We've argued previously about the ineffectiveness of animal research in producing reliable results for humans. But let's look at something else today: how the regulatory system is supposed to work. What would you expect from a well-monitored system? How about four reasonable expectations?
1. That researchers would be familiar with the licences that they worked under?
2. That staff worried about animal welfare feel able to raise their concerns with the management?
3. That the Home Office Inspectorate (HOI) would act swiftly when concerns were identified?
4. That research licences would be published so that there could be a public discussion of whether they should have been granted?
Now let's look at real life. The official Animals in Science Committee (ASC), the government advisory body, has just reported to the Government on the conclusions to be drawn after BUAV's Imperial College London (ICL) investigation and the subsequent Home Office enquiry. The Home Office inquiry as a whole is being kept secret, but the ASC reports parts of it.
1. The ASC says the Home Office found that in Imperial College - not an obscure backwater, but a jewel in the crown of British research, a world leading university - "a proportion of licensees were unfamiliar with and had poor working knowledge of the conditions attached to their licences". What is the point of requiring a licence if the people who are working under it don't know what it says?
2. The ASC reports that "staff members with causes for concern in respect of animal welfare issues did not always feel able to raise these with their supervisors or the site management". What kind of working atmosphere makes it difficult for staff concerned about unnecessary animal suffering to express their concern?
3. The ASC reports that "a pattern of concerns was identified by the Home Office Inspectorate as early as 2012". So what did the Inspectorate do? Did they discuss the issues with the management? Well, the ASC says, at the end of 2012, the HOI was waiting for the new heads of unit to "bed in". A meeting "where the HOI's concerns would have been discussed" would have been held in 2013, "had it not been pre-empted" by the BUAV investigation. So where the inspectorate identifies a pattern of concerns about animal suffering, they wait for up to a year for the administrative convenience of the office-holders. Perhaps one should understand the difficulty. Just 22 inspectors are responsible for monitoring sites conducting over 4 million experiments a year.
4. Not only are animal research licences not normally disclosed. It is actually a criminal offence for the Home Office to disclose what anyone else's research licence says. If the Home Secretary, for instance, wanted to open a public discussion of whether the licences granted to Imperial College were appropriate, she would be committing a crime and could go to prison for two years. Even the official Home Office report into the failings at Imperial College is not being published.
So we have a system of secret licences, unread by staff or licence-holders themselves, unchallenged by worried internal staff and monitored by overloaded lack lustre inspectors with a turnaround of up to a year. In the case of Imperial College, the ASC's finding is devastatingly blunt:
"The regime at ICL clearly fell short of the standard required". Remember, this is all avoidable suffering over and above the often high suffering which is permitted by the experiments.
"The Minister should consider whether he can continue to have confidence in the current Establishment Licence Holder at ICL retaining this role."
Faced with this, the BUAV expects the Licence Holder to resign from his responsibility. But isn't it the basic structure of animal experiment licensing that needs to change? The research industry needs to admit that the secret system is simply not working.
The Government is considering allowing licences to be published (anonymised and without commercially sensitive information). That's a good start, if they actually do it, rather than just sketching it out for a future Government. Beyond that, the least that can be expected is that everyone doing the research is familiar with the licences; that anyone with ethical concerns feels free to raise them with management without fear; that staff are not just there nine to five, even after highly invasive experiments; and that a proactive Inspectorate with adequate numbers acts vigorously whenever concerns arise.
Otherwise, we don't actually have a system that is working even under its own terms. It should not take an undercover investigation by the BUAV to expose the reality.