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Public Consultation on Revision of Animal Research Directive
Individual researchers now have a chance to influence the content of the new Directive - and it is important that they express their views to the European Commission
The European Commission has recently started the public consultation on their proposals to revise Directive 86/609, which regulates animal experimentation within the EU. The Commission has adopted a careful approach with the consultation, by offering two quite different versions: one for the public and the other for experts in “animal welfare, animal testing, animal science, natural sciences (especially biology, medicine, pharmacology and toxicology), legal and economic affairs related to these areas.”
It will be very important for academic researchers to respond to the expert consultation. Some of the things being proposed could have a seriously harmful effect on important areas of research. Although the consultation form is lengthy, it is only necessary to comment on those parts which are of concern. The number of responses received to the consultation will be very important. If only a few hundred responses are received, the European Commission may conclude that such a limited response indicates that few people have concerns about the proposals.
The closing date for submissions, which can only be made via the web (http://ec.europa.eu/environment/chemicals/lab_animals/ia_info_en.htm#5), is 18th August.
The public consultation is fairly short and concentrates on opinions about the appropriate levels of protection for laboratory animals, the acceptability of various purposes for using animals, which species should be used, transparency and alternative methods.
The expert version of the consultation will be very important because it is designed to solicit comments on the preliminary findings of the impact assessment that is being conducted on the proposals for the revision. This means that the questionnaire gives a detailed explanation of the new provisions that are being considered for inclusion in the new Directive. This is the first time the proposals have been set out in such detail. Because many academic researchers have not been consulted by the company preparing the impact assessment, it is particularly important to respond to this consultation to ensure that the views of the scientific community are properly understood before legislation is drafted.
Although there are only about 20 specific proposals, the questionnaire is quite long – the downloadable pdf version is 64 pages long – because it gives background information to each of the proposed measures. Indeed, it is sufficiently complex that the instructions tell users to download the Word version, draft out their responses and cut and paste them into the response web page. This page can only be accessed for 90 minutes before it shuts down, which would probably not be time enough to write all the replies necessary on the page itself.
As expected, it appears that the overall effect of the proposals will be to create a new Directive similar to the United Kingdom’s national legislation, considered by many to be the most rigorous of any EU Member State. This will undoubtedly result in a significant increase in administrative burden both for researchers and the national authorities in those member states with more relaxed legislation.
The results of the consultation will be made public, but the expert version of the consultation allows users to withhold their name and institution from being made public.
In the following articles in this EBRA Bulletin, we examine the few proposals which are likely to cause serious problems for EU bioscience research, identify the ones that will produce a general increase in administrative burden in certain member states and, finally, identify those proposals which are reasonable and unlikely to cause any problems.
Further information about any of these proposals or their effects, or advice about responding to the consultation, can be obtained from EBRA, by e-mailing matfield@ebra.org.