The National Commission for the protection of animals used for scientific purposes (CNPAfis), created in 1987 under the name “Commission nationale de l’expérimentation animale” (CNEA until 2020), is a national advisory commission reporting to the Minister of Agriculture and the Minister of Research.
The commission is made up of a chairman, 8 government representatives and 15 qualified personalities appointed for a renewable five-year term by joint order of the ministers of agriculture and research. It meets at least twice a year.
Since 2005, a national committee for ethical reflection on animal experimentation (“Comité national de réflexion éthique en expérimentation animale” – CNREEA) has been working alongside the company to issue opinions on the ethical issues raised by animal experimentation.
The “CNPAfis/CNREEA” pairing is intended to play the role of the National Committee for protection of animals used for scientific purposes, as provided for in Article 49 of Directive 2010/63/EU on protection of animals used for scientific purposes.
CNPAfis missions
In particular, CNPAfis gives its opinion on any project modification of national legislation or regulations relating to animal experimentation.
It advises the Minister for Agriculture on training courses for personnel involved in designing experimental procedures using animals, applying procedures on animals (performing technical and even surgical procedures), and maintaining and caring for animals used in procedures. If the opinion of the CNPAfis is favorable, the training course is approved for a period of five years by the Minister of Agriculture. Renewal of approval is subject to a new opinion from the commission.
It may also be consulted by the ministers to whom it reports, as well as by the Minister of Defense or the Minister of Health, and may issue opinions and make any proposals it deems useful on subjects relating to the use of animals for scientific purposes, their rearing, transport and housing conditions, the training of personnel required to use or care for animals, the validation and promotion of alternative methods, and the annual reports on CNREEA’s activities.
The missions and composition of CNPAfis and CNREEA are defined in articles R214-130 to R214-38 of the French Rural and Maritime Fishing Code (CRPM).
As of 2017, the CNEA has produced several recommendations that can be found on the Ministry of Higher Education and Research’s dedicated page.
Among the most recent (in French):
– recommendation on tutoring for new employees who will be required to perform technical tasks on animals: recommendation-tutoring
– recommendation for no-wake-up procedures: recommendation-no-wake-up-procedures
– recommendation on euthanasia of newborn rodents: recommendation-euthanasia-newborn-rodents
– recommendation on the use of animals in higher education: recommendation-use-animals-in-higher-education
OBSERVATIONS
CNPAfis recommendations mainly concern training or good practice in animal experimentation, and are aimed at staff who have to perform technical procedures on animals used for scientific or educational purposes. They focus primarily on the application of the refinement principle (minimizing the suffering inflicted on animals).
No recommendations on alternative teaching tools, their use or development. We note in particular that nothing has been envisaged for the “practical” training of personnel required to apply procedures on non-human primates (whose use has been prohibited for training purposes since the adoption of European Directive 2010/63/EU in 2010).
More generally, there are no recommendations on the validation and promotion of alternative methods.
No recommendations on housing and transport conditions for animals intended for scientific or educational purposes, when some are transported thousands of kilometers and others come from unapproved farms.
Nor is there any recommendation for changes to current national regulations, which would nevertheless be desirable, since these are merely a minimal transposition of European regulations, and the interests of animals could be much better taken into account. Other member states of the European Union have adopted provisions that are more favourable than European ones for the better protection of animals.
Furthermore, article 49 of the aforementioned directive stipulates that “national committees shall exchange information on the operation of animal welfare structures and on project evaluation and share best practices within the Union”.
The minutes of CNPAfis meetings make no mention of any exchanges with other European national committees. Yet this mission is provided for in the 2nd paragraph of article R214-131 of the CRPM.
In short, due to a lack of resources or a lack of will and interest, CNPAfis is only very partially fulfilling its regulatory missions.
Records of decisions from the CNPAfis biannual meetings have been published on the Ministry’s website since 2022.
