Alternatives to animal experimentation

Alternatives to animal testing include:

• In Vitro Cell Culture – sophisticated tests using actual human cells and tissues (also known as in vitro methods)
• In Silico Models – advanced computer-modeling techniques
• Organoids – miniature in vitro organs which mimic some of the structure and function of real organs. Many organoids have already been generated, including the kidney, liver, heart and lung.
• Organs on Chips – These are microfluidic cell culture devices with channels lined by living cells.  A number of microengineered organ models have already been generated and continue to be optimized, including models of the liver, lung, kidney, gut, bone, breast, eye and brain.To see the actual functioning of a lung and other organs on chips, see “Human Organs-On-Chips: Exhibit Video” by the Wyss Institute
• Human on a Chip – The goal of the Human-on-a-Chip is to generate a miniature 3-D model which includes 10 different human mini-organs linked together to form a physiological system.
• Computer Simulation – Advances in simulation technology allow researchers to test new ideas and try different experimental conditions.
• Autopsy studies and study of postmortem specimens – During the procedure, doctors can determine the cause of death, how a disease progresses and whether spectific treatments have been effective, and they can collect specimens of tissues and body fluids for further study.
• Epidemiological studies – Epidemiology is a field of research focused on the incidence, distribution and control of disease in a population.  Epidemiologists determine risk factors associated with disease as well as factors that protect against disease.
• Noninvasive imaging – Use of medical technologies that provide images of the body are used to increase our understanding of how the body works and it plays an important role in diagnostic medicine.
• Microdosing – In “phase zero” clinical trials, also known as microdosing, a very small number of human volunteers, one or two people, receive a very low amount of a new drug, a dose so low that it will not produce a pharmacologic effect or adverse reaction. From these studies, the fate of the compound in the human body, including information on how the body absorbs, distributes and metabolizes the drug, can be determined. Because the microdose of the new compound is so low, the risk to the human volunteer is very small.Source of all information above and for even more information:  NAVS – The National Anti-Vivisection Society – USA – “Alternatives to Animal Research” – https://www.navs.org/what-we-do/keep-you-informed/science-corner/alternatives/alternatives-to-animal-research/#.XMOEiKR7k2w

Also see PETA – “Alternatives to Animal Testing” – https://www.peta.org/issues/animals-used-for-experimentation/alternatives-animal-testing/

Also, view from 6:45 minutes onward – “It’s Time to Think Outside the Cage” – by  Dr. Charu Chandrasekera:

 

Validation is the process by which the reliability and relevance of a humane, effective non-animal test method is established.  This validation is required before national and international regulatory agencies will adopt that method – even though no such scientific validation was required for many currently accepted animal tests.

Some consider that Canada is lagging behind other countries in seeking alternatives to using animals in research.

In the U.S., the National Institutes of Health announced “that animal safety testing for environmental chemicals and drugs will largely be replaced by alternative research methods in a decade, citing results that are “more accurate, lower cost and higher throughput.”

“Elsewhere, the European Union has banned animal testing of cosmetics and has changed the legal status of animals from “things to sentient beings,” said environmental lawyer David Boyd, author of The Right of Nature and an associate professor at UBC.

“New Zealand also bans experiments on great apes — gorillas, chimpanzees, orangutans and bonobos.”

Source:  Vancouver Sun – “Jump in animal research in Canada generates debate on science ethics” by Larry Pynn – March 19, 2018

Yes – but so will construction of the St. Paul’s Hospital research facilities.  The date currently slated for opening of the hospital is 2026.  However, since the hospital development was stalled for 12 years, it may well be that the 2026 date is unrealistic.

Much progress in non-animal alternative testing methods will take place in the years before the hospital research facilities are opened.

Furthermore, one of the two proposed research facilities is marked “expansion” – to be constructed in a later phase.

Of course, non-animal research can take place at the laboratory – and its expansion – as soon as they are open.

Source:  Vancouver Sun – “New St. Paul’s Hospital gets green light from B.C. government” by Kevin Griffin – February 16, 2019

Billions of dollars of your money (collected directly by donations or indirectly through your tax dollars) are wasted on misleading animal experiments by the federal government, companies, universities, and many health charities.  These funds should instead be directed to human-relevant, non-animal test methods that could actually benefit humans.

Let’s look at skin allergy or sensitization testing as an example.

In animal tests, experimenters repeatedly smear chemicals onto the skin of between 32 and 80 guinea pigs or between 16 and 60 mice or inject the substances into their bodies before killing them. These tests take weeks to conduct and cost between $4,000 and $7,000(US) each.

The non-animal test – which is intended to replace these animal tests and has been validated by the Organization for Economic Co-operation and Development (OECD) –  takes three to four days to complete and costs less than half as much as the animal test.

See PETA – “PETA Funds Non-Animal Methods” 

https://www.youtube.com/watch?v=G6cVcGmFm28

Although a very few breakthroughs in the past were made as a result of animal experimentation, researchers are now faced with more complex issues.   Today we have sophisticated alternatives to animal experimentation.

Please take a few minutes to read – PETA – “Animal Testing is Bad Science: Point/Counterpoint”

Animals differ from humans in both size and physiology.  There are genetic differences and variations in biological targets – things to which drugs are directed and bind.

The artificial way in which the human disease is induced in the animal is very different from the way diseases occur naturally in people.

“We are not 70 kilogram rats.”  Thomas Hartung, researcher at Johns Hopkins University, Baltimore

“It is not possible to accurately recapitulate complex, multifactorial human diseases in other animals. Immutable inter-species differences that occur at every level of biological action—from nucleic acid to whole organism level—are further confounded by biological variability (age, sex, and strain), and even differences in housing and husbandry practices, to say nothing of experimental conditions. Even the control animals do not serve as appropriate controls—with rampant obesity, insulin resistance, and hypertension, their health is poor by human standards.”

Source:  Canadian Centre on Alternatives to Animal Methods – “Current Paradigm”

For an excellent discussion on this issue,  see NAVS (the National Anti-Vivisection Society – USA) –  “Failure of Animal Models”

See also:  PETA – “Experiments on Animals: Overview”

There were more than 3.5 million animals in experiments in Canada in 2015.

 By 2017, that number had increased to 4,415,467 animals used in research, teaching, and testing reported to the Canadian Council on Animal Care.

Even categories representing less than one per cent of the total involved a lot of animals – 5,879 cats, 11,045 dogs and 6,412 primates.

Probably surprising to most people, that number included 1,192,740 birds, 842,405 fish, 19,390 pigs, and 646,283 cows.

Those figures do not include animals used in experiments at facilities that are not certified by the Canadian Council on Animal Care.

Source:  Canadian Council on Animal Care – Annual Data Reports –“ CCAC Animal Data Report 2017”

Many animals used in labs are bred specifically by the research industry, for the sole purpose of enduring cruel and unnecessary lab experiments.

Other times, the research industry will steal wild animals from their natural homes to use in tests.

In many places, including in parts of Canada, experimenters take dogs and cats from animal pounds and shelters and subject them to painful tests.

Source:  Animal Charter – “Animals Used for Experimentation” 

Species of animals used in testing include fish, cats, dogs, guinea pigs, mice, monkeys, sheep, beavers, hamsters, pigs, rabbits and rats.

Virtually all types of animals are used for experimentation –  not just those listed above, but also nonhuman primates (including orangutans, macaques, and lemurs),  farmed animals, amphibians, reptiles, and octopuses.

Source:  Animal Charter – “Animals Used for Experimentation” 

“Mice and rats are curious, intelligent, and resourceful animals; they often make loving companion animals. They are incredibly social and sensitive to the emotions of fellow rats. Rats are capable of altruism; they will even forgo a food reward to save a drowning companion. Yet these smart and gentle creatures make up nearly half of the animals reported as used and killed, often enduring painful and lethal experiments.

Fishes are sensitive, can use tools, and have impressive cognitive powers; yet they make up nearly a third of the animals reported as used in research.”

Source:  Animal Charter – “Animals Used for Experimentation”

Furthermore, all animals are important.

“Like us, these animals embody the mystery and wonder of consciousness.

Like us, they are not only in the world, they are conscious of it.

Like us, they are the psychological centres of a life that is uniquely their own.”

(Earthlings, 2005)

No.  Animals in laboratories are also used for biology lessons, for medical training, for curiosity-driven experimentation, and for chemical, drug, food, and cosmetics testing.

As illustrated below, only 1/3 of animals are experimented upon for the purpose of medical or clinical studies.

The Canadian Council on Animal Care has created five categories of Purpose of Animal Use (PAU) –  the reason why an animal was included in a scientific study.

PAU 1 Fundamental Research – studies of a fundamental nature in science relating to essential structures or functions – 43.8% of animals

PAU 2 Medical or Clinic Studies – studies for medical purposes, including veterinary medicine, that relate to human or animal diseases or disorders – 33.0% of animals

PAU 3 Regulatory Testing – studies for regulatory testing of products for the protection of humans, animals, or the environment – 4.7% of animals

PAU 4 Development of Products or Devices – studies for the development of products or appliances for human or veterinary medicine – 12.6% of animals

PAU 5 Education and Training – education and training of individuals in post-secondary institutions or facilities – 5.9% of animals

Source:  Canadian Council on Animal Care – Annual Data Reports – “CCAC Animal Data Report 2017”

See also CCAC “Facts and Figures”

As an example, for decades scientists have known the hazards of mercury and that exposure to mercury in dental fillings caused reproductive effects in dental hygienists.  Yet researchers unsuccessfully attempted to duplicate these known effects by forcing rats into contraptions that resemble medieval torture devices.  In the end, the scientist concluded “We weren’t able to reproduce any of those effects in our animal model.”

See  PETA – “Wasted Money, Wasted Lives” – “mercury inhalation”

There is no law in Canada that prohibits animal experiments where the information is already well-know.

As an example, it is already known that toxic contaminants such as arsenic and lead can pose a serious health risk to humans, particularly infants and children.  Toxicity studies were conducted on immature pigs, which were fed food and water mixed with toxins.   These tests were completely unnecessary, since non-animal alternatives – using a simulated gastrointestinal tract – have been available and in widespread use by European countries since 1994 and can be conducted for a small fraction of the cost of animal tests.

See PETA – “Wasted Money, Wasted Lives” – “metal bioavailability”

There is no law in Canada that prohibits animal experiments where there is a viable non-animal alternative.

“Before their deaths, some animals are forced to inhale toxic fumes, others are immobilized in restraint devices for hours, some have holes drilled into their skulls, and others have their skin burned off or their spinal cords crushed.”

Souce: PETA – “Experiments on Animals: Overview”

Dalhousie researchers faced backlash in 2015 when reports surfaced that they were sewing shut the eyelids of kittens.  (Source:  Animal Charter  – “Animals Used for Experimentation” )

(The following information is from Humane Charities Canada – www.humanecharities.ca)

“Macaque monkeys were repeatedly injected with an industrial chemical and contaminant of illegal drugs to create lesions in their brains, then chemically paralyzed and given electric shocks without pain relief.

“A crude version of a stroke was simulated in macaque monkeys by injecting increasingly large styrofoam balls into their arteries.  The animals were forced to live like this for weeks, suffering multiple strokes and partial paralysis before being kiled.  The surgical procedure was botched in three of the monkeys, and as a result, they had to be killed before completion of the study.

“The sciatic nerves of mice were exposed and crushed, crippling them.  The mice were left to suffer for up to a month, additionally enduring pressure being applied to their feet until they pulled them away in pain.  At the end of the study, the feet of the mice were dipped in ink and they were forced to drag themselves across sheets of paper to records their level of crippling.  The animals were then killed with a needle of formaldehyde jabbed into their hearts.

“Lethally irradiated and “humanized” mice (transplanted with fragments of human organs and tumours) were forced to endure the growth of tumours inside their bodies for weeks before being killed.  Their turmours were then removed and re-injected into other mice only to have the process repeated over and over again.”

To read about the use of rabbits in experimentation – see PETA – “Rabbits in Laboratories”

To read about smoking experiments still being conducted on animals – see PETA – “Smoking Experiments on Animals”

The following is from NAVS – The National Anti-Vivisection Society – USA – “The Cruelty and Waste of Animal Experimentation”

No words can adequately describe “the physical pain, deprivation and emotional distress experienced by animals who are cut up, poisoned, burned, irradiated, gassed, shocked, dismembered or genetically designed to suffer. Nor does it reflect the tragedy of each individual life—however short and brutal—caged in an artificial environment which deprives them of experiencing life as nature intended.”

Through FOI (Freedom of Information) requests, the Animal Alliance received a number of reports of inspections of animal laboratories conducted by OMAFRA (Ontario Ministry of Agriculture, Food and Rural Affairs), covering the years 2013 to 2017.

Here are some of the “numerous examples of neglect, incompetence and outright abuse of dogs and cats cited by inspectors”:

• animals medicated, or even anesthetized for a surgery, using an expired drug
• dogs being housed in small, rusty cages where the lights are never turned off, but they can’t see the other dogs barking nearby, and humans don’t show up on weekends to feed the dog or clean their cages
• dogs having difficulties getting up, possibly due to the slippery surface of the pen

For more information, click “To read the full story” at https://www.animalalliance.ca/campaigns/pets-research/lifeinthelab/

“In addition to the torment of the actual experiments, animals in laboratories are deprived of everything that is natural and important to them—they are confined to barren cages, socially isolated, and psychologically traumatized.”

Souce: PETA – “Experiments on Animals: Overview”

For more insights into the life of animals in laboratories, see PETA – “Cruelty to Animals in Laboratories” –

“Video footage from inside laboratories shows animals who cower in fear every time someone walks by their cages. They don’t know if they will be dragged from their prison cells for an injection, blood withdrawal, a painful procedure, surgery, or death.  Often they see other animals killed right in front of them.”

Also please see PETA – “Animal Testing 101” –

“The complete lack of environmental enrichment and the stress of their living situation cause some animals to develop neurotic types of behavior such as incessantly spinning in circles, rocking back and forth, pulling out their own fur, and even biting themselves.”

No.

The Canadian Council on Animal Care (CCAC) acknowledges:

“Animals may experience a greater degree of pain and/or distress when subjected to experi­mental procedures by inexperienced individuals who do not possess the appropriate knowledge, skills and competency.”

However, there are no legal standards or even voluntary Canada-wide standards for the training that laboratory staff must have.  Training standards are determined by each institution.

The Canadian Council on Animal Care (CCAC) confirms:

“The actual training requirements and the competency of those who work with animals in science are to be determined by institutional animal care committees, together with those responsible for training in practice and with the institution’s senior administrator.”  [underlining added]

Source: Canada Council on Animal Care – Training – https://www.ccac.ca/en/training/

Although the CCAC has  “Guidelines on: training of personnel working with animals in science”, those truly are simply guidelines – not mandatory requirements. Guidelines are policies or recommended standards – they do not have the force of law.

An example of a CCAC guideline is:  “Institutions must strive to sustain an institutional culture of respect for animal life.”  [underlining added]

Source: Canada Council on Animal Care – Guidelines on: training of personnel working with animals in science – https://www.ccac.ca/en/training/modules/

For more information, see Canadian Council on Animal Care – Animal Care Committee – and “Terms of Reference for Animal Care Committees” https://www.ccac.ca/en/certification/about-certification/oversight-system.html and CCAC policy statement on: scientific merit and ethical review of animal-based research

Not always –

“Expression of pain and distress is limited or very subtle for many species, and assessment of these states can be imprecise.”

Source:  Canadian Council on Animal Care – Guidelines – “guidelines on: euthanasia of animals used in science”

“Animals such as non-human primates, rodents, rabbits and some livestock may not show many behavioral changes even when in severe pain.”

Source:  Canadian Council on Animal Care – guidelines on: choosing an appropriate endpoint in experiments using animals for research, teaching and testing

The Canadian Council on Animal Care has established “categories of invasiveness in animal experiments” – from Category A to Category E.  These categories indicate the level of pain and/or distress that an animal could potentially be exposed to while undergoing a scientific study.

An example of Category B is:

• “decapitation preceded by sedation or light anesthesia”.

28% of animal experimentation is at this category – 1,300,049 animals (2017).

Category C includes:

• “short periods of food and/or water deprivation which exceed periods of abstinence in nature;
• behavioral experiments on conscious animals that involve short-term, stressful restraint;
• exposure to non-lethal levels of drugs or chemicals”.

44% of animal experimentation is at this category – 2,082,338 animals (2017) .

Category D includes:

• “the exposure of an animal to noxious stimuli from which escape is impossible;
• the production of radiation sickness;
• prolonged (several hours or more) periods of physical restraint;
• induction of behavioral stresses such as maternal deprivation, aggression,    predator-prey interactions;
• procedures which cause severe, persistent or irreversible disruption of sensorimotor organization”.

26% of animal experimentation is at this category – 1,204,079 animals (2017).

Category E  is described as “ Procedures which cause severe pain near, at, or above the pain tolerance threshold of unanesthetized conscious animals and includes:

• “exposure to drugs or chemicals at levels that (may) markedly impair physiological systems and which cause death, severe pain, or extreme distress;  burn or trauma infliction on unanesthetized animals”.

2% of animal experimentation is at this category – a total of 95,144 animals (2017).

See Canadian Council on Animal Care – Fundamental Principles – “categories of invasiveness in animal experiments”

See also Canadian Councilo on Animal Care –  “Facts and Figures”

See also  Canadian Council on Animal Care – Annual Data Reports – CCAC Animal Data Report 2017

Some animals are killed but most are subject to experimentation while alive.  This is called vivisection.

These animals usually killed.  The animals are not sent to sanctuaries or adopted because of the associated cost of veterinary care, housing and transport.

Animals are also killed which have been bred for research, but are subsequently not needed – this is called culling.

Source:  Canadian Council on Animal Care – Guidelines – “guidelines on: euthanasia of animals used in science” https://www.ccac.ca/en/standards/guidelines/general-guidelines.html

The killing of animals is a nasty business – details have been spared here so as not to upset the reader.

The Canadian Council on Animal Care has established guidelines for the euthanasia of animals in experimentation.  Note that these are guidelines only – not legally required standards.

Animal care committees are responsible for approval of the method of euthanasia for any study involving the use of animals.  For limitations on animal care committees, see question below “Can’t we rely on the Canadian Council on Animal Care?

Euthanasia of lab animals is permitted in various ways –

• gassing by inhalation of argon – “pigs and poultry have been shown to enter lethal concentrations of argon for access to rewards”
• stunning using a captive bolt
• concussion stunning (physical shock to the brain) by crushing blow to the head
• penetrating captive bolt or free bullet
• electrical stunning
• cervical dislocation –using one’s hands to snap the neck of the animal
• immersion or injection of benzocaine
• SC injection of barbiturates into lymph sac
• overdose of inhalant anesthetics
• IV or IP injection of barbiturates
• maceration (placement into a high-speed grinder)
• freezing of unhatched bird eggs and fish
• emergency killing of an animal by blunt force trauma, gunshot, potassium chloride injection, etc.

In some circumstances, euthanasia is permitted in other ways:

• gassing by inhalation of carbon dioxide (CO2) – “Once deep anesthesia with markedly suppressed respiration or even respiratory arrest has occurred, CO2 may take a very long time to cause death.”
• Decapitation
• Gun shot

Sometimes animals subject to these methods need to be subjected to a second method to ensure they have really died:

“For some methods of euthanasia (such as CO2 inhalation, stunning using a captive bolt or cervical dislocation), death of the animal should be ensured without it regaining consciousness through application of a second step (e.g., exsanguination, cervical dislocation, decapitation or opening the chest) after application of the primary method of euthanasia.”

Secondary methods of killing an animal include:

• exsanguination is the draining of the blood of an animal
• cervical dislocation (snapping the neck with the hands) – “It is essential to check that the neck is broken at the end of the procedure.”
• decapitation – “Where decapitation is used, blades should be kept very sharp and guillotines should be well maintained and cleaned between uses to prevent transmission of olfactory clues. …. The length of time of residual consciousness experienced by the severed head of an animal following decapitation has been under debate in the scientific literature.”
• pithing to damage the deeper parts of the brain and to prevent convulsions
• delivering compressed air into the cranium
• opening the chest
• opening of the brain
• piercing/severing the spinal code.

To confirm, these secondary methods are applied to animals that may be still alive despite application of the primary method.

Not all methods ensure a quick death – “In general, overdose of an inhalation anesthetic agent is an effective method of euthanasia for many species. However, time to death is quite lengthy, and therefore use of a second procedure to ensure death of the animal is recommended once the animal is unconscious as a result of the anesthetic.”

It is not always known what is a humane method of euthanasia:  “Scientific information on humane methods of killing animals is available for certain species, strains, physiological states (e.g., neonatal or pregnant) and situations; however, conclusive information is not available for all species and situations.”

Lab animals can be very stressed by the euthanasia of others:  “Considerations should be given to circumstances where the method of euthanasia itself, or its application, may result in audible, visual or olfactory alarm signals that might negatively affect other animals in the vicinity. Exposure to alarm signals of other animals may cause stress in some species …… While use of separate rooms is preferred, a separately ventilated hood or cabinet is also acceptable. Ideally, equipment should be thoroughly cleaned between animals to ensure animals are not exposed to residues that may contain olfactory alarm signals.”

There are guidelines for the euthanasia of feutuses and baby animals:  “Neonates should be euthanized immediately after removal from the mother, unless an alternate experimental procedure has been approved by the ACC. When separated from their mother, pups should be provided with supplemental heating …”

Finally, the efficacy of euthanasia methods depends on various circumstances, including worker training and fatigue.  “There may be emotional and psychological effects on the people performing the euthanasia … Some people may raise psychological defense mechanisms that could result in reduced ability to empathize or less respectful handling of the animals.”

There is no standard of training for workers doing euthanasia:  “Institutions are responsible for determining the actual training requirements and the competency of personnel …”

Note:  all underlining is added

Source:  Canadian Council on Animal Care – Guidelines – “guidelines on: euthanasia of animals used in science”

Also see “Frequently Asked Questions for the CCAC guidelines on:  euthanasia of animals used in science” https://www.ccac.ca/en/facts-and-legislation/ccac-facts-and-figures.html

No – unlike most other provinces, BC does not have any legislation which specifically addresses animals acquired and used for scientific purposes.

See Canada Council on Animal Care – General Guidelines – “Procurement of Animals” –

https://www.ccac.ca/en/standards/guidelines/general-guidelines.html

No – the federal government does not have jurisdiction to pass laws that involve experiments on animals.

The federal government merely has an indirect influence over animals in experimentation.

See Canadian Council on Animal Care – “Canadian Legislation and Policies” – https://www.ccac.ca/en/facts-and-legislation/canadian-legislation-and-policies/

All the following information is excerpted from:  Animal Charter – “Animals Used for Experimentation” – “Lack of Oversight and Secrecy” – https://www.animalcharter.ca/experimentation/

[all underining below added]

What is the CCAC?

“The Canadian Council on Animal Care (CCAC) is a non-governmental organization with no legal authority.  All it does is set voluntary guidelines for animal research.”

“The CCAC is run primarily by animal researchers and others who support animal research, including the pharmaceutical industry, medical researchers, universities, the scientific community, and federal granting agencies.”

There is no national coordination by the CCAC to ensure that experiments are not being needlessly duplicated by different labs.

CCAC Has No Power to Enforce

“Because the CCAC has no legal authority, it cannot prosecute labs that inflict illegal distress and suffering upon animals.

Even when the CCAC can influence institutions to, for example, replace animal use with alternatives as per its 3Rs programme, it has failed  to do so.”

CCAC Assessments

“The CCAC conducts its own assessments of animal research labs only once every three years.

Inspections are scheduled well in advance, giving labs ample time to clean up and give the appearance of compliance with CCAC animal care guidelines. If a lab passes inspection, future assessments may be reduced to one visit every five years.

In principle, a lab that is not in compliance may have its research funding cut off, but there is no evidence that this has ever once happened in the 49-year history of the CCAC.”

Animal Care Committees

“Furthermore, the CCAC delegates experiment approval to Animal Care Committees at the research facilities themselves.

“Animal Care Committees (ACCs) are dominated by sympathetic fellow animal researchers and are often eager to approve cruel and questionable experiments; they have the power to exclude or outvote any person on the ACC who disagrees with animal research. There is a very low approval threshold for research projects even when a project causes significant animal suffering. There is no national coordination by the CCAC to ensure that experiments are not being needlessly duplicated by different labs.”

Animal Care Committees are internal groups, basically composed of persons within the research institution itself.  In other words, they are not independent, external groups.

What is striking about the composition of Animal Care Committees is their lack of required expertise.  In fact, what is most striking is the requirement that the members not have expertise with animals!   The Canadian Council on Animal Care website informs that the group should include “a veterinarian, normally experienced in experimental animal care and use.”  Another member should be an “institutional member who does not work with animals”.  Other members should be community representatives who have not done “research, teaching or testing” on animals.  Other members should be students (if applicable).  Other persons who could be members of the Animal Care Committee are “public relations liaisons“.

This lack of expertise is acknowledged in the CCAC policy statement on: scientific merit and ethical review of animal-based research:  “Where ACCs are unfamiliar with the proposed type of work, they are encouraged to seek relevant expertise.”

Animal Care Committees are also responsible for monitoring animal use after approval for an experiment is given.  However, the fact that the Animal Care Committees are not independent external bodies is clearly problematic.  The CCAC acknowledges “collegial working relationships must always be protected and promoted. … Post-approval monitoring procedures must not be cumbersome or intrusive. In fact, the ACCs, veterinarians and animal care staff in most Canadian institutions successfully identify and address most difficulties without ‘policing’, and this collaborative approach must be retained in any post-approval monitoring program.”

Source:  CCAC policy statement for: senior administrators responsible for animal care and use programs.

Shockingly, it is these Animal Care Committees that play a “vital” role in establishing what are called “endpoints”:

“”Endpoint” is defined as the point at which an experimental animal’s pain and/or distress is terminated, minimized or reduced, by taking actions such as killing the animal humanely, terminating a painful procedure, or giving treatment to relieve pain and/or distress.”

“The animal in a moribund state may be past suffering (and actually comotose).  A moribund animal is one that is close to death and may be comatose or unresponsive to stimuli, exhibit .. severe breathing problems, hypothermia, prostration, etc.  However, before the animal gets to the point of being moribund, detailed observations .. can help to set an earlier endpoint ..”.

Source:  Canadian Council on Animal Care – guidelines on: choosing an appropriate endpoint in experiments using animals for research, teaching and testing

To learn more about the limitations of the Canadian Council on Animal Care (CCAC) and Animal Care Committees, see Animal Charter – “Animals Used for Experimentation” – “Lack of Oversight and Secrecy” –

There is no legislative mechanism to find out what happens behind the closed doors of a private research lab.

Labs that receive public funds must be “certified” by the Canadian Council on Animal Care (the CCAC).  However, it is a voluntary body and it has no legal ability to regulate certified laboratories.

There is no public transparency or accountability of CCAC activities. Although it publishes aggregate numbers of research animals, very little additional information is available. Basic information – source of the animals, province where the experiments are conducted, number of animals used, acute verses chronic experiments – is not available.

There is no legal way to compel the CCAC to provide information.  Even though it is  funded by tax dollars, it is not subject to Freedom of Information requests.

Source of all the above information:  Animal Alliance of Canada – Animal Research in Canada – Why Does This Still Happen? https://www.animalalliance.ca/animal-research-canada/

Apparently not.  Information online indicates that the Hospital undertakes research, through the Providence Health Care Research Institute, with approximately a dozen research “partners”.  However, the information sent by the Hospital to the City of Vancouver Planning Department refers only to research by UBC – which is only one of its listed research partners.

The following is the full response which the Hospital sent to the City of Vancouver Planning staff.  Our comments are below.

“It’s a little too early to talk about the precise research plans at the future St. Paul’s Health Campus, as those considerations haven’t been finalized and it’s not determined whether there will be any research activities requiring laboratory animals.  Currently, like any teaching and research hospital in B.C., the UBC research activities at St. Paul’s sometimes include the use of laboratory animals (usually mice) as federal law requires animal models be used to assess new therapies before any human clinical trials may be conducted.  These are important issues that researchers and the provincial and federal governments take seriously.  When fighting diseases like cancer, heart disease or diabetes, and when considering the toll these diseases take on people and families, research plays a critical role, and it needs to be done in an ethical, humane way.

UBC subscribes to replacement with non-animal resources when possible, and a reduction in the number of animals used when it is not.  As new technologies arise, continual refinement takes place.  As we work towards building a new St. Paul’s hospital and any related research facilities, these principles of replacement, reduction and refinement will remain.

All of the research involving animals at UBC and by UBC researchers at other facilities, such as St. Paul’s Hospital, is ultimately aimed at improving human and animal health.  There are numerous safeguards in place to ensure responsible research.  Peer review ensures scientific justification for the use of animals and any procedures must be reviewed and approved by the university’s Animal Care Committee, which has representatives from the public and academic organizations.  In addition, research is carefully reviewed by veterinarians trained in laboratory animal medicine.

For more information, please visit this UBC website: animalresearch.ubc.ca/animal-statistics.html “

Timing:  As mentioned above, if the decision is made after the rezoning  to undertake research with laboratory animals at the new hospital, then the City of Vancouver and its residents will have permanently lost the opportunity to address this issue.

Required by law: Please see information above from the Canadian Council on Animal Care confirming that only 4.7% of animal studies are for regulatory purposes.  This is a very small percentage of all animal experiments.

Furthermore, even though a regulatory authority may initially require animal-based tests, it is possible to seek a waiver in order to use an alternative test method or not produce a data set that the institution considers unnecessary.

“Because regulatory agencies do not always clearly require animal-based tests, and are themselves looking for alternatives to live animal-based tests in several cases, institutions and their ACCs are encouraged to work with regulatory agencies ..”

Source:  Canadian Council on Animal Care – policy statement for: senior administrators responsible for animal care and use programs

In fact, the Canadian Centre for the Validation of Alternative Methods is working in partnership with Canadian regulators—primarily Health Canada—to expedite the development, validation, and regulatory acceptance of new approach methodologies (alternatives to animal testing).

It is also important to realize that,  by the time the hospital is actually open, there will by then be even greater improvements in alternative methods.

Finally, although we are opposed to all animal experimentation, the fact is that there are other locations at which the Hospital’s research partners could undertake this small amount of regulatory testing.

Reference to cancer, heart disease and diabetes:  Please see the materials above regarding the failure of animal research over past decades to result in any cure for the diseases mentioned.

Reference to ethical, humane research:  In light of the materials above, please decide for yourself whether you think animal experimentation is “done in an ethical, humane way”.  If you are in any doubt, please watch “Animal Testing in 60 Seconds Flat” https://www.youtube.com/watch?v=G6cVcGmFm28

Reference to research review:  This appears to indicate that completed research is reviewed by veterinarians.  Review of research after animal experimentation is of no assistance to the animals.

Reference to UBC  Animal Care Committee: The following is a summary of information under the heading above “Can’t we rely on the Canadian Council for Animal Care?”

“Animal Care Committees (ACCs) are dominated by sympathetic fellow animal researchers and are often eager to approve cruel and questionable experiments; they have the power to exclude or outvote any person on the ACC who disagrees with animal research. There is a very low approval threshold for research projects even when a project causes significant animal suffering.”

Furthermore, animal care committees are required to have members with no expertise on animal care or use.

Because animal care committees are not external independent bodies, they are inadequate to monitor animal abuse.   In relation to monitoring, the CCAC mandates:

• the protection and promotion of collegial working relationships,
• monitoring that is not cumbersome or instrustive, and
• a collaborative approach “without policing”.

Reference to peer review: The Hospital’s response mentioned peer review as a way to ensure scientific justification for the use of animals.

The CCAC policy statement on: scientific merit and ethical review of animal-based research does include, as a policy (non-binding recommendation), that there “should be” “an independent, expert peer review of the scientific merit of the research program or project.”

However, nowhere is there any explanation of what is required for an “independent” review or an “expert” review or who could be considered a “peer”.  It is made clear that “it is the institution’s responsibility to develop and implement a mechanism to ensure that proposed research that will involve animals is indepently reviewed for scientific merit by expert peers.”

In other words, “independence”, “expert” and “peers” are whatever the institution decides they are.

It is noteworthy that the purpose of peer review is to consider “scientific merit” – not to consider the appropriateness of animal experimentation. There is no requirement that peer review be done by someone with knowledge of or experience with non-animal experimentation.

Furthermore, if the research funding included a peer-review process, then the above-described process is not required.

Most likely funding would be granted through the Canadian Institutes of Health Research, in which case the purpose of peer review is “to assess the quality and/or potential impact of the proposed research and/or the research related activities, within the context of the funding opportunity objectives and evaluation criteria”.  Proposed research projects are not assessed within the context of the animal experience – in fact, we were not able to find the word “animal” anywhere within the CIHR peer review documentation.

See Canadian Institutes of Health Research:  College of Reviewers Membership Roles and Responsibilities http://www.cihr-irsc.gc.ca/e/50401.html

Policies of other research partners:  The Hospital mentioned the current research policies of UBC, but it did not mention the research policies of its other research partners.  Furthermore, the Hospital has no way of knowing the research policies of its future research partners.

Policies of research partners may change: Whatever policies the research partners may now subscribe to, these may change – perhaps without approval of the Hospital – and perhaps without even notice to the Hospital.

Reminder:  policies are guidelines only – not legal requirements:  As explained above, any policies that a research partner might subscribe to are undoubtedly derivered from the Canadian Council on Animal Care (CCAC) guidelines.  These are recommendations only – they do not have the legal force of law.

Hospital enforcement of policies?:   Since the federal government, the BC government – not even CCAC itself – has the ability to enforce CCAC guidelines, it is highly unlikely that the Hospital would have any avenue of enforcing policies that had been subscribed to by one of its research partners.

Hospital is not promising City it will enforce:  Importantly, even if the Hospital had some way of enforcing research policies subscribed to by its partners, the Hospital is not making any commitment to the City that it will do so.

City cannot enforce research partner policies:  The City of Vancouver has no authority whatsoever to enforce policies subscribed to by the research partners – no matter what happens to the animals in experimentation.

Yes.  Although we are opposed to all animal experimentation, the fact is that the one research partner specifically mentioned by St. Paul’s – namely, UBC – already undertakes animal experimentation on campus.  It is not necessary for animal experimentation to be conducted at the new St. Paul’s Hospital.

The Constitution of the Providence Health Care Society contains the following Mission Statement:

“The Society is a Catholic health care community that respects the sacredness of all aspects of life.  Inspired by the healing ministry of Jesus Christ, the staff, physicans and volunteers are dedicated to service and to the support of one another.  In this environment of service, support and respect, the Society meets the physical, emotional, social and spiritual needs of those served through compassionate care, teaching and research.    This clause is alterable.”

and its Values include:

“Sprituality.  We nurture the God-given creativity, love and compassion that dwells within us all.”

[underlining added]

The Hospital is required by law to comply with its Constitution.  Let’s hold St. Paul’s Hospital accountable to follow its Mission and Values – with loving and compassionate non-animal research.