Initiative to amend 2 annexes of the European Directive 2010/63/EU on the protection of animals used for scientific purposes -call for action @ end

Dear ZHA members,

There is an ongoing initiative to amend two annexes of the European Directive 2010/63/EU on the protection of animals used for scientific purposes. The changes include standards for species currently not covered by the annexes but within the scope of the Directive (such as the zebrafish). The European Commission has published the draft and is open for feedback until February 1st.

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Personal version

After reviewing the document, we think that some changes are very beneficial, such as the inclusion of the water parameter reference table, and the rapid-chilling/hypothermia method for euthanasia. However, there are 3 topics that would benefit from clarification to avoid misunderstandings or misinterpretations that could potentially arise.

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Association version

The Zebrafish Husbandry Association (www.zhaonline.org) is a non-governmental and non-profit organization devoted to promoting and developing zebrafish husbandry standards, with currently about 500 members from all around the globe. After reviewing the intended amendments to Annexes III and IV of the EU Directive at board level, there was support for most of the changes pertaining zebrafish, such as the inclusion of the water parameter reference table, and the rapid-chilling/hypothermia method for euthanasia. However, there are 3 topics that would benefit from clarification to avoid misunderstandings or misinterpretations that could potentially arise.

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1. Annex III, Section A (i), where the following point is added: “(d) for aquatic animals, equipment causing noise or vibration, such as power generators or filtration systems, shall be separated from the animal holding tanks.” While this is highly desirable, currently, many commercial zebrafish systems have built-in filtration systems and pumps that cannot be displaced to a different room. Therefore, we suggest this to be a recommendation and not mandatory, to allow changes to be made gradually, as new systems and facilities are built or restructured.

1. Annex III. 11.6.2 Lighting. “During the light phase, the light levels shall be constant. Dark phase shall be completely dark.” According to the literature, for zebrafish, gradual change of lighting to simulate dawn and dusk have been suggested as an environmental enrichment strategy. However, this gradual transition may not be technically possible to implement in all facilities, Therefore, it could be stated as a recommendation. We suggest an amendment of the sentence to: During the light phase, the light levels shall be constant. Dark phase shall be completely dark. Sudden transitions of light intensity should be avoided, and a gradual transition between light/dark cycles is recommended.

1. Annex III. 11.6.3. Stocking density and environmental complexity. “water volumes smaller than 1 litre shall not be used for adult zebrafish. Stocking densities shall not exceed 10 fish /litre.”

While the volume limit probably refers to a general husbandry practice, it would be beneficial to consider exceptions to allow procedures, mating, and genotyping, that are frequently done in smaller volumes for very short periods of time.? This could be clarified by amending to: Concerning the housing of zebrafish adults in small volumes (less than 1 litre), it is allowed for short periods to permit individual genotyping, matings, and other experimental procedures. Water volumes smaller that 1 litre shall not be used for long term housing of adult zebrafish.

Regarding the proposed maximum stocking density of 10 fish /litre, we suggest the inclusion of the word “adults”, to:? 10 adults /litre. By specifying this limit for adults, increased stocking density at younger life stages is allowed, which is common practice during larval stages, and is not known to have negative consequences for the animals.

Call for action

It is important to massively convey the feedback of the community, so the proposed document does not turn into law in its current form. If you agree with the amendment suggestions (totally or partialy), please go to the following link and leave your feedback. Feel free to copy the above text. Take note that this is time sensitive, and the deadline is

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13628-Animal-welfare-Animals-used-for-scientific-purposes-adaptation-of-standards-on-care-accommodation-and-killing-_en

Thank you for your support!