To the Editor:

Your December 2008 editorial1 on the proposal to revise the animal experiments directive of the EU acknowledges that the use of animals in research has long been a matter of concern to the public, that animal welfare must not take a backseat to economic considerations and that leveling the playing field across the EU is important—but then argues that all of that is trumped by the desire of poorer countries to build up their science base.

This would imply that animal research standards, instead of being ratcheted up to those of the best countries, be allowed to drop to those of the worst—something hardly consistent with promoting animal welfare.

The proposal is defective but not for the reasons you list. It represents an improvement on the current legislation—for example, an ethical evaluation by a national authority will now be required—but it would still allow severe suffering. Under this directive, animals can still be used for research into weapons, tobacco, alcohol and household products, to test psychology theories, and to test just about anything else one cares to mention, as opposed to strictly medical research. Additionally, the antiduplication provisions are inadequate, as are those on transparency, and there is no strategy to coax research toward the use of nonanimal alternatives, which everyone says he or she wants to see.

Determining the benefit of a piece of research represents an important part of the scientific and ethical process that should precede any form of experimentation on sentient beings. I would argue that, in a world that uses approximately 115 million animals in research every year2, this process is not conducted nearly as rigorously as it should be, even by those countries such as the UK and Germany that already require an evaluation.

I would hope that the medical research community would see the revision of the directive 86/609/EEC as a golden opportunity to showcase to the rest of the world how to do humane science rather than an economic or bureaucratic hurdle to be avoided. After all, whether a rabbit is being used in Bulgaria or the UK, its capacity to suffer is just the same.