Minister reveals no animal testing licences are refused

A recent statement by Home Office Minister Lynne Featherstone reveals that a staggering 9908 out of 9908 animal research licence applications were approved by the Home Office between 2008 and 2010. These include:

• personal licences authorising an individual to perform specific procedures on animals
• project licences – the most important – which specifically authorise a programme of experiments
• certificates of designation that authorise an establishment to be a location for animal experiments

The Minister claims that pre-application advice (a traditional Home Office line in relation to their high approval rates) effectively weeds out weak applications. But as I explain below, this cannot really account for this extraordinary phenomenon, as in practice Inspectors don’t have a great deal of time for pre-application discussion, so there’s no way on earth it could so effective. (I don’t think any pre-application advice process could be that effective!)

A look at Inspectorate resources provides clues to this 100% approval rate.

Pages 6 and 7 of the 2010 Inspectorate report is revealing. It refers to the Inspectorate providing advice on 44 project licence pre-applications that were not proceeded with. It doesn’t say why they were not proceeded with – so presumably not all were halted due to advice of likely refusal. Also, it doesn’t say how many pre-applications were advised upon in total.

Each Inspector (or full-time equivalent FTE) deals with an average of 394.5 licence applications and amendments per year. The Home Office states that a third of their time is spent on all licensing (personal, project and establishment) so that’s about 78 days per year – about 5 licence applications/amendments per day. The Home Office say project licence assessment is the most time consuming, so we’ll estimate half of licensing time is spent on project licences. These normally last 5 years and, I deduce from current figures, involve an average of 1354 animals per year (6771 over entire project). So these are major research projects, often involving several separate studies and the licence is supposed to provide lots of detail about scientific justification, likely adverse effects that the animals will suffer, and likely results/benefits to accrue. See here for some example – check out ND1 for instance. All this is supposed to be required so Inspectors can check the scientific validity, check if there are non-animal alternatives and conduct a cost-benefit assessment.

The Inspectorate report states each inspector dealt with 22.7 project licence applications and 72.5 licence amendments per year (this doesn’t include pre-application advice as they don’t provide a figure). If half their licensing time – 39 days – is spent on project licences, then on average they each approve about 2.44 applications/amendments per day. This equates to 3303 animals per day. Obviously they will spend more time on initial applications than amendments, but at best they are going to spend about a day and a half on each project licence application. In practice that will almost always be insufficient to thoroughly scrutinise them.

Coupled with targets for turning around licence applications within 35 days (which seems to be the Inspectorate’s principle goal) and the shared professional background of most Inspectors and researchers, and it’s easy to see why the licensing system is essentially a rubber-stamping exercise.