FAQs fish

FAQs

In summary: Medical progress has never depended on just a single research method. Human observation, epidemiology, clinical research, imaging, autopsy and donated tissue, cell culture, engineering, chemistry and computational science have all contributed to scientific and treatment advances. 

Some examples include – identifying the relationship between smoking and lung cancer through population research; understanding disease through clinical observation and post-mortem examination; developing technologies like X-rays, CT, MRI and PET through physics and engineering; and improving treatments through human clinical trials. 

Other human-based sources answer different questions: genetics can identify how inherited variation contributes to disease; donated cells and tissues can reveal patient-specific mechanisms; biobanks, health records and large population datasets can uncover patterns across many people; and clinical trials determine whether an intervention is acceptably safe and effective in humans. The advent and increased uptake of Non-Animal Models including in vitro technology through patient-derived organoids, induced pluripotent stem cells, organs-on-chips, artificial intelligence and other computational models. 

Animals have also been used during the history of many discoveries. However, their presence along the research pipeline does not by itself show that the animal study was essential, that it predicted the human outcome, or that the discovery could not have been achieved any other way. A fair historical account asks what each method contributed and whether the evidence that ultimately mattered produced translatability and human relevant outcomes. 

AFSA’s position is forward-thinking, today’s model should be chosen because it is the most scientifically appropriate and ethically responsible way to answer the question, not just because it is traditional. Non-Animal Methods now allow researchers to study mechanisms and variation that many historical approaches could not capture (CSIRO, 2023; FDA, 2025). 

Reference:

Commonwealth Scientific and Industrial Research Organisation (CSIRO) (2023) Non-animal models: a strategy for maturing Australia’s medical product development capabilities. Available at: https://www.csiro.au/en/work-with-us/services/consultancy-strategic-advice-services/CSIRO-futures/Health-and-Biosecurity/Non-animal-models (accessed 19 August 2026).

In summary: A treatment that improves or extends life is a genuine benefit. However, the historical involvement of animal research does not justify keeping animal models as the default. Research should begin with the human question and the most human-relevant methods available. 

It is too absolute to say that every medicine was developed either ‘because of’ or ‘in spite of’ animal research. Drug development usually combines laboratory studies, chemistry, computational work, animal studies, clinical observation and human trials. The evidence of whether a medicine is safe and effective for humans ultimately comes from human data. 

Animal results sometimes align with human outcomes and sometimes do not. They may help generate hypotheses while failing to predict outcomes in patients. AFSA does not deny that animal studies have formed part of successful development histories;  but it challenges the assumption that historical use proves continuing necessity or makes animal models the routine ‘gold standard’. 

AFSA’s position is that an animal model should not be the starting point simply because it is familiar, established or expected. Researchers, funders and institutions should first ask whether the question can be answered using human data, computational models, and in vitro methods like patient-derived cells or tissues, organoids, organs-on-chips, or a combination of the above Non-Animal Methods. 

The burden of justification should rest with those proposing animal use. They should be able to show that relevant NAMs used alone or together have been properly considered, explain why they cannot answer the question, and demonstrate that the expected benefit is realistic and proportionate to the harm involved. Familiarity, existing infrastructure, status quo, or regulatory are not, by themselves, sufficient scientific reasons to default to animals. 

It is ethically important to acknowledge the animals who were used and harmed in research that contributed to medical knowledge. But acknowledging that history does not require us to preserve the same methods indefinitely. The appropriate response to successful treatments is to build on medical progress with methods that are more directly relevant to patients—not to preserve animal use by default. 

Non-animal models may lack the integration and longevity of an intact organism. They are designed to stimulate human biology up to a certain level or organisation and complexity. However, despite the current limitations, they are superior to the inaccurate animal model. A whole living rat does not represent a whole living human.

The alternatives to animal testing are primarily based on biochemical assays, experiments in cells that are carried out in vitro and computational models and algorithms. These techniques are typically far more sophisticated and specific than traditional approaches to testing in whole animals, and many in vitro tests are capable of producing information about the biological effects of a test compound that are equally accurate and in some cases more accurate than the information collected from studies in whole animals*.

There are efforts underway to develop human body-on a-chip systems to integrate multiple organ systems*

*Humane Research Australia (2019). Better ways to do research

*Li, Z.A., Tuan, R.S. Towards establishing human body-on-a-chip systems. Stem Cell Res Ther 13, 431 (2022). https://doi.org/10.1186/s13287-022-03130-5

In Summary: For some research questions, there is not yet one accepted Non-Animal Method that can replace every part of an animal test. However, a combination of NAMs and human data may provide the information needed. Claims that there is “no alternative” should be carefully questioned, as the barrier may be limited funding, access, expertise or regulatory acceptance. Animal use should not continue simply because it is familiar; it must be regularly reviewed and justified. 

Replacement is not always a one-for-one exchange. An animal study may be replaced by a combination of NAMs ,for example, human cell-based methods, computer models, existing human data, read-across, microdosing and evidence from clinical research or real-world settings. In some cases, the research question can also be redesigned so that the information is obtained more directly from humans. 

Claims that there is “no alternative” should be carefully questioned. This may mean that a method has not yet been accepted by a regulator, that no single NAM can reproduce every part of the existing animal test, or that the research team lacks the funding, access or expertise to use or develop a suitable method. These are different barriers and do not necessarily mean that animal use is the only scientifically valid option. 

AFSA supports a planned transition away from animal use. This means prioritising areas where replacement is most achievable, assessing methods against human evidence, investing in their development and standardisation, and providing clear regulatory guidance. The FDA is implementing a roadmap to reduce animal testing in drug development, while the NIH is prioritising NAMs. The European Commission has also adopted a roadmap towards phasing out animal testing for chemical safety assessments.  Australia should build on this global progress by reviewing existing animal-testing requirements and removing those that are no longer scientifically necessary. Animal tests should not remain the default simply because they are familiar or have always been used. 

References:

United States Food and Drug Administration (FDA) (2025) Roadmap to reducing animal testing in preclinical safety studies. Available at: https://www.fda.gov/media/186092/download

National Institutes of Health (NIH) (2025) ‘NIH to prioritise human-based research technologies’. Available at: https://www.nih.gov/news-events/news-releases/nih-prioritize-human-based-research-technologies

In summary: There is no single Australian approval pathway for every NAM. The evidence required depends on the method’s intended use whether that be, drug development, chemical safety,  veterinary medicines or medical devices , etc. 

Australia does not currently have one clear national process for validating and accepting NAMs. The pathway depends on what the method will be used for, and researchers often rely on validation undertaken internationally. 

In simple terms, validation asks whether a method works reliably for a clearly defined purpose. Researchers may need to show that it produces consistent results, reflects the relevant biology, includes appropriate controls and has clearly understood limitations.  

Importantly, a NAM should not always be required to reproduce the result of an older animal test. If the method is intended to predict a human response, its relevance to human biology should be central to how it is assessed. However, this is not always the case with current validation processes which often compare the NAM with animal data or endpoints traditionally generated by animal models.  

For chemical safety testing, Australia can use non-animal methods included in internationally recognised OECD Test Guidelines, for which the Department of Climate Change, Energy, the Environment and Water is involved. Through the OECD’s Mutual Acceptance of Data system, participating countries can accept results produced according to these guidelines and Good Laboratory Practice. This means Australia does not need to create or repeat a separate national validation process for every internationally accepted method.  

Pharmaceutical testing guidelines developed by the International Council for Harmonisation (ICH) and the International Cooperation on Harmonisation of Technical Requirements for Registration of Veterinary Medicinal Products (VICH) cover animals used for human drug development and veterinary medicines..   The responsible agencies in Australia are the Therapeutic Goods Administration (TGA) and the Australian Pesticides and Veterinary Medicines Authority (APVMA), working alongside Animal Medicines Australia (AMA)

These agencies are responsible for adopting international guidelines and may consider alternative methods and supporting NAMs validation evidence within an individual application, but Australia does not have a dedicated, coordinated pathway that tells developers how NAMs will be assessed and accepted across different uses. 

This lack of a clear national pathway can create uncertainty for researchers and companies. They may have developed a scientifically credible NAM but still be unsure what evidence an Australian regulator will require or whether the method will be accepted. 

Depending on its intended use, the process may involve: 

  • Developing the method: clearly defining what it measures and what it is intended to do. 
  • Assessing its performance: examining its reliability, human relevance and known limitations. 
  • Independent testing: determining whether other laboratories can produce comparable results. 
  • Scientific review: having independent experts assess the supporting evidence. 
  • Regulatory acceptance: deciding whether the method provides sufficient evidence for a specific regulatory purpose. 

Acceptance for one purpose does not automatically mean that a method will be accepted for every use. Australia therefore needs clearer guidance, stronger coordination and earlier engagement between NAM developers and regulators. 

AFSA resource: Regulation of Human Medicines

In Summary: Some methodological problems, such as poor study design, small or unrepresentative samples and selective reporting, can affect both animal research and NAMs. However, NAMs avoid the additional uncertainty of translating findings from one species to another when they use human cells, tissues or data. No method is perfect, but NAMs can provide evidence that is more directly relevant to humans while avoiding harm to animals. Their limitations should be openly addressed, and they should be prioritised wherever they provide evidence of equal or greater value 

We should not expect any research method to be perfect. The important question is whether it is reliable, suited to the research question and capable of producing meaningful evidence for humans. Its scientific limitations must also be considered alongside the potential harms involved. 

NAMs have limitations, as all research methods do. Results from human cell-based methods and organoids can vary between batches, donor samples may not represent the wider population, and cells may become contaminated. Computer models may also perform well using the data on which they were developed but be less reliable when applied to new data. These risks can be addressed through careful study design.  

These risks can be reduced by designing studies carefully, using cells and tissues from a diverse range of people, checking that results can be repeated, and openly reporting findings—including when they do not support the original hypothesis. Animal studies face even more of a challenge regarding cross-species translation. Even a carefully designed animal study may not accurately predict how humans will respond when important biological differences exist. NAMs based on human cells, tissues and data can reduce this uncertainty by studying human biology more directly. Their limitations can also be better understood and addressed as the methods develop, human datasets become more representative and complementary NAMs are used together. 

NAMs do not need to be perfect to represent meaningful scientific and ethical progress. Each method should be assessed according to the quality of the evidence it produces, its relevance to humans and its suitability for the question being asked. Animal models should not receive the benefit of the doubt simply because they are familiar or have traditionally been treated as the scientific standard. Where a NAM can provide evidence of equal or greater value without causing harm to animals, it should be prioritised (Hirst et al., 2014; GAO, 2025).

References:

In summary: When the intended patient is an animal, NAMs can be developed using cells, tissues and data from that species. Veterinary knowledge can also be advanced through clinical research involving animal patients who already have the condition, rather than deliberately creating illness or injury in healthy animals. AFSA supports research that genuinely benefits animal health and wellbeing and does not treat animals primarily as a means of advancing human or commercial interests. 

Veterinary NAMs can use cells, tissues, organoids and organs-on-chips developed from the species the research is intended to benefit. Other approaches include computer modelling, advanced imaging, ethically donated animal bodies, realistic simulators, stored biological samples and clinical research involving animal patients who already have the condition being studied. 

Research involving an animal patient is ethically different from deliberately causing disease or injury in a healthy animal. Like clinical research involving humans, it should be designed to offer the animal patient a reasonable chance of benefit, involve informed consent from their guardian, undergo independent ethical review and provide appropriate veterinary care. Guardians must also clearly understand the difference between treatment intended to benefit their animal and research that may not provide a direct benefit. Any conflicts of interest should be openly identified and carefully managed. 

AFSA supports veterinary research that genuinely aims to improve the health and wellbeing of animals, this includes the development of species-specific NAMs. Animals should not be harmed primarily to increase productivity or advance human interests when they receive no meaningful benefit. The value of the research must be considered alongside its purpose, and the harm involved and whose interests it ultimately and is intentionally trying to serve.

In summaryMice, rats and fish are among the animals most commonly used in research, but their numbers and default use do not make their suffering less important. “Vermin” is a label peoplgive to certain animals; it does not change their ability to experience pain, fear or distress. Ethical consideration should be based on an animal’s capacity to suffer—not on how humans view, value or imbue a particular species. 

Calling an animal ‘vermin’ describes a human judgement about the animal; it is not a biological category that removes capacity for pain, fear or distress. The same rat can be treated as a companion, a research subject or a pest depending on context, while the animal’s capacity to experience harm remains constant. 

Scientific evidence shows pain perception in fish, although their nervous systems and expressions of pain differ from mammals. Australian animal-research frameworks include fish within protected species, reflecting the need for ethical oversight. 

Numbers also matter. Mice, rats and fish are often used in large numbers, but their use receives less public attention than research involving animals such as dogs, cats or primates. This can make their suffering easier to overlook. AFSA’s position is consistent across species: ethical scrutiny should be based on sentience, the harms imposed, the claimed benefit and whether a scientifically appropriate non-animal approach is available—not on how familiar or likeable the species is. 

Drugs have been developed in spite of animal research and not necessarily because of animal research; it may just so happen that there is the same outcome in a particular species (or even particular age or strain or gestational status) to which the results can be extrapolated similarly by chance.  The same findings could have been found through alternative methods and in fact animal research may have delayed the discovery of cures through abandoned treatments found to be ineffective in animals.

Animal-Free Science Advocacy is not suggesting that medical associations and associated bodies do not have a genuine interest in curing diseases. However, perspectives on how this can be achieved are influenced by many factors; vested interests, support of the status quo, money (grant income for universities and institutions), career dependency and status are just some. Responsible parties don’t want to admit that have been sustaining an ineffective model (how can they explain that to the public who are donors, patients and tax payers?) and there are challenges with learning new research methods, changing engrained practice, the time taken to validate alternatives, technical issues in comparing results and pressure from peers not to speak out (see the videos Test Subjects and interview with Dr Ray Greek for more).

Research is approved by peer review not systematic reviews or meta-analysis which would result in greater scrutiny of research projects.

It should also be noted that many scientists and medical professionals do not support medical research and there are organisations comprised of medical professionals opposing animal research on scientific grounds, such as Physicians Committee for Responsible Medicine , Safer Medicines Trust and the Medical Research Modernization Committee, who agree that experiments on animals do not lead to cures for human disease.

In summary: Historical animal can provide a useful measure of comparison, but they should not be treated as the final measure of accuracy. A NAM should be assessed against the biological effect or outcome it is intended to predict. If the purpose of research is to understand human health, the strongest benchmark is evidence that is human relevant, not simply whether the method reproduces an animal result. 

Legacy animal methods were not subject to the stringent validation standards required today and many were ‘grandfathered’ into global guidelines, becoming a test reference for new methods.. This comparison showed whether the new method could reach the same regulatory decision. It did not prove that the animal test accurately reflected what would happen in humans. 

Today, validation is moving towards more human-relevant evidence, including clinical outcomes, population data, responses in human tissues, known biological pathways and real-world evidence. It is also important to distinguish between reliability—whether a method produces consistent results—and human relevance—whether it measures the biology that matters for the decision being made. An animal test may be consistent without being an accurate predictor of human outcomes. 

This distinction is also ethically important. If animal evidence is automatically treated as the “correct” result, a non-animal method may be rejected simply because it identifies a human-specific response that the animal test cannot detect. This reinforces animal testing as the default, even where it may be less relevant to humans. Furthermore, methods should be judged against the most scientifically appropriate evidence, not protected because they are familiar or historically accepted – embedded in the research infrastructure. Continuing to use animals also requires clear ethical justification, particularly where more human-relevant methods are available. 

OECD Test Guideline 497 provides a useful example. Its defined approaches for assessing skin sensitisation were evaluated using both mouse data and carefully reviewed human data. When compared with human outcomes, these approaches performed as well as or better than the mouse test. This shows why validation should not simply ask whether a non-animal method can reproduce an animal result. The more important question is whether it can provide reliable and relevant evidence for protecting and advancing human health (ICCVAM, 2024; OECD, 2025b).

References:
  • Interagency Coordinating Committee on the Validation of Alternative Methods (ICCVAM) (2024) Validation, Qualification, and Regulatory Acceptance of New Approach Methodologies. Available at: https://doi.org/10.22427/NICEATM-2
  • Organisation for Economic Co-operation and Development (OECD) (2025b) Supporting document to Test Guideline 497 on Defined Approaches for Skin Sensitisation. OECD Series on Testing and Assessment. Available at: https://one.oecd.org/document/ENV/CBC/MONO%282025%292/en/pdf 

In summary: Institutional support reflects the current research system, legal responsibilities and status quo. It is not proof that animal models are always necessary or optimal. 

Governments and medical bodies are responsible for protecting patients while supporting research. They may view established animal studies as part of precautionary evidence, particularly where no accepted alternative yet exists. For decades, research funding, facilities, professional training and regulation have also been organised around animal models. 

Institutions can be slow to change because they must manage uncertainty and because abandoning a familiar method carries perceived legal and reputational risk. There is also genuine disagreement: scientists differ about the value of particular animal models and about how quickly NAMs can replace them. 

What’s important to note is that policy is changing. The FDA has a roadmap to reduce animal testing; the NIH now prioritises human-based research technologies and no longer designs new funding opportunities exclusively around animal models; and the UK published a 2025 strategy aimed at replacing animals in all but exceptional circumstances. These changes show that support for the status quo is neither universal nor permanent (NIH, 2025; UK Government, 2025). 

References: 

In summary: Yes. No country has fully replaced animal research, but some have introduced stronger laws, clearer and more accessible public reporting and national plans for moving towards NAMs. Australia does not necessarily need to copy one system. It can draw on the strongest parts of several.

The United Kingdom has a national licensing system and publishes summaries of approved animal research that easily readable and accessible for the public. Its 2025 strategy also set a long-term mission to eliminate animal use in all but exceptional circumstances, and includes goals for funding, regulatory support and timelines for replacing certain tests (UK Government, 2025).

The European Union requires a recognised non-animal method to be used where one is available. It also supports dedicated organisations that assess NAMs and helps move them into regulation. In 2026, the European Commission adopted a roadmap towards phasing out animal testing for chemical safety assessments (European Commission, 2026).

In the United States, the FDA is reducing animal testing in drug development and providing clearer guidance on when evidence from NAMs can be accepted instead of animal data. Its approach is being introduced gradually, beginning with certain antibody-based medicines. The NIH is also giving greater priority to human-based research in its funding approach (FDA, 2025; NIH, 2025).

These systems still allow extensive animal use, so none provides a complete model. However, they show what Australia could adopt: stronger national oversight, transparent reporting, dedicated funding for NAMs, clearer regulatory pathways and meaningful timelines for replacing animal tests.

AFSA resource: From promises to implementation: global moves advancing animal-free research

Whilst the species difference is removed, Animal-Free Science Advocacy proposes that replacement methods also be used for veterinary research and education (for example, there are simulators that can be used for surgical training, or ethically sourced cadavers or supervised surgeries) and organs-on-a-chip can be used with animal cells to test veterinary applications*.

Only in the case of trailing treatments in ill animals for which there is no current cure would Animal-Free Science accept the use of animals suffering from the said condition as veterinary research.

Some veterinary research is focused on increasing the productivity of animals or sustaining industry standards, rather than for the health and well-being of animals, to which Animal-Free Science objects. An example is here. 

*RVC awarded grant to develop first-ever organ-on-a-chip facility for veterinary species – News – Pathology and Diagnostic Laboratories – Royal Veterinary College, RVC

In summary: A person does not lose their right to bodily autonomy because they have committed a crime. Prisoners can take part in research, but only when their choice is genuinely voluntary and they are protected from pressure or exploitation. However, protecting prisoners does not make it acceptable to transfer the harm to animals. The ethical response is not to find another vulnerable group to experiment on, but to develop research methods that do not depend on harming either. 

 Modern research protections were developed partly in response to serious abuses involving people who were captive, marginalised or unable to freely consent. The Nuremberg Code and the Declaration of Helsinki make it clear that medical research must respect the rights, safety and dignity of participants. A prison sentence removes a person’s liberty; it does not remove their humanity or give researchers permission to use their body (Nuremberg Code, 1947; WMA, 2024).. 

This question also creates a false choice between experimenting on prisoners and experimenting on animals. We should not protect one group by transferring harm to another. Animals cannot consent, withdraw from a study or explain what they are experiencing. Their vulnerability should give us a greater responsibility to protect them—not make them more available for experimentation. Australia’s animal-research Code itself states that respect for animals must underpin decisions about their use and that harm, including pain and distress, must be avoided or minimised (NHMRC, 2013). 

From AFSA’s perspective, the better question is not who else can we experiment on? It is how can we conduct meaningful research without deliberately harming those who have the least power to refuse? Human-relevant Non-Animal Methods offer a more scientifically progressive and ethically responsible way forward. 

References:

This is a moral issue which society needs to consider and on which Animal-Free Science Advocacy has no position.

However, scientists discovered that a mature fully specialised cell, for example a human skin cell, in the right conditions could be induced to mimic the characteristics of an embryonic stem cell. These are known as induced pluripotent stem cells (iPS cells)*. iPS cells have the potential to replace animals in some research.

*Humane Research Australia (2019). Better ways to do research

In summary: Research methods do not cure diseases on their own. New treatments are developed through many stages of research, so it can be misleading to claim that either animal research or Non-Animal Methods (NAMs) alone produced a cure. 

 Human-based research has played an essential role in medical progress. Studies involving people have helped identify the causes and risk factors of disease. Human cells have been used to study viruses and cancer, while computer models can help researchers design and screen possible medicines. Patient-derived organoids can be used to better understand a person’s disease and, in some cases, help predict how they may respond to treatment. Organs-on-chips are also beginning to help researchers decide which possible treatments should move forward. 

Cystic fibrosis is one example. Researchers can grow small intestinal organoids using cells from a patient. These organoids can be used to study how the disease affects that person and whether they may respond to certain medicines. Human iPSC and organoid models are also supporting research surrounding neurological, genetic and infectious diseases. 

AFSA does not claim that NAMs have independently cured diseases. Rather, NAMs can provide important evidence throughout the research process, from understanding disease and assessing safety to selecting treatments and preparing them for clinical trials. Because these methods are based on human biology, they can also reduce the uncertainty involved in applying or translating results from one species to another. 

The methods used to develop treatments matter as well as the final outcome. Research should aim to produce reliable and relevant evidence while avoiding harm wherever possible. As NAMs continue to develop and gain greater regulatory acceptance, they offer an important opportunity to improve human health while replacing the harmful use of animals in research and it is a realistic expectation to see drugs approved without animal safety or efficacy data in the near future.  

AFSA resource: AFSA case studies

In summary: Yes. Basic research is essential but it’s crucial to understand that this does not mean that animals are automatically the appropriate model for every basic question. 

Basic research looks at how cells, biological processes and diseases work. It may not directly lead to a new treatment, and sometimes its value only becomes clear later on. However, that does not mean animals are automatically the right or most appropriate model. Fundamental questions can also be explored using human cells and tissues, organoids, organ-on-chips, computer models, microorganisms and ethically conducted research involving people. 

There is also a risk that findings from animals are presented as though they tell us more about humans than they actually do. If the purpose of research is to help us understand human biology or disease, then human relevance should be prioritised and considered from the beginning. Researchers should be honest and transparent about what the animal model can actually tell us, as well as its shortcomings. 

AFSA supports scientific discovery. However, curiosity itself is not enough to justify harming a sentient being. Where the possible benefit is uncertain or adds little value, justifying that harm needs to be examined under greater scrutiny. Funders, institutions and Animal Ethics Committees need to be asking: Has this research been done before? Is animal use really necessary? Were NAMs genuinely considered? Animal research should not face less scrutiny simply because it is labelled “basic research.”

The majority of biomedical research is conducted on rodents and fish. Regardless of the species and the classification we afford them, there are ethical and scientific concerns. It is unacceptable to justify their use in research by comparison with other inhumane treatments of that species outside of the laboratory context. The collective evidence is now robust enough that biologists and veterinarians increasingly accept fish pain as a reality*. Whilst fish may not typically evoke the same empathy that a cat or dog would, they have a right to be protected from harm.  

*Jabr (2018) It’s Official: Fish Feel Pain. Hakai Magazine

There is no legal requirement for animal experimentation in basic research, nor for it to be part of education and training. However, Government regulators require that new consumer products, medicines, and industrial and agricultural chemicals are tested to identify potential dangers to human and animal health, as well as to the environment. For some product types (drugs and vaccines, biologicals), this includes testing for efficacy as well as safety (toxicity). Before a drug can be marketed in Australia, it must be evaluated by the Therapeutic Goods Administration (TGA). Whilst the TGA Act does not mandate animal testing, the underlying guidelines often imply that animal test data is expected. For example, one of the stages in the evaluation process is to evaluate animal pharmacology and toxicology data. A drug sponsor may request a waiver where validated alternatives exist or there is no animal model to mimic the disease under investigation. For more information, see here. 

Macaques and marmosets are commonly used for research in the fields of neurological, cognition, vision research or HIV research. Baboons are used for diabetes, pregnancy hypertension, cardiovascular disease and kidney disease research. Baboons are also used for animal- to animal xenotransplantation. Examples can be found in our case studies.  Animal-Free Science Advocacy also draws to attention unethical research involving international companies. For example, Animal-Free Science Advocacy joined UK organisation Action for Primates in condemning infant formula research in which baby monkeys were killed, as a cruel and callous waste of life. Twenty-three female rhesus macaques suffered the trauma and loss of having their babies taken from them and 23 baby monkeys were purposefully killed at 6 months of age for a human infant milk formula that is already on the market. The study was funded by Abbott Nutrition and the US National Institutes of Health.

Our everyday language can intentionally or unintentionally reinforce the acceptance of animal experimentation.

We inadvertently objectify non-human animals whenever we refer to them as “it”. When we instead refer to an animal as “they” it acknowledges that we are not talking about an object but a living being. When we objectify animals, it makes it a lot easier for humans to justify animal experimentation.

Calling animals that are used in laboratories “laboratory animals” or “lab animals” is a commonly used term that has imbedded itself into our everyday vernacular.

However, this can be problematic as it implicitly reduces an animal’s identity down to its utility and defines the animal as existing merely for the purposes of being used for experimentation in laboratories. This framing reinforces the normalisation of animals being used for scientific research and education.

As an antidote to this, try saying “animals in laboratories”. And whenever possible address the animal by their species for example “mice used in experimentation”.

Sometimes we avoid calling things by their name and we use words in ways that are inaccurate. This approach is used to minimise the implications of actions. For example:

“The dogs were euthanised at the end of the testing period” instead of “dogs were killed after they were no longer of use for testing purposes”. The nuance may be subtle but can make a big difference in our perception of a situation, with the term sacrifice implying that it was for a greater good.

Terminology evolves. For example, editors of the Journal of Animal Ethics have asked prospective authors to replace the word ‘pet’ with the word ‘companion animal’. Animal-Free Advocacy chooses to use the term ‘animal membership’ for our symbolic animal membership as opposed to ‘pet membership’ and uses the terminology animal companion or animal friend.

The terminology we use to describe animal-free research methods is explained here

Summary: Outsourcing is a possibility whenever regulations are strengthened, but that risk alone does not justify keeping weaker protections in Australia. Australian institutions should remain responsible for research they fund, commission or conduct overseas. The aim should be to prevent animal harm from being relocated, while investing in NAMs that replace the research altogether.

There is always a risk that people or organisations will try to avoid stronger laws by moving an activity elsewhere. We see this across many areas of regulation. However, we do not usually respond by deciding that regulation is pointless. The possibility that a law may be avoided does not mean the law should not exist—particularly where harm is involved. 

The same principle applies to animal research. Australia should not overlook weaknesses in its current system because an institution might move its research overseas. That would mean allowing the threat of outsourcing to set our ethical standards. It would also place the interests of research institutions ahead of the animals who experience the harm. 

Instead, Australian institutions should remain accountable for animal research they fund, commission or conduct overseas. The Australian Code already states that overseas projects involving Australian researchers or institutions should follow its governing principles and must not be moved overseas to avoid Australian requirements. These projects also require AEC approval and appropriate monitoring (NHMRC, 2013). 

These responsibilities should be strengthened and properly enforced. Institutions should have to explain where overseas research is taking place, why it is being conducted there and how the animals are being protected. Australian funding and research contracts should also require equivalent standards, regardless of the country in which the work occurs. 

Most importantly, stronger regulation should not simply push the same animal experiment across a border. Australia should be investing in NAMs that offer more human-relevant and reliable ways of conducting research without animal harm. The purpose of reform is not to export the ethical problem. It is to change the research landscape so that reliance on animals is no longer treated as inevitable. 

References:

National Health and Medical Research Council (NHMRC) 2013, Australian code for the care and use of animals for scientific purposes, 8th edn, updated 2021, NHMRC, Canberra, clauses 2.6.9–2.6.14, Australian Code.

In summary: While animals continue to be used in research, Australia needs stronger and more independent regulation. The system should not only ask how harm can be reduced; it must first ask whether using animals is necessary at all. AFSA supports nationally consistent oversight, greater public transparency and proper investment in the transition towards Non-Animal Methods. 

Animal research in Australia is governed by state and territory laws and the Australian Code for the Care and Use of Animals for Scientific Purposes. The Code sets the national standards that institutions and Animal Ethics Committees are expected to follow, including the principles of the 3Rs – Replacement, Reduction and Refinement. However, the Code has remained largely unchanged since 2013 (although currently under review at the time of writing) and is applied through separate state and territory systems, which creates concerns about consistency, enforcement and whether Replacement is actually being prioritised. Australia’s current system also relies heavily on Animal Ethics Committees (AEC) within the institutions conducting the research. AFSA has identified concerns around AEC’s regarding conflicts of interest, power imbalances, inconsistent or lack of training and limited transparency. AECs need greater independence, nationally consistent training and better support for Category C and D members so they can confidently question complex research proposals. 

We believe the system should first ask, Is animal use justified?—not simply, How we reduce harm? Researchers should be required to show which NAMs and existing evidence they considered, why these approaches were not suitable and why the expected benefits justify the harm involved. 

Australia also needs consistent public reporting of the animals used, the procedures performed, the expected harms and the research outcomes. Government regulators should have the authority and resources to conduct audits, investigate complaints and respond when institutions do not meet their responsibilities and standards. 

Whilst we have established that stronger oversight and more stringent regulatory frameworks should be implemented around animal use, there should be just as much focus and attention on changing the research landscape itself. The shift away from animal use and towards NAMs must also be prioritised. 

AFSA resource:

 Australian regulations relating to animal use

Rethinking Animal Ethics Committees

New Report Calls for Overhaul of Animal Research Oversight in Australia

In Summary: Language shapes what people notice, whose interests count and which practices appear normal or not. Accurate, respectful wording helps shape public understanding that animals used in research are sentient individualsnot equipment, commodities, or raw materials.

Terms such as ‘laboratory animal’ can define an animal entirely by the human purpose and interest imposed on them. ‘Animals used in research’ or ‘animals in laboratories’ makes the action and setting visible. Where practical, naming the species—such as ‘mice used in an experiment’—is clearer still. Referring to an animal as ‘they’ rather than ‘it’ avoids treating a living being as an object. 

This distinction matters because language carries associations. Describing an animal as ‘it’ or solely as a research tool can make a living individual seem like an object or an interchangeable unit. Describing them as ‘they’, or as a mouse, dog or primate who was used in research, reminds us that the subject is a someone rather than a something: a sentient being capable of experiences and with interests of their own. 

Language can also hide harm. ‘Sacrificed’ may mask that an animal was killed; ‘procedure’ may obscure experiences ranging from a minor intervention to severe suffering; and ‘humane endpoint’ does not mean the animal experienced no harm.  

Terminology matters scientifically too. AFSA uses ‘Non-Animal Methods or Non-Animal Models’ and ‘NAMs’ for methods that do not use live animals. In regulatory settings, ‘New Approach Methodologies’ can be broader and may include approaches that reduce or refine animal use. Clarifying the intended meaning prevents confusion and protects AFSA’s message. 

Thoughtful language is not about policing every word. It is about communicating honestly, avoiding euphemism and keeping both the animals and the scientific question visible. 

Acknowledging animal personhood and granting them a right to dignity is not an act of charity, but a duty of rightful respect toward our fellow living beings, to achieve this we need to consider the language we use to discuss them. 

In summary: Ethics asks us to examine what we value, how we justify our decisions and whose interests may be affected by them. It encourages us to move beyond black-and-white thinking and consider different perspectives, competing interests, potential harms and benefits, and our responsibilities to both humans and animals.

Ethics is connected to morality and the law, but it is not the same as either. Something can be legal without necessarily being ethical. Ethics asks us to look beyond what is permitted and consider what is right, what is fair, what may cause harm and whether that harm can genuinely be justified. 

Our ethical views are shaped by our experiences, environment, culture and the value we give to different lives and interests. Every issue has multiple angles and shadows. Ethics encourages us to question our assumptions and consider perspectives beyond our own, particularly those of individuals who are vulnerable, unable to consent or whose interests may otherwise be overlooked. 

This is essential when discussing animal research. We cannot consider only the hoped-for benefit to humans. We must also consider the animals who experience the harm, whether they receive any benefit, whether the research is necessary and scientifically sound, and whether Non-Animal Methods could be used instead. 

Moving away from animal experimentation is not only about preventing animal suffering. It is also about producing better science for humans. Greater use of human-relevant methods can improve how well research applies to human biology, help identify ineffective or unsafe treatments earlier, reduce research waste and make better use of public funding. More efficient and accurate research can lead to better outcomes for patients and the wider community. 

For AFSA, these scientific and ethical considerations are closely connected. If a method avoids animal harm while also producing evidence that is more relevant to humans, prioritising that method benefits both animals and humankind. Ethical scrutiny must therefore ask more than how harm to animals can be reduced. It must ask whether their use is necessary at all, whether the expected human benefit is realistic and whether a more responsible and human-relevant approach is available. 

AFSA opposes the harmful use of animals in research and teaching on both ethical and scientific grounds. We believe it is unethical to cause harm to sentient beings for research that offers them no direct benefit, particularly when they cannot consent to their use or refuse participation.

Our ethical position is founded on five key principles:

  • Animals are sentient, meaning they are capable of experiencing pain, fear, distress, and other subjective experiences
  • Animals are used in research that provides them with no direct benefit
  • Animals cannot give informed consent to participate in research
  • The potential benefits of animal experimentation do not justify the ethical costs of harming animals, particularly given the scientific limitations arising from species differences
  • Animal experimentation can also harm humans by producing misleading or non-predictive data that can delay or compromise medical progress

AFSA believes ethical review should extend beyond asking how animals are used to asking whether they should be used at all. While the Australian Code for the Care and Use of Animals for Scientific Purposes seeks to minimise harm, it begins from the assumption that animal use is acceptable and gives insufficient weight to animals’ autonomy, sentience and intrinsic interests. 

We therefore advocate for stronger ethical scrutiny of animal research, greater recognition of animal sentience, and accelerated investment in modern, human-relevant, animal-free methods that deliver better outcomes for both animals and people. 

AFSA supports the application of principles guiding the research ethics of human subjects extending to non-human animals in light of their vulnerable status and inability to dissent (or for such dissent to be recognised and acted upon). These principles include respect for autonomy, obligations to beneficence and justice, and special protections for vulnerable individuals and population..

Ultimately, AFSA advocates for the replacement of animal experimentation with modern, human-relevant research methods and for a stronger ethical framework that scrutinises whether animal use is justified, rather than simply how it is conducted.

For more information on the ethical case for opposing animal experimentation, see this bioethicist’s webinar, or watch peter Singer’s video on ethics in animal research

Further resources on ethics:

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