Lausunto koe-eläindirektiivin muutoksista
EU-komissio järjesti julkisen kuulemisen koe-eläindirektiivin tulevista muutoksista. Animalia jätti oman lausuntonsa asiasta.
Public Consultation: Animal welfare – Animals used for scientific purposes (adaptation of standards on care, accommodation and killing)
We are pleased to have the opportunity to comment on the Draft Delegated Act amending Directive 2010/63/EU of the European Parliament and of the Council as regards the requirements for establishments and for the care and accommodation of animals, and as regards the methods of killing animals. We support the comments and recommendations submitted by Eurogroup for Animals. In particular, we would like to submit the following comments for your consideration:
For the revision of Annex III of Directive 2010/63/EU
- A table outlining water-quality parameters specific to each stage of development for commonly used fish species (other than zebrafish) should be included.
- When mature, rats stand at a height of approximately 26-30 cm. However, the minimum enclosure height for rats, irrespective of their body weight, is set at 18 cm in Annex III, which prevents rats from standing upright and compromises their welfare. Consequently, we recommend raising the minimum cage height for rats to 30 cm.
- During the nursing period it is important that nursing female rabbits are able to isolate themselves from their young if necessary to minimise stress and aggressive behaviour. We therefore recommend that nursing female rabbits be provided with a nest box with an entrance that they can close to allow them to isolate themselves from their young.
- Very few dogs used for scientific purposes have access to outdoor runs, despite evidence of a significant positive impact on the welfare of dogs housed in laboratories. The language in Annex III should be strengthened to explicitly require outdoor runs as a standard provision for dogs unless there is scientific or veterinary justification to the contrary.
- On the basis of a literature review, it is preferable for young macaques to remain with their mothers until they are behaviourally independent, and the minimum weaning age should not normally be less than 10-14 months. Consequently, we recommend that the minimum time after birth that macaques are allowed to be separated from their mothers should be revised in Annex III, to ‘not less than 10-14 months’.
- Based on a literature review, it is advised that young macaques stay with their mothers until they are behaviourally independent. Therefore, the minimum weaning age should generally not be less than 10-14 months. As a result, the suggested minimum weaning age in Annex III should be revised to reflect this recommendation accurately.
For the revision of Annex IV of Directive 2010/63/EU
- Confirmation of death by rigor mortis is not appropriate and should be removed from Annex IV. If the method of killing has not correctly been executed, there is a potential risk that the animal may experience suffering between confirmation of death by rigor mortis and actual death, which is unacceptable.
- Methods for killing zebrafish at stages < 16 days post fertilisation are missing from Annex IV, although these larval forms are covered by Directive 2010/63/EU. Based on the literature, we recommend that the use of a mixture of lidocaine hydrochloride, sodium bicarbonate and ethanol be included in Annex IV as an appropriate method for killing zebrafish at stages < 16 days post-fertilisation.
- Birds may experience severe distress and suffering when killed by CO2 and decapitation. Therefore, these methods should be eliminated from Annex IV.
- The use of a percussive blow to the head to stun fish may result in unnecessary suffering to the fish as there is a risk of incomplete stunning or prolonged stunning. Consequently, this method should be eliminated from Annex IV.
- Rodents killed by decapitation may experience conscious pain prior to the onset of insensibility. Consequently, this method should be eliminated from Annex IV.
Kuva: Jo-Anne McArthur / We Animals Media