Independent External Review of the Operations of Institutions that use Animals for Scientific Purposes

As outlined in Chapter 6 of the Australian Code for the Care and Use of Animals for Scientific Purposes (The Code), every four years James Cook University conducts an external review of its Animal Ethics Committee (AEC) and animal operations. The review is conducted by an external panel of specialist professionals with experience in conducting compliance audits, animal ethics, animal care and husbandry, animal research legislation and the Code, veterinary science and animal welfare.

In December 2020, JCU commissioned Scientific Auditing Services Pty Ltd to conduct an external review. The review included:

• A desk-top assessment of the policies, procedures, forms and records selected from the years 2017 – 2021 were provided for review by the JCU to provide an overview of the institutional program governing the care and use of animals for scientific purposes;
• Discussions with the Animal Ethics administrative team, AEC Chair and members, animal facility managers and staff, investigators to provide detail in regard to the processes involved in the Animal Ethics Framework. (2nd, 3rd and 4th of December, 2020);
• Attendance at an Animal Ethics Committee (AEC) meeting to demonstrate the process of ethical review and monitoring of projects. (3rd of December, 2020);
• An on-site inspection of JCU’s animal facilities and animals at the Townsville and Cairns campuses.

Findings

The independent external review concluded that ‘JCU has achieved a very high level of conformance with the Code’. The review panel’s conclusion was based on the review findings identified during the review, which are summarised below.

The review panel commended the University for promoting the governing principles of the Code within the institution, the continual program of improvement of the animal ethics system, the program to ensure those working with animals are competent in the procedures they undertake, the high level of commitment of the animal facility staff for the animals they care for, as well as for promoting responsible and ethical animal use for scientific purposes through its commitment to achieving a high level of compliance to the Code.

Recommendation 1

Institutions should consider making publicly available an annual report of compliance with the Code and a summary of the independent external review report.

Recommendation 2

JCU should appoint an animal care representative to the AEC.

Recommendation 3

The University should provide additional hours to the position of animal ethics officer to ensure there is sufficient allowance to include development to improve the AEC processes and support.

Recommendation 4

JCU should, for transparency record the make-up of the Executive Committee in the agenda or minutes for Ratification of Executive decisions.

Recommendation 5

JCU should provide extra resources if necessary to manage SOPs to ensure only approved SOPs are available for use by investigators and animal facilities and continue with the review of SOPs to ensure they are best practice and approved for use.

Recommendation 6

The University should ensure there is a meeting between the institution and the AEC Chair and Manager Animal Welfare and Research Ethics to discuss the operations of the AEC and it is recorded in the minutes.

Recommendation 7

The Chair should ensure all annual and final project reports are discussed in the meeting and the outcome of deliberations noted in the minutes.

Recommendation 8

JCU should include a Category C-Animal Welfare or D-Community Lay members in all inspections of animal facilities and projects or activities.

Recommendation 9

JCU should consider more serious penalties under institutional guidelines in regard to discipline that may impact the performance of the individual or group.

Recommendation 10

The University should ensure that access is provided to approved project protocols to all animal facility staff.

Recommendation 11

The AEC application should be amended to:

• Specifically request how the design of the project will meet its aims;
• Requests a description of the steps taken to consider and apply the 3Rs;
• Request details and justification for the care and management of animals that does not accord with current best practice.

Recommendation 12

Amend the animal rehoming policy to include appropriate conditions for animal transport between facilities.

Response

JCU accepts Recommendation 3 in principle, however this is unlikely to be actioned until current budgetary pressures ease, however JCU accepts the remaining recommendations and is well advanced implementing the recommended changes.