Okay, good evening. I'm Vaughn Black, I teach here at the law school. I've turned off the mic because I hope I'm audible in the back row without it. The problem with the mic is I tend to wander around and if the mic is on, I'll go in and out of my crate. If I'm not audible, let me know and I'll turn it back on and I'll try to tether myself to this. But thanks very much for coming out. I can think of at least two independently good reasons why people might want to stay at home on a daylight today. But I appreciate people coming out for this. I've actually given two of these mini-law talks before, I don't know if any of you was at any of the others. The first two were just on animals on the law, generally. And I enjoyed them, but a problem I had with each of them is that on the blurb on the poster, I said I'd deal with legal regulation of animals in a number of contexts, companion animals, agriculture, hunting, and research. And I never got to research in either of those. I sort of intended to, but then I sort of sensed people wanted to move to question period. And I should say, I'm not gonna talk for more than an hour, probably about three quarters of one and we can have a question period at the end. But I made lots of notes each of those times and I didn't get to do what I was gonna say about the regulation of research on animals. And I consciously made the choice not to deal with that when I realized I just had too much material. And the reason I dumped the research part of that was because of the numbers. I'm concerned about animal welfare, the number of animals that are used in Canada for research, according to the data from the most recent year, 2012, 2013, is about three and a third million of them. That used to be mostly mice. Until about five years ago, mice were in the lead followed by rats. Mice have been displaced as the number one research animal by fish, and fish aren't broken down into categories, but the numbers of animals used in research in Canada has grown slightly. And fish are largely responsible for that growth. That's partly research on fish used in agriculture, but I think far more prominently, there's a new animal called the zebrafish, which is sort of the new mouse. It's amenable to a lot of genetic manipulation and creation of transgenic strains of animals and people are using zebrafish a lot, just in the last four or five years. But as I said, three and a third million is a lot, but the reason I didn't get to the research part of the talk was that that number is minuscule compared with the use of animals in some other spheres, notably agriculture. That is, if we kill or use, not all animals in research are killed, but most of them are. Three and a third million a year, we kill that many chickens about every day and a half. There's just a lot more animals used in agriculture that is for food and fiber than there are for research. And when I was thinking before about which part of my talk to Chuck, I thought, well, I'm concerned with the numbers issue, where is the most animal suffering? And let's chop out the research part because it just is, of all three million animals is a lot. It's small compared with some other uses of animals. But reflecting on that now, it might not have been the right choice or at least there might be something to be said on the other side because I think, and your presence here tonight is some testimony to that. People have long been particularly interested in the use of animals in research. Even though the numbers may be small and maybe we can investigate the reasons for this in question period, but people, although the numbers are small, people have long focused on the use of animals in research. In Victorian England, which is the first evidence of concern of animal welfare, the main focus there was use of animals in research. The anti-vivisection society in England was the single, which concerned itself with the use of animals in research in Victorian London was the primary animal welfare movement. It resulted in 1875, we'll get back to a bit of this, but it resulted in 1875 in a Royal Commission in England into the use of animals in research, which then resulted in a statute the following year. That is the focus, even though there was a lot of use of animals in agriculture then, the public concern about animal welfare was interestingly focused on the use of animals in research. It's long had a, for whatever reason, maybe our concern, the picture of some crazed Frankenstein-type scientist who's lost his moral bearings has got maybe a grip on the public imagination that is maybe out of proportion to the numbers. It's interesting, in Canada, I mentioned a second ago, the Royal Commission in England, we've never had much public debate about the use of animals in research. We've got a law, but it's not the result of any Royal Commission or country-wide inquiry, or to my mind, any sustained public dialogue about the subject. In fact, the law, well, I'll explain it in a little more detail in a minute, but our law on the use of animals in research has largely been made by the scientists for themselves, and that's something we haven't done in any other field. We are no fan of our laws on animal welfare and agriculture, but they haven't been set by the farmers. I'm no fan of the laws dealing with regulation of zoos, but we haven't allowed the zookeepers to set it, as we'll see in a few minutes. So the laws with respect to the use of animals in research have overwhelmed when we be made by the scientists. Now, when I explain it, you may think they've done a good job. Let's, we're content with that, but we've allowed them to run the show to an extent that I think hasn't been done elsewhere on the use of animals in Canada, and it's my sense, and some of you might share this and some don't, that there really is room for a bit more public dialogue on this subject. I do think as a member of the Dalhousie community, there should be more discussion at this university about our standards for the use of animals in research, and even those of you here tonight who aren't members of Dalhousie, it's your tax dollars that support this research, and I tend to think it would be nice to have a little more public debate about the subject than we've had, and maybe we can have a little bit of that to a little start later on. I don't, in suggesting that there could be some public debate here, I don't for a second imagine that it's an easy one. The subject has often been one that's, if not outright polarized, at least characterized by a fairly wide range of opinions. I suspect there are people here tonight that I would describe as abolitionists who would think that there should be no invasive research on animals, and I imagine there are people at the other end of the spectrum who think that the existing regime is just fine, or maybe is too inhibitory of research and stands in the way of some research that should be done. Certainly the public opinion polls that I've seen on this subject in looking at Canadians and elsewhere have tended to indicate that it's one where there's a pretty broad range of opinion, and moreover, where that opinion hasn't changed much over the last decade or so. We're all familiar with subjects, same-sex marriage would be the best example where public opinion has changed markedly in the last 20 years, and I could give some other examples. The research polls tend to show that on a question of animal research, there hasn't been much change. That is the portion of abolitionists isn't growing, it's about what it was a decade ago. So I don't imagine if we have any public discussion of this that it will be easy. It might just be opening a can of worms, but still I guess in a sort of optimistic fashion I think it might be useful to take a few steps down that road. Let me then turn to a description of the legal regimes that we have impinging on research on animals. And there are three, and I'll talk about them in order. The first is the general anti-cruelty provision in the criminal code of Canada. The criminal code's a federal statute. It has had almost since its inception a provision dealing with animal cruelty that among other things can bear on research on animals. So that's the first and we'll get back to it in a second, but just to list the other two, there is provincial animal cruelty legislation, animal protection legislation in this province and in every Canadian province that Nova Scotia has called the Animal Protection Act and we'll look at some of its provisions in a second and how they might bear on this subject. And the third regime, I'll spend more time on this, is the regime established by the Canadian Council for Animal Care, which you may or may not have heard of, but is the regime that has the most effect in this area. Now, one comment, I said I'm talking about legal regulation of research on animals. There's lots of other statutes that might bear on particular kinds of research if somebody wants to do some research in Nova Scotia where they catch a fish from a lake and tag it, they may need some permission under fisheries or wildlife legislation to be able to do that if they're fishing out of season. There are lots of statutes that bear on if somebody needs some research animal shipped in from another country, then getting permits for that kind of importation. So there's a variety of statutes that deal with say use of toxic materials in research and so on, but the three that I'm focusing on, I'm focusing on because they impinge and focus on the welfare of the animals that are used in research. And that I take it that was probably what you expected when you came, it's not the question of whether somebody can catch a fish and tag it and get, you know, has got the right permit under the Fisheries Act. We're talking about the statutes that bear on some control of the extent of suffering or pain or distress that the animals can be subjected to. Let me then focus a little bit on each of those three. The first one, and there is a sort of a one-page handout, I hope people got it when they came in that contains a couple of excerpts that might be useful to have before you in print. And the first of those, the one headed number one, is what I call the general anti-cruelty provision of the criminal code of Canada. The one that says, everybody commits an offense who willfully causes or being the owner willfully permits to be caused unnecessary pain, suffering or injury to an animal or bird. Strange they call it animal or bird.  We could have a whole session on how the criminal code classifies and talks about animals. It's a curious and very out-of-date practice. Now, it doesn't mention research there. I'm talking about the general anti-cruelty provision because it applies to all uses of animals in Canada. It's the one that can be brought to bear and has been brought to bear on keepers of zoos and runners of rodeos on people who abuse their companion animals on people who transport farm animals and have them freeze to death on the ride to the... It just applies to everything. There are no exceptions. It doesn't mention research, but it covers research. There are in the criminal code a couple of very specific statutes or provisions dealing with some, if I say quite specific things, like no dog fighting, no running a cock fight or things like that. The criminal code's got a couple of odd historical things that focus on sort of narrow uses of animals. It's got one that says it's illegal to run a regime where you have captive birds and let them go just to be shot after they're just as they're flying away. So it's got a few specific things like that, but by and large, it doesn't. It's essential provision is the one that I've just quoted which is the general anti-cruelty provision. It's modeled on an English Act that goes back to 1822 when Canada was confederated in 1867. It took about a year and a half for us to make that part of our criminal law. We put it in the criminal law from an early stage. It's been changed and altered about a dozen times between its passage in January of 1869 and now, but it's roughly the same sort of provision. Outlaws or seeks to outlaw with a penalty that's currently a maximum of five years in jail, so that maximum has never been imposed, but it outlaws people who willfully cause unnecessary pain, suffering or injury to an animal. A lot of animals in research do suffer injury and pain, but of course that doesn't trigger the cruelty provision in the criminal code because it only outlaws unnecessary cruelty or pain, and the criminal code doesn't offer a definition of unnecessary. It's left that up to the courts, and here you have to bear with me while I take a minute or two to describe the content that courts have given to that. It's a pretty open-ended word. You might well imagine court saying, it's not necessary to do any research on animals, and in one sense it's not. We could stop, but of course that's not the meaning that's been given to unnecessary in that provision. What is the meaning? Well, curiously there are two. There are two strains of meaning given to the word unnecessary in the criminal code provision. You'd think it would be sorted out by now. The Supreme Court of Canada has never entertained an appeal on this provision of the criminal code. They've been asked to, but they get to pick and choose what they want to hear, so they haven't sorted it out. So we have to choose between some decisions of the Quebec Court of Appeal and decisions of the BC Court of Appeal trying to give some content, and interestingly there are conflicting ones. Very briefly, the first is what I would describe as lexical priority, and it's this. If we think that a use of animal is a good thing, then we're allowed to do it even if it causes pain, so long as it doesn't cause more pain than necessary. And let me illustrate this with a decision of the British Columbia Court of Appeal. It's not an animal welfare, it's not an animal research provision, but it's one where someone sought to charge a rodeo with inflicting unnecessary pain and suffering on an animal because the rodeo uses what's called a flank strap that sort of, if a horse is gonna be bucking, you make them buck more by tightening the strap that goes sort of around their back and basically through their groin and either causes a lot of pain or a lot of irritation and they buck more. So we're intentionally causing pain in that case to a rodeo horse because they buck more. Is that unnecessary pain? Well the court thought not, and here's its reasoning, it's stripped down. The goal of rodeos is a good one, it's family fun, it's not sadism. The rodeo people have to make money. If the horses don't buck enough, not enough customers will come out to the rodeo. So it's necessary to cause pain to make them buck more. It's not being done sadistically, it's being done for profit and rodeos are in competition with, I don't know, these days, what, you know, Netflix or everything else. They've got to get the customers to come out. So it's necessary to cause the pain to do that. And that's one answer and it could be applied in research this way. If somebody wanted to market a new shampoo and they thought they wanted to do some testing on animals on the shampoo to make sure it wasn't toxic, didn't make your hair fall out or something and they wanted to market a new shampoo that was flavored like kumquats or something like that. You might think, is it necessary to do this test? Well, in one sense, you know, when I go to the shopper's drug market, there's not as short as the choice of shampoo. I've noticed that, you know, I can get the watermelon or the lemon flavored, it's not necessary to have kumquat flavored or, you know, essence shampoo. But the company could get away with doing the testing and the testing on animals by saying, well, I'm doing a good thing. I'm providing jobs. I'm providing a new shampoo and more consumer choice. I'm not in testing this shampoo on animals being sadistic. So to the extent that test causes some pain, it's necessary pain because we need the pain to achieve the goal of animal testing. That's one instance, but there's a second one. And it's one that, and here I've given you my second quotation, bold number two, that is applied by the Quebec Court of Appeal in a Menard case, again, not a research case where the Quebec Court of Appeal said, in judging whether pain is necessary, we have to look not only at the end that's sought to be achieved, like getting people into rodeos or getting a new shampoo, but balance the worth of that end against the pain that the animal suffered. Have some kind of balancing where you sort of ask, how much do we really need a new shampoo? Is it worth killing X number of animals for? And we entertain a balancing not only about the means used, but about the worth of the end. And I think that sort of utilitarian balancing, although it may seem not enormously different from what I've described before, is. And I've given you, in the third heading, an example of how animal research is currently regulated in the European Union that I think gives an example of that sort of balancing. This is the European Union on the directive and it had to be instantiated in the laws of the member countries, United Kingdom, and so on. It says, in deciding whether research on an animal is necessary, the likely harm to the animal should be balanced against the expected benefits of the project. That, I take it, is an example of balancing applied specifically in the animal research context, which represents, quite specifically, and I think very easy to understand, terms the second approach in the criminal code. Now, you might be then, and asking yourself the question, well, if there's two approaches to the criminal code, which one has been applied in prosecutions of scientists for research on animals? The short answer is there's never been such a prosecution. Criminal code, as I said, has been brought to bear on rodeos and zoos and farmers and animal transporters. It's never once, by a crown prosecutor, been brought to bear on researchers of animals in Canada. There have been prosecutions in some other countries in Canada, not. Now, a possible answer is that there's just never been any animal cruelty in any lab in Canada. There may be other explanations. So we don't have a prosecution there, or, but here I back off and qualify something. We don't have a prosecution by the crown, but here's something, and you might not have known this before, it's possible for private individuals to bring prosecutions. You can lay a murder charge. There are a few things under the criminal code that specifically say charges can only be laid by the attorney general, but there aren't very, many of them. Individuals can go down if the crown attorney doesn't bring a charge, and try to bring their own charge for sexual assault or fraud, I don't recommend it. It's really hard. You have to figure out how to serve the subpoenas and do the disclosure, and it's not any accident that crown attorneys have got a big office and bureaucracy in the system, so police officers and so on. But you can lay a private prosecution, and there actually have been two of them with respect to research in Canada, both by a sort of animal welfare group by the name of Life Force. Can't tell you a lot about them. One of them was laid against research being done against a baboon, a baboon just called B33 at the University of Western Ontario in about 1985. A private prosecution was started and the case was settled. The university said, okay, we won't do anymore.  It's not clear, but they settled the case, so the matter never went to trial. We don't have a judicial determination arising from that case about what the test should be. The second charge was laid by the same group in respect of a dog being subjected to research at a hospital in Vancouver, the Vancouver General Hospital, and the Attorney General of British Columbia put an end to it. Here's the thing with private prosecutions. If you can go out, as I said a minute ago, and lay your own charge for assault or fraud or whatever, but if the Attorney General doesn't like it, they can go down and withdraw it. And that's what happened in BC. And who knows for what reason. Maybe it was a frivolous charge and the Attorney General thought that it was not in the public interest to pester the good doctors at the hospital with a prosecution that had no chance of succeeding. Who knows? So in short, you might wonder, why did I talk about the criminal code at such length if it's never actually had an impact on research? Well, good question. Maybe I shouldn't have. I do want to editorialize later and say this. I think that there is room for criminal code prosecutions in respect of a considerable amount of the research that's being carried on in Canada. And I would like the crown prosecutors to, I know they've got their priorities and they've got to chase the murderers and the rapists and so on. I think they should think a bit more broadly and I want to sort of expand a little bit on that at the end. But let me move to the second heading. All the provinces have got provincial legislation dealing with animal welfare. Nova Scotia, this is called the Animal Protection Act. And I've got the main provision of that in note four. No person shall cause an animal to be in distress. There's a fair bit of overlap between the criminal code's general anti-cruelty provision and the anti-distress provisions in provincial statutes. In a lot of circumstances where someone's not paying attention to a companion animal or a farmer isn't feeding the cows and they're being left to starve out in the back 40, the prosecutor will have a choice as to whether to lay a charge under the criminal code or provincial legislation. There's a fair bit of overlap, although it's not complete. Here's the big difference with the provincial legislation and you see it in section 40 at the bottom. It says the governor in council, that is the cabinet, can make regulations exempting research activities if the research are carried out, pursue it to an audit program approved by the Canadian Council on Animal Care. That is, there cannot, unlike the criminal code, which doesn't exempt anybody and which applies to research, as it applies to other matters, the provincial legislation says research is exempted if it complies with the program of the Canadian Council on Animal Care. So it would be only research that didn't comply with that program which I'm gonna try to explicate in a minute. So there's not as much scope under the provincial legislation for charges to be laid against researchers as there is under the criminal code. And again, no charge has ever been laid. There has never been a crowned prosecutor in Canada who's laid a charge either under the criminal code or provincial legislation. Now, again, we may say that maybe because no research offends these provisions. Again, I'm gonna have a little pitch at the end to say that I think it does and I think there are other reasons why there haven't been any charges. But let me move to what I think is the main focus of research in Canada. It's the third regime. It's the Canadian Council on Animal Care and its provisions on animal research. And you've got that title in bold heading number five there. The phrase, sorry, the name of the group, the organization Canadian Council on Animal Care is maybe a little bit deceptive because you might think it's just concerned about animal welfare. It's like the Humane Society or the Canadian Federation of Humane Society. It's not. The Canadian Council on Animal Care is the main body of scientists and users of animals in research. I wish they would put research in their title to sort of clarify that. I don't know why they don't because as I say, the title Canadian Council on Animal Care makes you think they're growing up and rescuing animals. But they're the body that controls research and sets up regulations for it, largely a body of scientists. Although it does have a body of animal users, but it does have, as part of its membership, organizations like the Canadian Federation of Humane Society, which is sort of not animal research users but want to be in part of that picture. Let me give a little bit of history about the CCAC regime. I mentioned at the outset that in the United Kingdom, there was a public inquiry or royal commission into the use of animals and research in late Victorian times, 1875, that resulted in a statute, very briefly that the statute that was passed in 1876 in England just required people doing experimentation on animals to get a license. Once you got a license, we didn't much monitor it. And if you're a doctor or a graduate of Oxford or Cambridge and worked in a university, you got your license. If you were a quack, maybe you didn't.  And that was the regime that came in then. It was and persisted for about 110 years. Canada didn't have any specific regulation until then. We didn't get it until the 1960s. And what happened in the 1960s that caused this? Because other countries, apart from England, had started to regulate before that. I think we have to look to a couple of strange events in the United States in 1965 and 1966. The first one was an article in of all places sports illustrated in 1965 about a family dog, a Dalmatian, that ran away and couldn't be found but was finally found to be captured by a pound and sold to a university or hospital and experimented on. And when people found their pet had been killed, it was good copy for sports illustrated. Even bigger in terms of the public splash and those of you who wanna go do some website research, the February 4th, 1966 edition of Life Magazine saw that there was good traction in this sports illustrated story and did a big spread, I don't know if those of you under 40 might not remember the impact of Life Magazine but great photo spreads. And this was one of a dog pound in the state of Maryland that kept dogs and sold them to research institutions and the pictures were of just horribly emaciated, ill kept animals. And again, you can find all of the old Life Magazine things online and just go by issue to, as I say, February 4th, 1966, pages 22 through 30. So it stirred things up a lot and there were newspaper stories in the same vein. People, for whatever reason, got very exercised about research on animals in the United States and as I understand it, in Canada at that time, in the United States they then passed a law about it. The Animal Welfare Act was passed by Congress pretty promptly late 1966 and they got what England had had since 1876 a dedicated statute dealing with research on animals. It's just called the Animal Welfare Act. It doesn't have research in the title but it's pretty much exclusively about research. So Congress acted in the United States and passed the Animal Welfare Act. Very briefly, I mean, it only dealt with a limited number of animals. What were they? Cats, dogs, guinea pigs, you know, pets basically. It didn't include rats or mice. It did include monkeys, chimpanzees that were not pets but broadly people were worried about research on fluffy and skippy and not rats and mice but they got a statute. There was push in Canada for a statute around the same time and the government of Canada, government of Lester Pearson said, let's refer it to the National Research Council. They'll come up with something and I think there might have been an expectation that we too would get a statute in Canada. Like England had had since Victorian times and like the United States had just had. That's not what the National Research Council did. They basically said, let's let the scientific community run our own show. We can do it. We'll regulate ourselves and you can watch if we don't do a good job, you know, step right in and pass this statute but give us a chance to run our own show and that led to the formation in 1968 of the Canadian Council on Animal Care and the regime that I'll try to describe in just a second. Now, I can see you might be asking now, at this point, well, hold on, I thought this was about legal regulation of animals and this is a regime where the animal user said, don't pass a law, let us regulate ourselves. So what's that got to do with law? Well, again, a fair question but people like to talk about the law often go on and a little bit outside the bounds of the law and look at this sort of phenomenon which isn't at all uncommon where there's a threat of a statute or a push towards a statute to regulate a certain practice or industry and the group says, hold off, let us regulate ourselves. If you don't like the job we're doing, you can pass a law but give us a chance to self-regulate and that's, although it's not technically law, it's close enough that legal scholars often talk about it in the same context and I'll say a few things in a minute that show that the effect of the CCAC regime is in some respects, at least in the sanctions that it's able to impose, harsher than the law. Let me briefly describe the CCAC regime. Three main parts to it. One, the CCAC, this national body will set standards for use of animals in research including standards for acquisition, for how they're housed, for how they're fed, for the ventilation, for the exercise they have to get for the social interaction they get and set a variety of standards for recent and including things like methods of euthanasia and the whole regime. They set, and the standards are very detailed. They're too big to be in a statute. They'd be fatter than the income tax act because you don't have to deal with here's the proper diet you have to have for hamsters and here's what it is for mice and here's what it is for zebrafish and so on. They set those standards for their member institutions. Secondly, come out and do inspections to make sure that the standards are being enforced so the CCAC will come to Dalhousie periodically and tour this institution's animal housing facilities, tour its laboratories with a little checklist to make sure that we're in compliance with all the regulations. Thirdly, and I'll discuss this in considerable more detail later, all research that is done under this regime has to be vetted and approved by a committee, an animal research committee. So any institution, including this university and hospitals and laboratories that wanna do this research on animals has to have a committee. And if somebody wants to do research, a professor at Dalhousie saying here's what I wanna do, they have to fill out a bunch of forms in triplicate saying here's what I wanna do, here's what I wanna do it, here's how many animals I need, here's how I'm gonna treat them and so on and they have to get the permission of the committee to go ahead and if they don't get the permission, they can't do it. Now, in a minute I wanna get back to what I think is the most important point, what are the standards of those committees? When does the committee say yes and when does they say no, that's the single most important feature but there has to be a committee that approves this. But I said it's a voluntary organization. What if you just don't wanna join the CCAC? Well, you don't have to but in practical terms for institutions like Dalhousie, it's absolutely mandatory and here's why. There's an understanding and a memorandum of understanding that we sign that research at Dalhousie has to be conducted in accordance with the CCAC standards and if it isn't, we get cut off, this institution gets cut off from the three main federal grant funding agencies. The Canadian Institutes for Health Research, NSERC, the Natural Sciences and Engineering Research Council and the SSHRC. And it's not just the case that, don't understand this too narrowly, it's not just the case that an individual professor goes ahead on research without getting the permission of the research committee that that professor is cut off the funding. It's Dalhousie can't get any of that funding. And think about it, how long, you couldn't run this place two minutes without the funding of those, the lights would go off, right? Right in about a minute and a half if we were cut off from the funding of those three federal granting agencies. That is, their requirement is Dalhousie, nobody at Dalhousie, even those guys who aren't doing research on animals can get money from the federal granting agencies if we don't have the certificate of good standing from the Canadian Council on Animal Care. So, well it's technically optional for Dalhousie and hospitals and other things not to belong in practical terms, we've got no choice, right? We have to belong to the CCAC because we can't get along without that money. So, and that's why I say, although this isn't technically law, the hammer is, I mean it's almost, it would be like capital punishment for Dalhousie to get cut off from the granting agencies. It's, we obviously get lots of money from tuition and from the provincial government but a big part of what keeps the place humming is funds from the main federal granting agencies. And so you have to be in good standing with the CCAC to get those. And we are. A little bit more then about the CCAC. Let me go back over each of those three things that it does and say something about them. They set their own rules. Is that good or bad?  A good thing for the CCAC setting its rules, the rules that it sets about how big the cages have to be and how good the ventilation has to be and the diet and the handling methods and the methods of euthanasia and so on is that they're experts and they're up to date and if a new method is changed, if something comes online that's a new and better method of analgesia for guinea pigs, that finds its way into the rules quickly. They're under constant revision, revised far more often than cabinet or any sort of regulatory law scheme could keep up to date. So it's got the advantage of being flexible and nimble and up-to-date. The disadvantage is that the people who make the rules are the scientists who do the research and although they're good people, it's just anything, any group that you say just regulate yourself and set your own rules. You've got to worry if the rules are good ones. So that's one pro and con on that. On the second standard about them doing inspections to check things out, again, they're very knowledgeable when they come here, they do a thorough job, they look closely, they look under the tables and around there they visit the labs and note an effect of a recommendation in their report that is they visit every once in a while, they write a report. If they say dial house, it has to do something, then the effect of the need for the funding money means that we just do it. That is at a CCAC visit from a couple of years ago, they looked at one of the animal housing agencies, or not agencies, but areas here at Dow Housing and said you need new ventilation. The ventilation in this room doesn't change the air quickly enough, it's below our standard. It just gets done. It just goes in as a line item in the next budget because Dow Housing can't afford to say, uh-uh, we can't afford to, I mean, they can't afford to fix this building, but they don't have any choice if the CCAC says you need new ventilation, you just do it. So it's got that advantage, but there's, again, I'm going through the pro and con. What's the con? Well, they visit once every three years and they always give six months notice and they say we're coming on the 4th of August and you do get a chance to clean up the act and hide the bodies. And it's not quite like inspections that might be done from kind of food inspection agency in a slaughterhouse which doesn't give notice, it just inspects. So there's some pro and con. What I want to spend a little more time on because it's, I think the nub of things is the standard that is applied by the animal care committees in deciding whether research goes ahead. And it's really, it's the second part of bold heading five. The standards that the committee is supposed to apply, there's many parts of them, but the core is this thing called the three R's. You might have thought I grew up the three R's was read and write and then arithmetic and then now it's reduce and recycle, but it's something different. It's for the animal care committees, it's replace, reduce and refine. And this goes back to an article that was published in 1959, I'm sorry, a book that was published in 1959 about ethical standards for research on animals by the two guys Russell and Birch, but they promoted the three R's, which have been very broadly adopted around the world. And here's how they work. If some research is thought to be worthwhile at the house and involves research on animals, the committee has to, under the first of the R's, ask whether animals can be replaced. It looks at the hypothesis sought to be proved when the person applies and say I need 900 mice to test this hypothesis about such and such. It asks the question, can you do it without mice? If this hypothesis can be tested using a computer program or not done on mice, then you don't get permission. You have to show that you can't test the animal, you can't test the hypothesis or do the, not every research protocol has an hypothesis. Sometimes it's just an inquiry of fundamental nature. You can't do it without animals. And if the committee says, well, you can, then you don't get permission. Now, briefly in practical terms, this hasn't been a lot of progress in this area. In most cases, the committee can't find an alternative. The one area where I'd say there actually has been a change in recent years under the first of the three R's is in the use of animals for teaching. I've been talking about animals for research, but it's the same protocol that involves use of animals just for teaching. And there has been some progress for people who at this university and elsewhere say, you know, I want all my students to dissect to rat. And there has been some progress. Look, there's actually a really good computer program. You can do that on or you can watch it on a video and they can do this using this model. And there has been some progress in that area, but you don't need animals for this teaching. But not so much for research. The second heading is reduce. And that's pretty simple. If somebody says I need 500 rats to test this hypothesis and the committee says, no, you can do it with 420. You only get permission for 420. You don't get to use more animals for research than is necessary for the process. And the committee has got experts on it that will look at that and say, you don't need 500 rats, you can do it before. And then you only get permission to use 400 rats. The third of them, refine, doesn't refer to replacement or the numbers. It's can you cause less pain while you're doing it? If somebody says I need 500 rats and I'm gonna do this and they don't put down that they'll give them analgesics and painkillers and the committee says, there's no reason why you can't give painkillers here. Then you don't get permission to do it without the painkillers. Now sometimes painkillers are bad. They can confound the inquiry that you're wanting to make into the blood and you have to do research without the painkillers. But if the committee says, the numbers are fine, but we've got a method by which you can cause less pain to the animals in doing this research, then they will require that method to be done. That's the main standard. So protocols are assessed by that and as I would say rarely rejected, but often modified. That's the CCAC regime. Now I wanna take five minutes or so to explore something that I said I would do at the beginning which is to why haven't there been more claims under the criminal code? Who does this fit with the criminal code? I would make this claim. This is the editorial part of the evening. I think that the CCAC regime doesn't live up to the standards of the criminal code. I think if we examine the regime, it doesn't protect animals as well as the criminal code of Canada says they need to be protected. That's not to say that all research permitted under that scheme here at Dalhousie or anywhere is a crime or is against the criminal code because of course it might well be that a given research proposal would satisfy a higher standard, the standard of the criminal code, but my claim is just a simpler one that I think the CCAC regime falls short of what's required by the criminal code and let me just try to very quickly do the nuts and bolts of that. I think if we go back to the two interpretations of the criminal code, one I call the lexical priority that simply looked at things in two stages. Is the goal worthwhile? If it is, are you causing any unnecessary pain to the animals along the way? That's one. As opposed to is the goal worthwhile compared with the pain and the suffering along the way? The CCAC regime is the first of those. It never asks this question of a given research protocol.  Is it worth that many lives to test this hypothesis? It doesn't do what is required in the European Union by bold heading three, a comparison of the harm to the animal balanced against the expected benefits. It's a two-stage program under the CCAC regime. The two stages being this. First, the determination that the research is worthwhile. That isn't done by the animal care committee. That's done by the funding agencies. The people come and say, I got some money to test this hypothesis, it's worthwhile, I want to kill 900 rats to do it. There's no point of asking, nobody asks the question, is it worth killing 900 rats to test this hypothesis? It's a two-stage proposal in Canada. Is it a worthwhile hypothesis? The funding agencies determine that. And then at stage two is if you're pursuing that goal, are you using more animals than necessary? Are you causing more pain than necessary? It's very much the lexical priority approach. And I would make this claim that of the two approaches to interpretation of unnecessary cruelty in the criminal code, the better one, the one with a better pedigree as being more recent and being decided under the existing provisions of the criminal code is the one that requires balancing. The one that requires us to ask of any individual protocol. A question that just isn't asked at this university or elsewhere. You say you want to test this hypothesis and you'll do it without using more animals than necessary and you'll do it without causing more harm than necessary. But even so, is it worth taking that many lives to test it? And my sense is that's what the criminal code requires. I don't think there's ever been a crown prosecutor in the world. I think they should do that. Basically what I would like in Canada, that sort of modest improvement is that we move to a regime that's like the European one that I've tried to encapsulate and it's more complicated than this, but try to encapsulate in the one page, or one sentence extract in note three that research has to balance the harms to the animals, the pain and suffering, the lives that are lost against the likely expected benefits of the research. And we don't do that. I would say we're falling short of what the criminal code requires and I'll stop it there. Some crown prosecutor should stop this, whatever I say. I could go on, but it's your turn now. Either questions or comments. Yeah. The University Committee for Laboratory Animals and the University's Ethics Committees, how's it decided who sits on those committees? Well, again, the CCAC regime speaks to, to a certain extent, the composition of those committees. There has to be a university veterinarian who sits on it and is the chair and we have a couple of veterinarians and we have more than one on ours. There has to be a member, two members of the public and those have to be there at every meeting. So it's not all animal users on that. There has to be a university member who's a non-animal user. In fact, I sat on that on this committee and I was, I don't do research on, I'm not invasive research on animals, so I sat on it in that capacity and a certain number of other members who are animal users for the expertise. They're from the departments of pharmacology and biology and medicine and dentistry and psychology and so on. As well, there are members of the people who are in charge of our aquatron, our big fish tank and the animal housing. So we have to go sit on the committees and that's standardized and private laboratories have to have their own too and they've got a different competition. What uses the term, real full negligence, which is? Right, not in this provision, but in one way. Yeah, yeah. But I've been thinking about this for quite a while. I'm trying to think about how CCA got, CCA's the guidelines, I don't know if it's the other. I'm wondering if you were to use the Willful negligence part of the quote and look at the CCAC guidelines that require three R's and if a proposal came to an ACC and the person making the proposal did not make any effort to replace and there was a perfectly viable alternative to using an animal. Would that potentially be Willful negligence? Right, now it would be up to the committee to try to suggest that, but maybe if the committee didn't investigate the possibility of replacement, charges could be brought against the animal care committee as well. Sure, I think on my feet and I'm not primarily a criminal lawyer, but certainly the argument that people didn't make a good faith or sufficiently diligent effort to explore those alternatives might be negligent. Part of the problem is that I don't think it's very clear what the term Willful negligence means. How could it be Willful negligence? Yeah, and certainly part of the problem is the criminal code is they haven't updated it much. I mean, it's way out of date in a lot of its terminals. Yes. Can you come in your fifth item here discussing peer-reviewed, taken as evidence assigned to peer-reviewed, would not be enough, if it's peer-reviewed, would that not be a way of justifying the use of the animals and look at its worth? Well, technically it could, but because of the weird way it's bifurcated and thank you for asking this question because I refer you to the first quotation under heading six, and it's from Dalhousie's website. Funding of a research project by a major peer-reviewed funding company is evidence of scientific merit. Things are in Canada really done in two stages. Very little research gets done without the funding agency. The funding agency says, yes, it's worthwhile exploring this new drug that will cure Alzheimer's or breast cancer or whatever it is, and you've got a good methodology to do that, but the funding agencies don't look at the separate crisis, is it worth killing 1,000 rats to do so? They say, that's the job of the Animal Care Committee, and then when it comes to the Animal Care Committee, they say, it's already been decided this is a worthwhile project, and they will not undertake any effort to say, is it worthwhile enough to kill 1,000 rats? They just want to say, could you do the project with 900 rats? So there's a complete, Schizophrenia isn't the right word, but bifurcation of the assessment of whether something is worth doing and the secondary ACC assessment of are you doing it in a way that doesn't use more animals or cause more animal pain than necessary, but never has that weighing at all. The weighing that you see encapsulated in that item three with the directive, it's just because things are decided on different days by different groups, it's almost a way of sort of insulating the two stages. Yeah. I sit on the Animal Care Committee, and certainly most research that causes any kind of pain, that's felt for, you know, it's required to be peer reviewed, but more recently, protocols haven't changed so that we do require that the researchers justify the numbers and what they're doing pain, and as you said, we all have said that before, revisions. Well, I think that's right.  I actually think there is a tendency in some discussions to move toward the balancing that you see in number three. It's a natural tendency that I think a lot of members of Animal Care Committees have when they're saying, because you get protocols, they're not all for Alzheimer's, it's sort of, I want to investigate curing male pattern baldness or something. Well, how many rats do you have to kill for that? And the committee might think, gee, you know, that's not all that important. And there's a tendency to want to balance. But I think you, institutionally, because of the bifurcation in this structure, a lot of committees can't go down that road as much as they'd like to. But I think you're right. I think it's a lot of people out there who have a sense that balancing is the better way to go about it. To my mind, it's the institution that blocks it. What if they say on the adverters, at the end of a movie or something, no animal suffered in the process of making this movie, but they actually did? Or where does suffering, who measures the suffering? And how can you talk to an animal to gauge? Well, yeah. Obviously, people have been taken to court sort of under that circumstance? They have, I'm not in the context of research.  But more recently, some courts have said, come on, I can tell animal suffering. They're prepared to do it from, and common sense is dangerous here too, because some animals, of course, hide their suffering. But courts are prepared to take a stab at it. Cosmetic companies who say no animals were used, but perhaps they were. Can you ever get away from not using animals? Well, there have been prosecutions under, and there was a famous one in England of the body shop, Anita Roddick or whatever, was prosecuted for lying about that, just under false advertising. That's a separate thing from animal cruelty, but they said, sorry, we did test. There's actually one thing, I wanna take a question, but I just realized I forgot an important point to make about the CCAC regime. Universities have to belong. Private labs that don't rely on government funding can if they want to, and quite a number, you can go on the website and see who's got the CCAC animal, and it's, you know, Pfizer does and things like this, but they don't have to. And there are labs in Canada that don't belong. So when I said that it's three and a third million animals killed in research, those are the numbers in the annual report of the CCAC, which combines all of, you know, Dalhousie has to report its thing. We allowed this professor to kill 300 rabbits and that went to kill 40 mice and we send off the data and you get that and all the private labs who voluntarily belong so that they get the certificate of good animal care, which might be, you know, fixed back into your notion of good public relations, but you don't have to.  I actually think not that many because everybody says Canada doesn't do any R and D anyway, but there are in Montreal and some other places, some labs, but just say, you know, we don't rely on funding from NSERC or CIHR and those are governed by what? The criminal code under which there's never been a prosecution and how many more animals are used there? We don't know. So number one, that seems an argument there. We need a statute somehow, but yeah. Actually, I have a couple things. How is it justified with thorough research that has been done for 20, 30 years to continue using animals? I'm thinking smoking primarily, where the effects are known and you have enough people that have participated in that activity that you could want to them. Also, what about products I'm thinking field-based, which is a vegan product, which has recently, because of labeling issues, been ordered to test on animals to measure the protein confidence, where it goes against everything that stands. On the first one, there is, I think, a measure of repetition of somebody says, there's been a test that, you know, used 500 mice and test this hypothesis. I wanna do it again. And the question is, is that a good science or not? There can be reasons for duplicating an experiment or maybe triplicating, but how far it goes, let me know, after 20, we know this, it's not justified. But the short answer is, in Canada, we let the funding agencies determine that. If somebody comes and says, I got a grant from, it's not just the CAHR, the kidney foundation, the heart foundation, the Alzheimer's foundation, that says I can investigate this hypothesis. And someone on the animal care committee says, hold on, that's already been done. There was a paper published on that three years ago. The usual short answer is, the funding agency had expert review and peer review and they decided it was worth doing, for whatever reason, because some things are, you know, maybe the first one was some dubious methodology and the short answer is, if you come to an animal care committee and you've got a grant to do something and the people on the committee see, I thought this was proven, but pretty much the short answer is, at least as far as I've seen this, they got a grant to do it. The grant had the assessment of some real experts. Not our job. It's scientifically valid to explore this and do this a second time. So we just looked to see, you know, you want 500 mice to do it, we actually think you can test it with 400 and do it that. Yeah, I'm sorry, I didn't get to your second question. Could you repeat it again, I'm sorry, no. Recently there was a vegan product and because of label, the Canadian Food Administration decided that it needed to be tested on animals to prove the protein content. So how can that legally, you know, it goes against everything that stands for a percentage, right, do you know what I mean? Well, I guess it's just charging with hypocrisy here. There are things that are required by law to be tested on animals and Canada finds it hard to change because a lot of those rules are set initially by the FDA in the United States and if we want to market something, so we have to follow them. But the Therapeutic Products Directorate requires animal testing of basically pharmaceuticals and things like that at a certain stage. It doesn't require it for shampoos and things. There it's an option, you can market yourself as we don't test it on animals or not. Yeah. I'm just wondering about the actual sort of mechanics of the committee at the university. So the way I understand your explanation is the committee, if they already had the funding, the committee doesn't have the power to say, no, you can't do this even if they feel strongly that it's cruel or whatever. They can say, no, you can't do this because you could do it without animals because they often think the funding agency maybe thought it was a worthwhile thing to investigate this hypothesis but maybe didn't turn its attention to whether it could be done without animals. Although that's rarely, I mean, certainly the funding committee, the AC's often reduce the number of animals. They don't very often replace. Does this committee work as a democracy or like, how do they do their decisions? Well, I don't know. I mean, again, you take an oath of confidentiality when you sit on them and I certainly would respect that. I think they try to go by consensus. And usually if there's sort of even one dissenter who says, no, no, I really want to dig in my heels and push for that, the committee will, my sense, pay a lot of attention to them. They tend to go by consent. It's hard.  And there's a real problem, I think, with the non-scientists on the committee not being able to weigh in on scientific questions. It's interesting at Dalhousie, there's required to have a non-animal user on the committee. And that used to be, for years, it's always been somebody from the law school who's another member here. They've now got a non-animal user who's from the biology department. I'd be interested to know whether other universities across the country do that. Separate. You'd get more expertise, but maybe less distance. Question that's twofold. One, in this day and age, is any animal testing even necessary? I thought that we had so many technologies now that we just rendered it just completely unnecessary. And secondly, in terms of the replacing, is there some sort of, I guess, balancing? What if you can replace it, but it costs significantly more than a bunch of rice and rats do? Rice and rats, man, rice and rats. And so, do they say, oh, yes, we could replace it, but it's just gonna cost so much more and we'll get funding for that then? Then, I mean, because that's different. That's not just asking, oh, well, can it be replaced? It's asking, is it financially wise or whatever? Yeah, I'll answer the second question first. In theory, the CCAC rules say the cost is no object. If you can cause less pain by doing this, you can't say, oh, yeah, but my grant won't cover it. In practice, I don't know if it pushed that way. The more difficult question and more central one, I think, is the first one, is it necessary? It's interesting, if you look on Dalhousie's website, it says animal research is necessary for medical progress and scientific progress. That's the first statement if you're going, you know, that's manifestly false. I mean, they are saying if you stop using animals, there will be no medical process. I mean, you might buy the argument that it would be slower and we'd pay some cost in human lives, but Dalhousie just makes this blatantly ridiculous. There will be no scientific progress and no medical progress unless we kill animals. That's just false, but the question is it justified? I actually, although I'm not a straight-up utilitarian, I was sort of advocating the balancing, but I think that when you're doing the sort of balancing I would like to see, and this also gets back to the question about the composition of the committees. I would like the committees to be broader than they now are, and I think that would make the balancing a little different, but it seems to me that the balancing that you have to do, and this to my mind would make for far less permission for research than is currently granted, is not simply saying if we cure Alzheimer's or make the step at better Alzheimer's treatment, is it worth 1,000 mice? Because that's not the balance. The 1,000 mice will die anyway, for sure. What are the chances that this investigation will make progress on Alzheimer's? And the answer is it's less than 1 in 1,000. I mean, if you look at the number of recent and the number of things that turn out into new drugs it's more like this is what you've got to answer. Is it worth a 1 in 10,000 chance to have a better curate for this cancer to kill 1,000 rats? I mean, that seems to be the true balance, and that's not an easy question. It's hard to know how much research would be slowed down if we didn't use animals, and what the chance is. There's not an easy gauge on that. There's certainly people who think that, although, as I say, Dalhousie overstated it when it said there would be no progress without animals, there's certainly people who think it's really important to use animals, and the alternatives are not very good, and some other people emphasize that use of animals has got lots of false negatives and false positives, and they point to things like thalidomide that was tested in rats, and there was no problem, but David DeHumansen caused these birth defects, all sorts of things that don't work on the animal. This is very interesting. This is gonna be a little tangential, but I don't know how many people saw Elizabeth May when she spoke here last week, it's nothing to do with this, but it reminds me that when she was a law student here, this is 33 years ago, she brought a suit against spraying of aerial herbicides in Kate Breton, and there was a number of plaintiffs, and she was one, and her claim was that these things were carcinogenic, heratogenic, fetotoxic, the whole range of these, basically Agent Orange, that they were gonna be spraying on the trees in Kate Breton that would get into the water table, and she brought in lots of experts that showed that it was carcinogenic, and the Nova Scotia Court refused to stop it, and what it said, Justice Merlin said, all those experts have only shown that it's carcinogenic to rats. Like, you can't rely on animal trials to say that it's gonna kill people, therefore the plaintiffs lose. So if you've got courts that are prepared to, when you're trying to stop somebody screwing up your water table to say, animal things don't necessarily translate to human benefit, why wouldn't they, or we, assessing the balance in a claim at least discount for the likelihood that a given animal trial might not show anything, it might show something in animals that doesn't translate to humans. Now that still doesn't get over the fact that it's a difficult balancing. Yeah. Are there exemptions to any of these rules? Like you say, take a situation, the disease control center wouldn't pay calls down to move down, says that we need your medical staff to help us find a cure for the Ebola problem. Can all these rules and guidelines be sort of pushed aside to take that to its front if you get my drift? Yeah, but I know of, I don't, I mean we, I think committees will speed up approval protocols pretty quickly if they have to be done right away for those reasons. Yeah? Yeah. What are sometimes the issues lie with the FDA in Health Canada who are responsible for approving say a drug to get to market and they're saying these are the tests on animals that we need to see and we need to see those results in order to approve the drugs sort of thing. So we need really for them to say, okay, no, we want to go with this surrogate biomarker test instead where we can take a blood from a human patient and test it rather than testing on the animals. Yeah, I think a relatively small amount of the testing is done for product approval but at a certain stage that kicks in. And you're right, Health Canada sort of has to pay attention to what the FDA does because if we approve something here but it's not test on animals and then you can't market south of the border. That's going to drive things. Yeah. So there are certainly some changes to be made in that area. You had a handle. What can the average person who's not a lawyer who doesn't know all the legalities and everything if they are unhappy with the current laws because I know there have been in the past like trying to strengthen just the animal cruelty so that they can have different penalties on the animal cruelty side as opposed to the agriculture or the research. And I know the agriculture sometimes comes in saying, no, we don't want to do this because they don't worry it's going to affect them. What can the average person do to help move that if they are concerned about that? Because the issue too as well, I don't know if in research circles it's anything like how it works sometimes in politics and in business you can have a committee and that non-animal user could be a buddy so is the one in the research and that can happen too. So you sort of need, you want to see some regulation that's not just buddy buddy that you could get around it or the people who aren't to make sure that the users of the recent animals if they're not on part of that committee that they're abiding without what can you do in the state besides writing politicians or to show or to try to address some change for the positive. You know it's more a question for an activist than you should almost ask Hugh Chisholm who's a student who is so effective in getting some new regulation for cats in the latest revisions to the Nova Scotia Animal Protection Act and you know ran tuxedo stand for, you know he's the, and there's probably others in the room who've been successful activists and could talk about, I mean I would like Dalhousie to do, I mean there's things that you could put pressure on Dalhousie for, for instance the University of British Columbia released its report, the report that the CCAC wrote about it. It's private, it didn't have to do it under some pressure, you know it crossed out the names because you don't want to say you know the name of the university that is such and such and he's an office such and such because people do worry about security from animal terrorists since I don't know how much of that is legitimate but there's a lot of redaction but UBC published their report, I would wish Dalhousie would do that. But how you get things on the public agenda, I don't know, because it does seem to me we've had sort of royal commissions on new reproductive technology, a whole range of things. There's been cross country inquiries and we've never had that on animals and obviously we're a long way from it, I don't see it happening any time, so it would be nice to have it part of a public debater if you can ask the, you know, your federal candidates when they knock on your door for the election in the year from now, do you think we should have stronger legislation on regulation of animals and research and not let the CCAC run its own show, or any other, you may have some, I don't know, I almost turned it over to the activists in the room and they're one. I just have one comment and another question, like the question about whether there's exceptions, there's like an upload, a break is still so anthropocentric in itself into push humans face to the forefront and pushing animals off to the back, and that's like the problem, that's like the base of the problem with all of this. And secondly, my question is, I don't like that, but in terms of cosmetic testing, is there, you know, if you want to sell an organic product, you have to be certified organic and there's a body that certifies you and I'm wondering to be able to put a cruelty-free symbol or something on a product, is it who, can you just do that, or is there like a body that you have to get a proof of? I have no idea. Well, that's a good, that last question is a good one. There are federal, like certified organic, sometimes the federal government steps in and sets standards and police is very closely who can use given labels like certified organic, but they've never done that on any animal cruelty provision.  There are a range of private agencies, like the Laughing Bunny on cosmetics and some other ones. There's all sorts of problems with the private one. I mean, how, what are their standards? How do you find out about them? And so on, it would be nice, this is something I think quite separately from experimentation on animals, if the federal government would do for animal cruelty, even a range of things. You know, the way they do the inner guide when you buy your new refrigerator, so you can see that if there was a compulsory label on your meats, they're ranging from one to 10, you know, people might pay a little bit more for the four as opposed to the five. They haven't been, haven't been persuaded to do that. Or they won't do GM, so it's not much. Yeah. What's the government's policy on auditing private policies for research? I mean, the private labs who don't belong to the CCAC? No, not affiliated with the CCAC, but you mentioned how we find out about their standards. How does the government go about auditing them? Do they audit them? No, I mean, that's, I mean, technically if there's a whistleblower and they give evidence that there's activity on them that offends the criminal code, they can get their search warrant and come in, but they're not governed by the CCAC, so the only thing around is the criminal code of Canada and the whatever province they're in, the animal cruelty provisions and hard to tell. I mean, there are private labs. I said Pfizer belongs, but not all the pharmaceutical companies do it. Who knows what goes on in those things? And it might be better than what goes on.  There, yeah, at the back. What kind of animals does Dal test on and like how many animals do they use in a year? I don't know how many animals they use in a year. Dalhousie, unlike some institutions, has never done research on primates. No monkeys or chimps. Unlike, say, queens in the University of Western Ontario and Department of National Research, there's a, well, Canada wide, I think about 4,000 primates used last year, mostly macaque monkeys and other ones, but none that Dalhousie, I don't know. I mean, Dalhousie I think is fairly standard, except as you might expect, sort of more on fish than they would do at, you know, the University of Saskatchewan because of people who are interested in research and connection with the agriculture industry and some other things. But I think the standard CCAC stats that said out of the three and a third million, it was a million and a third fish. And fish don't get broken down. Unlike mammals, they're not broken down to, you know, trout and sharks and whatever. It's just so many fish, but a lot of those are zebrafish. Mice were number two at a little over a million. Rats, I think about a quarter million. I mean, I don't think Dalhousie is, I know I put Dalhousie's name on the poster of, you know, come, you know, we do this research at universities, including Dalhousie, but I don't have any sense that Dalhousie's any different, better or worse than any other research institution of its same size. So I think the notable thing is we've never done the primate stuff here and we're a bit heavier on the fish stuff than some of the more landlocked universities. Large breeding companies like Jackson Laboratories are regulated and like, what are their restrictions on who they can sell animals to for research? You know, some of them are regulated because they're outside Canada. And they're not regulated. Well, there is a provincial statute in Ontario, but not a lot of places. And it's interesting when, this is directly answering your question, but when committees look at the research that's done on rats and mice, it's if they just start here at Dalhousie, but they were born somewhere and separated from their mothers and kept and fed in a lab. Now most of those labs are affiliated with the CCAC and like the good CCAC seal of approval, just for public relations, but they're not otherwise much, other than just the criminal code and we don't bring charges against them. So there's very little. Most of the animals that are acquired here are sort of shipped in from big commercial companies like you mentioned, Charles River and Jackson and some in Quebec and a lot in Boston. You just order out a thousand mice. They fed excellent animals. All right, thanks. Let's go.