What does this mean in practice?
As a Personal Licence holder, you may, where appropriate, delegate certain limited tasks to individuals who do not hold a Personal Licence. However, this should only be done where the task does not require significant technical skill or regulated procedure authority.
Delegation must always involve clear instruction, appropriate supervision where required, and consideration of the individual’s current abilities and experience. For example, you should not delegate tasks involving animal handling to someone who is not confident or competent in handling the species involved.
The types of tasks that may be delegated are limited and commonly include:
- Restriction or withdrawal of food or fluids
- Placement of animals into non-invasive behavioural test arenas
- Providing altered or medicated food or water to animals
(but not preparing or mixing the compounds) - Pairing or mating genetically altered breeding animals
All delegated tasks must be clearly authorised within the Project Licence.
Any delegated activities should also be accurately recorded within your procedure records, including who the task was delegated to. As the Personal Licence holder, you remain responsible for the delegated task and any welfare or compliance outcomes associated with it.
It is good practice to discuss delegation with the Project Licence Holder before asking someone to carry out a task under the authority of the licence.
If you are unsure whether a task can be delegated, you should seek advice from the Named Training and Competency Officer (NTCO), NACWO, or other appropriate named persons. Some establishments may apply additional local restrictions to reduce the risk of non-compliance. For example, some facilities may require licensed or specially trained staff to select appropriate genetically altered breeding animals.
How do I comply with PIL Standard Condition 18?
You should maintain clear communication with any individual carrying out delegated tasks and ensure there is an appropriate audit trail of that communication. You should always confirm that the delegated task has been completed correctly and never assume it has been done.
Before delegating any task under the authority of a Project Licence, you should discuss this with the Project Licence Holder (PPLh). This allows them to approve the individual working under the licence and ensure the person has the appropriate training and experience for the delegated activity.
You should also assess the individual’s level of confidence and ability before delegation takes place. Someone may technically understand the task but may not yet feel confident carrying it out independently or under remote supervision.
At some establishments, such as Newcastle University, individuals carrying out delegable procedures are typically authorised under a remote supervision framework rather than being assessed as fully competent. This reflects the fact that the licensed individual remains legally responsible for the delegated activity and its outcome.
You should involve the Named Training and Competency Officer (NTCO) or local training team to confirm that appropriate training and supervision arrangements are in place before delegation occurs.
Delegation should be planned in advance. Competency and confidence take time to develop, and you should not expect an individual to become appropriately trained or ready for delegated responsibilities immediately before the task is required.
What resources are available to support me?
When considering delegation of tasks, you should review the Guidance on the Operation of ASPA, section 4.13.5, “Delegating Tasks”. This guidance explains which activities may be delegated and outlines appropriate approaches to delegation and supervision.
It is important to maintain clear records of all communications relating to delegated tasks. You should ensure that:
- Instructions are clearly communicated
- The delegated individual understands the task
- Confirmation of task completion is received
- Any issues or concerns are documented and followed up promptly
If confirmation has not been provided, you should actively check that the task has been completed correctly rather than assuming it has been done.
Task management software and animal management databases can help support delegation and provide an audit trail of completed activities. Many systems include functionality for assigning and recording task completion.
However, direct communication is usually the most effective approach. Messaging platforms (such as MS Teams and WhatsApp) or other mutually agreed methods of communication can help ensure that instructions are understood and tasks are completed safely and on time.
What happens if I don’t comply with PIL Standard Condition 18?
If you delegate a task that is outside the permitted scope of delegation, or beyond the ability of the individual carrying it out, you may be in breach of your Personal Licence conditions.
This may be reported to ASRU either:
- By the Project Licence Holder as a breach of Project Licence Standard Condition 18, relating to unauthorised application of procedures by an unlicensed individual
- By the establishment as a potential non-compliance incident
The seriousness of the incident will often depend on the nature of the task delegated and any animal welfare impacts resulting from it.
Examples of activities that are commonly misunderstood as delegable, but generally are not, include:
Head fixation or restraint systems
Examples include:
- Neck plating in non-human primates
- Head fixation systems in rodents
Restricting free head movement for restraint or procedural purposes is a complex task that requires technical skill, experience, and understanding of animal welfare impacts. Incorrect application can cause injury, distress, or damage to equipment.
Examples of tasks that may be delegated instead could include:
- Placing a non-human primate into a transport chair without restraint
- Placing a rodent into a weighing box
Monitoring animals under anaesthesia
Unlicensed assistants may assist during surgical procedures, but they should not independently monitor animals under anaesthesia.
Anaesthetic monitoring requires the knowledge and judgement needed to:
- Assess anaesthetic depth
- Recognise signs of recovery or distress
- Respond appropriately to welfare concerns
- Maintain anaesthesia safely
Tasks that may be delegated during surgery can include:
- Passing surgical instruments
- Assisting with surgical preparation
- Cleaning and preparing the surgical area
Welfare scoring and body condition scoring
There is an important difference between monitoring and scoring.
Monitoring involves making general observations about an animal’s appearance or behaviour and identifying whether something appears abnormal.
Scoring or assessment requires the ability to interpret clinical signs using recognised welfare assessment systems and make decisions about animal management or humane endpoints based on those findings.
Because this requires training, knowledge, and judgement, formal welfare scoring is generally not considered an appropriate delegable task.
Failure to delegate appropriately, either because the task exceeds permitted authority or because the individual lacks the required skills, can result in:
- Retraining or increased supervision
- Non-compliance investigations
- Suspension or revocation of licences
- Restrictions or additional controls being placed on the Project Licence
In serious cases, poor delegation practices may demonstrate inadequate understanding of ASPA requirements or breakdowns in communication and supervision within the research group or establishment.
How does ASRU assess compliance with PIL Standard Condition 18?
ASRU assesses compliance with PIL Standard Condition 18 by reviewing how Personal Licence holders delegate tasks to unlicensed assistants and how those delegated activities are supervised and managed.
During an inspection, ASRU may review Standard Operating Procedures, local guidance, and training materials relating to delegation, supervision, and competency assessment for delegated tasks. Inspectors may also examine records demonstrating how delegation decisions are made, communicated, and monitored within the establishment.
Compliance may additionally be assessed through discussions with the Named Veterinary Surgeon (NVS), Named Animal Care and Welfare Officer (NACWO), and Personal Licence holders to confirm that delegated tasks are limited to appropriate activities, that individuals have received suitable instruction and supervision, and that Personal Licence holders understand they remain responsible for delegated procedures.
ASRU may also directly observe delegated activities and supervision arrangements to ensure delegated procedures are being carried out appropriately, within the limits of ASPA guidance, and without compromising animal welfare or regulatory compliance.
How do I know if I am complying with PIL Standard Condition 18?
You can be confident that you are fulfilling this Standard Condition if the individual you delegate tasks to clearly understands:
- What is expected of them
- How the task should be performed
- What records must be maintained
- When the task must be completed
- That you, as the Personal Licence holder, remain ultimately responsible for the delegated activity
You should provide clear instructions, appropriate context, and access to any relevant resources or guidance needed to complete the task safely and correctly.
For example, if you delegate a food restriction protocol, you should explain:
- What restriction is required
- What food or materials should be removed or provided
- What outcomes are expected
- When the task must be completed
- What records or cage updates are required
You should also explain why the procedure is important, how it relates to the project objectives, and why accurate communication and record keeping are essential for maintaining both animal welfare and compliance.
There should be a clear process in place to:
- Confirm task completion
- Record relevant observations or outcomes
- Update cage cards or records where necessary
- Communicate any concerns or unexpected findings