Professions Allowed to Test on Animals
Article 29 of the Animal Protection Act states:
(1) Experiments on animals which cause them pain, suffering, injury or death may not be performed for educational purposes.
The exceptions, listed in the continuation of the article, are certain professions to which a regulatory body may grant permission to perform experiments for educational purposes, as long as the same take place in universities or scientific institutions.
During the meetings of the Committee for Amendments to the Animal Protection Act in 2015 and 2016, one of the members of the Committee (who performs experiments on animals as a part of her profession) exercised extreme pressure on other members to extend the right to perform experiments and surgeries on animals to additional professions not covered by the Act.
As an organization devoted to the protection of animals, we strongly oppose the amendments. Animal testing represents the old and dated "science", the kind for which there is no place in the 21st century. Croatia should not rely on animal testing as a way of promoting scientific advancement, but rather opt for the more advanced alternative methods, which also provide more accurate and reliable results. Scientists who produce an abundant amount of scientific work containing views harmful to both science and animals need to realize that this is the century when we abandon the barbaric methods used in the 19th and the 20th century. Scientists need to educate themselves all throughout life, as well as continue to improve their professional expertise and apply the new scientific knowledge and accomplishments in the education of students and in their own scientific work, without the need to abuse animals.
Explanation: Our suggestions and opinions are based on the Directive 2010/63/EU of the European Parliament and the Council of the European Union of 22 September 2010 on the protection of animals used for scientific purposes (OJ L 276, 20.10.2010), implemented by the means of the Animal Protection Act, as well as all other EU documents that allow animal testing in the case of certain professions. As for the educational purposes, there is an entire hierarchy of methods that need to be properly inspected before allowing their use on live animals.
The Directive, along with the other documents, aims to restrict the use of animals and their replacements, in accordance with the 3Rs Principle which is a part of the Animal Protection Act. This is especially relevant in the undergraduate programs which are not only allowed but often required to provide their students with alternative methods (which are being developed daily), since their education is not specialized enough at that stage for it to justify the use of live animals.
In the continuation we list the documents which support the above statements:
1) Directive 2010/63/EU and the guidebooks
The Directive 2010/63/EU aims to minimize or completely replace the use of live animals in experiments and education. Law should provide the grounds for advancement, not the preservation of the status quo. It is the responsibility of universities to keep up with the newest trends and adapt accordingly because new methods are being produced daily.
The Directive 2010/63/EU states, among other things:
(10) … this Directive represents an important step towards achieving the final goal of full replacement of procedures on live animals for scientific and educational purposes as soon as it is scientifically possible to do so. To that end, it seeks to facilitate and promote the advancement of alternative approaches. It also seeks to ensure a high level of protection for animals that still need to be used in procedures. This Directive should be reviewed regularly in light of evolving science and animal-protection measures.
(12) Animals have an intrinsic value which must be respected. There are also the ethical concerns of the general public as regards the use of animals in procedures. Therefore, animals should always be treated as sentient creatures and their use in procedures should be restricted to areas which may ultimately benefit human or animal health, or the environment. The use of animals for scientific or educational purposes should therefore only be considered where a non-animal alternative is unavailable. Use of animals for scientific procedures in other areas under the competence of the Union should be prohibited.
We also want to point out the "Working document on the development of a common education and training framework to fulfill the requirements under the Directive".
The section entitled "Justification for the use of live animals in education" contains a following statement: "In many Member States, the use of animals for this purpose has been in decline for many years. If education without the use of live animals is achievable in some institutes (e.g. many medical schools) the question beckons why this would not be achievable elsewhere."
Furthermore, in the above mentioned section, it is stated that the use of animals in training should be restricted to only those individuals who are at a stage in their career development where animal use is considered necessary, including "those who will work with animals, use animals in scientific projects, and require the use of animals to develop surgical skills for clinical purposes."
In conclusion, the above mentioned document more readily greenlights the use of animals in specialized training (researchers working on projects) than in education (students at a university). Nevertheless, even when the animals are used in training, it is necessary to set limits.
In that context, it is impossible to justify the use of animals in undergraduate studies where the students have yet to decide on their specialization and will not necessarily perform experiments on animals as a part of their future profession, as well as in those studies where the students are not being educated in a highly specialized matter. As it is stated in the Directive 2010/63/EU:
(39) It is also essential, both on moral and scientific grounds, to ensure that each use of an animal is carefully evaluated as to the scientific or educational validity, usefulness and relevance of the expected result of that use. The likely harm to the animal should be balanced against the expected benefits of the project. Therefore, an impartial project evaluation independent of those involved in the study should be carried out as part of the authorisation process of projects involving the use of live animals. Effective implementation of a project evaluation should also allow for an appropriate assessment of the use of any new scientific experimental techniques as they emerge.
Moreover, in the documents available at http://ec.europa.eu/environment/chemicals/lab_animals/pdf/guidance/education_training/en.pdf and http://ec.europa.eu/environment/chemicals/lab_animals/pdf/guidance/project_evaluation/en.pdf, the section on the requirements and the assessment of projects involving the use of animals in education and training states the following:
The general order applied is: the use of alternative, non-animal methods, the use of cadavers, and, in the end, the use of live animals.
1) No animal use
- • Theory
- • Demonstration of procedures/techniques (or physiological responses) by the use of e.g. pictures, videos, interactive audio-visual tools;
- • Observation of a competent person performing the procedure live as part of an existing study;
- • Practice of technical/practical skills on "simulators".
2. Use of cadavers
3. Use of live animals
a. Non-recovery (anaesthetised) animals
- • Use of the animal for more than one technique is recommended since the harms for the animal are the same.
b. Use of conscious animals
- • If the procedure will not influence experimental outcome, or significantly affect severity, training could be done on animals within an existing study;
- • Training should always begin with teaching of the appropriate handling techniques to the species in question.
It may be concluded that even in the context of specialized training, the use of animal and non-animal methods is a hierarchy which continually strives to find alternatives to the use of live animals.
For those reasons, universities should come up with alternatives, as the guidebook suggests:
Confirmation should be provided that a thorough search for suitable alternative methods has been made.
The range of alternative teaching methods available should be explored (particularly experiments on human volunteers, video and computer-based learning methods, and in vitro and ex vivo studies).
2) Other documents advocating for the use of alternative methods:
European Convention for the Protection of Vertebrate Animals used for Experimental and Other Scientific Purposes has been advocating for the use of alternative methods ever since its first appearance in 1986. Article 25, pertaining to the education and training, thus states: "Procedures carried out for the purpose of education, training or further training for professions or other occupations… shall be restricted to those absolutely necessary for the purpose of the education or training concerned and be permitted only if their objective cannot be achieved by comparably effective audio-visual or any other suitable methods." (paragraphs 1 and 3).
In a report from a workshop organized by ECVAM (European Centre for the Validation of Alternative Methods), entitled "Alternatives to the Use of Animals in Higher Education", the following statements about the use of animals for educational purposes may be found:
The following groups of alternatives have been identified:
- models, mannequins and mechanical simulators;
- films and interactive videos;
- computer simulations and virtual reality systems;
- self-experimentation and human studies;
- plant experiments;
- observational and field studies;
- waste materials from slaughterhouses and fisheries;
- in vitro studies on cell lines;
- dead animals from a humane and ethical source (for example, animals which have died naturally or which have been killed humanely after scientific procedures); and
- clinical practise.
[use of animals] only acceptable when:
a) animals are observed in their natural setting or during brief periods of captivity;
b) animals are obtained from an ethical source, for example, dissection of animals that have died naturally or those which have been humanely killed for other reasons;
c) learning occurs in the clinical setting, where only animals in need of veterinary medical assistance are subjected to invasive procedures; or
d) learning occurs by closely supervised apprenticeship in the research laboratory (specifically for students entering fields where they will need to use laboratory animals).
Animal use for training purposes, particularly those experiments that involve suffering, should be delayed until a student decides to pursue a research career which involves animal experimentation.
Depending on the learning objectives, animal-free models have several advantages over animal experiments.
- a specific animal experiment might only be offered once, whereas an alternative model can often be used over and over again without constraints on time and place of study;
- alternative models can offer unambiguous and complete data, and so can avoid the negative learning experience of an "unsuccessful experiment";
- an alternative can have built-in selfassessment to allow students to gauge whether staged learning objectives have been achieved; and
- alternatives which make use of modern audio-visual techniques offer the possibility of demonstrating phenomena that are normally unobservable in the equivalent animal experiment, such as animations of organ and cell functions and "flythroughs" of organ systems.
3) Studies on the effectiveness of alternative methods:
In his work "Humane teaching methods prove efficacious within veterinary and other biomedical education", Andrew Knight states the following:
'"Twenty one studies of non-veterinary students in related academic disciplines were also published from 1968 to 2004. 38.1% (8/21) demonstrated superior, 52.4% (11/21) demonstrated equivalent, and 9.5% (2/21) demonstrated inferior learning outcomes using humane alternatives. Twenty nine papers in which comparison with harmful animal use did not occur illustrated additional benefits of humane teaching methods within veterinary and other biomedical education."
In their work "Alternatives to Animal Experimentation in Biomedical Education", Franz P. Gruber and David G. Dewhurst emphasize the following:
''In countries where animal testing in education is reduced to close to zero, there is no evidence that the students who are being trained are less capable or qualified. There are sufficient alternatives available at relatively low-cost and with proven educational efficacy to allow the vast majority of students who study biomedical science courses to qualify without using animal experiments. However, in many universities across Europe, there is still a resistance to adoption of such methods amongst faculty. The global situation is probably worse with animals still being used in high school teaching in some countries such as the USA.''
More information about alternative methods as superior educational methods may be found here.
We especially support the part of the 3Rs Principle which speaks in favor of the alternative methods, and we believe the legal provisions pertaining to experiments should likewise favor the alternatives.
The Directive 2010/63/EU allows the use of animal tissue or organs for the development of in vitro methods. This means that universities with studies in physiology, anatomy, and pharmacology may use the tissue and organs of animals that were killed, and whose organs and tissue was not manipulated before their death. On the other hand, the Directive and all the other documents are actively trying to limit animal testing as a part of the education of individuals attending the graduate-level or integrated university studies.
This opinion was presented by the Organization at the meetings of the Committee for Amendments to the Animal Protection Act in 2015 and 2016.