Animal Welfare (Scientific Purposes) Regulations 2003

The regulations introduce and rely on several key concepts that structure the legal obligations for those using or supplying animals for scientific purposes.

Scientific use code. This is the designated external standard that all licensed activities must follow. Regulation 2 prescribes the latest edition of the Australian code of practice for the care and use of animals for scientific purposes published by the NHMRC. The code is incorporated by reference, including any future amendments. This means the regulatory obligations change each time the NHMRC updates the code, without any amendment to the regulations or parliamentary scrutiny. The licensee must track those updates independently. The code itself is not reproduced in the regulations, so a person regulated by these regulations must obtain and read the latest edition of the code to know what is required.

Scientific purposes. The Act’s definition of “scientific purposes” includes, by paragraph (d), “any other prescribed activity”. Regulation 3 prescribes the use of an animal to demonstrate a product or a technique as such an activity. This extends licensing to scenarios that might not otherwise be considered scientific research or teaching. Demonstrations of veterinary products, agricultural techniques, or even educational demonstrations in commercial settings now fall within the licensing net if they involve animals.

Licence types. The regulations contemplate two distinct licences: a licence to use animals for scientific purposes (Form 2) and a licence to supply animals for scientific purposes (Form 3). A person or establishment may need one or both depending on their activities. The application form (Form 1) requires the applicant to specify which licence is sought - use, supply, or both. The conditions differ: a use licence requires the licensee to maintain a register of approved projects and ensure persons involved have appropriate veterinary skills. A supply licence does not include those specific conditions in the prescribed form, though the Minister may add conditions under regulation 6(c).

Animal ethics committee. This concept is central to the licensing system. The Minister must have regard to the applicant’s access to an animal ethics committee that complies with the scientific use code. The application form (Form 1) requires the applicant to indicate whether they have established their own committee or arranged for another committee to act. The committee then plays an ongoing role: the licensee must provide the CEO with an annual statement from the committee indicating compliance with the scientific use code for that year. The committee thus serves as a gatekeeper and auditor, though the regulations do not specify the committee’s composition, powers, or decision making process (these are presumably detailed in the scientific use code itself).

Prescribed matters for Ministerial consideration. Under regulation 5, when assessing an application for issue or renewal, the Minister must have regard to two prescribed matters: the information supplied on the application form, and the applicant’s access to a compliant animal ethics committee. These are in addition to whatever the Act already requires the Minister to consider. The regulations do not weight these factors or indicate how much influence they should have. The Minister retains broad discretion.

Licence conditions. The regulations impose three mandatory conditions (regulation 6) on use licences (and, by extension from the Act, on supply licences as well). The annual statement from the animal ethics committee is a recurring obligation. The obligation to provide such details as the CEO requests from time to time is open ended and could involve significant administrative costs if the CEO requests detailed records of every animal used or supplied. The third condition allows the Minister to impose additional conditions set out in or provided with the licence, which could be unique to each licensee and create uncertainty.

Fees. Schedule 2 sets out a simple fee structure: $100 per year of licence, up to a maximum of $300 for three years. This is a flat fee, not scaled to the number of animals used or the complexity of operations. It covers both issue and renewal. The fee is recoverable as a debt (under the Act, presumably), but the regulations do not address refunds or waivers.

Forms. The forms in Schedule 1 are prescribed, and under regulation 7, any matter for which a form is prescribed must be done, effected or set out in that form, subject to section 74 of the Interpretation Act 1984. This means deviation from the form may be permitted if the deviation is not material, but the safest approach is to use the exact form.

These concepts together create a regulatory framework that is largely procedural, with the substantive animal welfare standards left to the external scientific use code. The regulations do not themselves prohibit any specific practice; rather, they ensure that anyone using or supplying animals for scientific purposes is licensed, subject to an animal ethics committee, and bound by the code.

The regulations directly affect any person or scientific establishment that uses or supplies animals for scientific purposes in Western Australia. “Scientific purposes” as defined by the Act and expanded by regulation 3 includes product and technique demonstrations, so the net is broader than traditional research and teaching. A veterinary practice that demonstrates a new surgical technique to colleagues using live animals, a pharmaceutical company that runs product demonstrations for clients, or an agricultural training centre that demonstrates animal husbandry techniques could all fall within scope. They must hold a licence or risk prosecution under the parent Act.

The applicant for a licence must be the “person or scientific establishment responsible” (regulation 4(1)(b)). This is likely the institutional animal welfare officer, the head of the research facility, or the individual scientist in a smaller operation. The staff and students of the licensee are also affected because the licence permits them to use animals (Form 2 says the licence permits the scientific establishment, its staff and students, to use animals). The application form (Form 1) requires disclosure of prior offences of the applicant and, to the best of the applicant’s knowledge, any staff or students - meaning the compliance burden includes background checks on personnel.

Animal ethics committees are directly affected. The applicant must have access to an AEC that complies with the scientific use code, presumably one that meets the code’s requirements for membership, functions and decision making. The committee then bears the ongoing responsibility of providing an annual statement to the CEO indicating compliance. The committee’s own workload, liability and independence are not addressed in the regulations, but the annual statement requirement creates a de facto audit role. If the committee fails to produce the statement, the licence is at risk.

The Department, through the CEO, is the administrative counterparty. The CEO must receive applications, process them, issue licence documents, accept annual statements, and respond to requests for details. The CEO also has the power to request further details from licensees “from time to time” (regulation 6(b)), which can impose intermittent compliance costs on licensees. The Minister makes the final decision on licence issuance or renewal, but the regulations give little guidance on how the Minister should weigh the prescribed matters.

Suppliers of animals for scientific purposes are a distinct category affected. A supplier licence (Form 3) permits the supply of animals from specified places. This could include commercial breeders, dealers who supply laboratory animals, or institutions that breed animals for research. The supplier must comply with the scientific use code (which likely includes standards for housing, transport and breeding) and must provide details to the CEO on request.

Indirectly, the regulations affect the animals themselves. The entire scheme is designed to regulate how animals are used and supplied, imposing welfare standards via the code. However, the regulations do not create any direct rights for animals or for third parties to enforce animal welfare; enforcement is left to the Department and the courts under the Act.

The fee schedule affects all licensees. At $100 per year, the financial burden is minimal as a direct cost, but the associated costs of establishing and maintaining an animal ethics committee, producing annual statements, maintaining registers, and training staff in the scientific use code can be substantial, particularly for smaller operations.

Finally, the regulations affect the broader research and commercial community by creating a uniform licensing framework across Western Australia. All users and suppliers of animals for scientific purposes must go through the same process, pay the same fees, and adhere to the same code. This may reduce regulatory fragmentation but also imposes a one-size-fits-all approach that may not suit all activities.

Duties of licensees. The regulations impose several specific duties on the holder of a licence to use or supply animals for scientific purposes. The most prominent is the duty under regulation 6(a): the licensee must provide the CEO of the Department with an annual statement from the relevant animal ethics committee indicating compliance with the scientific use code for that year. This is an ongoing recurring obligation, not a one-off. There is no grace period specified; presumably the statement must be provided within a reasonable time after the end of the relevant year.

Under regulation 6(b), the licensee must provide such relevant details in relation to the licence (including details of the animals used or supplied) as are requested by the CEO from time to time. This duty is open ended. The CEO can demand information repeatedly, and the licensee must comply. There is no express limit on the scope of the request, no cost recovery for the licensee, and no time limit for compliance. The only limit is that the details must be “relevant” to the licence, which would be a matter for judicial review in extreme cases, but in practice the CEO has broad discretion.

Regulation 6(c) requires the licensee to comply with such other conditions imposed by the Minister as are set out in or provided with the licence. This is a catch-all provision that can be used to impose bespoke conditions on individual licensees. Those conditions become legally binding as soon as they are set out in the licence document or provided to the licensee.

Additionally, the forms themselves impose duties. Form 2 (use licence) states that the licensee must maintain a register of all approved projects and be able to identify current projects. The licensee must also establish and maintain a method of ensuring any person involved in conducting an approved project has the appropriate veterinary skills for that project. These duties are not in the regulations as such but are printed on the licence form, and because the licence is issued subject to those conditions (and regulation 6(c) incorporates any conditions set out in the licence), they are enforceable.

The duty to use or supply animals only in accordance with the scientific use code is inherent: the licence permits use “in accordance with the scientific use code” (Form 2). Failure to comply with the code would be a breach of a licence condition.

Rights of licensees. The regulations create a right to apply for a licence or renewal. Once the application is lodged with the prescribed fee, the Minister must consider it. The Minister is required to have regard to the prescribed matters (information on the form and access to an AEC), but the regulations do not guarantee that a licence will be issued. The right is procedural only: the right to have the application considered according to the statutory criteria.

Licensees have the right to use or supply animals under the licence, subject to compliance with conditions. The licence is for a fixed period (one, two or three years as chosen). There is no express right to transfer the licence or to challenge conditions before they take effect.

Duties of the Minister. The Minister must have regard to the prescribed matters when considering an application (regulation 5). This is a duty to consider, not a duty to decide in a particular way. The Minister may also impose other conditions (regulation 6(c)), but the regulations do not limit the power to impose conditions; they only require that the conditions be set out in or provided with the licence.

Duties of the CEO. The CEO must receive annual statements and information requests. The CEO has the power to request details, but there is no corresponding duty to review or act on the information. The annual statement from the AEC goes to the CEO, but the regulations do not specify that the CEO must assess it or take any particular action.

Duties of the applicant. The applicant must provide complete and accurate information on Form 1. The penalty for false or misleading information is $20,000 and imprisonment for one year (referenced in the note on the form, under section 76(a) of the Act). The applicant must also disclose prior offences under the Act or equivalent legislation in any Australian jurisdiction, as well as any suspension or revocation of previous licences.

Rights of third parties. The regulations do not create any rights for members of the public, animal welfare organisations, or competitors to enforce compliance. The annual statement goes to the CEO only. There is no requirement to publish licences, annual statements, or information requests. Transparency is minimal.

The regulations themselves do not create any penalties. Instead, they rely on enforcement mechanisms in the parent Animal Welfare Act 2002. However, the regulations contain implicit enforcement triggers. A breach of a licence condition (including the conditions in regulation 6 or the conditions printed on the licence form) is likely to be an offence under the Act or at least grounds for suspension or revocation of the licence under section 17 of the Act, as noted on the licence forms. The forms state: “This licence may be suspended or revoked for reasons set out in the Animal Welfare Act 2002, section 17.”

The most directly referenced penalty is on Form 1: giving information known to be false or misleading in a material particular is an offence under section 76(a) of the Act, carrying a maximum penalty of $20,000 and imprisonment for one year. This applies to the application form itself and presumably to any other information provided under the regulations, such as responses to CEO requests. The penalty is substantial, reflecting the seriousness of dishonesty in the licensing process.

Failure to provide the annual statement from the animal ethics committee (regulation 6(a)) is a breach of a licence condition. The Act likely makes such a breach an offence, and it is certainly grounds for suspension or revocation. The same applies to failing to provide details requested by the CEO (regulation 6(b)) or failing to comply with Ministerial conditions (regulation 6(c)). Enforcement is in the hands of the Department, which can investigate, issue notices, or refer matters for prosecution.

The regulations do not specify any monetary penalties for breaches of the scientific use code. Instead, compliance with the code is a condition of the licence, so any violation is a breach of condition. The code itself may contain reporting requirements or prohibitions, but the regulations do not incorporate those as independent offences.

The fee non-payment is enforceable: the regulations state fees are payable, and under the Act they are likely recoverable as a debt. The fee schedule does not include late payment penalties, but if a licence is issued subject to payment, failure to pay could result in non renewal or cancellation.

The regulations do not create a system of infringement notices, on the spot fines, or administrative penalties. Any enforcement action would need to proceed under the Act, which may involve court proceedings. The regulator (likely the Department of Local Government and Regional Development, based on the Minister’s title on the forms) has discretion to prosecute or take administrative action. The regulations provide no guidance on how that discretion is to be exercised.

One notable gap: the annual statement from the AEC must indicate compliance, but the regulations do not require the CEO to verify that statement or to take any action if it shows non compliance. The statement is simply provided. The CEO could request further details under regulation 6(b), but there is no mandatory follow up. In practice, the enforcement regime depends on the Department’s willingness to actively monitor and request information.

The penalty for false or misleading information ($20,000 and imprisonment) is the only specific penalty mentioned in the source. For all other breaches, one must refer to the parent Act. The regulations themselves are procedural, not punitive.

These regulations are made under the Animal Welfare Act 2002 (WA) and are subsidiary to that Act. They implement sections 5, 8, 9 and 11 of the Act, among others. The parent Act provides the overarching framework: definitions, offences, licensing powers, and enforcement. The regulations fill in details such as the prescribed code, prescribed activities, application procedures, and licence conditions. Any inconsistency between the regulations and the Act would be resolved in favour of the Act.

The regulations also interact with the Interpretation Act 1984 (WA) through regulation 7(2), which notes that prescribed forms must be used subject to section 74 of that Act. Section 74 allows for substantial compliance with a prescribed form if the deviation does not affect the substance. This provides limited flexibility for applicants who cannot precisely comply with Form 1, but the safe course is to use the exact form.

The most significant interaction is with the external Australian code of practice for the care and use of animals for scientific purposes (the scientific use code). Regulation 2 incorporates this code by reference, including future amendments. This means the code is not contained in the regulations and is not subject to disallowance by Parliament when updated. The code itself is a non legislative document published by the NHMRC, a Commonwealth body. It is likely enforceable as a condition of the licence, but challenges could arise if the code changes in ways that are impracticable or inconsistent with other state laws. The regulations do not specify how conflicts between the code and the Act or other WA laws are resolved; presumably the Act prevails.

The regulations affect the operation of other animal welfare laws. In Western Australia, the Animal Welfare Act 2002 is the primary statute. These regulations carve out a special regime for scientific purposes, which may displace some provisions of the Act. For example, conduct that would otherwise be an offence (e.g. causing pain to an animal) may be lawful if carried out under a scientific licence and in accordance with the scientific use code. The regulations thus create an exception to general animal welfare prohibitions, subject to strict licensing conditions.

Interstate implications: The application form (Form 1) asks about prior offences under “any equivalent legislation in another Australian jurisdiction”. This means the regulations interact with animal welfare laws in other states and territories. A conviction in New South Wales, Victoria, or Queensland for an animal cruelty offence must be disclosed in a WA application. The WA Minister may take that into account when deciding whether to issue a licence. There is no mutual recognition of licences across states; anyone moving research operations to WA must apply for a new licence under these regulations.

The regulations do not interact directly with Commonwealth laws (e.g. the Australian Animal Welfare Strategy or NHMRC Act), but the scientific use code itself is a Commonwealth publication. The regulations give it legal force in WA.

There is no reference to the Criminal Code or other general criminal laws. The penalty for false information references section 76(a) of the Act, which is a specific offence provision. If the false information also constitutes a general offence (e.g. fraud), that could be prosecuted separately under different laws.

Finally, the regulations interact with administrative law principles. The Minister’s decision to issue or refuse a licence is a decision under an enactment, subject to judicial review under the Judicial Review Act 2000 (WA) or at common law. The prescribed matters in regulation 5 constrain the Minister’s discretion to some extent, but the Minister retains residual discretion and can consider other factors not listed. A refused applicant could challenge the decision on grounds of failing to take into account a relevant consideration (the prescribed matters) or taking into account an irrelevant consideration.

Based on the compilation table in the source, the Animal Welfare (Scientific Purposes) Regulations 2003 were gazetted on 21 March 2003 and commenced on the same day (21 March 2003). The compilation table shows only one entry: the original regulations. There is no record of any subsequent amendments in the source provided.

This means the regulations have been in force unchanged since 2003. Over two decades have passed without any amendment to the regulatory text. However, the scientific use code prescribed under regulation 2 is the “latest edition … published from time to time” - that code has almost certainly been revised multiple times since 2003. The regulatory text has remained static, but the obligations it imposes have evolved through changes to the external code. An amendment to the regulations would have been needed only if the government wanted to alter the prescribed activities (regulation 3), the licensing procedure, the fee structure, or the prescribed matters for ministerial consideration.

The absence of amendments is noteworthy. The fee schedule in Schedule 2 has not been updated. At $100 per year for a licence, the real value of the fee has declined due to inflation. The forms have not been modernised. The application form still asks for fax numbers (the form includes a field for “Business Fax”). The Minister responsible is identified as the “Minister for Local Government and Regional Development”, a portfolio that may have changed over the years.

This lack of amendment history suggests that the regulations were seen as adequate at inception and have not required legislative revision. Alternatively, it may reflect low political attention or bureaucratic inertia. For regulated entities, the stability is a double edged sword: predictable and unchanged requirements, but also a regime that may not reflect current best practice in animal ethics or administration.

The compilation notes indicate that this is a compilation of the regulations (meaning it is an up to date reproduction incorporating all amendments). Since there are no amendments, the compilation is simply the original text. The table confirms no amendments have been gazetted.

Users should verify whether the compilation is current at the time of reading, but based on the source, the regulations have not been amended.

The source provided contains no references to any litigation concerning these regulations. There are no case citations, no notes of judicial decisions, and no references to court proceedings in the text. The regulations themselves do not create private rights of action, and the parent Act’s penalty provisions would be enforced in the Magistrates Court or higher courts, but the source does not record any such cases.

It is possible that cases have been litigated under the parent Animal Welfare Act 2002 that involve these regulations, but the source does not mention them. The regulations are subsidiary and procedural; most disputes would likely concern whether a licence was properly refused or revoked, or whether the scientific use code was complied with. The Minister’s discretion under regulation 5 could be challenged on administrative law grounds, and the CEO’s information requests under regulation 6(b) could be challenged for being too broad or irrelevant. However, without evidence, it cannot be stated that such litigation has occurred.

One potential area of litigation is the scope of “scientific purposes” as extended by regulation 3 (product or technique demonstrations). A person might argue that a particular demonstration is not a “scientific purpose” because it does not involve any scientific method or knowledge creation. The regulation itself declares that such use is a prescribed activity, but the overarching definition in the Act may still require a nexus to “scientific purposes”. Courts could be asked to interpret whether the regulation is within power. No such case is cited.

Another possibility: the incorporation by reference of the scientific use code (including future amendments) could be challenged as an unconstitutional delegation of legislative power, but that would be a highly unusual challenge under state law. No case is recorded.

The regulations have been in force for over twenty years. The absence of reported litigation may indicate they are working without major legal controversy, or that disputes are resolved administratively or through confidential settlements. It could also mean that the financial stakes are low (fees are minimal, and licence revocations are rare or not appealed). For a practitioner, the lack of case law means there is little judicial guidance on the interpretation of the regulations. That creates uncertainty: terms such as “relevant animal ethics committee” or “compliance with the scientific use code” have not been judicially defined.

In summary, the source contains no litigation history. The analyst cannot invent cases. The deep dive must note the absence.

Several provisions in these regulations create traps for the unwary that may not be obvious on first reading.

The scientific use code changes without notice. Regulation 2 prescribes the latest edition of the NHMRC code “including any amendments” published from time to time. This means the code is a moving target. A licensee who last read the 8th edition (2013) may be non compliant if the NHMRC publishes a 9th edition with new requirements. The regulations do not require the Department to notify licensees of code updates. The licensee bears the entire burden of monitoring NHMRC publications. Failure to keep up is no defence.

Demonstrations are caught. Regulation 3 prescribes the use of an animal to demonstrate a product or a technique as a scientific purpose. Many businesses may not realise they need a licence. For instance, a veterinary sales representative who uses a live animal to show how a new drug works, or a farmer who demonstrates a marking technique to a group of students, may be unlicensed. The regulation does not require that the demonstration be for a scientific audience; it could be for commercial clients.

The CEO can demand information at any time. Regulation 6(b) requires the licensee to provide such relevant details “as are requested by the chief executive officer … from time to time”. There is no limit on frequency, no limit on the scope beyond “relevant”, and no reimbursement for the cost of compliance. A CEO could request detailed records on every animal used for the past five years, with a tight deadline. The licensee must comply or risk revocation.

Open ended ministerial conditions. Regulation 6(c) allows the Minister to impose “such other conditions … as are set out in, or provided to the licensee with, the licence”. These conditions can be anything reasonably related to the licence. They are not published in the regulations and may differ per licensee. A licensee could be subject to conditions they did not anticipate and did not agree to. The only limit is that the conditions must be set out in or provided with the licence.

The annual statement must come from the AEC, not the licensee. The licensee must provide an annual statement from the relevant animal ethics committee indicating compliance with the scientific use code. If the AEC is unwilling or unable to provide such a statement (e.g. it has ceased to operate or disputes the licensee’s compliance), the licensee is in breach even if the licensee believes they are compliant. The regulations do not allow the licensee to substitute a self certification or alternative evidence.

Prior offences disclosure is broad. The application form requires disclosure of convictions under the Act or equivalent legislation in “another Australian jurisdiction” for the previous three years, not just WA. It also asks about any suspension or revocation of a licence under equivalent legislation anywhere in Australia. An applicant must check the criminal records of staff and students to the best of their knowledge. Failure to disclose could lead to a penalty under section 76(a) for false information.

The fee is per year of licence, not per application. The fee in Schedule 2 is $100 per year, payable upfront for the chosen licence duration. If a licensee chooses a three year term and pays $300, but the licence is revoked after one year, the fee is not refundable. The regulations do not address refunds.

No grandfathering or transitional provisions. The regulations commenced in 2003 and provided no transitional period for existing users. Any person who was already using animals for scientific purposes at commencement had to immediately apply for a licence. The source contains no transitional provisions.

The forms must be used. Regulation 7(2) says that if a form is prescribed, the matter must be done in that form, subject to section 74 of the Interpretation Act 1984. While substantial compliance is permitted, the safest course is to use the exact form. An application submitted on a customised version that omits required fields could be rejected as invalid.

Licence conditions printed on the forms are not in the regulations. The conditions on Form 2 (maintain register of projects; ensure appropriate veterinary skills) are not mentioned in regulation 6. They are only on the licence form itself. A licensee who only reads the regulations might miss them. However, they are binding as conditions set out in the licence under regulation 6(c). The point is to read the entire licence document carefully.

The penalty for false information applies throughout the licence period. The note on Form 1 warns of the penalty under section 76(a) of the Act. This penalty applies not just to the application but to any information provided under the Act or regulations. If a licensee later provides false information in response to a CEO request, that is also caught. The penalty is $20,000 and imprisonment for one year, serious for an administrative breach.

Complying with these regulations involves distinct steps: obtaining the correct licence, maintaining it, and meeting ongoing obligations. The following is a practical guide for a person or scientific establishment in Western Australia.

Step 1: Determine whether a licence is needed. If you use animals for scientific purposes or supply animals for scientific purposes (including demonstrating a product or technique), you need a licence. There is no de minimis threshold. Even a single animal used once for a demonstration triggers the requirement. If you are unsure, treat the activity as covered unless a court or the Department says otherwise.

Step 2: Obtain the prescribed forms. Download or request Form 1 (Application for licence to use/supply animals for scientific purposes) from the Department. Do not create your own version. The form is in Schedule 1 of the regulations.

Step 3: Ensure access to an animal ethics committee. You must have access to an AEC that complies with the scientific use code. If you do not have your own, you need a written arrangement with another establishment’s committee. The AEC must be willing to provide an annual statement of compliance. Verify that the AEC exists and is recognised before applying.

Step 4: Complete Form 1 accurately. Fill in all fields. Provide the name, address, type of licence (use, supply, or both), primary activity, places where animals will be located, details of the AEC, and evidence of experience and competence. Attach details of staff and student experience. Answer the prior offences question thoroughly. Check the criminal history of the applicant and, to the best of your knowledge, staff and students, for the previous three years. Disclose any convictions under animal welfare laws in any Australian jurisdiction, and any licence suspension or revocation.

Step 5: Pay the prescribed fee. Calculate the fee based on the number of years you want the licence (one, two or three years). The fee is $100 per year. Make the payment as directed by the Department.

Step 6: Lodge the application. Submit Form 1, any further information required to complete the form, and the fee to the Department. Keep a copy of everything. The application must be in writing and lodged by the person or scientific establishment responsible.

Step 7: Wait for the Minister’s decision. The Minister will consider your application, the information on the form, and your access to an AEC. The licence may be issued with conditions. Read the licence document (Form 2 or Form 3) thoroughly. Note any additional conditions imposed by the Minister. Those conditions become legally binding.

Step 8: Comply with the scientific use code. Obtain the latest edition of the NHMRC Australian code of practice for the care and use of animals for scientific purposes. Read it and implement its requirements. Ensure all staff and students who handle animals are trained in the code. Monitor for updates to the code.

Step 9: Set up internal systems. For a use licence, you must maintain a register of all approved projects and be able to identify current projects. Establish a method to ensure any person involved in an approved project has appropriate veterinary skills for that project. For a supply licence, ensure you can identify the source and destination of animals supplied.

Step 10: Provide annual statement from the AEC. Each year, before the anniversary of the licence, obtain a written statement from your animal ethics committee indicating compliance with the scientific use code for that year. Provide that statement to the CEO of the Department. Keep a copy.

Step 11: Respond to CEO information requests. If the CEO requests details relating to the licence (including details of animals used or supplied), respond promptly and accurately. There is no prescribed form for these responses; use a clear written format. Be truthful - false information attracts a $20,000 penalty and possible imprisonment.

Step 12: Comply with any other conditions. Review the licence document for any additional conditions imposed by the Minister. These might relate to record keeping, reporting, or restrictions on certain procedures. Comply with them exactly.

Step 13: Renew the licence before it expires. Use Form 1 again for renewal. Ensure the fee is paid and the AEC still supports the licence. Renew at the same duration or choose a different period.

Step 14: Keep records. Retain copies of all correspondence with the Department, annual statements, registers of projects, and any information provided to the CEO. Records may be needed to demonstrate compliance if the licence is audited or challenged.

Common pitfalls to avoid:

• Not updating knowledge of the scientific use code.
• Assuming a demonstration is exempt.
• Failing to disclose a prior offence from another state.
• Providing false or incomplete information.
• Missing the annual statement deadline.
• Ignoring conditions printed on the licence form.
• Failing to respond to a CEO information request.

The regulations are procedural and the fees are low, but the compliance costs of maintaining an AEC, training staff, and responding to government requests can be significant. Budget for those costs and treat them as ongoing, not one off. The regulations do not offer amnesties or warnings for first breaches; any non compliance may jeopardise the licence and result in prosecution under the parent Act.