The Extreme Consequences of Naivety, Ignorance of Current Science, and Lack of Critical Thinking Skills in the Animal Protection Community. Part I.

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This series of essays will revolve around the Three Rs and my concern vis-à-vis WHY we are still talking about the Three Rs and similar issues in light of the implications of Trans-Species Modeling Theory for animal modeling in general.

I have written and spoken over the last twenty years regarding the use of animals in science in general and biomedical research in particular. Despite publishing

  • five books
  • twenty or so articles in the peer-reviewed scientific literature, some of which introduced the only theory that explain why animal models will never be predictive for human response to drugs and disease—Trans-Species Modeling Theory
  • miscellaneous book chapters
  • articles in the nonscience literature and making numerous public appearances

the same problems never seem to disappear. I have explained many times why the Three Rs are nonsense and counterproductive in terms of why animal modeling persists and these reasons are not that difficult to understand. So why do I find myself addressing the Three Rs and alternatives again and again?

In part this is due to the fact that new people come into the animal protection movement or new scientists are exposed for the first time to the perfidy of animal modelers. But the number of new people in whichever context does not account for the fact that every time an old argument like the Three Rs is trotted out, the animal protection or science community as a whole seems to be

shocked [yes shocked(!)] that such an outstanding and brilliant pro-animal use argument exists. The argument invalidates everything written before and therefore anything that animal modelers need to do to keep us alive is OK.

 Or the animal protectionist states something like the following:

THE best anti-vivisection organization in the universe, _______ (fill in the blank with whatever organization the animal protectionist supports) confirms that the Threes Rs and alternatives are really great and therefore the Three Rs and alternatives must be THE answer to the problem of vivisection.

This is what I hear from people who self-identify as animal protectionists! The scientific community is much more smug but many are just as naïve and scientifically illiterate.

In this essay, I will address for the umpteenth time why the Three Rs and alternatives are dangerous and counterproductive nonsense. The following is from FAQs About the Use of Animals in Science: A handbook for the scientifically perplexed.

So how does one properly define the word alternative?

The word alternative comes from the Latin alternare—meaning to interchange.

According to The New Oxford American Dictionary it means: “One of two or more available possibilities.” The important thing here is that it implies viability.

A scientifically invalid practice cannot be replaced with an alternative. Consider this example: Eating broccoli is not an alternative to eating rocks for nutrition, but it is an alternative to eating asparagus.

The Encarta Dictionary defines alternative as follows:

Other possibility: something different from, and able to serve as a substitute for, something else.

Example: You could take the bus as an alternative to driving. Note that the original choice in this example—taking the bus—is viable.

Possibility of choosing: the possibility of choosing between two different things or courses of action.

Example: We gave you the alternative; you decided to stay. Again, the original choice—leaving, presumably—is the original and viable choice.

Option: either one of two or one of several things or courses of action to choose between.

Example: I can’t decide which of the two alternatives is worse. Both are viable, just not great.

The Cambridge Dictionary defines alternative as follows: “Something that is different from something else, especially from what is usual, and offering the possibility of choice: an alternative to coffee.” The original choice is viable—in this case, coffee. 

Another example: There must be an alternative to people sleeping on the streets. The original is viable; in this case, people are actually sleeping on the streets.

I’m afraid I have no alternative but to ask you to leave (that is what I have to do). Again, the original is viable; in this case, staying is viable if the person behaved better. 

The opposition parties have so far failed to set out an alternative strategy. The original is viable; in this case, the original strategy is viable, just not acceptable to all.

An alternative venue for the concert is being sought. The original is viable; in this case, the concert was scheduled for a certain venue and could have been held there, but now needs to be changed.

We could go to the Indian restaurant or, alternatively, we could try Italian. Again, the original choice is viable because indeed the Indian restaurant serves food.

Is there a circumstance when it is appropriate to use the word alternative when referring to nonanimal based modalities?

Yes. As we have seen earlier in this book, there are clearly scientifically viable uses for animals, such as replacing a damaged human aortic valve with a valve from a pig. Using animals as incubators or bioreactors to grow viruses is also scientifically viable. Within this context, then, it would be appropriate to say that a synthetic aortic valve is an alternative to a pig valve.

Remember, in order for something to be an alternative, the original choice or course of action must be viable. The use of animals as predictive models is not viable; therefore, a predictive modality that does not use animals is not an alternative.

If predictive modalities are not alternatives, then why do I hear so much about alternatives and the Three Rs? 

The Three Rs is a concept that has been embraced by groups that would seemingly be on opposite sides of the issue: the animal experimentation community and many in the animal protection community. That fact alone should give one pause. One must question the motivation of groups that support the Three Rs when the very people whose conduct they supposedly oppose also support this concept. This does not prove malfeasance but it suggests closer examination is needed.

The Three Rs has been around for almost 60 years. In 1959, two British scientists, William Russell and Rex Burch, published the results of a systematic study they conducted on the ethical aspects of animal research and the development and progress of humane techniques in the laboratory. This study launched the concept of the Three Rs: Reducing the number of animals used; Refining techniques so the animals suffer less; and Replacing animal-based tests as alternatives are invented.

In the ensuing years, finding alternatives to animal tests—the Replacement component of the Three Rs—has become a cottage industry consuming billions of dollars and employing thousands of people. Yet the Three Rs has been a dismal failure. More animals are used in research and testing now, and more money goes to animal-based studies, than in the 1950s and 1960s when Russell and Burch were popularizing the concept. Additionally, more animals are used now than when the Three Rs groups—the European Centre for the Validation of Alternative Methods (ECCVAM) and the Interagency Coordinating Committee on the Validation of Alternative Methods (ICCVAM)—were organized.

Why? Because the Three Rs have been applied to animal use that purports to predict human response. As we have discussed earlier, most animal use is justified by scientists to society-at-large on the grounds that it is predictive for humans. Now consider the number of people whose employment hinges on the search for alternatives to tests that don’t work in the first place. It’s no surprise that they are outraged whenever it is pointed out to them that if a test does not fulfill the function it was designed to fill, it should be abandoned for that purpose regardless of what else is or isn’t available. 

Waiting to abandon a test that does not work until we can find one that does (finding an “alternative”) is not just a misuse of the word but utter nonsense as well. The Three Rs should never have been applied to animal use that purports to predict human response. But there are more problems with this failed concept.

What other problems do you see with the Three Rs?

To answer that, let’s examine who defends the animals as predictive models industry. They can generally be divided into two groups. The first group is made up of the animal experimenters themselves—those who use animals in research or their representatives. They have their incomes directly linked to animal experiments. The second group is the people involved in the Three Rs industry who, like the animal experimenters themselves, have their incomes linked to strong claims about the predictive utility of animal models.  Included in this latter group are those who profess to be advocates for animals but who say: “Gosh darn we just have to experiment on animals. We just have to.” (This is a direct quote from the current chairman of the board of a large, prominent animal protection organization.)

What both groups have in common is the difficult problem of saying animals are capable of predicting human response while simultaneously saying that is not why they are used, since the evidence that animals cannot be used to predict human response is overwhelming. 

Are you saying that in fact the very people who support the Three Rs also claim that animal models are predictive for humans?

The Humane Society of the United States (HSUS), The Fund for the Replacement of Animals in Medical Experiments (FRAME), the Johns Hopkins-based Coalition to Abolish Animal Testing (CAAT), and the UK-based Royal Society for the Prevention of Cruelty to Animals (RSPCA), all support the Three Rs and claim, either by direct statement or implication, that animal models are in fact predictive for humans.

From FRAME’s website ( “However, FRAME recognises that immediate abolition of all animal experiments is not possible.”  Because:

Vital medical research must continue to find treatments for diseases which lessen the quality of human and animal life. New consumer products, medicines, and industrial and agricultural chemicals must be adequately tested in order to identify potential hazards to human and animal health, and to the environment.

The implication that animal tests are predictive is obvious in the above statement. 

Alan M Goldberg, PhD and director of CAAT:

In my statement, I acknowledged that laboratory animals are—and will continue to be—necessary for much research, but I emphasized the need to minimize or eliminate pain and distress in in vivo experiments through the Three Rs of replacement, reduction, and refinement. [1]

David O Wiebers, MD is professor of neurology at the Mayo Clinic in Rochester, Minnesota and is the Chairman of the Board of the Humane Society of the United States (HSUS). Dr. Wiebers delivered the keynote address at the HSUS symposium held in Washington, D.C., on October 11, 1991 and stated the following:

Let me make a few comments about alternatives to animal research. Most physicians and scientists would agree that the development of alternatives to using live animals in research is desirable. Indeed, some encouraging progress is being made in this area with regard to the use of tissue cultures and other in vitro testing, as well as mathematical and computer models. However, we should not be under any false illusions that all of the findings of animal research can be reproduced in a computer model or tissue culture given our current level of technology and understanding.

 The official position of the HSUS is:

We carry out our work on behalf of animals used and kept in laboratories primarily by promoting research methods that have the potential to replace or reduce animal use or refine animal use so that the animals experience less suffering or physical harm. (Replacement, reduction, and refinement are known as the Three Rs or alternative methods.) The Three Rs approach, rigorously applied, will benefit both animal welfare and biomedical progress. [2]

All of the above individuals and organizations will go to great lengths to explain to you that animal tests are predictive. [One of us (RG) was on the HSUS scientific advisory committee for years and is very familiar with their official and unofficial position: they strongly hold that animal models are predictive.]

We are not saying that all members or employees of the above mentioned organizations are disingenuous. Many people in these organizations are sincere but not familiar enough with science to understand what is really going on. We encourage the reader to explore these concepts with these organizations and come to their own conclusions.

End of quote from FAQs About the Use of Animals in Science: A handbook for the scientifically perplexed. (For the references see the book.)

The following are more recent examples of people or organizations that support the Three Rs and either state or imply that animal models are predictive. Michael Balls, in an op-ed about the European Citizens’ Initiative: Stop Vivisection states:

In my opinion, the Commission’s response to the Stop Vivisection Initiative is well-considered, well-written and constructive, and the organisers of the Citizens’ Initiative should feel that all the effort put into collecting the signatures in support of it was truly worthwhile. . . .[3]

In reality, the European Commission completely dismissed the Initiative out of hand. See Stop Vivisection And The European Parliament and The Vested Interest Groups Comment On ECI Stop Vivisection.

Balls continues: 

while it is recognised that animal studies have historically been key to the development of ways to prevent and treat human and animal diseases, and while animal models have limitations as well as strengths, some use of animals continues to be necessary.

Balls’ is clearly implying predictive value.

Balls continues:

That is all very promising, and it is to be hoped that genuine progress will be made so that animal models of dubious value will be replaced, and valid non-animal procedures and testing strategies will be put in place, which, in the words of the Citizens’ Initiative, will provide data directly relevant for the human species. The Commission and the animal welfare movement will not be able to achieve that progress on their own. It will be essential that the scientific community and the relevant industries also demonstrate their genuine and practical commitment to the Three Rs, by highlighting and tackling the outstanding need to replace animal experiments with scientifically-valid and human relevant alternatives as soon as is practicably possible.

Granted, Balls does acknowledge that not all animal models have predictive value but then so do essentially all animal experimenters. Moreover, essentially all vivisection activists claim that some models are better than others. But they conclude that: “Gosh darn we just have to experiment on animals. We just have to.”

For more on alternatives and the Three Rs see: The Anti-Science And Anti-Animal Position Of The RSPCA And HSUS and Loving Animals Does Not Make You A Scientist. For more on the science of why animals can never have predictive value for human response to drugs and disease see the articles and books in the Resources section of the website and the next essays in this series. .

The above mention of the Resources section leads me directly to my questioning of WHY we are still talking about the Three Rs. I will address this in detail in the next essays but will give you a hint now: If an animal protectionist wants to understand the science of animal experimentation AKA vivisection AKA animal modeling, he or she must have formal training in science in addition to putting in hundreds of hours studying the relevant science on their own. There is simply no way around this.


1. Goldberg A. (2002) Select committee on animals in scientific procedures minutes of evidence. Memorandum by professor goldberg, director, center for alternatives to animal testing. Last update date: 2002 [cited  August 2, 2009]; Available from: http:

2. HSUS. (2008) accessed  5-15-08; Available from:

3. Balls M (2015) The European Citizens’ Stop Vivisection Initiative. ATLA 43: 147-150.