The 3Rs are a set of guiding principles widely promoted by the animal experimentation industry.
"The concept of the 3Rs is to replace and reduce the number of animals used in research, testing and teaching, and refine experimental techniques to minimise pain or distress." — National Animal Advisory Committee (NAEAC) Deputy Chair Dr Peter Larsen.
We much prefer the definition outlined by scientific experts below:
"It [the 3Rs] is an alleged ethical policy for the protection of animals – it is not a science policy and entirely ignores current scientific knowledge." — Patients Campaigning for Cures.
Put simply, the 3Rs are:
- The Refinement of scientific techniques;
- The Reduction in the numbers of animals used;
- The Replacement of animal procedures with non-animal procedures.
The problems with the 3Rs:
At first glance, the 3Rs sound positive, which is exactly what the organisations promoting them want you to think. One could interpret the 3Rs as protecting animals and decreasing the number of animals used for experimentation, but unfortunately, this is not the case and history has shown us that they are more a lip service than actionable guidelines.
Even though the Animal Welfare Act mentions the 3Rs, they are not enforced and the Act instead only "promote efforts" of the 3Rs. They are nothing more than a recommended guideline that "must be considered." Groups and individuals using animals for research, testing and teaching (RTT) will often state that they "promote" and "encourage" the 3Rs, but we are yet to hear of anyone in NZ enforcing them.
It's important to note that even if the 3Rs were enforced, they wouldn't be effective in genuinely ending animal experimentation. This is because they only critique animal experimentation on ethical grounds. The 3Rs completely ignore the many scientific issues involved in using animal models to predict the human response — a good reason for supporters of vivisection to promote them... they want animal experimentation to have public acceptance and to be able to continue.
In reality, the 3Rs promote the concept that animal experimentation is justified as long as it is performed as "humanely" as possible. We think this is incredibly problematic as it essentially helps perpetuate the ongoing use of animals for RTT by tricking the public into believing the huge misconception that animal experimentation is a necessary evil.
The principles of refinement and reduction only encourage researchers to "improve" and "perfect" animal experiments. No matter how well planned an experiment using animals is, it will never create viable results that can accurately be extrapolated to humans. Whether you use ten mice or 10,000 mice, the sample size will not be able to predict the human response reliably.
The third R, replacement, only promotes the replacement of animals if there is an "alternative" available. Firstly, for research and testing, the animal model is broken and has never worked to predict human outcomes accurately. In all forms of research and testing relating to human health, non-animal based methods should be continuously developed and embraced so only relying on methods that currently exist isn't going to create progress.
Also, only relying on "alternatives" creates huge limitations as an alternative method to an animal model is a model that can replicate the same response as the animal, rather than predicting what we have wanted to know all along... the human response. If you are familiar with NZAVS and our position on animal-based research, then you will know that we are careful with the use of the word "alternative." You can read more about the proper use of this word here.
For example, HIV researchers have developed 90 vaccines that protect non-human animals from HIV infection; none of these vaccines are effective in humans.1 If researchers were to look for an alternative method, they would be trying to replicate the same outcome as the animal models created, which in all 90 cases wasn't the same as the human response. Therefore instead of using an alternative method for HIV research, viable non-animal based and human-relevant methods should be used - which the 3Rs doesn't promote. If the 3Rs were followed in this case, then we would see the number of vaccines that can protect animals and not humans increase steadily; the 3Rs does a fantastic job of encouraging the exact same non-viable results to be found over and over again.
When it comes to teaching methods, many viable alternative methods to using live animals already exists. The 3Rs "must be considered," but often organisations explain why any alternative methods would be an inconvenience, or they give a vague answer to why using an alternative method isn't "realistic." Therefore, they technically have "considered" the option and therefore followed the 3Rs, without actually taking an alternative method into real consideration.
A better set of principles:
If the 3Rs were edited slightly, used in a manner that is motived by ethics AND scientific evidence, and were then enforced rather than promoted, then the animal experimentation industry would cease to exist because:
- The minimum number of animals required for RTT is much closer to zero animals rather than the approximately three-hundred thousand animals used each year in NZ alone. The minimum number of animals required for medical research and product/substance safety testing is zero.
- Refined techniques of RTT would be non-animal based in most* cases.
- Non-animal based methods of RTT should be used in most* cases.
(*there are very few exceptions, i.e. doing non-invasive observational studies on animals in their natural habitat for conservation purposes.)
A much better guideline system would focus on one R, the absolute replacement of animals in RTT and no longer waste time on "relative" replacement, refinement or reduction.
Supporters of the 3Rs:
As mentioned already, the 3Rs are heavily promoted by supporters of animal experimentation who have a vested interest in the ongoing use of animals for RTT. A good example of this in NZ is ANZCCART, an organisation with the aim of making animal experimentation appear as humane as possible. They focus on pain relief and continuing animal experimentation rather than addressing the fundamental scientific issues involved in animal-based research. Their main sponsors are Universities New Zealand and AgResearch Ltd which makes us question just how independent they are.
One of the most renowned pro-vivisection groups, Speaking of Research also promotes the 3Rs which proves our point even further. They spread propaganda such as this:
Guidelines like the 3Rs and groups like ANZCCART and Speaking of Research are dangerous as they put a lot of resources into making animal experimentation appear both kind and necessary.
The extent to which the 3Rs are promoted and followed in NZ:
MPI and the Government are meant to encourage the principles of the 3RS when animals are being used in RTT, and animal ethics committees have an obligation to consider them in the approval process. We know that this doesn't happen in reality by looking at the number of animals used for RTT each year in NZ. Viable non-animal based methods already exist in many cases and just aren't being used!
The 3Rs are promoted heavily in New Zealand and are even mentioned in legislation (the Animal Welfare Act.) Read more about the extent to which the 3Rs are "enforced" in NZ here.
To summarise, the 3Rs are currently used as a smokescreen to distract the public from the proven scientific flaws involved in animal-based research. They:
- Focus only on "ethics" and not on science-based evidence (helping give the industry a social license)
- They aren't enforced
- If they were enforced only the use of animals for teaching purposes would end. The use of animals for testing and research methods would continue
The only area in which the 3Rs aid our work in ending animal experimentation is in the use of animals for teaching purposes. We are yet to come across an invasive animal based teaching method where there is no viable alternative available. This highlights just how ingenuine these principles are and we will be working hard to point this flaw out to the key stakeholders in NZ who promote the 3Rs.
1 Akhtar, Cambridge Quarterly of Healthcare and Ethics, 2015, p. 412.