Tests on animals to check safety of medicine must be humane
I read with interest the confusion caused by the implementation of the registration for traditional Chinese medicine ('Chinese medicine off shelves as law bites', December 4).
These laws are required for the safety of consumers, but this does not justify inhumane treatment of animals used in toxicity testing. The Chinese Medicine Board's guidelines encourage inhumane treatment with no consumer benefit.
The Organisation for Economic Co-operation and Development (OECD) has comprehensive guidelines for toxicity testing. They are internationally accepted and comply with modern concepts of humane animal usage. Therefore it is a surprise that the board's guidelines for toxicity testing of traditional Chinese medicine do not comply with internationally accepted norms.
I would like to give a number of examples.
The criteria for the choice of rats lack scientific rigour. The guidelines stipulate that rats 'are white'. The OECD guidelines describe criteria on which to choose rats, but they do not specify colour, as it has no scientific merit. The board guidelines do not comply with the OECD's Global Harmonisation System, which ensures internationally standardised testing, making results comparable. Results using the board's tests will not be internationally accepted.
The harmonised tests have removed the inhumane 'LD50' safety test, which requires the painful death of rats. The OECD's toxicity tests do not require the deaths of the animals, thereby reducing animal suffering.
The board's LD50 testing is contrary to the Hong Kong government's Code of Practice on the Use of Animals in Research. The code recommends research should meet international norms and the LD50 test is not the international norm.
Why is the board not monitoring the developments in science to ensure Hong Kong's regulations are current?
The board's guidelines use too many animals. OECD tests generally require only females (as they are toxicologically more sensitive) and can be decided by as few as six to nine animals but never exceeding 12 to 15. The board's guidelines use at least 20 rodents of both sexes. Animal ethics committees usually won't allow projects with group sizes greater than 15 animals, unless they are scrupulously justified. Large group sizes are ethically and scientifically unjustifiable.
What is the board's scientific justification for the number of '20 rodents' per group?
OECD guidelines are the most humane we have. If Hong Kong is Asia's world city, why is it not following the world's best practice?
Furthermore, the chief executive in his 2010 policy address said he was committed to animal welfare. We can do better than the Chinese Medicine Board's guidelines to protect consumers and ensure our humanity to laboratory animals.
As a civil society we owe nothing less than the humane treatment of animals that give their lives to protect our safety.
Anthony James, director, Laboratory Animal Services Centre, Chinese University of Hong Kong