Comments on revised draft of “A Guide to the Use of Australian Native Mammals in
Biomedical Research”
May 2012
I have summarised my comments in dot-point format below. In general, the Guide is poorly
written and lacks focus, although it is commendable that the NHMRC intends to produce a
guide for such an important topic. The endeavour is highly worthwhile; the draft Guide just
needs to be refocussed and the authors really need to consider the implications of what they
are suggesting for wild animals.
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At no point does the Guide define “biomedical research”. Biomedical research should
be defined very clearly in the “Purpose of the Guide” and again in the “General
Considerations” section.
Biomedical research, if used for the study of human health, should not utilise wild
native animals. However, (as an example) the use of wild animals may be acceptable
if they are being used to study the efficacy of contraceptives for control purposes in
those species, if it is not possible to do so with captive animals. If the authors feel that
there is a pressing need to use wild animals in biomedical research then they should
give examples of where this situation may occur.
Under “General considerations”, a number of broad examples are given of how native
mammal research has made contributions to science. These examples should be more
specific than they currently are (to provide context) and should be referenced in-text.
The document should state very clearly that in all situations, the use of captive-bred
animals is preferred.
To suggest that it is acceptable to use wild, threatened species in research is
irresponsible. Do not address that theme; if researchers feel that it is absolutely
necessary to use threatened species then they will need to support their arguments to
their ethics committees and when attempting to gain a permit from their state National
Parks and Wildlife Office (or similar).
In “General Considerations” it is stated that “scientific research using Australian
native mammals is essential to our understanding of their biology”. However, that is
not the focus of this Guide. This Guide is concerned with biomedical research only
and should address that topic only. Also, in “General Considerations” the Guide
comments on the conservation of native animals; that is not the purpose of this
document and it should not suggest that conservation of native animals is part of its
purpose. It is simply a guide to the ethical use of native animals in biomedical
research.
The Guide attempts to give detailed information on the trapping of wild animals;
these sections should be removed completely. Researchers should seek advice from
experts in the field if they feel the need to capture wild animals (they should avoid
that at all costs), not refer to information in this Guide, which cannot possibly give
sufficiently detailed information to guide the trapping of wild animals. The trapping,
handling, and housing of wild animals are complicated and cannot be addressed
adequately in this document. It is stated in the “Purpose of the Guide” that the
document is not intended to be an “exhaustive source of information...” and yet it
proceeds to do exactly that by providing information on trapping of wild animals. The
topic of animal trapping is treated very flippantly in the Guide overall.
Under “Sources”, it should be made explicit that all researchers using native animals
(any animals in fact) have to pass an ethics review process and obtain a scientific
permit from their relevant National Parks and Wildlife Service (if obtaining wild
animals, which they should avoid anyway). It is not merely a process of contacting
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Comments on revised draft of “A Guide to the Use of Australian Native Mammals in
Biomedical Research”
May 2012
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authorities to gain more information; the ethics and permit applications involved are
extensive. Currently, the Guide skips over that fact.
The Guide requires extensive editing to ensure that it is correct grammatically and
that expression is clear. I.e. “taxa” is the plural form of “taxon”; the word “taxons”
does not exist.
In summary, the Guide should a) define “biomedical research” in the context of this
document, b) remove information relating to the capture of wild animals (it cannot be dealt
with adequately here and should not be promoted as a means of gathering study animals
anyway), c) remove references to the conservation of native animals (that is not the purpose
of this document), d) remove the suggestion that it might be appropriate to capture,
threatened wild animals, and e) undergo an extensive editing process.
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