“I have a cunning plan….”

Institutional 3Rs strategies are not a new thing. NC3Rs has been recommending that all establishments should have one for a number of years. But insofar as we can tell (they are rarely published), only a minority do. At the recent LASA Establishment License Holders forum, we asked people to raise their hands if they had a 3Rs strategy. On a rough count, around 1 in 5 hands went up.

What we didn’t ask, but I suspect would have made the majority of hands go down again, was “how many of those with a 3Rs strategy feel that it adequately addresses Replacement?”

Catch-22

So why am I so pessimistic that anyone has a strategy that properly addresses replacement? Well, the nub of the issue is this:

• 3Rs is a concept that exists in the world of animal research. It is a legal requirement for establishments, written into the ASPA legislation.
• Therefore, 3Rs strategies are usually driven by people who govern or have a key role in animal research within an establishment (heads of biological services facilities, named persons, etc). Let’s call this group A.
• Replacement involves knowing about what is possible in research without animals; the current state of NAMs science. In an institution at the basic level, it involves knowing what animal-free technologies and expertise might be on your doorstep – even within your own department.
• NAMs researchers not using animals (let’s call them group B) may have nothing to do with 3Rs; it could be entirely irrelevant to them, and as we’ve discussed previously, they may have no concept of the technologies they work with being ‘replacements’ at all.
• Group A has no structural power over group B. They can invite them to share their research at, e.g. a 3Rs day or similar, but there is no incentive for them to attend or participate. When we know everyone is extremely time poor, and academics are under huge pressure to get the next grant in, why would they take time out to attend something that doesn’t have a direct relevance to their research?

And herein lies the problem we see time and again. The people trying to develop Institutional 3Rs strategies can only go so far. They can produce detailed and actionable plans on reduction and refinement, but come up short when it comes to replacement.

Which is why leadership is critical, and a theme I will come back to.

What the higher-ups are doing

The same dichotomy has been present within government: the implementation of the 3Rs (of which Replacement is the primary) under ASPA sits with the Home Office, and the development of alternatives sits with DSIT. When I first started this job I wrote to Professor David Main, then Chair of the Animals in Science Committee, to ask how the Committee was staying abreast of the rapidly developing NAMs landscape in order to effectively implement replacement, and received a somewhat frustrating response that the Committee’s work was about “how” animals were used in science not “whether” they were used, exactly illustrating this paradox. As we know Prof Main has since been a great advocate for NAMs and I’m sure has played a key role in influencing the development of the current roadmap, so I’m not picking on him specifically, but just illustrating the point.

So, one of the things that has made me very happy about the new government strategy is the fact that it has addressed this issue of cross-departmental working head-on, with appropriate governance structures in place. There will be ministerial leadership for alternatives, and DSIT will directly feed into the Animals in Science Committee (and vice-versa), ensuring that advice to the Home Office on animal use will include the most up-to-date information about what is possible in relation to alternatives.

But what about you?

The question for establishments then becomes, with the increasing funding for NAMs and increasing political drive to phase out the use of animals, how is this cross-cutting governance being modelled at an institutional level? When the Home Office comes to audit your establishment and AWERB, and asks about strategy, procedures, and activities in respect of replacement, what will you say?