Category Archives: Public health

The new NHMRC Corporate Plan – a missed opportunity

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Source: Flickr/ Igor Spasic

As more and more researchers point to the inadequacy of using animal models to study human conditions, Australia’s National Health and Medical Research Council (NHMRC) – the major funder of biomedical research – still does not seem to make any moves towards encouraging more human-relevant research.

The NHMRC’s Corporate Plan 2018-2019 has just been published. From the NHMRC website:

The NHMRC Corporate Plan 2018–2019 covers the period 2018–19 to 2021–22. It identifies the major health issues for this period, how we will deal with these issues and a strategy for medical research and public health research, in line with the requirements of the NHMRC Act. It also describes NHMRC’s purposes, planned activities and performance measures for the period and addresses our capability, environment and risk oversight and management.

The Plan does not touch on the transition from outdated animal research to human-relevant research. While “advances in technology” and “engagement with industry and support of innovation” are mentioned in the section on “NHMRC’s environment”, the strategy to dealing with this “risk” is limited to “timely and effective leveraging of advanced technology to reduce the burden on applicants and assessors and enable reporting on the return on investment in health and medical research.”

Animal studies do not predict adequately what will happen in humans. Many research “breakthroughs” observed in animals do not translate to clinical trials with humans and into medical practice. However, this is not acknowledged in the Plan, which includes a section on research translation. (The NHMRC does fund several research and translation centres)

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Source: Flickr/ National Center for Advancing Translational Sciences. Neurovascular Unit-on-a-chip

The value of animal experiments for predicting the effectiveness of treatment strategies in clinical trials has remained controversial, mainly because of a recurrent failure of interventions apparently promising in animal models to translate to the clinic. (van der Worp et al., 2010)

Following target discovery, as much as 90% of novel medications fail to make their way through the different phases of clinical trial to approval. The majority fail to pass at phase II – the transition through proof of concept to large scale trial at Phase III (Cook et al., 2014; Perrin, 2014; DiMasi et al., 2016). Many critics attribute this high rate of attrition to the models on which the targets are discovered – usually laboratory rodents; the argument being that the differences between animal models and human disease are too great to be able to draw valid conclusions between them. In other words, targets derived from animal models are not suitable for use in clinical populations, and hence fail at trial. (Perry & Lawrence 2017)

The lack of leadership is disappointing. Other countries’ government agencies are more proactive. For example:

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Source: Flickr/ National Center for Advancing Translational Sciences. Growing mini-brains in a dish.

Indeed, in the past few years, a substantial number of research grants have been invested in organ-on-a-chip projects from the National Institute of Health (NIH), the Food and Drug Administration (FDA), and the Defense Advanced Research Projects Agency (DARPA) in the USA, from Framework Program 7 (FP7) in the EU, and from Japan Agency for Medical Research and Development (AMED) in Japan. This investment also shows the magnitude of expectations for research related to organ-on-a-chip technology. (Kimura, 2018)

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Source: Flickr/ National Center for Advancing Translational Sciences. This illustration highlights some of the tissue and organ systems that scientists in NCATS’ Tissue Chip for Drug Screening program are working on.

It’s disappointing that we are not pulling our weight in contributing to innovative biomedical research, that Australia is lagging behind comparable countries. It’s disappointing that a good proportion of public funds are wasted on ineffective research. It’s disappointing that, as a consequence, patients are not seeing the treatments and cures that are missed because our scientists study the wrong species. Actually, the latter is more than disappointing. It’s infuriating.

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Good news from Brussels for cats, dogs and primates of all kinds

The Netherlands were first with their plan for a transition to non- animal research. Now the Brussels-Capital Region, one of three regions in Belgium, has announced a ban on experiments on dogs, cats and non-human primates:

From 1st January 2020, experiments involving dogs, cats and primates will be forbidden in the Brussels-Capital Region. Not only will tests on dogs, cats and primates no longer be allowed, from 1st January 2025 animal experiments will also be prohibited in education and in safety tests except in cases where no alternatives are available and the tests are deemed absolutely necessary.

This is great news, and it shows it’s possible to phase out animal research. Of course, animal testing on cosmetics has already been banned in the 28 European Union countries, as well as in Norway, India and Israel. Several other countries are considering a ban.

Phasing out animal experimentation is not only possible, it is also necessary because the results vary for different species, strains and sexes. Transferability from animal to human studies can’t be assumed.

A recent news item illustrates this: 11 babies died after their mothers were given a Viagra-like drug during pregnancy. The women were part of a drug trial in the Netherlands that tested whether the drug sildenafil citrate could help boost the growth of the baby. Sildenafil had been tested on several animal species, including mice, rats, rabbits and dogs, and the authors of a systematic review concluded that:

… no teratogenic or fetotoxic effects of sildenafil have been reported in experimental animal models at dose levels much higher than those used in humans.

The review also included reports about a small number of pregnant women who were treated with sildenafil as a treatment for premature delivery. The efficacy of sildenafil was reported as “limited” and “conflicting”.

Meanwhile, a Queensland study using sildenafil on pregnant women has been temporarily halted. The Queensland study is different to the study in the Netherlands, and so far has no negative outcomes.

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Leo, a former “tool for research”. Source: Humane Research Australia

But back to the “good” news. Phasing out animal research depends on the availability of non-animal, human-relevant methods and technologies.

This month, researchers from the Johns Hopkins University demonstrated that artificial intelligence is more accurate than animal testing in spotting toxic chemicals. Professor Thomas Hartung, one the researchers, wrote:

… we have now developed a computer method of testing chemicals that could save more than a US$1 billion annually and more than 2 million animals. Especially in times where the government is rolling back regulations on the chemical industry, new methods to identify dangerous substances are critical for human and environmental health.

Hartung’s research group found that chemicals that are known to be toxic in humans are only proven so in about 70 % of repeated animal tests. The new computer software, however, identified toxic substances in 89% of 48,000 (toxic) chemicals that were tested.

Another area where fast progress is being made is organs-on-chips. The organs-on-chips market is expected to grow rapidly: from US $9.6 million in 2017 to US $45.6 million by 2022. (see also previous blog post from 25/04/2017)

Animal research is an inaccurate “science”, and better, human-relevant methods and technologies have been and are being developed. Which country or jurisdiction will be next to start phasing out animal research?

 

 

Animal agriculture – a taxing problem

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Source: Flickr / Brian Hart

The Guardian today published an article about a “green taxation shift” in Norway. Via taxation and other incentives, the Norwegian government encourages its citizens to switch to electric cars. Electric cars do not attract import tax and VAT, are subject to a reduced road tax (which will go down to zero next year), and owners of electric cars do not have to pay road tolls, ferry fees and city emission charges. They don’t pay for parking and can bypass traffic by driving in some bus lanes. To top it off, running costs are lower because in Norway electricity is cheaper than petrol and diesel.

These incentives have resulted in nearly a third of new cars being electric cars, and this proportion is expected to rise to 40% next year. What a great set of policies to nudge people towards more sustainable driving, and for the government to meet its greenhouse gas emissions targets.

But what about the foregone revenue? A politician commented:

Of course the government needs its revenue. But this is part of what we call a green tax shift. You have to tax what you want less of, and promote what you want more of.

Exactly. That’s what I would expect a rational government to do.

With animal agriculture accounting for more greenhouse gas emissions than the global transport sector – including ALL modes of transport, such as cars, motorcycles, trucks, trains, ships, aircraft – wouldn’t it be a rational move to tax meat and other animal products to reduce their vast contribution to climate change?

Research by Chatham House found that it will not be possible to limit temperature rises to below the “danger level” of 2°C if “livestock” production and consumption are not reduced.

 … adopting global dietary guidelines with lower meat consumption would cut food-related emissions by 29%, vegetarian diets by 63%, and vegan diets by 70%

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Source: Flickr / Like_the_Grand_Canyon

Governments in Denmark, Germany, China and Sweden have reportedly discussed creating animal product related taxes in the past two years. An added benefit of a reduced consumption of these products would be the health benefits and cost savings from diets based on plants. Still, increasing taxes for meat and other animal products is not popular with producers and most consumers.

A recent University of Oxford study suggests that if unaddressed, the public health and environmental expenses associated with the increased demand for animal products could be up to $1.6 trillion globally by 2050.

In Australia, 40% of cancer deaths are preventable, claims a recent study. One of the eight lifestyle factors that contribute to these deaths includes a low intake of fruit and vegetables and high intake of red and processed meat. But no, the Australian government does not intend to address its people’s high consumption of animal products. On the contrary, it has been claimed that

The Australian government has a vested interest in ensuring the country’s consumption of meat remains the highest in the world, even to the detriment of the population

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Source: Flickr / theunquietlibrarian

So what are we to do? With our government dragging its feet, it’s up to us to think about the future and make our lifestyle choices more sustainable. A toast to plant-based diets and good health in 2018. Let’s be gentle with our planet and compassionate towards all life that it sustains.

When evidence and vested interests collide

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Source: Flickr/ Etienne

The scientific method is the best approach we have to study and learn about the physical and natural world. When new knowledge is gained and comes to be the best available evidence at the time (until new, more accurate or in some other way better evidence becomes available), one would hope that the new knowledge finds its way quickly into the relevant disciplines, that practitioners take note and incorporate it into their practice, procedures and policies. In the health area, this time lag has been assumed to be 17 years – but we don’t really know, and “further research is needed”, as they often write in research articles.

There are many reasons for the length of the health research translation process. One of these is conflict of interest. A recent article in MJA InSight demonstrates this nicely. The article is titled “Prostate cancer: urologists fight back”.

We have known for some time that – from a population perspective – screening for prostate cancer and the resultant surgical procedures have overall little benefit for men. Two recent studies have now shown that for men with early prostate cancer, prostatectomy (i. e. surgery to remove all or part of the prostate gland) did not result in reduced mortality, but left many with nasty side effects.

Two recent clinical trials, Prostate Testing for Cancer and Treatment (ProtecT) and Prostate Cancer Intervention versus Observation Trial (PIVOT), completely undermine the stratospheric spin associated with prostate cancer being a death sentence. They are unambiguous in their implications.

The bottom line? Men with early stage abnormalities of the prostate who do not undergo surgery or radiation treatment, but whose condition is monitored for any progression of the cancer, live just as long as men who opted for complete removal of the prostate and who now live with its immediate consequences, including incontinence, intimacy issues, bowel problems and intervention regret.

This should be good news for older men. But they may never be told.

The MJA InSight article quotes prominent urologists who appear to have difficulty accepting the new evidence. Instead, they dismiss the two studies as being flawed.

Besides, a radiation oncologist claims that the surgeons are gatekeepers who often don’t refer higher risk patients to radiotherapy, which – she claims – is as effective as surgery:

There’s a massive financial conflict of interest there, because they don’t have a vested interest in referring men on to a radiation oncologist. They lose income if someone chooses a non-invasive intervention. People are reluctant to say it, but that’s the elephant in the room.

But might radiation oncologists have conflicts of interest as well?

Meanwhile, it may be worth pondering the results of a US study, which compared the recommendations of urologists and radiation oncologists for the treatment of localised prostate cancer. Surprise, surprise: for the same cases, the specialists overwhelmingly recommended the treatment that they themselves delivered.

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Source: Flickr/ Patrick Marioné

I argue there are parallels to animal experimentation. Animal researchers have built their careers on experimenting on animals. That’s their area of expertise, that’s the subject of their publications and conference talks, that’s how they make their living. In universities, the pressure to publish or perish is such that researchers rarely have the luxury to take time out for learning new non-animal, human-relevant methods. Operating on mice and using advanced computer-modelling techniques, for example, are quite different skills.

Grants are won on the basis of prior experience, and the peer review system “punishes researchers with innovative projects that may be risky, but could be highly successful”. Doing things differently and taking risks doesn’t pay:

Well established investigators with mature projects produce large amounts of preliminary data for applications. However, younger researchers (who completed their PhD less than 15 years previously) with new research programs or groundbreaking research, struggle to generate similar volumes of data; their teams are smaller and have less funding; they take more risk and this leads to lower success rates in obtaining funding.

Also, it takes a special person to be able to acknowledge after a career in a particular area that much of their work was of limited use. Dr Elias Zerhouni, ex-director of the US National Institutes of Health (NIH) had this to say:

We have moved away from studying human disease in humans,” he lamented. “We all drank the Kool-Aid on that one, me included.” With the ability to knock in or knock out any gene in a mouse—which “can’t sue us,” Zerhouni quipped—researchers have over-relied on animal data. “The problem is that it hasn’t worked, and it’s time we stopped dancing around the problem…We need to refocus and adapt new methodologies for use in humans to understand disease biology in humans.

The pressure to publish for the sake of publishing can lead to dreadful research. Dreadful because of its cruelty in the treatment of animals, and dreadful because it is a great waste of limited resources. This page on the Retraction Watch website critiques one such study.

The evidence for the limited value of animal experimentation is accumulating. Some point the finger at inferior study design in animal research, or more broadly a lack of scientific rigour, compared to studies that involve humans, while others identify species differences as responsible for the poor predictive value of animal models. For further links to studies that highlight why animals are not good models for human medicine, go to this website and search for the keyword “bias” (without the quotation marks).

Why do we let vested interests, financial or otherwise, have such a detrimental influence on the allocation of resources for biomedical research? That might be a topic for another blog post.

 

 

The Netherlands – Not just a pretty country

In December 2016, the Netherlands National Committee for the Protection of Animals Used for Scientific Purposes (NCad) provided an advisory report to the Dutch Minister of Agriculture Martijn van Dam after the Minister had requested a schedule for phasing out animal procedures. The report is titled “Transition to non-animal research – About the possibilities for phasing out animal procedures and stimulating innovation without laboratory animals”.

Earlier in 2016, the Dutch Parliament had already passed a motion to phase out all research on non-human primates. The Government aims now at phasing out animal research methods by 2025 and becoming a world leader in animal-free science.

So what is the NCad’s advice?

Overall, the NCad observes that it is time for a paradigm shift. While the animal model has become the “golden standard” in a number of research areas, it inflicts pain and suffering on animals and is perpetuated, for example, “because the current scientific quality assessment system is generally based on bibliometric criteria”, because journals impose animal data requirements on authors, and because the use of animal procedures is stipulated in many guidelines and laws.

Conversely, alternative approaches are becoming more common and “will increase in number and importance”. But the provision of funding for alternatives and innovation is not enough for a paradigm shift to occur. The parties involved in the field will also need to no longer regard animal research as the golden standard, or animal research is “no longer delivering the necessary results”.

In regard to the latter, I would argue that for some decades animal research has not delivered the necessary results for governments and citizens, although it has delivered profits and careers for the industry.

The report argues for strong government leadership to enable a paradigm shift to animal-free science.

The NCad believes that it is only with a broad-ranging and coordinated effort by the ministries involved and other stakeholders that significant progress can be made in reducing the use of animals in research. The choice of a clear direction, clear objectives and concrete steps is essential in this context, but emotions, social structures and other factors over which less influence can be wielded inevitably play a role, given the nature of transitions.

According to the report, regulatory research and testing can and should be phased out by 2025:

The use of laboratory animals in regulatory safety testing of chemicals, food ingredients, pesticides and (veterinary) medicines can be phased out by 2025, whilst maintaining the existing safety level. The same applies to the use of laboratory animals for the release of biological products, such as vaccines.

This should occur together with an international review of the regulatory risk assessment process.

However, the NCad suggests that regulatory pre-clinical research “cannot be phased out at the same pace”.

In regulatory clinical research, medicines that were successful in animal procedures often fail in clinical trials. For these instances, so-called backward validation studies can be used to investigate or determine the predictive value of pre-clinical animal tests and innovative methods for clinical research on human subjects. On the basis of the insights obtained, pre-clinical research models can be improved. The NCad recommends for the Minister for Agriculture to make funds available for this.

For fundamental scientific research, the NCad recommends the development of a 10-year plan for the different areas of basic research in consultation with the public and the scientific community.

In regard to applied and translational research, the NCad observes that “more rapid progress can be made than is being made at the present time. There is a great deal of innovative potential that could be better exploited.”

For education and training,

NCad recognises that the use of laboratory animals in training professionals involved in the field will continue to be necessary to a certain extent, but believes that, here too, cultivating a mindset that does not rely on laboratory animals will help keep the number of animal procedures to a minimum.

The NCad encourages the Netherlands Government to take leadership at the international level. For example:

Urge the European Commission to define a European strategy that takes an ambitious and integrated approach to non-animal research, one that includes animal welfare and the 3Rs in impact assessments and the development of new legislation and regulations. Also, call for existing legislation and regulations to be critically reviewed in this respect, and for it to be mandatory for accepted alternatives to be included, for funds to be made available for the further development of innovations without laboratory animals and for EU standards to be observed in commercial treaties.

…consider collaborating with the US organisations EPA (for the risk assessment of substances and pesticides) and FDA (for the risk assessment of medicines and food additives), as part of a European alliance or otherwise, on the theme of New Risk Management in approval of substances.

… In collaboration with the ministries of Health, Welfare and Sport and Infrastructure and the Environment, the RIVM and relevant international organisations, endeavour to obtain European agreements that make it easier to depart from regulatory animal procedures where possible through the use of validated alternative methods. Also, aim for transparent communication regarding situations where alternatives to the regulatory animal procedures have been used.

Overall, this is a great initiative towards phasing out animal experiments. It shows that it can be done given the political will. Congratulations to Minister van Dam and his government. Congratulations also to the citizens of the Netherlands who have advocated for this change. I hope that other countries will follow your example.

Meat, a not so palatable investment?

Recently, I have noticed warnings by the finance industry about investing in meat. While many of us have known for some time that meat is bad news for human health, the environment and of course the animals whose flesh is eaten, it’s good news that the finance industry starts pointing out the unsustainability of the meat industry.

The meat industry is powerful, and proclaiming the obvious can lead to a backlash. For example, in June this year the Bayer Crop Science Twitter account reportedly suggested that going vegetarian can cut a person’s carbon footprint in half. The tweet has since been deleted and Bayer has apologised to the industry. Bayer apologised for expressing a view based on evidence, but unwelcome to Bayer’s business partners:

Source: Twitter/ @Bayer4Crops

Source: Twitter/ @Bayer4Crops

Last month, a coalition of 40 institutional investors launched an engagement with 16 multinational food companies highlighting the risks of investing in industrial animal production. The coalition represents investments of US $1.25 trillion and includes investors such as Swedish state pension funds AP2, AP3 and AP4, Aviva Investors, Boston Common, Coller Capital, Folksam, Nordea and Robeco. Australian Ethical Investment is also part of the coalition. The investors are urging food companies to transition to plant-based sources of protein.

The investors are responding to a recent Oxford University study which calculated that if global diets reduced their reliance on meat it could lead to healthcare – related savings and avoided climate damages of $1.5 trillion by 2050. The analysis report also points to regulatory trends as a driver for corporate action – such as Denmark’s consultation on the introduction of red meat tax and the Chinese government’s plan to reduce its citizens’ meat consumption by 50%.

The company Nestle’s response is reported in an article on the Fortune.com website:

A Nestle spokeswoman said the company did not use much meat, “so our main strategy is not to focus on replacing the meat that we do use as its impact would be minimal. Our main opportunities lie in innovating new products using alternate proteins”.

Meanwhile, Forbes.com reports that “Tech Companies Join Fight Against America’s Top Killers”. The article provides examples of tech companies that give health care providers and patients tools to help them with the transition to a plant-based diet, thus preventing and fighting chronic diseases.

If the pharmaceutical industry produced a pill that provided the healing power of a plant-based diet, it would be a blockbuster.’ – Dr. Rob Ostfeld.

Tyson Foods is one of the worlds largest meat processors. So it might be surprising that Tyson is investing in Beyond Meat, a company that produces plant-based alternatives to meat. Taking a 5% stake in Beyond Meat is considered a shrewd move. It probably is, given that people in the US are eating more plant-based foods and this is reflected in (plant-based) industry growth.

In Germany, large meat processors are now in competition with smaller companies that produce meat alternatives, and some of the latter fear they may be pushed out of the market. Two years ago, Rügenwalder Mühle started with a side-line of plant-based sausage and meat products, and many other meat processors have since followed.

Research conducted jointly last year by the NPD Group, Midan Marketing and Meatingplace, an industry publication, found that 70 percent of meat eaters said they used a meat substitute in place of meat protein at least once a week. And 22 percent said they were using such substitutes more frequently than a year earlier.

The trend away from meat towards plant-based foods is evident not just in the US, but also in other countries, such as Australia, Germany, the UK, Denmark and the Netherlands. The finance industry does well to take note.

 

Further reading

Alan Briefel (2016) Why factory farming is becoming a major risk to portfolios.

FAIRR and Share Action (2016) The future of food: The investment case for a protein shake up.

Kirschner’s Korner (2016) Beyond meat CEO responds to concerns about Tyson Foods investment

Neal Barnard (2016) FDA: don’t label meat ‘healthy’

Consultation on animal welfare reform in Victoria needs our ideas

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Source: Victorian Government

The Victorian Government is consulting on animal welfare reform. Submissions to Improving the Welfare of Animals in Victoria. Draft Action Plan 2016-2021 are due on 11 October.

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I have just emailed my submission, and if you live in Victoria, I encourage you to have your say, too.

Here is what I wrote to The Hon Jaala Pulford MP, Minister for Agriculture, and Ms Lizzie Blandthorn MP, Member for Pascoe Vale (I have not commented on all aspects of the draft plan):

 

Dear Minister Pulford and Ms Blandthorn,

Thank you for the opportunity to comment on the “Improving the Welfare of Animals in Victoria. Draft Action Plan 2016-2021”.

Overall comments

I agree with the broad three action areas proposed in the draft plan. I also share your view that Victoria needs a proactive plan that promotes evidence-based animal welfare practices and reflects community expectations, and that we need a collaborative approach to accomplish this. To achieve all this, it is of utmost importance that the animal welfare portfolio and the regulation of animal welfare are free of conflict of interest. Currently, this is not the case while these roles sit within the Department of Economic Development, Jobs, Transport and Resources. To be effective, fair to the animals and responsive to community expectation, the animal welfare portfolio has to be independent of the agriculture and industry portfolios. An independent office of animal welfare, set up as a statutory authority, is needed.

In the draft plan, you point out correctly that “Animals are able to perceive their environment, and experience sensations such as pain and suffering, or pleasure and comfort”. Our knowledge of animal sentience and cognition is constantly increasing. For example:

  • fish perception and cognitive abilities often match or exceed other vertebrates, and fish experience pain in a manner similar to the other vertebrates (1)
  • animals suffer psychological pain in the form of fear and stress, caused by conditions such as captivity, confinement, physical harm, loss of social bonds, and isolation (2)
  • in 2012, a group of cognitive neuroscientists, neuropharmacologists, neurophysiologists, neuroanatomists and computational neuroscientists declared “that humans are not unique in possessing the neurological substrates that generate consciousness. Non-human animals, including mammals and birds, and many other creatures, including octopuses, also possess these neurological substrates” (3).

Thus animals deserve moral consideration and it is our obligation to protect them from human-inflicted pain and suffering. For example, animal use for sport and entertainment that results in pain, suffering and/or death is morally indefensible and should stop. Consequently, as a first step, recreational shooting (in particular duck shooting), jumps racing and greyhound racing should be disallowed in Victoria. Some states have already banned duck shooting, and greyhound racing will be banned in NSW and possibly the ACT from next year. If it is possible in other states, why not in Victoria?

In regard to the action areas as outlined in the draft plan, I offer the following comments:

Action area 1: Victoria has contemporary animal welfare laws

As you state in the draft plan, it is important that welfare legislation in Victoria is contemporary. The community expects that animal welfare legislation is developed with compassion and fairness. Therefore, the development of animal welfare legislation should be led by a body free of conflict of interest, such as an independent office of animal welfare.

The development of regulation and legislation should be, as you note, evidence-based and consequently free of conflict of interest. Therefore, the plan should spell out clearly that on relevant panels and decision-making groups those individuals and groups with a financial or other personal interest in the use of animals (such as recreational shooters) should be in the minority, if consulted at all.

In your list of stakeholders you include animal owners, industries, stakeholder and enforcement groups and the community. Where are animal welfare/ animal advocacy groups? The words “animal advocacy” or “animal advocate” do not appear in this document. Given that this document is concerned with improving the welfare of animals, and not improving the use of animals for the benefit of humans, and that animals can’t speak for themselves, animal advocates need to be given greater prominence in the document.

Codes of practice have in the past been developed by industry. They are part of industry self-regulation and have not served animals well. For example, the commercial production of “food animals” allows practices that the community finds abhorrent, such as tail docking and castration without anaesthesia or pain relief. The development of appropriate and humane animal husbandry practices should not be left for industry to decide. An independent office of animal welfare, as suggested above, should take a leading role in the development of codes of practice and animal husbandry regulation.

A review of Victoria’s current animal welfare legislation is timely. For example, Victorian primary and secondary schools are required to obtain approval from an animal ethics committee (AEC) for educational projects that involve live animals. However, there is no such requirement for early childhood services. Thus, for example chicken hatching projects undertaken in schools require ethics approval, but the same projects undertaken in early childhood services do not. This must have been an oversight when the legislation was introduced, and early childhood services should be brought in line with schools.

Action area 2: Collaborative approaches underpin knowledge, commitment and investment in animal welfare

A collaborative approach works best when it is free of conflict of interest. As noted above, it is crucial that the animal welfare portfolio is independent of industry and other groups with an interest in the commercial or recreational use of animals.

2.1 a) Identify opportunities for innovation, collaboration and investment, on activities that promote and implement sound animal welfare practices.

Animals that are used for their meat, eggs and milk comprise by far the largest number of animals whose welfare depends on humans. The large number of “food animals” is unsustainable for three reasons:

  1. The conditions under which animals in factory farms are kept are inhumane: confinement, overcrowding, surgical procedures without anaesthesia or pain relief, the creation of “waste animals” (such as male chicks and male calves). If we kept our pets in such conditions, we would be rightly accused of animal cruelty. Many common practices in factory farming are legalised animal cruelty.
  2. The over-consumption of animal products is one of the factors that have led to a public health crisis in Australia. Dairy and meat products have been linked to various cancers, cardiovascular disease, diabetes and Alzheimer’s (e.g., 4, 5, 6). Further, the emergence of antibiotic resistant bacteria is largely due to the non-therapeutic use of antimicrobials in factory farming. It leads to the development of drug resistance and is already a serious problem for our health system (7, 8).
  3. The negative impact of meat and dairy production on the environment has been well documented (e.g., 9, 10-12). For example, it contributes to the pollution of our land, air, and water, and to climate change.

The fact that factory farming is unsustainable has also been identified by the finance industry (e.g., 13, 14). It is therefore in the best interest of the community and the animal agriculture sector for governments to support producers to transition to plant-based products.

2.1 d) Ethical care and use of animals for research, testing and teaching

Ethical care and use of animals in research and teaching requires transparency and making information that is of interest to the community publicly available. Given that much animal research is publicly funded, transparency is also part of accountability to the public. For example, why does Victoria not make the names of licence holders publicly available, like some other states do (e.g. Tasmania)? Why are the licensed institutions’ annual reports to the state government not publicly available (identifying details redacted)?

I suggest that you add to this section a statement declaring the intention to provide greater transparency in regard to animals used for scientific purposes and teaching. Further, I suggest that Victoria work together with other states/territories to achieve consistency in reporting of animal use data in research and teaching.

The Australian code for the care and use of animals for scientific purposes (15) states that opportunities to rehome animals should be considered wherever possible. I suggest that Victoria go beyond the “should be considered” and require serious rehoming efforts for suitable animals at conclusion of their use in research and teaching.

Action area 3: Compliance and enforcement is efficient and effective

Compliance and enforcement relies on adequate resources. The compliance and enforcement system needs to be better funded and supported to do its important work. A commitment to adequate funding should be included in the plan.

3.2 b) provide training and advice to applicants and holders of licences to use animals for research, testing and teaching

Further to the training courses and best practice guidelines as suggested in your draft plan, I propose training for institutions and AECs not only about the Australian code for the care and use of animals for scientific purposes and its interpretation, but also about non-animal methods to strengthen implementation of the 3Rs (Replacement, Reduction and Refinement) as required by the Code.

Overall, most of the deliverables as outlined in the draft plan appear worthy of support, but I have not commented on these to keep my submission brief or because I do not know enough about the issues to be able to comment (e.g. wildlife management).

I commend your initiative to develop this plan and am looking forward to a Victorian animal welfare plan that promotes strong protection and that will improve the welfare of animals in our state.

Sincerely,

Monika Merkes PhD (public health)

References

  1. Brown C. Fish intelligence, sentience and ethics. Anim Cogn. 2014 2014/06/19:1-17. English. Available at: http://dx.doi.org/10.1007/s10071-014-0761-0.
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