Stop the killing of animals for teaching in Egyptian universities

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The Issue

In Egypt, whether killing an animal is lawful already turns on necessity. Article 357 of the Penal Code punishes anyone who intentionally kills, poisons or seriously harms a domesticated animal without necessity, and Article 355 does the same for livestock and for riding, draught and pack animals. Neither article exempts universities. Neither has ever been considered in relation to a teaching laboratory.

Necessity is not a fixed quantity. It is measured against what was available, so the reach of the prohibition changes every time a method arrives that produces the same result without the animal. Simulators, synthetic tissue and validated software have changed what is available a great deal since these articles were drafted. No Egyptian authority has been asked what that means for a dissection performed to teach a class, and none has published anything that would let the question be answered.

The principle that would answer it is not foreign to Egyptian universities. They have already adopted it. Mansoura University's committee on the ethics and rules of animal use states that decisions on animal work are taken in accordance with replacement, reduction and refinement. Cairo University established the country's first institutional animal care and use committee at its Faculty of Science in 2012, on the basis of a requirement of the World Organisation for Animal Health, and adopted an American guide because Egypt had compiled none of its own. The account its founders published in 2016 records the difficulties they met as an absence of any law governing the use of animals in research, an absence of guidelines, and the absence of any animal welfare instrument covering research or teaching.

Every one of these committees is confined to research. The rules stop where the curriculum begins. A rabbit used to generate data for a thesis is reviewed by a committee applying the 3Rs. The same rabbit, used to demonstrate the same procedure to a class the following week, is reviewed by nobody. The legislation stops at the same line. Law No. 214 of 2020 on the Regulation of Clinical Medical Research defines pre-clinical research as work carried out through laboratory testing or through the use of laboratory animals, in accordance with the established international standards for such research. That is the whole of the statutory recognition, and it goes no further than the laboratory.

The international standard does go further. Chapter 7.8 of the Terrestrial Animal Health Code of the World Organisation for Animal Health applies to animals used in research and in higher education, and states in terms that education includes teaching and training. Its purpose is to assist member countries in framing regulatory requirements of their own.

Other states reached this point without new legislation, by applying a duty they already held. India's Prevention of Cruelty to Animals Act 1960 requires in section 17(2)(d) that experiments on animals be avoided wherever it is possible to do so, naming medical schools and colleges expressly, and in section 17(2)(f) that they not be performed merely for the purpose of acquiring manual skill. On that basis the Ministry of Environment and Forests directed the Medical Council of India, the University Grants Commission and the Pharmacy Council of India in 2012 to end dissection and animal experimentation in undergraduate and postgraduate teaching. The Dental Council of India followed in 2013. The Medical Council prohibited dissection in undergraduate medical courses in March 2014, and the University Grants Commission extended the prohibition across life sciences programmes in July 2014 by Notification No. F-14-6/2014 (CPP-II), effective on issuance. In the United States and Canada the practice was standard at most medical schools as recently as 1994 and had ended at all of them by 2016. The 216 schools surveyed across both countries now teach through simulation and other human-relevant methods, and their graduates qualify on the same terms as before.

Egypt does not require new legislation either. Under Article 12 of Law No. 49 of 1972 on the Organisation of Universities, the Supreme Council of Universities plans the general policy of university education and scientific research and coordinates between universities, and Article 19 sets out its competence to draw that policy and direct it. Under the Executive Regulations of the Law, its sector committees lay down the bases on which curricula and study plans are developed at undergraduate and postgraduate level. The power to set a standard for the use of animals in teaching is already held. What is missing is the decision to use it.

We call on the Minister of Higher Education and Scientific Research, who is the supreme head of the universities and supervises them by virtue of his office, to act on five points.

1. Survey the use of animals in teaching in the faculties of medicine and veterinary medicine, and publish what the survey finds.

2. Extend the mandate of the university animal ethics committees that already exist so that it covers teaching, and the replacement, reduction and refinement they apply to research apply to the classroom.

3. Require a validated alternative to be used wherever one exists for the teaching objective concerned, including simulation, synthetic models and ethically sourced cadaveric material.

4. Recognise the right of a student to decline participation in a procedure that kills or injures an animal, with an alternative route to the same assessment. Italian Law No. 413 of 1993 obliges academic faculties to inform students of that right, and India's first measure in 2011 took the same form.

5. Issue a published standard for the use of animals in teaching, consistent with Chapter 7.8, with an authorisation procedure, a means of verifying compliance, and annual publication of the number and species of animals used.

The Decision Makers

Dr. Abdelaziz Konsowa
Dr. Abdelaziz Konsowa
Minister of Higher Education and Scientific Research

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