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Outcome of HPRA Scientific Animal Protection fees consultation 2015
4 December 2014
Introduction
The HPRA received responses from 12 interested parties to the consultation on fees for scientific animal protection. Most respondents were concerned about the possible impact of HPRA plans for full-cost recovery on the future of animal-based studies in Ireland, and the associated implications for scientific research endeavour in this country.
Summary of the responses
The university sector is strongly opposed to project fees, including amendment fees which are resented by researchers and considered to be unfair, bureaucratic, and stifling research. They favour a system of individual authorisation fees coupled with an establishment fee (which would be billed rather than paid in advance). Other stakeholders flagged that amendment fees add to the bureaucracy and should not be billed as a separate fee item. Two stakeholders favoured establishment fees exclusively, although the quantum foreseen by each party was quite different.
Revised proposal
Based on the feedback received the HPRA and in an effort to address the concerns of stakeholders, the HPRA has revised the fee model as follows:
1. Individual fees: These will be set at €150/annum for 2015, but are expected to increase within 2 years to €250/annum (in line with the expected reduction in the Department of Health subvention during that timeframe). The fees will apply to any new individual applying for authorisation from 1 January 2015 (i.e. they will have to accompany the application for individual authorisation). The annual maintenance fee in respect of those individuals who already have a current HPRA/IMB individual authorisation will also be €150/annum for 2015. This fee will apply to everyone in the establishment concerned; including technicians carrying out procedures or euthanasia of animals, as well as researchers, project managers etc. An invoice for the number of such individuals in each establishment will be issued altogether to the establishment in question in late summer, based on the presence of the individual in question in the establishment on the 30 June 2015 (and annually thereafter). In effect, this means that an individual holding an authorisation on 1 January 2015 will not be billed until summer 2016. Where an individual has two or more authorisations in respect of more than one establishment, a single fee will be payable. In the case of short-term individual authorisation applications (e.g. for the purposes of demonstration of a procedure, or for training in a procedure, where the authorisations are for a period of 2 weeks or less), the fee for this authorisation will be €50 payable at the time of application.
2. Establishment fees will be payable for each establishment based on the number of individual authorisations in place at the establishment. For 2015, the following fees will apply:
The establishment fee will be billed to institutions during Quarter 2, 2015, for payment in May or June 2015. The establishment fee for 2016 and beyond is expected to rise pro rata with any adjustments to the individual fee, as necessary to meet the government requirement for the HPRA to reach self-funding status.
3. There will be neither project fees, nor project amendment fees for 2015, even though projects were submitted in the expectation of such fees becoming payable during 2015 and beyond. However, future applications that are submitted without ethical review or where an application for expedited (fast-track) service is requested will attract a fee of €2000 as currently.
4. No routine establishment inspection fees will apply (as is the case currently). However, in the event that the HPRA must conduct a follow-up inspection as a result of an earlier non-compliance, the usual HPRA inspection fee of €1500/day will apply.
Conclusion
A full consensus view on the fees to be charged for 2015 did not emerge during this consultation. That said, the majority of stakeholders who took part in the consultation are in agreement that if there must be service fees the model as outlined above represents the most fair method available and is similar to that in place in the United Kingdom.
ENDS Page 2 of 2 Banding criteria for user establishments
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Annual fee per establishment
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Band 1: Small institution with no animal facilities or establishment with 1-3 individual authorisation holders
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€250
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Band 2: Establishments with 4-10 individual authorisation holders
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€500
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Band 3: Establishments with 11-20 individual authorisation holders
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€750
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Band 4: Establishments with 21-50 individual authorisation holders
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€1,500
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Band 5: Establishments with 51-100 individual authorisation holders
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€3,000
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Band 6: Establishments with 101-150 individual authorisation holders
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€5,000
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Band 7: Very large establishments with 151-200 individual authorisation holders
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€7,500
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Band 8: Very large establishments with > 201 individual authorisation holders
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€10,000
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