What does this mean in practice?
Anaesthesia should only be used when it is necessary. If the risks or harms associated with anaesthesia would be greater than the pain or distress caused by the procedure itself, the procedure may be carried out without anaesthesia.
The licence holder must be able to demonstrate that the procedure would not cause severe pain without anaesthesia, or that any pain caused would only be mild and short term.
How do I comply with PIL Standard Condition 9?
Fulfilling this condition depends on your ability to assess the level of pain or distress an animal may experience and whether the use of anaesthesia would cause greater harm or stress than the procedure itself.
For example, inhalant anaesthesia can be aversive during induction, particularly with repeated exposure. Similarly, using an injectable anaesthetic does not remove the pain associated with needle administration, as the animal must still be injected to induce anaesthesia.
Anaesthesia should not be used simply because a licence holder lacks the confidence or competency to restrain an animal or perform a technique without anaesthesia. If a procedure is routinely carried out by trained colleagues without anaesthesia, this may indicate that the need for anaesthesia is related to competency rather than the procedure itself.
There are, however, exceptions. For example, an animal that has become sensitised or highly stressed by restraint or repeated procedures may benefit from the use of anaesthesia to reduce overall suffering.
What resources are available to support me?
If you are unsure whether the use of anaesthesia would be considered an additional harm, you should first review the relevant protocol step within the Project Licence (PPL). The permitted use of anaesthesia is identified using the following codes:
- AA – No anaesthesia
- AB – Anaesthesia
- AC – Non-recovery anaesthesia
- AD – Neuromuscular blockade
If a protocol includes multiple options, for example IV injection (AA/AB), this indicates that the PPL holder has authorised the procedure to be carried out either with or without anaesthesia where appropriate.
You should also discuss the procedure with the PPL holder, Named Veterinary Surgeon (NVS), NACWO, or experienced colleagues if you are unsure whether the use of anaesthesia is appropriate in a particular situation.
What happens if I don’t comply with PIL Standard Condition 9?
The consequences of failing to comply with Standard Condition 9 can be understood through two common scenarios.
Scenario 1 – Using anaesthesia when it is not justified
You observe a colleague using inhalant anaesthesia on a group of animals and ask what procedure they are performing. They explain that they are carrying out subcutaneous (SC) injections.
You know this procedure is commonly performed on awake animals using appropriate restraint. When you ask why anaesthesia is being used, the colleague explains that the protocol does not authorise anaesthesia for the procedure, but they believe its use is justified under Standard Condition 9 because they are not confident in restraining the animals and are concerned about being bitten.
In this situation, the use of anaesthesia is not being driven by the procedural harms, but by a lack of confidence or competency in handling and restraint. You report your concerns to the Project Licence Holder (PPL holder) because you believe the condition may have been interpreted incorrectly.
This would likely be treated as a compliance concern.
Scenario 2 – Not using anaesthesia when it may be required
You observe a colleague carrying out hydrodynamic injections and ask about the procedure. They explain that they are performing the injections without anaesthesia.
You know this procedure is commonly performed under anaesthesia due to the large injection volume and the potential welfare impact if administration is unsuccessful. When you ask why anaesthesia is not being used, the colleague explains that the protocol authorises anaesthesia (AB), but they believe avoiding anaesthesia is justified under Standard Condition 9 because they consider restraint to be less harmful overall. They also state they are confident in maintaining venous access throughout the procedure.
You report your concerns to the PPL holder because you are unsure whether the colleague’s interpretation of Standard Condition 9 is appropriate and whether they have failed to follow the welfare controls outlined in the Project Licence.
This could result in an SC18 report for failure to adhere to Project Licence controls.
Summary
In either scenario, the incident would likely need to be reported to ASRU. The PIL holder involved may be required to undergo retraining in ASPA requirements and the correct application of Standard Condition 9.
Additional retraining may also be required in:
- Animal handling and restraint (Scenario 1)
- Anaesthesia techniques and welfare assessment (Scenario 2)
These situations may indicate that competency was not adequately assessed during training, or that the individual has deviated from the trained and authorised procedure.
How does ASRU assess compliance with PIL Standard Condition 9?
ASRU assesses compliance with PIL Standard Condition 9 by reviewing whether regulated procedures carried out without anaesthesia are justified appropriately and performed in accordance with the Project Licence.
During an inspection, ASRU may review Standard Operating Procedures (SOPs), training records, competency assessments, and anaesthetic records to confirm that staff understand when anaesthesia should and should not be used.
Inspectors may also speak with the PEL holder, PPL holder, Named Veterinary Surgeon (NVS), NACWO, animal care staff, and PIL holders to assess understanding of procedural harms, anaesthetic use, and competency requirements.
Compliance may also be assessed through direct observation of procedures to ensure animals are managed appropriately and that anaesthesia is only withheld where scientifically and ethically justified under the licence.
How do I know if I am complying with PIL Standard Condition 9?
The key to fulfilling this condition is making a justified welfare decision, not a personal or practical one. If your reasoning would not stand up to review, it should be reconsidered before the procedure takes place.
You can be confident that you are meeting this condition if you can clearly justify your decision about whether anaesthesia should or should not be used. Your decision should be based on animal welfare considerations, not convenience, confidence, habit, or personal preference.
This means you have:
- Considered whether the procedure could cause severe pain or distress.
- Assessed whether the use of anaesthesia could introduce equal or greater harm.
- Understood the expected severity and duration of the procedure.
- Reviewed the severity classification and normal practice for the protocol step within your establishment.
- Checked the relevant PPL protocol codes (AA, AB, etc.).
Where anaesthesia is optional, for example AA/AB, you understand that this is not simply a free choice. The decision must still be justified on welfare grounds.
You should also be competent and confident in the techniques required for the chosen approach, including:
- Animal handling and restraint techniques if anaesthesia is not being used.
- Anaesthetic techniques if anaesthesia is being used.
Importantly, you should recognise when limitations in your own skills or confidence could influence your decision-making and seek advice from the PPL holder, Named Veterinary Surgeon (NVS), NACWO, or experienced colleagues where needed.