Lynne Featherstone MP
Parliamentary Under Secretary of State
Home Office
2 Marsham Street
London SW1P 4DF

July 29th 2011

Dear Lynne,

I am writing to express my concern that the new EU Directive on animal testing will weaken current standards when incorporated into UK law. As you are aware, Directive 201/63/EU is a small step forward for protecting animals in many countries across the EU. However, UK animal testing standards have been higher for some time and if transposed directly the Directive could lead to weaker controls.
There are at least two key areas of concern for the transposition of the Directive into UK law. Firstly, there is the possibility of a reduction in central controls. The Directive does not require the Home Office Inspectorate to maintain its important role of advising on license applications and ‘best practice', nor will it ensure the Inspectorate's current participation in expert working groups and conferences. Moreover the Directive could permit a large reduction in the number of inspections carried out at a national level.
The reduction of local controls also constitutes an area of concern. The Directive only requires an Animal Welfare Body (AWB) at a local level, which compared to the UK's current Ethical Review Process (ERP) has a much smaller remit and a narrower required membership. The current ERP has been in existence for the last 10 years and has much support within the research community for raising standards of animal welfare and for providing a robust framework for scientific and ethical review.
Further concerns include: the loss of the personal license system for people carrying out scientific experiments; particular clauses and annexes to the Directive that could permit increase suffering to a larger range of animals including primates; and a reduction of transparency in certain projects that would be able to waiver a retrospective assessments for the public domain.
There appears to be cause for serious critical discussion on how best to implement the Directive, and maintain current excellent UK standards. I would like therefore to request a parliamentary debate to be scheduled on this issue. I would also like your assurance that the Government remains committed to reducing animal testing for scientific research, as set out in the Coalition Agreement, and would be interested to know both what steps are being taken to this end and whether you are satisfied that implementation of the Directive will help.
I look forward to hearing from you with regards to how the Government intends to maintain current UK standards and in response to my request for a parliamentary debate.
Yours sincerely,

Caroline Lucas, MP, Brighton Pavilion

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