What does this mean in practice?
Appropriate pain relief plans should be developed and used to minimise pain and suffering in animals undergoing procedures.
Where possible, analgesia should be administered before anaesthesia or surgery so that pain pathways are blocked before painful stimuli occur. This is known as pre-emptive analgesia and helps reduce overall pain experienced by the animal.
An exception may apply in studies involving pain models, where the use of analgesia could interfere with the scientific objectives of the study.
How do I comply with PIL Standard Condition 11?
Fulfilling this condition requires you to plan pain management carefully and ensure that appropriate analgesia is used unless there is a clear and scientifically justified reason not to.
This begins with developing a pain management plan in consultation with the Veterinary team and Project Licence Holder. The plan should be appropriate for the species, the procedure being performed, and the expected level and duration of pain.
Wherever possible, analgesia should be administered pre-emptively, before pain occurs, to prevent activation of pain pathways rather than reacting after pain has already developed.
You should be familiar with the expected adverse effects described within the Project Licence and ensure that analgesic use aligns with these, alongside any protocol-specific requirements or restrictions.
During and after the procedure, animals must be monitored appropriately for signs of pain, distress, or discomfort. Additional analgesia should be provided where required and where permitted within the authority of the licence.
Your decisions should always be based on the welfare needs of the animal, rather than convenience or routine practice. Any decision not to provide analgesia must be clearly justified within the Project Licence, for example in specific pain models where analgesia would interfere with the scientific objectives of the study.
You should also be confident in recognising signs of pain in the species you work with and know when to seek advice or support from the Veterinary team, NACWO, or experienced colleagues.
What resources are available to support me?
There are several sources of support available to help ensure that appropriate analgesia is provided.
- The Named Veterinary Surgeon (NVS) plays a central role in advising on suitable analgesic protocols, including drug selection, dose, timing, and route of administration. They can also advise on refinements that improve animal welfare without compromising the scientific objectives of the study.
- The Named Animal Care and Welfare Officer (NACWO) can support you in recognising signs of pain or discomfort in animals and ensuring that appropriate monitoring and welfare interventions are in place.
- The Named Training and Competency Officer (NTCO) is responsible for ensuring that you are appropriately trained and competent in administering analgesics and recognising when pain relief is required.
- The Project Licence Holder (PPLh) can provide guidance on protocol-specific requirements, including any scientifically justified restrictions on analgesic use.
In addition, local Standard Operating Procedures (SOPs) and Experimental Plans provide important guidance on approved analgesic regimens, monitoring expectations, and intervention points. These documents help ensure consistency, animal welfare, and regulatory compliance.
What happens if I don’t comply with PIL Standard Condition 11?
Failure to provide appropriate analgesia can result in animals experiencing unnecessary pain and suffering. This is a serious breach of both animal welfare standards and legal requirements under ASPA.
Such failures may result in incidents being reported to the Home Office Inspectorate (ASRU), suspension of procedures, and investigation into the circumstances surrounding the non-compliance.
Potential consequences include:
- Retraining in pain recognition and analgesic use
- Reassessment of competency
- Increased supervision
- Amendment, suspension, or revocation of a Personal Licence in serious cases
Non-compliance may also affect the Project Licence Holder and the wider establishment.
Common failures include:
- Not administering analgesia when it is clearly required
- Inadequate monitoring of animals following procedures
- Incorrectly assuming that a procedure does not require pain relief
- Failing to follow approved analgesic protocols
Even where analgesia is withheld for scientific reasons, this must be clearly justified and authorised within the Project Licence. Failure to do so would be considered non-compliance under ASPA.
How does ASRU assess compliance with PIL Standard Condition 11?
ASRU assesses compliance with PIL Standard Condition 11 by reviewing how Personal Licence holders manage pain relief when animals undergo procedures involving general or local anaesthesia.
During an inspection, ASRU may review Standard Operating Procedures, training materials, anaesthetic protocols, and records relating to the use of analgesia and peri-operative care. Inspectors may also examine evidence that staff have received appropriate training and competency assessment in anaesthesia, analgesia, and post-procedural pain management.
Compliance may also be assessed through discussions with the Establishment Licence Holder (PELh), Project Licence Holder (PPLh), Named Veterinary Surgeon (NVS), Named Animal Care and Welfare Officer (NACWO), animal care staff, and Personal Licence holders to confirm that appropriate pain-relieving methods are being used and that procedures are being carried out in line with approved protocols and good veterinary practice.
ASRU may additionally assess compliance through direct observation of anaesthesia and peri-operative animal management to ensure animals receive appropriate analgesia and welfare support following procedures.
How do I know if I am complying with PIL Standard Condition 11?
You can be confident that you are fulfilling this Standard Condition if you are actively considering and managing pain relief as part of the animal’s overall care, rather than treating it as an afterthought.
This means that an appropriate analgesic plan has been developed in advance, with input from the Veterinary team, and that it reflects the expected level and duration of pain associated with the procedure.
You are administering analgesia at the correct time and in accordance with the Project Licence, local guidance, and approved protocols. You are also monitoring animals effectively after the procedure, using your understanding of species-specific behaviours to recognise signs of pain or discomfort and taking appropriate action if additional analgesia is required.
Where analgesia is not used, you understand the scientific justification for this decision and can confirm that it is authorised within the Project Licence. Your decision-making should always be based on animal welfare considerations and supported by appropriate guidance, rather than assumption or routine practice.
You should also be able to clearly explain:
- What analgesia has been provided
- Why that analgesic approach was chosen
- How pain is being monitored
- What actions would be taken if pain or distress is identified