What does this mean in practice?
All regulated procedures will cause some level of pain, suffering, or distress. What matters is how severe that experience is and how it is managed. If an animal is expected to experience severe pain or distress, there must be a clear plan in place to reduce it, for example through the use of appropriate analgesia or other supportive care.
You would not carry out a surgical procedure without planning how pain will be minimised, using anaesthesia during the procedure and analgesia afterwards. The main exception to this is in specific, authorised pain models. Even in these cases, the pain or distress should not be long‑lasting, and there must be clearly defined intervention points or humane endpoints, even if analgesics are not used.
If pain, suffering, or distress is observed during or after a procedure, action must be taken to improve the animal’s experience. This includes seeking veterinary advice on analgesia, consulting the NACWO about supportive care options, and checking that any actions are authorised within the project licence.
In some situations, the only appropriate way to alleviate pain, suffering, or distress will be humane euthanasia. It is the responsibility of all Personal Licence holders and animal care staff to ensure this is carried out promptly when required, to prevent further suffering.
How do I comply with PIL Standard Condition 6?
Before carrying out any regulated procedure, you must have clear actions in place for responding to adverse effects. These actions are defined in the project licence as controls or interventions and apply to all procedures, including minor ones such as injections or blood sampling.
As the primary PIL holder, responsibility for implementing these intervention plans sits with you. Where possible, they should be built into your experimental or study plan. If your establishment does not use experimental plans, your actions should align clearly with relevant SOPs. Intervention plans must be easy to follow and clearly communicated so that animal care staff and other PIL holders working with your animals understand what to do and when.
For surgical work, most researchers are familiar with having a post‑operative care plan to manage pain. However, it is helpful to think more broadly in terms of post‑procedure care plans, as all regulated procedures, not just surgery, have the potential to cause pain, suffering, or distress and may require active management.
Some situations may be less obvious. For example, during the breeding of genetically altered zebrafish, animals may experience pain or distress associated with being egg‑bound. In these cases, you should have predefined actions to ameliorate harm, such as facilitating spawning to allow egg release or carrying out humane euthanasia if suffering cannot be alleviated.
Having clear, agreed intervention measures in place before work begins is key to fulfilling this Standard Condition and ensuring animal welfare is managed effectively at all times.
What resources are available to support me?
Animal scoring sheets are a key resource for managing this Standard Condition effectively. They are designed to set out expected adverse effects alongside clear intervention and action points, helping ensure that appropriate steps are taken promptly. Scoresheets are usually linked directly to the project licence and support consistent, welfare‑led decision‑making.
Most establishments have support available for developing and reviewing scoresheets, typically through the NACWO or the veterinary team. At Newcastle University, example scoresheets are also provided for common laboratory species, along with typical adverse effects and standard control measures. These resources help licence holders recognise when intervention is required and demonstrate good practice in managing animal welfare.
How does ASRU assess compliance with PIL Standard Condition 6?
ASRU assesses compliance with PIL Standard Condition 6 by reviewing whether Personal Licence holders take prompt and appropriate action to ameliorate severe pain, suffering, or distress arising from regulated procedures.
During an inspection, ASRU may review evidence of training on controls and limitations within the relevant project licence protocols, along with documented discussions with the Project Licence Holder. Inspectors may also interview the PIL holder, PPL holder, NACWO, and NVS to confirm competence and understanding of when and how amelioration measures must be applied.
How do I know if I am complying with PIL Standard Condition 6?
You can be confident you are fulfilling this Standard Condition when you understand how to interpret welfare controls where pain or suffering may occur, and you act promptly to alleviate that harm. This includes being prepared to intervene early, even if that means euthanising an animal before the planned experimental endpoint, to prevent further suffering.
It is also important to recognise that responsibility for pain management does not sit only with the primary PIL holder. Even if you are not the lead licence holder for the study, you remain responsible for ensuring that appropriate pain relief or other amelioration is applied when required. Clear communication with colleagues involved in the work is essential.