In the Spotlight
UK Home Office adopts ban on the testing of household products on animals and releases first Delivery Report on reducing the use of animals in scientific research
A March 12, 2015 news release by the UK government announced that “testing of household products on animals will be banned.”
This new animal testing ban will come into effect in October 2015. It will apply to all finished household products, including “detergents, polishes and cleaning products, laundry products, air fresheners, deodorants, paints, and other decorating materials,” and to chemicals “primarily intended” for use as an ingredient in household products, meaning that over 50% of their use is intended or expected to be as such.
Dr. Gerry Kenna, scientific director of FRAME, said: “FRAME is delighted to see this change, which could mean a huge reduction in the number of animals used for safety testing each year in the UK.”
Emily McIvor of The Humane Society International gave a more cautious welcome, commenting that: “It is good to see an acknowledgement that animal testing can be prohibited for household products as well as cosmetics, but the exemption for ingredient testing carried out to meet regulatory requirements means that this is a first step, rather than the end of household product testing on animals.”
Home Office minister Lynne Featherstone said, “The ban on the testing of household products and ingredients on animals demonstrates our continuing commitment to safeguard animal welfare and advance the use of the 3Rs principles in research and development. It will also help to ensure the UK stays at the forefront of global work to find and use alternatives to animal testing.”
Exceptions to chemical ingredient testing will include the need to meet other legal requirements. An example might be testing needed for the REACH regulation. Late last year the European Commission and ECHA released clarification on the EU animal testing ban for cosmetics ingredients by saying that “the testing and marketing bans in the Cosmetics Regulation do not apply to testing required for environmental endpoints, exposure of workers, and non-cosmetic uses of substances under REACH.”
The UK is already recognized as a global leader in promoting and adopting the 3Rs (replacing, reducing, and refining animal use). The Home Office announcement explains that this new animal testing ban is part of a series of UK government reforms on animal testing begun in 2010.
Written Ministerial Statements to Parliament from the Home Office on July 18, 2011 explain the coalition government’s agreement on two commitments:
- To end the testing of household products on animals – to be implemented by adding a condition to relevant project licences
- To work to reduce the use of animals in scientific research – through a science-based program by the National Centre for Replacement, Refinement and Reduction of Animals in Research (NC3Rs) in collaboration with government departments and agencies, academia, industry, and other animal welfare interests
Progress on both of these commitments was reported by the Home Office in March 2015. As explained above for the first commitment, the October 2015 animal testing ban on household products was announced on March 12. The publication on March 26 of the Delivery Report, Working to reduce the use of animals in scientific research, updates us on the progress made on the second commitment.
The second commitment was launched in February 2014 with the publication of a Delivery Plan, Working to reduce the use of animals in scientific research. This Plan was developed from the collaborative input of many government departments, and proposed new and existing initiatives for promoting the adoption of scientific and technological advances in support of the 3Rs.
In a government press release announcing the Delivery Plan, Crime Prevention Minister Norman Baker said, “Through our delivery plan, we are showing how alternative methods can provide fast, high-quality research that also boosts economic growth.”
The Delivery Plan starts out by reaffirming the continuing need for the use of animals in scientific research, and explains that the UK’s regulatory system “ensures that animal research and testing is carried out only where no practicable alternative exists, and under controls which keep suffering to a minimum” (p. 7). This goal can be achieved only if the principles of the 3Rs are considered in every research proposal.
The three strategic priorities defined in the Delivery Plan (p. 9), intended to put the 3Rs at the heart of a science-led program, are the following:
- Advancing the use of the 3Rs within the UK
- Using international leadership to influence the uptake and adoption of 3Rs approaches globally
- Promoting an understanding and awareness about the use of animals where no alternatives exist
The first section of the Delivery Plan provides data on the numbers and types of animals used in research over recent decades. The Plan explains, however, that the Government commitment to reducing the use of animals in scientific research “is not focused on baseline numbers which are influenced by a range of extraneous factors” (pp. 7-8). The annually published statistics on the number of animals used in procedures “do[es] not count the number of animals which have not needed to be used as a result of implementing the 3Rs to replace and reduce animal use” (p. 14). Case studies, instead, will be used to monitor success of the proposed approaches/actions in the Delivery Plan in implementing the 3Rs.
Section 2 of the Delivery Plan explains the Government’s proposed actions to address each of the three strategic priorities (defined above), and Section 3 is a series of tables summarizing these actions in detail, including partners, and milestones to evaluate progress. Progress is to be evaluated a year following the launch of the Delivery Plan, and has now been summarized in the recently published Delivery Report.
The March 26, 2015 Delivery Report describes the progress made on the initiatives proposed in the 2014 Delivery Plan. A short section provides an overview of progress on each of the three strategic priorities followed by a series of tables outlining the specific actions taken to implement each of the 3 strategic priorities. Table information in both the Delivery Plan and Delivery Report include these sections: Title/Lead Organization(s), Actions, and Measures of Success and Key Milestones, with the final column “Timelines” in the Plan now shown as “Progress” in the Report.
Summary of progress on strategic priority 1: Advancing the use of the 3Rs in the UK
“Since the Plan was published, a wealth of significant new research and knowledge dissemination on the 3Rs has been completed. It includes the launch of the first products from the NC3Rs open innovation programme CRACK IT, a £4m competition run by Innovate UK and the NC3Rs to fund the commercialisation of non-animal technologies, and the publication of important new studies on veterinary and human vaccine testing by Defra and Public Health England which have identified scope to reduce the numbers of animals used in developing vaccines. New joint working by the RSPCA and the Home Office has additionally produced refined testing models to reduce animal suffering” (p. 3).
Summary of progress on strategic priority 2: Influencing the uptake and adoption of 3Rs approaches globally
“We have taken major steps to encourage greater international adoption of 3Rs techniques, including a ground-breaking programme of knowledge-sharing with regulators and life science associations in China led by the Animals in Science Regulation Unit. In addition, we have published collaborative research across the global life sciences sector led by the NC3Rs and the UK’s Medicines and Healthcare Products Regulatory Agency to minimise the use of recovery animals in pharmaceutical development” (p. 3).
Summary of progress on strategic priority 3: Promoting an understanding and awareness about the use of animals where no alternatives exist
“The use of animals in scientific research rightly attracts considerable attention and scrutiny. The public is entitled to know why such research is carried out, how animal welfare needs are addressed and what steps are being taken to reduce dependence on animal-based research. We are therefore delivering on our commitments to increase openness in the use of animals for research in the UK. In particular, we have consulted on options to reform section 24 of the Animals (Scientific Procedures) Act 1986 to allow greater access to animal research information. Greater openness brings increased opportunities to explain why the carefully regulated use of animals in scientific research remains of vital importance in improving our understanding of human and animal disease, and in ensuring the safety of new medicines” (p. 3).
More details on the specific actions defined for each of the 3 strategic priorities and the progress at one-year can be found on pages 16-33 of the Delivery Report.
The Report states that “We will build on the momentum generated and cross-sector relationships developed through this Plan’s implementation to ensure that the UK stays at the forefront of global efforts to find and use alternatives to animal testing, while continuing to make clear the important benefits that animal research brings to society” (p. 3). It is assumed that annual reports will continue on the Government’s commitment “to work to reduce the use of animals in scientific research,” but that was not made clear in the Home Office documents that were reviewed for this article.
The Humane Society International welcomed the publication of the Delivery Report, commenting: “it is valuable to see the progress that has been made towards the Delivery Plan’s milestones and we hope such reporting will continue to be provided every year going forwards. A critical area where the UK’s influence is needed in promoting uptake of the 3Rs concerns acceptance of alternative methods under the REACH Regulation, so it would be good to see future reports explain further how the UK’s work with the EU Commission and Chemicals Agency is supporting strategic priorities 1 and 2.”