Existing Regulatory Apparatus at Queen’s

Oversight of animal research at Queen’s is entrusted to the “University Animal Care Committee” (UACC), which reviews all experiments involving animals. Direct care and monitoring of animals is conducted by the University Veterinarian, who oversees the general living conditions and health of animals (ensuring that they have adequate food, shelter, warmth, medical treatment, etc.), and monitors experiments to ensure that protocols are followed, and unexpected outcomes affecting animals are responded to. The Office of the Vet also oversees the animal “care” course that all animal researchers are required to take. The course has a module on ethics and the 3Rs, but is focused primarily on techniques for handling and killing animals. As noted by University of Alberta lab director Pat Milke, “death is usually the way out”, for lab animals, whether by guillotine, gassing, cervical dislocation (breaking the neck), or barbiturate injection.

The Canadian Council of Animal Care (CCAC) is a national body which sets voluntary guidelines for animals used in university research (research in private labs is completely unregulated). CCAC inspection of university labs occurs every 3-5 years, and visits are always announced well in advance. Findings are not public, and no research facility has ever been denied accreditation or funding. The CCAC has fought every attempt to make its workings open to public review (although federally funded, it is shielded from freedom of information legislation). And far from standing up for animals, the CCAC actually intervened to oppose efforts by the Federal Government (under the Liberals) to modestly strengthen Canada’s woefully outdated anti-cruelty legislation. As many critics have noted, the role of the CCAC is to give the illusion of oversight, allowing researchers and universities to hide behind an imaginary regulatory apparatus. (Canadian scientist Sam Revusky, who experimented on rats for 20 years, describes the CCAC as a “secret society” used as “a public relations ploy against animal activists.”) However, by invoking the CCAC, researchers can side-step any need to explain or justify the ethics of their research. If you read a published study by a Queen’s animal researcher, it will typically contain a statement like this: “The animal care practices and experimental protocol were approved by the Animal Care Committee of Queen’s University and conformed to the guidelines of the Canadian Council of Animal Care.” Beyond this statement, the paper will not contain any discussion of the ethics of using animals for the study, what alternatives were considered, or how the animals themselves might experience what happens to them.

The UACC, in line with the (voluntary) guidelines of the Canadian Council of Animal Care (CCAC), is supposed to be committed to the 3Rs (to replace, reduce and refine the use of animals in research). But here is the problem. By the time the UACC reviews an experimental protocol, the basic parameters of the research, including its use of animals, are already fixed. The research proposal has already undergone peer review, and has garnered funding from the Federal Government (typically through the National Institutes of Health Research or Natural Sciences and Engineering Research Council), private companies, or non-profits (like medical charities) – often to the tune of tens or hundreds of thousands of dollars. The problem is that up to this point, nobody has done an ethical review of the research in terms of animal use. The peer review process is concerned with the question of whether the experimental procedure is scientifically valid and will procure the intended results, not whether it is ethically justified. So once the proposal reaches the UACC, it has already been deemed scientifically valid. But this, in turn, is interpreted to mean that the committee cannot address the first, and most critical “R”, which is to replace the use of animals. The best that the UACC can do is to try to reduce the number of animals used (Could you achieve the necessary results by using 12 monkeys instead of 15?), or to refine the procedures used (Could you reduce the number of days the monkeys are starved and still meet the objectives of the research?) This is the fundamental problem, then. The system is supposed to be committed to replacing the use of animals in research, but there is no step in the existing review and oversight process that examines the issue of replacement, or is tasked to ask the following key questions:

  1. Is this research question so vital to advancing scientific knowledge that it warrants harming innocent and non-consenting individuals?;
  2. Are there alternative ways to answer this research question?;
  3. Could the researchers devote some of their funds to finding an alternative way to answer this research question before proceeding?;
  4. Even if this is a vital research question, could the funds be used to support research that is equally vital but does not involve harm to animals? Indeed, according to Canadian scientist Sam Revusky, it’s easy for scientists to circumvent the CCAC, and in all of his years involved with the CCAC he never knew of a single scientist “who ever explicitly sought alternatives to animal use, as allegedly required.”

In addition to being fundamentally compromised by its limited mandate, the UACC has two additional fundamental flaws. First of all, most of the members of the Committee are themselves engaged in animal research, and/or have a direct interest in not challenging the existing ethos and procedures. Only one member of the committee is required to be at arm’s length from the animal research community. Furthermore, the discussions and findings of the Committee are confidential, so members of the Queen’s community, and Canadian citizens more generally (who fund the research) have no way to monitor, analyze, or challenge the deliberations of UACCs at Queen’s or any other university. The research community says “just trust us”.

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