sent out but only to MPs known to be supportive of animal welfare issues.
You can find your MP email address here https://members.parliament.uk/members/Commons
Please just add your MP Name and your own name and postcode then cut and paste in an e-Mail to your MP. If any MPs ask for further information please can you let us know so we can help with a response.
Martyn Day of Linlithgow and East Falkirk – we have a ‘special’ letter as he is a member of the petitions committee. Please let us know if you are in his constituency.
COPY & PASTE into a new email………..
Dear MP
I am writing, as one of your constituents, to advise you of a petition that I support and to ask that if it is debated you attend and participate in support of its aims.
https://petition.parliament.uk/petitions/611810
Below are some notes as background to the petition which is to ‘Ban commercial breeding for laboratories. Implement reform to approve & use NAMs.’
Unfortunately, the Government response to the petition comprises standard paragraphs on the use of animals in testing, the actual petition narrative has been ignored.
I would very much appreciate if you could spare time to read these notes and acknowledge receipt of this letter. If you have any questions please contact me and I will arrange a response. I will contact you again if the petition is timetabled for debate.
Yours
(put full name, House Number and Postcode)
The science
Species differences play a major role in holding back medical progress, due to problematic translation of animal results to humans. For example, over 92 per cent of drugs that show promise in animal tests fail to reach the clinic and benefit patients. (Bio, Pharma Intelligence, QLS Advisors. 2020. Clinical Development Success Rates and Contributing Factors) Most of these failures are due to adverse effects and/or lack of efficacy in humans, which were not predicted by results in animal tests.
A 2015 investigation concluded that between 50 and 89 per cent of all preclinical research, is not reproducible, with animal experimentation implicated as a serious problem area. (Freedman LP, Cockburn IM, Simcoe TS. The economics of reproducibility in preclinical research. PLoS Biol. 2015;13(6):e1002165).
GM animals have failed to translate to human biology and or to reflect the human situation being researched in many areas e.g. MS, Cancers, muscular dystrophy, diabetes, neurodegenerative diseases (Alzheimer and Parkinson’s), and more.
Major scientific breakthroughs in disease areas such as diabetes and breast cancer have relied on studies of human disease in patients; they would not have been possible using animal research.
Human diseases are not naturally occurring in the animals used in their research – they are artificially created, and different from the human conditions they attempt to mimic.
Immobile Global Regulator expectation is that two species (rodent and non rodent) will be used for safety/toxicity testing. Yet, it has been shown that tests in dogs and monkeys (Non Human Primates NHP) add negligible weight of evidence to existing probabilities that new drugs might be safe or toxic. Dogs add about only 2% to safety assurances and NHP about 0.4%. In 2021, this meant that around 2400 beagles were killed In Great Britain for a negligible 2% value. (Bailey J, Thew M, Balls M. An analysis of the use of dogs in predicting human toxicology and drug safety. Altern Lab Anim. 2013;41:335–50).
There is formidable evidence to stop using ALL animals immediately/
The Statistics
In 2021 there were 3.06 million scientific procedures involving living animals carried out in Great Britain. This is an increase of 6% on 2020. The use of dogs in procedures has increased by 24% over the last 10 years.
In 2017, additional statistics were published revealing that 1.81 million non-genetically altered (non-GA) animals were bred for scientific procedures but were killed or died without being used in regulated procedures. Assuming a similar ratio this would mean in 2021 another 1.46 million animals were potentially killed without regulated use. The exclusion of this figure means the statistics are very misleading.
Ethics
There is a strong ethical case for replacing animals with modern, innovative methods such as the use of advanced cultures of human cells and tissues, organ-on-a-chip technology and artificial intelligence.
During 2020, there were just 23 Home Office inspectors. This lack of regulatory oversight, combined with the sheer number of animals held in laboratories, means that shocking welfare violations occur.
Sadly, the cruel treatment of animals within laboratories continues under the falsehood that Animals (Scientific Procedures) Act 1986, revised 2012 (ASPA) provides adequate protection to animals.
Financial
In 2019, the UK government’s gross expenditure on research and development (R&D) was £ 38.5 billion. Around 40%, £ 15.4 billion, is spent on basic research which uses many animals and is largely publicly funded. The annual budget of the NC3Rs is around £ 10 million, of which around £ 6.375 million (538 projects, replacement 343), is for NAMS development. This equates to just 0.016%.
The Government must as a policy priority provide funding to improve the human relevance of research, this must be on a scale that reflects the urgency and importance of this issue. This investment would not require new funding but could be diverted from animal-based research that has failed to generate concrete outcomes for patients.
If the Government seizes this opportunity to ensure that the UK plays a leading role in the growing NAMs industry, this will benefit the economy and help to secure our position as a global science superpower. Additionally public, private and charitable funding bodies must redirect funds to non-animal methods.
In the existing animal research paradigm, novel drugs take 10 to 15 years to reach the market at a cost of over £1.5 billion.
NAMS
New Approach Methodologies (NAMs) are new scientific approaches that focus on human biological processes to investigate diseases and potential treatments, using human cells, tissues, organs and existing data.
These human-specific techniques represent BETTER science. They are not hampered by difficulties in translating from one species to another, and so they provide results that are much more human relevant.
Analysis of the Home Office’s non-technical summaries of animal licences granted during the first half of 2020, reveals numerous examples of researchers failing to sufficiently explain their strategy in searching for NAMs. In one case, the question was answered with a single word, and applicants often resorted to simply listing a few non-animal methods which they had dismissed as unsuitable without further explanation. This does NOT constitute evidence of meaningful and rigorous research for NAMs. Additionally, the harm-benefit analysis should take a more critical view of the realistic likelihood of benefit to humans as in reality, the choice made is between an actual harm to animals versus a hypothetical good for humans.
If researchers have always used animals themselves and are working in a field that has historically always used animals, they may be reluctant to consider a change of approach and/or see no benefit (scientific or other) in doing so. There is both habit and entrenched views.
The project proposal is reviewed by the local Animal Welfare Ethical Review Body (AWERB) committee prior to forwarding to the Home Office for final approval. As their review is not made public it is unknown how many, or if any, proposed project are rejected on the basis that the harm to animals outweighs any potential benefit to humans or that they can be replaced with a NAM. What we do know is they are unlikely to be experts in the use of NAMs so inevitably animal procedures will be approved, when non-animal methods exist.
The final approval of a project licence is made by the Home Office. No project applications to conduct experiments on animals were refused permission in 2018 – 2020. An answer is awaited as to when, if ever, an application was last rejected. A recent Freedom of Information Request asked what qualifications member of the licencing team were required to have. The response was: ‘’I can confirm that there is no requirement under ASPA for members of the licensing team to hold medical or veterinary qualifications, or to specialise in non-animal methodologies.’’ This leads us to believe the licencing team can be purely administrative and approval is just a tick box exercise.
We are therefore calling for an independent committee, comprising of specialists in various NAMs, to review project licences prior to Home Office approval. For EVERY proposed (and actual) use of animals – given the time to pull evidence together – they could demonstrate that (a) the odds of the findings in animals being sufficiently and reliably human relevant are slim, and (b) that using human-specific methods would give more reliable, robust results.
A great majority of animal research proposals could be avoided immediately with sufficient, and welcome, critical expert input on the animal research, and constructive expert input on a human-based alternative approach. This could take the form of drawing on a pool of scientists with expertise in specific research areas at some stage in the process. If the government is serious about moving on from, and avoiding, animal use in science, and in doing BETTER science, they would facilitate this.
NAMs are not a choice of an animal or a human loved one they provide an opportunity to use existing SUPERIOR, cutting-edge new approaches that are relevant to humans, not animals.
Often, we are told testing requires a whole biological system but this completely ignores the species differences between systems that actually means we need to do something else entirely.
We believe it is currently ‘scientifically satisfactory’ to replace and/or abandon ALL animal research immediately. Not only are there current NAMs replacements but there is also the opposite which is testing on humans.
Commercial Breeders
ASPA and its Codes of Practice set out minimum guidelines, not best practice.
The creation of animals who are ‘born to suffer’ raises serious ethical and animal welfare issues.
There are two commercial breeding companies in the UK. Both have a well a documented history international animal abuse and yet they are considered by the Animals in Science Regulation Unit (ASRU) to be low risk.
At MBR Acres, a laboratory beagle puppy farm, the dogs are left unattended 20 hours a day at weekends and 16 hours a day during the week. Once the ‘care’ staff have left only security is on-site patrolling the outside areas. Establishment standard condition 4 refers only to ‘adequate care and accommodation’ appropriate to species.
This huge facility at any point in time houses between one to two thousand dogs. These dogs, mans best friend, our family members are known to have sentience, thoughts, feelings and cognition comparable to that of a 3 year old child.
Profits are prioritised over animal welfare. These dogs are never let outside, not because of contamination but because it would mean employing more staff. From the statutory accounts staff numbers have fallen sharply 2021 – 24, 2020 – 25, 2019 – 26, 2018 – 33, 2017 – 41. A veterinary surgeon and care staff should be on site 24/7 this is a basic welfare need.
These dogs are housed in metal sheds which are known to have blue asbestos in the roofing and we do not know if they have air conditioning in the Summer heat. We do not know if the breeding bitches are repeatedly used to produce more stock. We do not know if they suffer alone giving birth during the majority of time when there is no-one to care for them. We do not know how many of the dogs die. We do not know if any are rehomed. The Animals in Science Regulations Unit ignore our concerns, they do not even acknowledge messages.
Envigo have three sites in the UK, the Belton facility has beagles on site. In 2021 an undercover investigation found 5000 beagle dogs and puppies intensively confined to small barren cages at a massive breeding factory in Cumberland Virginia. During the time of the investigation an eyewitness found more than 350 puppies dead among their live litter mates and mothers.
Section 24 the ASPA secrecy clause
Between 01.05.14 – 13.06.14 there was a consultation on the Review of Section 24 of ASPA. According to a 2022 Freedom of Information Request there is no confirmed date for the publication of the findings but it is expected by early Summer. A pressing issue has been the lack of a policy unit to manage this work. Over 8 years waiting for change so that stakeholders can review documents including project licences.
Thank you for taking the time to copy and paste the above into an email to your MP. Your help to get as many MPs as possible to attend the debate will make a difference, we just know it!
Together we are stronger!
