Correspondence

Letter from Lord Sharpe of Epsom with a forward commission for advice in 2024

Published 6 March 2024

This was published under the 2022 to 2024 Sunak Conservative government

Lord Sharpe of Epsom OBE
Parliamentary Under Secretary of State
2 Marsham Street
London
SW1P 4DF

Professor David Main Chair of the Animals in Science Committee Animals in Science Committee Secretariat 40 Wellesley Road Croydon CR9 2BY $A

29 February 2024

Dear Professor Main,

Animals in Science Committee – forward look commission for advice

Thank you for the recent work of the Animals in Science Committee and for your leadership in delivering advice through a range of important reports that have assisted in shaping our policies on animals in science regulation. I wish to express particular thanks for the service of those members who have recently completed their terms with the committee. I also welcome the newly appointed members who will bring a wealth of experience that I am confident will strengthen the committee’s independent advice to the government.

This government champions good science and the protection of animals used in science. The Minister for Science, Research and Innovation recently announced that he will bring forward a plan to accelerate the development, validation and uptake of technologies and methods to reduce reliance on the use of animals in science. This is a major step forward and follows cross-government work led by the Home Office to ensure all parts of government share our focus on advancing UK science whilst protecting animals. The Home Office will continue to play an active role in supporting the Department for Science, Innovation and Technology in their development of the plan and ensure the committee are engaged in the process.

As Home Office Minister, I am determined that Great Britain continues to lead the world in its regulation of animals in science. To do this we must be unrelenting in our drive for continuous improvement – this is our duty so we continue to fulfil our responsibilities to the public.

In the past 18 months we have embedded a new policy function, with new and improved ways of working with the regulator, across government, with stakeholders, and with the committee. This has supported high quality, evidence based and stakeholder informed policy development.

With consultation and advice from the committee, we have:

• clarified policy responsibilities for the use of animals in science across government departments, enabling accountability
• enhanced our engagement with stakeholders to ensure policy is informed by the full range of views
• commissioned the committee for advice using a new commissioning model that delivers greater clarity and transparency
• implemented a licensing ban to ensure that no chemicals exclusively used in cosmetics can be tested on animals in Great Britain, departing from the EU
• committed to restate retained EU law in the Animals (Scientific Procedures) Act 1986 (ASPA), which will maintain protections for animals and improve the clarity of UK law
• issued a call for evidence on the use of decapods in science to inform future regulation options; and
• published guidance with a clear and robust governance framework for training and continuing professional development of those using animals in science

I have been grateful too for the committee’s support and feedback on the development of reforms in the animals in science Regulator. By continuing to drive improvement within the Regulator, the Home Office will best deliver its purpose of protecting animals in science by maintaining compliance with ASPA. In addition, by reviewing and optimising our regulatory processes, we strive to continuously improve the quality of the service provided to the regulated sector to facilitate scientific progress. This will ensure the Regulator remains at the forefront of leading practice regulation that can adapt to the changing environment in which we operate. We have conducted a comprehensive review of the Regulator’s current and desired future state, with valuable input from stakeholders and the committee. In 2024, we will implement reforms to enhance the Regulator’s operations for the benefit of animals, the public and the regulated sector.

I have been pleased to see that the committee is also committed to continuous improvement. Under your leadership, the committee is developing a more strategic focus and is successfully implementing new ways of working, including enhanced evidence gathering from stakeholders to support robust advice.

The committee has provided advice on a range of important issues over the past 18 months, responding to commissions from the government on: a strategic review of antibody licences, non-human primates bred for use in scientific procedures, and the forced swim test. This is in addition to the committee’s advice on specific project licences and the committee’s valued input on policy development and regulatory reform. I know the committee has also supported the upskilling of animal welfare and ethical review bodies through a series of workshops.

I was pleased to accept the committee’s recommendations on antibody licences and the regulator has since implemented all of the short-term actions to address those recommendations. I look forward to responding to the committee’s advice on non-human primates and the forced swim test in early 2024.

Advice to inform policy and regulation

In accordance with Section 20(1) of ASPA, I am writing to you, in your capacity as Chair of the Animals in Science Committee, to commission advice to be developed over the next 12 months, to the end of 2024. The committee’s advice will inform government policy and direction on the regulation of the use of animals in scientific procedures. I may commission further advice during this period if required.

A detailed commissioning document setting out the issue and scope for the committee will be provided for each commission of advice. In keeping with Section 20(2) of ASPA, the committee is asked to have regard both to the legitimate requirements of science and industry and to the protection of animals against avoidable suffering and unnecessary use in scientific procedures. The priority areas for advice are:

1. Future regulation of decapods. The government has recognised the sentience of decapods (e.g., shrimps, lobsters, crabs) through their inclusion in the Animal Welfare (Sentience) Act 2022. I would like the committee to provide advice on the implications for ASPA. The advice will draw upon our recent call for evidence concerning the scope of use of decapods in UK science.

2. Ensure non-technical summaries (NTS) and retrospective assessments (RAs) deliver optimal transparency and learning. NTS and RAs are key for transparency around the use of animals in science. I would like advice from the committee on how these important summaries of licenced work under ASPA can best serve their purpose to inform the public and enable learning to support the 3Rs (replacement, reduction and refinement).

3. Strengthen leading practice for the regulated sector. The effective development and dissemination of leading practice on the 3Rs is critical for the regulated sector to fulfil their regulatory obligations and to support new developments in protecting animals used in science. I would welcome advice from the committee on how the science sector, including representative bodies, the National Centre for the 3Rs, and others, can best collaborate to this end.

4. Strengthen regulated establishment governance through a review of best practice for animal welfare and ethical review bodies (AWERBs) and named roles. Strong governance in regulated establishments is critical for the effective day-to-day delivery of the 3Rs and protection of animals used in science. The committee’s advice will inform leading practice by the regulated sector, Home Office guidance and effective audit by the Regulator.

Other issues on which the committee will be engaged

My officials will also engage the committee, in addition to the wider stakeholder community, on issues relating to the regulation of animals in scientific procedures, notably:

a. reforms for the animals in science Regulator

b. updating the ASPA guidance and code of practice

c. improving the utility of the annual statistics

d. the implications of the Genetic Technology (Precision Breeding) Act 2023 for ASPA

e. cross-government approaches to the promotion and adoption of alternatives to the use of animals in scientific procedures.

I value the committee’s advice, which will inform the science sector as well as our policies and reforms, as we collectively deliver on the intent of ASPA – enabling the UK to be at the forefront of global science, with the benefits that brings for humans, animals, the environment and the economy; while ensuring animals are protected and, increasingly, alternatives are used.

Yours Sincerely,

[signed]

Lord Sharpe of Epsom OBE

Parliamentary Undersecretary of State

Home Office