Animal testing has long been a controversial issue worldwide owing to the complexity and the scope of its influence. There are various opinions concerning whether animals research is acceptable. Some people are in favor of the research and some are against. There is also the opinion thinking that animal testing is basically valid and necessary. However, there is the doubt about the effort put to reduce the number and pain of animals involved is enough. This question implies the need of more serious concern and open debate regarding the issue. This policy paper aims at providing some recommendations to arouse the social concerns towards animal testing, with the ultimate goals of advancing the work of replacement, reduction, and refinement of animal testing (the three Rs approach). The possible approaches in stimulating the concerns and work towards minimizing animal testing are mainly in four areas: increasing information available, holding more fair debate, and promoting the importance of the three Rs approach.
Statement of the problem
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What are the practical measures for minimizing the harms resulted from animal testing? According to the Nuffield Council on Bioethics (2005) estimation, research around the world uses around 50 to 100 million animals annually. Animal welfare advocate blame animal testing for its violation of morality, lack of validity, and creation of extreme pain and distress to animals. Animal testing is not only cruel to animals, but also poses threat to human health. This is especially evident in cases of serious negative drug reactions (Nuffield Council on Bioethics, 2005). The profound effects of animal testing both to humans and animals should draw significant concern and thoughtful planning to the issue.
Background to the problem
Animal research raises two fundamental issues - the validity, usefulness, and relevance of these experiments, and the moral correctness of them. Medical discovery history proves the benefits of specific animals research types. However, the reliability of animal studies is still controversial due to the difficult progress in some animal medical research, such as cancer and Human immunodeficiency virus (HIV) research (Nuffield Council on Bioethics, 2005). The complexity of animals' nervous system means animals are able to feel pain (Grandin, 2002). This provides another strong support for protecting the welfare of animals.
Our organization's interest
Animal testing is arousing great concern worldwide owing to its significant impacts on human's well-being and morality. Adopting a more comprehensive policy model towards this issue will show that Hong Kong is a highly developed and caring society. The undoubted benefits will be the effective uplifting of Hong Kong's international image. Economic benefits from tourism and business investment boost can be enormous in the long run. Moreover, improved animal testing practice means lower incidence of misleading animal models and resulted products. Adverse chemical reactions in humans will be more effectively avoided. This will surely reduce the government's medical burden and the loss of valuable lifes. In short, the government will gain appreciable economic and social benefits in the long term by setting up a mature animal testing policy.
1. Issuing code of practice or protocol of animal testing
In Hong Kong, the Agriculture, Fisheries and Conservation Department (AFCD) has issued a Code of Practice to help protect the welfare of food animals (Animal Welfare Advisory Group, 2004). The code emphasizes investigators' responsibility in minimizing the sufferings and number of deaths of research animals. The Code of Practice also promotes the considerations of non-animal alternatives for the research projects (Animal Welfare Advisory Group, 2004). In the United States, a protocol submission to the institution's Institutional Animal Care and Use Committee (IACUC) before initiating an animal research is obligatory. The IACUC must write reports on the institution's animal research activities at least twice a year. (Applied Research Ethics National Association, 2002) In Taiwan, the governing committee in animal experiments is the Management Group of Animal Experiments (MGAE) (Yao, 2006).
Code and protocols of animal testing can facilitate researchers' conformity with the country's animal welfare laws. This can then reduce the resources and cost wasted in dealing with this issue. Also, the code of practice or the protocol review by the institution's animal experiments committee can increase public's understanding and trust in such research. This can relieve the conflicts between animal welfare advocates and testing institutions. Higher social stability is thus possible.
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The establishment of IACUCs may shift research resources to paperwork related to meet regulations. When there is a lack of research resources, the reliability and credibility of these researches may be lower. Another disadvantage can be the creation of interests' conflicts. As the IACUCs belong to the respective institutions, they may create untrue reports about their compliance to the regulations. A further disadvantage can be negative impact on academic freedom. As the members of IACUCs may not have enough expertise about laboratory animals, their review on research protocols may not be professional enough and so may hinder academic progress. Lack of reliability, interest conflicts, and obstruction to academic freedom are all the potential drawbacks of animal testing committees.
2. Banning animal testing on finished cosmetics or cosmetic ingredients
The European Commission has issued the Cosmetics Directive to prohibit animal testing on cosmetic products or ingredients (European Commission, 2010). It has come into effect from 11 September 2004. The marketing ban of comestic products tested on animals is effective from 11 March 2013. This banning is with the ultimate aim to gradually eliminate animal testing (European Commission, 2010).
As many consumers do not possess knowledge about animal testing, cosmetic companies may mislead their comsumers by alleging that animal testing in cosmetics is highly scientific and thus trustworthy. This banning can prevent cosmetic companies from misleading comsumers that their products are definitely safe due to successful testing on animals. Unnecessary economic costs due to consumers suing cosmetic companies for unsafe products can be better avoided.
The exemption (until 2013) to the sales ban of cosmetics tested on animals (European Commission, 2010) means that unpredictable number of animals will still suffer or die outside Europe in order to sell the cosmetics inside Europe. Companies may side-step the banning by moving its experimental base to places outside Europe. This will still result in violent protest from animal welfare advocates and consequently lower the country's international image.
3. Setting up a research centre about animal testing alternatives
The Johns Hopkins Centre for Alternatives to Animal Testing (CAAT) dedicates efforts in finding new methods of animal testing. It works with scientists from industries, government, and academia to facilitate the progress (Johns Hopkins University). Additionally, the UCDavis Center for Animal Alternatives (The University Library - The University of California, Davis) aims at publicizing information of alternative research methods. It also has a mission of contributing to the educational and research fields.
Establishing a research centre can provide more up-dated, detailed and comprehensive information to people in different fields. Specialists in research, industries, education, animal welfare organization, and the general public can more easily obtain the information about animal testing. Furthermore, investing in research works of the alternatives in animal experiments may speed up the technical progress in this issue. This may lead to reduction in the costs of adopting the alternative approaches. This means policy makers in industries will probably give higher priority to these approaches instead of relying solely on traditional testing methods.
Setting up a research centre involves significant costs in land, labor (scientists and specialists), and scientific equipments, this can put heavy burden in the government's financial planning. As the income gap between the rich and the poor is rather great in Hong Kong, investing in a large piece of land for animal welfare may cause violent discontent and protest from general public.
1. Increasing information available
The government can cooperate with well-known animal testing alternatives centers such as The Johns Hopkins Centre for Alternatives to Animal Testing to more effectively gather and announce the updated and useful information of animal research. The AFCD can select representatives to work with specialists in these centers and regularly review and submit reports regarding the working processes. In addition, the AFCD representatives should periodically hold seminars and workshops regarding animal testing. To take care of concerns of different interest groups, these seminars and workshops ought to invite specialists from the academia, industries, animal welfare groups, and the legislative councils. This will better ensure that different parties possess adequate knowledge about the backgrounds, facts, changes, and complexity of animal experiments. This approach's financial costs and technical problems are relatively acceptable compared to setting up a research centre. Thus the time frame for starting this approach should be approximately three months.
2. Holding more fair debate
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As many interest groups are strictly in favor of or against animal testing, holding more fair debate can improve mutual understanding and relieve conflicts. Fair debate can let different people know that animal testing may not be definitely right or wrong. This kind of debate should be open and fair by inviting sufficient representatives (at least 5) from different opinion groups. The host of the debate should remain totally objective and only give speech about the background, facts, and changes of the issue. To increase publicity, the government may work with some television channels and radio programs to broadcast the debates. The AFCD representatives should also be responsible for holding debate at least twice a year as this approach is not very expensive or complex.
3. Promoting the importance of the three Rs approach
The three Rs approach -- replacement, reduction, and refinement of animal testing is highly advocated by famous animal testing alternatives centers (Johns Hopkins Center for Alternatives to Animal Testing; Nuffield Council on Bioethics 2005). This approach does not directly ban the validity of animal testing. Instead, it is an approach that promotes the methods to grasp the merits of animal experiments while ensuring the reasonable welfare of laboratory animals. Within half a year, the government should set up a specialized committee to promote the three Rs approach mainly through holding conferences. This committee must contain members with diverse backgrounds, such as laboratory animal experts, different industries' policy makers, and animal welfare advocates. The successful promotion of this approach to different interest groups will surely lessen animal testing dispute and costs in the foreseeable future.