Correspondence

Letter from Baroness Williams to the Chair of the Animals in Science Committee (accessible version)

Published 5 October 2020

Professor David Main
Animals in Science Committee Secretariat
2 Marsham Street
London
SW1P 4DF

20 August 2020

Dear Professor Main

Animals in Science Committee – Commission of work

In accordance with section 13 of the Guidance on the Operation of the Animals (Scientific Procedures) Act 1986 (ASPA), I am writing to you, in your capacity as Chair of the Animals in Science Committee (ASC), to commission advice to be delivered over the next 18 months. This commission sets out the Government’s requirement for advice to support the Government’s delivery of the animals in science regulatory framework.

Below are outlined the key priorities for me over the next 18 months and where I would welcome the application of the Committee’s expertise. I encourage you to meet regularly with ASRU officials to ensure that we remain sighted of the Committee’s thinking as your advice is being developed. My commission from the ASC for 2020/21 is as follows:

Implementation of ASPA, Assurance and Delivery

1. Harms Experienced by Animals

The Animals in Science Regulation Unit has presented to the ASC on its development of a new strategy. ASRU has proposed a Mission: Protecting animals in science, that will guide all it does. ASRU has also proposed a Vision: We will reduce harms to animals in science through a focus on the continuous improvement of the governance of establishments, projects and ourselves. The Vision anticipates that measurement of reducing harm provides a suitable metric for the delivery of protecting animals in science. The harms to all animals will necessarily be a composite measure as it will include, at the very least, animals, species and severity. The proposal is not focussed on baseline numbers as these are influenced by a range of extraneous factors. Instead, ASRU seek to place the 3Rs (Replacement, Reduction and Refinement) at the heart of its approach. I would like the ASC to provide advice on developing a composite measure of harm that would be central to the delivery of the Government’s strategy. A more detailed scoping document is in preparation and I look forward to sharing this with you in due course.

2. Quality Management System

The published framework enables the effective delivery of ASPA through the Operational Guidance Code of Practice and Advice Notes. In a drive for continuous improvement I propose the embedding of a Quality Management System (QMS) within the framework, so quality can be

defined and there is greater consistency in delivery. I am grateful that ASRU has had preliminary conversations with you about this work and agree with your thinking that proposals will include the delivery of a QMS through ISO standards. The primary role of the ASC, as it relates to QMS, will be in advising on what the public would consider as critical to quality for ASRU deliverables. A scoping document is in preparation that will set out the approach and deliverables. This document will set out the points of engagement with the ASC. The Head of ASRU will provide you with a scoping document by mid-August.

3. Review of the ASC sub-Committees’ Terms of Reference

The UK’s exit from the EU has provided new opportunities, and it is therefore timely that the ASC reviews the Terms of Reference (ToR) of its sub-Committees. The transposition of EU Directive 2010/63 into ASPA aligned our requirements with the EU. Some of the consequences of these requirements had direct impact on the activities of the ASC. I would therefore like the ASC to review each sub-Committee’s ToR so we can be assured we are extracting maximum benefit from the advice that you produce. Specifically, I am keen that our approach to the ASC’s statutory responsibility to provide advice through the review of project licence applications is strategic and widely applicable, rather than focuses on advice pertaining to the individual application itself. The ASC Project Licence Review sub-Committee reviews those applications that include: the use of specially protected species in severe procedures; have major animal welfare or ethical implications; or, raise novel or contentious issues or that give rise to serious societal concerns (see p99 of the Guidance). Assuring ourselves that the ASC advice in this area has the greatest applicability leverages greater opportunity for protecting animals in science.

4. Project Licence and Non-technical summaries (NTSs)

This government is committed to quality service delivery through IT solutions. The animals in science e-licensing system continues to be developed to maintain rigorous scrutiny and oversight of applications and licences and also to reduce regulatory barriers. As part of this work the project licence application form and the associated Non-Technical Summary (NTS) have been developed. The NTS’ are published to improve openness and transparency and the wider public’s understanding of the work. Animal Welfare and Ethical Review Bodies (AWERB) have a crucial role in reviewing the NTS’ at establishments. Therefore, I would like the ASC to continue to work through its AWERB Subgroup, to maintain and assure the quality of project submissions and the associated NTS.

5. Non animal alternatives and the 3Rs

The co-ordinated dissemination of information on non-animal alternatives and 3Rs advances is important to the successful implementation of ASPA. I would like you to continue to develop the ASC AWERB hub network as an effective, secure, knowledge-sharing platform.

Incorporating Societal Concerns

6. Societal Concerns

I am aware that the ASC continues to consider issues of societal concern that involve the use of animals in science. You have indicated that you will write to me in the autumn with details of your considerations and advice regarding how future developments in science may impact on the use of animals in experimentation. I look forward to receiving the ASC advice during the period of this Commission.

Baroness Williams of Trafford