The Brown Report (2013)

1. In April 2013 the anti-vivisection group the British Union for Abolition of Vivisection (BUAV) published a report and undercover video footage raising serious allegations about the conduct of animal research at Imperial College London. The allegations triggered a number of actions which included Imperial inviting Professor Steve Brown, Director of the Medical Research Council’s Mammalian Genetics Unit, to set up and chair an independent committee to investigate how research using animals at the College is conducted, managed and overseen. The membership and terms of reference of the committee were at Professor Brown’s discretion.
2. Professor Brown convened an expert committee whose members have expertise in all aspects of animal research from animal welfare and veterinary matters to public engagement. The committee has undertaken a thorough review that included interviewing 30 scientists, technicians, vets and administrative staff, some of whom were featured in the BUAV allegations. The committee also requested and reviewed a wide range of documents from Imperial including minutes of meetings, and visited the building where animal research is conducted and which had been the focus of the BUAV film.
3. The committee’s investigation focused on four important inter-related areas that are listed below. The committee found that the staff responsible for the day to day care of animals (for example animal welfare checks plus providing food, water and clean housing) were committed to animal welfare. It identified, however, that there was considerable scope for improvement in a number of aspects of the operation, management and oversight of animal research at the College and it has made a number of recommendations to address this.

The Animal Welfare and Ethical Review Body

4. All institutions in the UK using animals in research are required to have an Animal Welfare and Ethical Review Body (AWERB). This has a number of important responsibilities including reviewing the use of animals, ensuring that the welfare of the animals is given full consideration and providing a forum for discussing the 3Rs (that is how to replace, reduce or refine the use of animals). The committee found that the AWERB at Imperial was not fit for purpose and recommended that a new more rigorous process needs to be implemented with greater focus on the 3Rs and increased involvement from the scientists.

Operation of Central Biomedical Services

5. Animals used in experiments at Imperial are cared for by staff in Central Biomedical Services. This includes vets and animal technicians. The animal technicians mainly carry out husbandry duties along with the daily checks of the animals (predominantly rats and mice). The vets and senior technicians provide advice to the licence holders (usually scientists) carrying out the experiments, for example on whether the welfare of the animals is such that the experiment should be stopped. Only those individuals who are licensed by the Home Office are allowed to carry out procedures on animals that may cause them pain, suffering, distress or lasting harm.
6. The committee found that animal technicians were committed to high standards of animal welfare but that they were under-resourced and under-utilised. It also found that communication between the vets, animal technicians and scientists could be improved, particularly around the issue of reporting of animal welfare concerns and deciding what intervention was necessary (for example whether the experiment should be stopped). The committee has made a number of recommendations to address the issues it identified, including the need to recruit more animal technicians.

Training and competency assessment

7. Ensuring that all staff involved in the care and use of animals used for research purposes are appropriately trained and supervised and that their competency is regularly assessed is essential for maintaining best practice and protecting animal welfare. The committee found that the approach to training, supervision and competency assessment at Imperial was ad hoc. It has made a number of recommendations to address this including increased resource allocation to support training.
   Culture, leadership and management
8. Responsibility for high standards in animal research lies with a number of individuals at any institution, including Imperial. Some individuals, such as those with licenses, have a legal responsibility under the Animals (Scientific Procedures) Act 1986 (amended), while others have a responsibility for setting and implementing the College’s standards and culture. The committee found that there was a level of complacency at Imperial with little opportunity for challenge or bringing in new ideas and that there was scope for improvement in the culture, management and overall leadership. The committee has recommended a new senior level appointment to provide a more coordinated and College-wide approach to the 3Rs and delivering first class animal research to the highest standards.

• Professor Steve Brown (Chair)
  Director, Medical Research Council’s Mammalian Genetics Unit
  MRC Harwell
• Professor Paul Flecknell
  Director, Research Animal Facilities
  University of Newcastle
• Professor Ian Jackson
  Head of Medical and Developmental Genetics, Institute of Genetics and Molecular Medicine
  University of Edinburgh
• Dr Maggie Leggett
  Head, Centre for Public Engagement
  University of Bristol
• Dr Vicky Robinson
  Chief Executive
  National Centre for the Replacement, Refinement and Reduction of Animals in Research
• Mr Neil Yates
  Director of the Biosupport Unit
  University of Nottingham

1. The committee will investigate and assess the culture and approach to animal care and welfare at Imperial, including areas such as:

• Management
• Operational procedures
• Reporting structures
• Supervisory practices
• Training
• Compliance monitoring
• Ethical review

The committee’s investigations will take into account, but not be limited by, the Home Office’s investigations and Imperial’s consideration of the incidents alleged by BUAV.

2. The committee will conduct interviews, visit facilities and explore with stakeholders involved with animal research at Imperial the approach to the design, implementation and local regulation of animal research. In so doing, the committee will aim to identify areas of best practice and any areas that fall short of best practice.
3. The committee, where appropriate, may enlist additional expertise to support its deliberations and investigations.
4. The committee will provide a report to the College, elaborating any areas where practice falls short of standards considered to be at the forefront of animal research and animal welfare standards in the UK. The report will deliver, where appropriate, detailed recommendations for improvements across relevant structures and practices involved in animal research at the College. The committee’s recommendations may also encompass advice on areas of priority to address, as well as potential structures and solutions for improvements.

• BUAV allegations
• Imperial response