9.23 Only a few witnesses brought up the issue
of product labelling.
There was little enthusiasm for using labelling to inform the
public better, even if appropriate labelling could be agreed.
9.24 We note that the labelling of pharmaceuticals
is governed by EU legislation, and would probably require more
effort to change than is warranted by the debatable benefits which
It is also unlikely that a form of words would ever be agreed
which would not create more confusion that it dispelled.
9.25 With regard to the labelling of other products,
there was again very little enthusiasm for changing any of the
regulations. We note that the labelling of some cosmetics products
is not always clear, as many of the individual ingredients will
have been tested on animals at some stage, even if the finished
cosmetic product has not been so tested. New EU regulations are
in any case likely to supersede any recommendation we might make.
We did not pursue this issue further.
STATISTICS OF SCIENTIFIC PROCEDURES
ON LIVING ANIMALS, GREAT BRITAIN
9.26 The statistics published by the Home Office
contain a great deal of information, but seem to be prepared for
statisticians, rather than for the general reader. They are consequently
difficult to interpret.
9.27 We recognise that, in recent years, the
Home Office has provided increasingly comprehensive introductory
notes. These go some way towards summarising key points for the
lay reader and certainly represent an improvement in the provision
of information to the public.
9.28 In oral evidence, the Home Office and Inspectorate
acknowledged that the presentation of the Statistics needed
to be improved, and said that they were actively addressing the
problem. They also noted, however, that an invitation contained
in the 2000 Statistics for users to suggest improvements
has so far failed to elicit a single response, although this may
be a reflection on their poor public outreach (Q. 1938).
9.29 We recommend that a formal consultation
on the Statistics is carried out with a view to making
them easier to interpret.
9.30 The problem, however, goes beyond presentation.
We agree with the RSPCA, who stated:
"The information contained
within the statistics appears to be detailed but is actually of
one cannot ascertain what was actually done to
animals (i.e. which procedures), how much suffering was caused
and for what purpose."
Currently, the only information on levels of suffering
contained in the annual Statistics is contained in Annex
B. This information is limited to giving the number of licences
in force in each severity band on a particular date.
Table: Project licences
in force on 31/12/2000
(Extract from the Statistics: Great Britain 2000, p. 96)
9.31 Each project licence can encompass from
one to several hundred animals. The number of licences in each
severity band do not therefore give any reliable information as
to the actual number of animals which may suffer. There is also
no information about the purposes for which the licences are granted
at the various severity bands.
9.32 We agree with the Reverend Professor Michael
Banner, the chairman of the APC, who when asked about information
on assessment of pain and suffering in the Statistics,
"It is astonishing to
to find that rather crucial bit of information buried
in an appendix to regular statistics. I think there would be considerable
merit if it could be done in ensuring that the degrees of pain
and the number of animals involved in each of those categories
is brought more to the fore." (Q. 51)
9.33 The Chief Inspector said that the only way
meaningful information could be gathered would be retrospectively
(Q. 89). While he was in principle in favour of providing statistics
on suffering, in practice, he was concerned that no accurate and
cost-effective system could be devised, and that any statistics
produced were likely to be misleading (Qs 1944-47). This is the
philosophy of despair.
9.34 From the licences we have seen, we consider
that the current system of assessing pain and suffering is already
highly misleading. Licences are allocated into one of three severity
bands, based on the experience of suffering of the "average"
animal. We consider that if a procedure involves 20% of animals
in mild severity, 70% in moderate severity and 10% in substantial
severity, then this should be recorded.
9.35 The Inspectorate itself could not possibly
assess the suffering experienced by the 2.6 million individual
animals used each year in Great Britain. Any assessment of suffering
would therefore have to be made by local staff (for example, the
Named Veterinary Surgeon or Named Animal Care and Welfare Officer)
and audited by the Inspectorate. This system would thus be largely
based on trust.
9.36 The availability of information as to levels
of suffering and purpose of each project is crucial to the public
understanding of animal procedures. Such information would enable
the public to make informed judgements about the justification
of animal research. Moreover, information would highlight where
there was greatest suffering, and hence where the need to develop
replacements, reductions and refinements was greatest.
9.37 Scoring systems are already in use for some
animals in some establishments.
We recognise that no system will be perfect, but consider that
the current situation, where little real information on suffering
is made available, cannot be allowed to continue.
9.38 We recommend that serious efforts should
be made to provide better statistics on animal suffering. The
Home Office Inspectorate should develop or approve a "scoring
system" for animal suffering which could be operated by Named
Animal Care and Welfare Officers and Named Veterinary Surgeons
and used to provide data for the Statistics.
9.39 We acknowledge that the prospect of assessing
every animal in every procedure is a daunting one, both in terms
of expense and bureaucracy. We therefore suggest that a pilot
system is developed to monitor the actual suffering experienced
by all animals covered by a range of project licences in each
of the three severity bands.