February 1997
PREAMBLE
The Federation of Laboratory Animal Science Associations (FELASA) is pleased to acknowledge the benefits which have arisen from publication of the guidelines attached to the Council of Europe 'European Convention for the protection of vertebrate animals used for experimental and other scientific purposes' together with its appended recommendations for accommodation and care of animals' - (Appendix A). The principles on which that Appendix is based remain appropriate for assuring high standards of laboratory animal welfare. FELASA further notes the issue of a report offered with the request 'that it be considered in further discussions on the subject' following a meeting on laboratory animal welfare, organised by the German Bundesministerium fur Ernahrung, Landwirtschaft und Forsten with the support of the European Commission, which was held in Berlin 17-19 May 1993 (the Berlin Document).
FELASA was not directly involved in discussions leading to this report. We welcome such initiatives as it is important to address the practical impact of all proposals for improving the welfare of animals kept for experimental and other scientific purposes. While accepting that all animal housing is likely to be a compromise with welfare, we believe it is essential to address the cognitive state of the laboratory animal rather than to provide environments based only on what humans might find attractive. Similarly, in recognising that the guidance offered by the Appendix should be updated as new information becomes available, we must recognise the advances which continue to be derived from its successful application; these reflect its careful formulation and the wide acceptance which results from the avoidance of frequent, minor changes. Recommendations in the Berlin Document made on the basis of value judgements or unrefereed technical or scientific reports should be scrutinised carefully before there is any question of their implementation. The cautious and well argued approach adopted in the rodent section is particularly commended. Factors which are currently the focus of attention need to be seen in relation to others which have been well established insofar as they may contribute to the wellbeing of laboratory animals. If there should prove to be a lack of specific information or of a framework within which to interpret apparently conflicting observations, we believe that no recommendation should be made at present. In all respects we accept the spirit of the introduction to the Appendix that the statements contained therein should be seen as recommendations rather than formal requirements (which is sometimes portrayed by use of the words 'should' and 'must'). Should the Appendix be seen as a mandatory requirement, no further information will become available on novel procedures likely to benefit animal well-being. FELASA also believes that it is important to ensure that as far as possible the guidelines are broadly compatible with other proposals such as the ILAR 'Guidelines for the care and use of Laboratory Animals' by the United States of America National Academy of Sciences; these should be carefully studied before final guidelines are drawn up.
GENERAL COMMENTS
Although FELASA believes that replacement of the Appendix is not desirable at present, the availability of new knowledge on the needs of laboratory animals makes it timely to issue a supplementary commentary on certain aspects of welfare. We believe three topics call for particular attention (where appropriate we show in parentheses the relevant item in the Appendix and in italics, the page number/boxed recommendation number from the Berlin Document).
1. The use of non-human Primates
We are aware both of public concern over the use of non-human primates in
scientific procedures and also of the continuing need for such studies to
advance our understanding of higher mammalian function for example to
ensure the safety and efficacy of pharmaceutical compounds. We believe that
it is appropriate to work towards being able to add monkeys and apes to
those animals listed in Article 21 of the Convention, which must normally
be acquired directly or indirectly only from registered breeding
establishments. We wish to see early and substantial improvements in care
and husbandry of non-human primates but the proposals offered in the Berlin
Document are so general and so unsubstantiated by reference to scientific
literature that we believe they are not sufficiently advanced to permit
inclusion in the commentary. Dimensions of cages recommended are smaller
than those proposed for dogs and yet in their natural environment they may
show comparable activity and in a three-dimensional milieu. This is a
matter of importance and we recommend that persons experienced in the
requirements of non-human primates should be consulted at an early
opportunity to formulate appropriate detailed guidance. There is an urgent
need to review new knowledge reflecting the diverse housing and husbandry
requirements of individual primate species including the great apes, as
reflected by their lifestyle, bodyweights, developmental stages, age and
sex. Wide consultation should not only determine what more is required but
also facilitate early acceptance and application of these deliberations.
The particular needs of non-human primates involved in long-term studies
which may affect their sensory or nervous system should be carefully
addressed.
2. Environmental enrichment by structuring accommodation and provision of
playthings
FELASA strongly supports the contention that it is often the quality of
space rather than its size which influences an animal's well-being.
Environmental enrichment can stimulate a range of behavioural responses
some of which are seen as desirable and contribute importantly to
laboratory animal welfare. However, the effects of enrichment may be
transient and can sometimes be actually harmful, for example by increasing
aggressive behaviour within groups of animals due to competition for
occupation of favoured areas, or by creating behavioural unpredictability
within a social group and so reducing its cohesiveness. The consequences of
environmental manipulation must be determined impartially and objectively
for the animal species involved, the nature of the study and the particular
enrichment proposed (rodents 7/2, 8/2, 9~1). Possible effects of enrichment
on the ability to inspect animals, on hygiene and on animal health should
be borne in mind and proposals such as that to restrict cleaning of rodent
cages for social reasons must be rigorously evaluated in those terms (8/2;
A 3.11). It is not safe to extrapolate findings between superficially
similar species, for example between dogs and cats or between mice and
rats. We therefore recommend that careful observations should be made of
enrichment strategies and that further scientific studies of their effects
on given species of animals in laboratory situations should be encouraged.
In order better to emphasise species differences in this respect, the words
'its physiological and ethological needs' in Article 5.1 of the Convention
should be replaced by the needs of that species', and 'certain ethological
needs' in Appendix A 3.6.3 by 'the needs of a given species'.
3. Housing laboratory animals in groups of the same species
Attention should be paid to the housing of species that normally manifest
social behaviour. Where possible, compatible animals should be housed in
groups in a cage or pen (Berlin Document, primates pages 81-82; rodents
5/1; A 3.6), and as far as possible the membership of such groups should be
kept constant. For example the breeding of rabbits in pens which at some
point will lead to males being transferred to individual cages is perceived
as a most unsatisfactory arrangement. There is also a need to further
evaluate the consequences of grouping species that in nature tend to be
solitary (hamsters, ferrets, cats 32/2). In particular the social effects
of sex and age need to be considered in the design of studies where such
variables are compared. We are cognisant that in groups of animals it may
be inappropriate to seek to eliminate all aggressive interactions as this
may impair social structuring of the group and thereby reduce animal
welfare. Where, for behavioural reasons or the particular requirements of a
scientific protocol, social grouping is not possible, consideration should
be given to accommodating animals within sight or sound of one another.
However, even in this situation adverse responses may occur with certain
species or in certain situations; a warning to that effect should be
incorporated in any published commentary and further scientifically-valid
study should be encouraged. In particular it must be acknowledged that when
animals are housed in social groups very high standards of husbandry may be
needed, particularly when groups are first established.
Guidelines can assist but never replace close observation of the particular animals involved, which should be continued throughout their lives. Castration or medication of animals to make them more compatible for grouping is not acceptable.
DETAILED COMMENTS WHICH WE SUGGEST BE INCORPORATED IN A COMMENTARY
The Berlin Document proposes a number of amendments to recommendations contained in Appendix A. It is not always apparent which of these are based on firm evidence. Because of the welfare and economic implications FELASA recommends that wider discussion should be initiated - particularly by the bodies represented by Observers to the Multilateral Consultation - to ascertain the likely significance of those proposals and to identify what evidence is already available and in what areas studies should be encouraged to determine that significance.
Some of the recommendations could lead to worthwhile gains in laboratory animal welfare while presenting little risk to present standards. These, together with the matters set out above, could with advantage be included in the commentary which we propose as a supplement to the Appendix.
They include:
- recommendations for cage sizes should be based on behavioural and
physiological needs of animals rather than their size alone (rodents 5/3;
rabbits 21/3; cats 33/3; mini-pigs 49/3; A 3.6.1, 3.6.3). We believe that
changes in cage and pen dimensions should be introduced progressively and
over suitable time scales with careful assessment of the consequences
rather than arbitrarily and dramatically. A similar view pertains to the
allocation of floor areas for dog-pens, in this respect we note the
differing opinions of experts quoted in the Berlin Document. Proposals
whose basis is a narrow one or where experience is restricted, no matter
how well argued should not be accepted without taking account of the views
and reasoning of others. In this respect we believe that the Swiss
proposals for rabbit housing both merit and need further careful study.
- consideration should be given to animal stocking densities and metabolic
requirements when determining ventilation rates (rodents 10/1; cats 35/1;
dogs 43/2; A 2.1, 2.3)
- noting that reported adverse effects on health of low humidity in rodent
environments have been challenged (rodents 10/3; A2.3)
- excessive light levels should be avoided, particularly for albino animals
(rodents 11/1; rabbits 27/2; A 2.4) . noise levels should be minimised
particularly those frequencies to which animals are most sensitive (rodents
11/27 11/3; rabbits 27/3; A 2.5)
- mention should be made of advances in cage or pen materials, size (cats
33/1, 33/2; A Table 6) and design (rodents 4/1; rabbits 27/1; cats 33/3;
dogs 43/1; A 3.6.2)
- emphasis should be placed on the disadvantages for some species of
housing in cages with grid floors (rodents 7/1, rabbits 25/2 )
- some species benefit from the provision of bedding material (rodents 7/1,
8/1; rabbits 27/1; dogs 41/4; A 3.9) although the Appendix (A2) draws
attention to the consequent possibility of the creation of local
micro-climates (rodents 10/2) differing from that in the room as a whole.
- special provision may be needed for contact or exercise for some species
(rodents 8/3; dogs 40/1, 41/1; A3. 10)
- any increase in the minimal areas recommended for caged hens (A. Table
13) should be based on established need rather than the arbitrary ten-fold
increase proposed (55/3). Floor areas of the size proposed would preclude
large-scale studies on poultry flocks that may be kept in commercial
conditions. The recommendation for provision of perches in cages (hens
56/1) of currently recommended size (A Table 13) is impracticable.
- the principal recommendations about animals for which specific guidance
was not offered in Appendix A - minipigs, reptiles, Xenopus and fish (pages
47-52; 59-63; 65-70; 71-80) - should form the basis for provisional
guidance until further consideration can be given to their elaboration and
inclusion in a revised Appendix. The section on fish is necessarily very
general and we believe the more commonly used species should be considered
on an individual basis. Mention should also be made of the need to purchase
healthy stock, to provide quarantine facilities and to check the purity of
water sources.
- Informed and interested parties should be invited to propose guidelines
for other species such as sheep, goats, calves and solipeds.
CONCLUSION
FELASA recommends that a thorough revision of Appendix A should be considered within the next decade. If this is done, the decision, taken when the Appendix was first formulated, not to make separate recommendations for breeding as opposed to stock animals should be reconsidered. Rather than altering Appendix A, at a time when some member states are still striving toward their full implementation we believe that new knowledge should be incorporated in a commentary which supplements the Appendix, particularly as the scientific validity of some of the proposals in the Berlin Document is open to question. The emphasis of the commentary should be on the needs of different laboratory animals, rather than broad statements of principle with insufficient regard to sex, age, lifestyle etc and it must also seek to promote further studies to a standard which promote continued improvements to laboratory animal welfare. The commentary should not preclude compromises where required by the nature of authorised scientific studies. FELASA offers to assist in the drafting of the commentary or in any other way which the Multilateral Consultation may wish.
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