PIL Standard Condition 8

In all circumstances where an animal which is being, or has been, subjected to a regulated procedure is in severe pain, suffering or distress which is likely to be long-lasting and cannot be ameliorated, the licence holder must ensure that the animal is immediately killed in accordance with section 15A.

(View the Official list of Personal Licence Standard Conditions.)

What does this mean in practice?

As a PIL holder, you must monitor your animals carefully.

If an animal is in severe pain or distress that cannot be relieved with treatment or pain relief, it must be humanely killed without delay.

You must have the skills, support, or access to trained staff to end the animal’s suffering. You should be competent in at least one Schedule 1 method of euthanasia, including a primary method and a secondary method to confirm death.

How do I comply with PIL Standard Condition 8?

1. Monitor animals regularly and identify any expected or unexpected adverse effects.
2. Use clear scoring systems to define welfare thresholds and trigger humane endpoints.
3. Act quickly if an animal is suffering beyond what can be relieved.
4. Be trained and competent in at least one Schedule 1 euthanasia method for the species you work with.
5. Know your local policies and support structure. If you cannot perform euthanasia, ensure someone competent is available.

Training steps for Schedule 1 methods may include:

• Performing the method under supervision until assessed as competent
• Learning legal and ethical aspects of euthanasia
• Practicing techniques on cadavers or models

What resources are available to support me?

Your Veterinary team and NACWO will be able to support with the development of scoresheets and assisting with decision making around potential treatments that could be used in some instances.

Your NTCO can support you with the acquisition of the skills needed to deliver a ‘good death’ to the species you work with or will indicate local policies in how it’s managed to reassure you that if you can’t someone else can.

The training for Schedule 1 methods is a highly emotional subject, and it is essential to approach its delivery in a mindful and supportive way.

What happens if I don’t comply with PIL Standard Condition 8?

• Failing to act may result in non-compliance, investigations, or suspension of project licences.
• Extending an animal’s suffering beyond what is authorised is a serious welfare breach.
• In exceptional circumstances, protocols and project licences have been suspended because of inadequate animal welfare management by licencees.

Example scenario:

You begin culling an animal at the end of a study using a CO₂ system. The animal weighs over 200 g, but due to an oversight, the CO₂ supply runs out. You realise that continuing would cause the animal to suffer, as the gas level is insufficient to induce a primary death.

You immediately stop the system, remove the animal, and apply cervical dislocation as a primary method. You then confirm death using exsanguination (snipping the jugular vein) as a secondary method.

Under A(SP)A, using a method not listed in Schedule 1 would normally breach the establishment licence. However, in this case, your actions were reasonable and necessary to prevent suffering.

Following this incident, improvements were made: an emergency vial of pentobarbitone was made available for future incidents, and the CO₂ SOP was reviewed to ensure daily cylinder checks and proper gas levels for safe operation.

How does ASRU assess compliance with PIL Standard Condition 8?

During an audit, inspectors may engage with NACWOs, NVS, PPL, and PIL holders to confirm training and competency in understanding humane endpoints. PPL and PIL holders may need to show proof of conversations between them about these endpoints.

How do I know if I am complying with PIL Standard Condition 8?

• You are on the Schedule 1 register or aware of who is competent to euthanise the species you work with.
• You use defined welfare parameters to assess animals and act promptly to end suffering where death through killing is required.
• You review incidents to improve procedures and prevent avoidable suffering in the future.

You’re complying with Standard Condition 8 if you monitor animals closely and immediately end their suffering when severe, unrelievable pain or distress is identified.