Opinion: Animal welfare legislation misses the mark

Leading animal welfare charities dismissed legislation introduced by Lib Dems in coalition as being not fit for purpose.

The new ban, coming into force in October 2015, will prohibit the testing on animals for finished household products in the UK – but not all their ingredients. The ban will only apply to ingredients where more than half of their usage is expected to be within household products. This is seen as a considerable u-turn by then Home Office Minister Lynne Featherstone, who announced in 2011 that the ban would ‘apply to both finished household products and their ingredients, although in practice mainly the latter are tested.’ As Mimi Bekhechi, director of PETA, confirmed, ‘finished products themselves have not been tested on animals in Britain since 2010’ meaning the ban will have very limited impact.

The dilution of this legislation, a key part of the Lib Dems’ work for animal welfare while in government, will represent a black mark against the party among charities and groups that once regarded Lib Dem MPs as the most animal friendly within parliament. It also leaves the UK lagging behind other countries such as Israel, India and New Zealand in terms of protection for animals used in research.

It’s difficult to know why Lynne and her team chose to introduce the legislation in this form, what pressures were upon them in coalition, and what else was going on in the background. Norman Baker’s resignation could definitely have had an impact, given his very active role in driving this policy within the party. Either way, I would suggest that a dedicated working group on animal welfare within the Lib Dems, such as what Labour has, would surely have been an asset in supporting this work within government.

With a fresh start for the party after its devastating election defeat, and a new pledge by the EU to move towards phasing out all animal testing, there’s an opportunity for the Lib Dems to be seen to lead the charge on tackling animal welfare issues in general within the UK. Some of us within the party have set up an informal facebook group where members with an interest in developing animal welfare policy can share ideas. We’re hoping that this can be a first step to achieving a dedicated Lib Dem animal welfare working group, and any members reading this who share a similar interest would be most welcome to join us.

* Wayne Simmons is a journalist, novelist and dog walker from Northern Ireland, now living in Cardiff. A former Lib Dem, who co-founded the LD Animal Welfare group ((http://www.facebook.com/groups/LDAnimalWelfareGroup), he is now a member of the Animal Welfare Party (http://www.animalwelfareparty.org). Find Wayne at his blog (www.waynesimmons.org).

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25 Comments

  • I agree with you, we do need to be doing more to stop the testing of chemicals on animals. They did not offer to be test subjects, just as most humans do not wish to be test subjects. A great deal if work has been done, but so much more needs to be done too.

  • It is pretty obvious why the ban takes this form Wayne. Everything in the world is made of chemicals, so cleaning products will have ‘chemicals’ in them which have a variety of uses not for cleaning purposes. If the primary use of a chemical is for cleaning then, yes it will be banned. If it’s something that appears in lots of things, no it will not be because we need to know, say, if it’s carcinogenic or what to do if Fred at the factory falls in a vat of it, or little Johnny presents at A&E having downed a litre of it. In practice, we’re talking about very few if any experiments in a typical year for this purpose, as we can see even without restrictions they haven’t happened at all since 2010 and haven’t been widespread since 2002.

    We should also be cautious that animal welfare means animal welfare, not banning scientific experiments on the basis of dubious campaigner claims. it is already against the law to use an animal if there is a whizzy computer program, human tissue or tech solution. There is a world of difference in making sure an animal receives good welfare standards in a lab, and banning it, transferring suffering from mouse to man.

  • The Liberal Democrats must, in all areas of science, be led by the evidence. We have received much support from the scientific community for this approach to scientific issues from drug policy, to climate change. Animal welfare must be no different.

    The “dilution” of the Liberal Democrat policy on household product chemicals must be no different. For instance, if a chemical is primarily used in, say, pesticides, but also turns up in a household product, then we must ensure that the chemical would not prove dangerous to fish or birds. What if a household chemical was also a component in a medical treatment, should we be prevented on testing it?

    This reflects the policy of other countries you mention. India has removed the requirement to test household product chemicals on animals, it has not prevented those same chemicals being tested if they are primarily being used for another purpose.

    The EU has not made any new pledge to phase out animal tests – that has been written into the animal research EU Directive since it began its life in 2010. The only recent development was the EU rejecting the ‘Stop Vivisection’ ECI which aimed to repeal Directive 2010/63/EU, in what appeared to be an attempt to prevent animal research across the EU.
    http://speakingofresearch.com/2015/06/03/european-commission-rejects-stop-vivisection-initiative/

    While I welcome improvements in lab animal welfare – an area where the UK is one of the leading figures (but not without some room for improvement) – it must be based on evidence. Animals remain a key part of medical development, and a rush to outlaw this component would damage medical progress in this country, drive such research abroad to countries with lower standards, and put the health of the nation at risk.

    Tom Holder
    Lib Dem 2015 PPC for Greenwich and Woolwich

  • Listen to Tom Holder. That is a very wise comment.

  • @MarkWright.

    It is definitely necessary to look at the wider issues. Though it would be unlikely any kind of bleach product would be tested on animals (at least not in the last 20 years). We already use many non-animal methods to check if something is dangerous – these are used before any animal tests.

    For household products, animal tests are not required, and since 2011 the Government has had a policy ban not to license any tests for household product purposes. However, if the primary use of a chemical is not household, but for medical or environmental product then sometimes we will need to use animals.

    To give everyone some perspective, here are the number of animals used in testing Household products OR their ingredients for the past 10 years:
    2014 = 0
    2013 = 0
    2012 = 0
    2011 = 0
    2010 = 24 (all rats)
    2009 = 0
    2008 = 132 (all mice)
    2007 = 1 (rabbit)
    2006 = 0
    2005 = 111 (mice and rats)

  • I appreciate that animal testing is a rather contraversial issue and quite complex, too. Regarding current legaislation and science, you’ll all probably be more clued in than I am. From my gut, though, I feel that it is totally unethical for us as a species to use another species for research that we ourselves would not volunteer for. Especially when such research involves high levels of pain and suffering as testing re: household products can involve (http://www.animalaid.org.uk/…/CAMP…/experiments/ALL/303/).

    I feel that an animal’s life/ comfort far outweighs the corporate interests in a company developing some new version of a product we already have a thousand versions of already. I feel that objecting to such development, based on an animal’s right to live a free and uninterrupted life, is something that liberals, who value protections for human life so vehmently, should be party to.

    To summarise my perspective, I believe that ethical standards re: animal welfare should trump corporate interests in the development of solely market-driven household products. Other research methods should be looked to if necessary. Using animals in this way is simply not acceptable.

    That all said, I want to highlight that the animal welfare facebook group that we’ve set up is not solely concerned with animal testing – it deals with the wider arena of animal welfare. We’re all going to have different views and different areas we are particularly concerned with, but will share the common goal of promoting animal welfare within the party. I look forward to meeting some of you in the group which, for your convenience, I will also link here:

    https://www.facebook.com/groups/LDAnimalWelfareGroup/

  • I strongly agree with Tom Holder.

  • Mark, you’re now talking of medical research while the whole thrust of this article is about household products.

    But as you’re asking, I donate to/ support the work of Dr Hadwen Trust who fund and foster the use of new medical research that doesn’t involve animals: http://www.drhadwentrust.org

  • Not to be pedantic, Mark, but I said:

    ‘From my gut, though, I feel that it is totally unethical for us as a species to use another species for research that we ourselves would not volunteer for. Especially when such research involves high levels of pain and suffering as testing re: household products can involve…’

    To which you jumped in with:

    ‘So will you be volunteering to be a test subject for organ transplants? Or will you instead turn down an organ transplant for your loved ones and let them die if you ever have to make that decision for them?’

  • I’m afraid that groups like Animal Aid simply don’t have the backing of the scientific community. In the last 10 years in the UK there have been 267 mice and rats and 1 rabbit used in household product/ingredient tests, yet the animal aid page has two pictures of rabbits and one of guinea pigs – which is hardly an accurate picture of the situation. Their claims that the science doesn’t translate is the same science they’ve argued for years and the scientific community isn’t buying it. It is important that the Liberal Democrats support the scientists.

    Furthermore, Wayne, I appreciate the ethical point you are standing on, but you are missing the point on household testing. Household product testing HAS BEEN BANNED. It hasn’t been done since 2010. What the Government is being careful of, is that they don’t prevent medical, veterinary or agricultural products being tested on animals JUST BECAUSE one of the chemicals also happens to be in a household product.

    The Dr Hadwen Trust does some great research, but it is very far from having any serious impact on the amount of animal research in this country. Scientific questions are varied, and non-animal methods need to be developed for each of these types of questions. Animals are very versatile (more so since the development of transgenic animals, which now account for around 60% of animal experiments) and so have many applications. That said, there is huge amounts of research being done with cell cultures, computers, and other non-animal methods – it’s just that sometimes you need a living, biological model to understand living, biological problems.

  • Tom Holder

    That said, there is huge amounts of research being done with cell cultures, computers, and other non-animal methods – it’s just that sometimes you need a living, biological model to understand living, biological problems.

    Worth pointing out that all of these will never substitute for animals in many experiments. You cannot model a complex living organism until you understand every component, and that requires the use of the animal. Having an end point of no animal experiments is simply an impossible demand if you wish to continue scientific research.

    Also, a lot of animal rights activists suggest using cell culture instead of animals, aside from the fact that these have severe limitations if you want to study an organism wide process, they also require the use of vast amounts of foetal bovine serum, amongst other animal reagents, so animals are still being sacrificed for use in science.

  • ‘In the last 10 years in the UK there have been 267 mice and rats and 1 rabbit used in household product/ingredient.’

    In my view, that’s 268 animals too many – especially when you’re justifying such in terms of the development of new versions/ brands of household products we clearly have a plethora of already. You wouldn’t justify the loss/ suffering of human life in those terms. And yet, from my experience of working with animals every day, I can assure you that all creatures great and small, to coin a phrase, have feelings, hopes and fears like us. We are animals too, remember.

    I think the main problem, Tom, is that we are coming from completely different POVs in this debate with different aims. You’re an apologist for science and seek to celebrate the use of animals to forward scientific research with a much lower threshold for animal suffering than what I have. On your website you describe yourself as pro-test. I am anti-testing and will seek to celebrate animal life and defend an animal’s right to the same freedoms that liberals vehemently afford humans. I think we are diametrically opposed in terms of our principles within this debate.

  • waybne simmons

    You’re an apologist for science and seek to celebrate the use of animals to forward scientific research with a much lower threshold for animal suffering than what I have.

    If you’re serious, you’d focus your attention on the welfare standards for animals in farming, not science. The latter is much, much higher. Simply ending intensive farming of chickens in the UK would do more to ease animal suffering than banning animal research across the entire world.

    Are you sure some deeper anti-science prejudice isn’t driving you here?

  • Hey wayne,

    I’m not diametrically opposed to your point here. I’m a lifelong vegetarian, animal-lover sort, but I do agree with many of Tom’s points and his statistics have been great. If zero animals have been killed in the UK for household testing over the past 5 years, I’d say that the likes of you and I have largely won that part of the UK debate. 45,000 badgers get run over by cars every year, so I’m reluctant to focus on 268 animal deaths from the 5 years prior to stopping household testing.

    Incidentally, I’ve got a friend who does household product allergy testing trials, he loves it! There’s no need to use animals to test cosmetics, cleaning products, etc, but since we don’t, there’s not really an issue.

  • Some agreement, some disagreement. Yes, 268 animals is too many – which is why I’m glad we have banned household product testing. However, if the primary purpose of a product is NOT household (perhaps it is veterinary, medical or relating to the environment), then we should not prevent its safety being properly evaluated because of an overzealous implementation of the household product ban.

    “I can assure you that all creatures great and small, to coin a phrase, have feelings, hopes and fears like us”
    There is no scientific basis for this statement.
    Animals DO feel fear. They DO suffer. They DO feel affection etc., but it is going beyond what we know scientifically to say either (a) they feel those emotions in the same manner we do or (b) they have the full range and extent of human emotion. There is a sliding scale of animal consciousness and there are scientific indicators for this.
    We can be pretty sure many animals do NOT have those emotions. For example, a pond snail has 11,000 neurons in its entire body. You have around 100 million neurons in your gut, and 86 billion neurons in your brain. A pond snail does not have the biological complexity necessary for feeling the sensation of pain (they may have nociception – the ability to recognize negative stimuli – but pain requires processing of these noxious signals).
    On the other hand elephants, dolphins and chimpanzees are much more complex and can feel not only pain, but a large range of emotions as well (though that does not mean they feel them in the same way to humans – we should not anthropomorphize). Therefore the Lib Dems, when making policy, should do so on the basis of the needs of these animals. We understand cetaceans (dolphins and whales) can suffer a lot by being kept in small enclosures, so we don’t allow it (in UK law) – this is evidence based animal welfare policy, and something the Lib Dems should embrace.

    Now mice and rats can suffer, though there are differences between their suffering and ours. A mouse will not know in advance that an injection’s pain is momentary, while a human can, on the other hand there is greater complexity in the mental anguish that can accompany, precede, and follow, physical pain for humans. That said, as we understand more about the physiology of different animals (and indeed about the nature of consciousness), we will continue to understand more about how to best care for the needs of these animals.

    We also need to the tools to fight human and animal ailments, and animal studies play a part in this process. We use lots of methods – computer simulations, cell cultures, mechanical models, human studies – but sometimes a whole, living organism is needed to answer questions we must answer, and sometimes that means using animals in a careful and regulated manner.

    I am an unapologetic animal welfarist. I’m a big supporter of the 3Rs – replacement, reduction and refinement of animals in research – but I am not an animal rightist. I care more that we meet the specific welfare needs of animals than fighting an ideological battle over rights.

  • G:

    ‘If you’re serious, you’d focus your attention on the welfare standards for animals in farming, not science.’

    What, is it an either/ or?

    ‘Are you sure some deeper anti-science prejudice isn’t driving you here?’

    No, what’s driving me is a respect for the welfare and rights of animals.

    ChrisB:

    ‘45,000 badgers get run over by cars every year, so I’m reluctant to focus on 268 animal deaths from the 5 years prior to stopping household testing. ‘

    Again, we wouldn’t use these broad stroke comparisons when talking about human life, or analyse pain in the way Tom has to justify suffering, so why is it seen as acceptable to do so when talking about animal life? For me, it isn’t acceptable.

  • ‘Are you seriously saying that you think we wouldn’t argue its better to focus our time on causes of death and suffering in humans that affect the most people? Have you ever heard of nasopharyngeal cancer? Probably not, because it’s a minor cancer that doesn’t kill many people, but has elevated risk among people who work in sawmills. Have you ever heard of lung cancer? Probably, because it’s a major cancer that kills thousands. Spend time and money in the area that will save the most lives and suffering – this applies to humans and animals.’

    I hadn’t heard of nasopharyngeal cancer, Mark. But I’m sure the family of someone affected by it are very much aware of it and campaigning bitterly to raises its awareness among medical professionals and politicians, such as your self, sir. My point is that it would be highly inappropriate for you to turn to one of those family members and say, ‘Actually, I don’t think that type of cancer is very important, in the scale of things. I think we should spend time and money in the area that will save the most lives and suffering and, well, it just doesn’t apply to you, unfortunately.’

  • Some good discussion points on this subject coming out of the facebook group that I thought would be good to share here:

    Despite Cosmetic testing being outlawed in EU in 2013, they do still test chemicals that may be an ingredient of those cosmetics, to comply with REACH regulations .

    As with cosmetic chemical testing, household products ingredients will be tested to comply with REACH and there is no separate figures for that. They will be amongst the ‘toxicolgy’ testing figures which means that Tom’s 268 figure from the Home Office stats is not an accurate picture of how many animals are actually tested on re: household products.

    As a general point, we’re also discussing the tories’ attempt to repeal the fox hunting ban and where our PMs stand on that issue.

    In addition, I’m delighted to say that both leadership candidates have joined the facebook group. You can too by following the below link:

    https://www.facebook.com/groups/LDAnimalWelfareGroup/

    Again, I’d like to

  • Whoops! Hit the post button there too soon 🙂

    More info on REACH for those unclear on their role:

    ‘REACH is a European Union regulation concerning the Registration, Evaluation, Authorisation and restriction of Chemicals.’

    http://www.hse.gov.uk/reach/whatisreach.htm

  • It’s worth clarifying this situation with REACH and cosmetic/household ingredients. It is about testing chemicals that appear in all areas of human use which we have no safety data for. This work is being done by countries across the EU to come up with a central database. The EU wants to know things like, whether an everyday chemical be carcinogenic or otherwise toxic.

    In the UK, you cannot test a new chemical because you intend to put it in a household product or cosmetic product. In the EU you cannot test any new chemical because you intend to put it in a cosmetic product. A chemical which appears in a medical product may be tested on an animal, and then at a later date someone might put it in a cosmetic, but this would not require further animal tests. So while an ingredient in a cosmetic may have been tested on an animal, it was not tested because it was in a cosmetic. As a parallel, if a researcher does an animal test on water to look at its effects on the liver, we would not regard this as a cosmetic/household ingredient test despite the fact water appears in most cosmetics/household products (and most medical/veterinary/agricultural chemicals).

    268 is a precisely accurate figure for the number of animals used to test ingredients intended for household products. That number has been 0 for the last 4 years, and will be 0 from now on thanks to a legal change implemented by the Liberal Democrats.

  • @wayne

    >we wouldn’t use these broad stroke comparisons when talking about human life,
    >or analyse pain in the way Tom has to justify suffering, so why is it seen as acceptable
    >to do so when talking about animal life? For me, it isn’t acceptable.

    Of course we would; if 45,000 kids a year were dying from problem A or 268 kids died over 5 years, 5 years ago from problem B, we’d hopefully focus on problem A (or we’d probably be extinct). Surely identifying and dealing with the biggest and most immediate problems would be the best approach to reducing animal suffering as a whole? In life and death scenarios often the kindest thing you can do is calculate well, to save the greatest number of people or reduce pain/suffering by the largest amount possible (“the needs of the many…” as Spock would have it). Or..:

    “I regard utility as the ultimate appeal on all ethical questions; but it must be utility in the largest sense, grounded on the permanent interests of man as a progressive being” – Mill, On Liberty

    The point you made about cancer is how rare cancer funding works in the UK much of the time to my understanding. A friend had a very rare form of nervous system cancer ~2 years ago, there had been no research into it and she was told she’d probably be dead in 7 months (but they’d only seen 1 other case, and that’s where all the info was coming from). They took a gamble and chucked many different treatments at her simultaneously (developed from fighting more common types of cancer), it worked and today she’s clear (and a research subject). We don’t phrase it quite in the manner you suggest, but ultimately that is the current position (unless you’ve got a few million to throw at the edge of it), you get told you’re going to die and they allocate a limited budget trying to stop that. Highly inappropriate or not, this is the world we’re living in so I don’t accept your argument.

    I’ve been protesting animal testing for the best part of 25 years, I’ve been arrested, threatened with loaded rifles but the law and public attitude have changed and the situation is far better than it was in the 80’s. I think there are bigger current issues of animal welfare to address and we should look for ways to maximise your stated utility.

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