In last year’s House Appropriation’s Bill HR 2029, the United States Congress asked the National Institute of Health to “conduct a review of its ethical policies and processes with respect to nonhuman primate research subjects, in consultation with outside experts, to ensure it has appropriate justification for animal research protocols.”
In an accompanying letter explaining their thinking behind the request, five members of Congress wrote:
We continue to believe that the time has come to critically evaluate the ethical policies and process surrounding all nonhuman primate research…We are confident that you will ensure the review is as independent as possible, so that the most difficult ethical questions with regards to the use of all non-human primates in a wide range of experiments can be honestly asked and answered…We look forward to working with you to ensure that critical taxpayer dollars are spent on research that is scientifically and ethically justified and appropriately humane to all non-human primate subjects involved.
In response, the NIH outlined their plans on a blog post for a Sept 7th Symposium focused on the ethics of primate research. After noting that the “NIH remains confident that the oversight framework for the use of non-human primates in research is robust and has provided sufficient protections to date,” the post explains the NIH’s plans to, “discuss the ethical principles underlying existing animal welfare regulations and policies” and requested 250 word comments from the public about the topics of the symposium and potential speakers.
This Congressional request and the workshop provide an excellent opportunity for thoughtful and informed discussion on the ethics of non-human primate research. Public views on research, the frameworks of professional ethicists, and scientists’ understanding of primate cognition have all evolved tremendously in recent years, and it is important for the NIH to make sure that their approach to research is responsive to these developments.
In their request for comments, the NIH noted that comments “may be shared publicly.” Since it is not clear if all comments will necessarily be shared publicly, and since this is a great opportunity to have a thoughtful discussion about the ethics of primate research, I have created this blog to highlight the comments from experts on ethics and primate cognition as a resource for the public and for future discussions. My hope is that academics and other experts will use the 250 word comments as an opportunity to think about what an ideal discussion of the ethics of primate cognition should look like. What ethical frameworks should be taken into account? What is the relevant research on the cognitive and affective capacities of primates? Which types of expertise should be represented in such a workshop?
If you haven’t already, please make sure to submit your 250 word comment to the NIH by clicking this link. If you would like your comment posted on this site, please email me at ashriver [at] mail.med.upenn.edu .
Some conscientious animal researchers explicitly advocate securing the cooperation of cognitively and socially complex animals when using them in research (e.g., Berns et al 2012; Matsuzawa 2006). In 2013, the NIH officially accepted most of the recommendations of an independent advisory council regarding chimpanzees used in NIH-funded research. This included only using acquiescent chimpanzees in comparative genomic and behavioral research (Altevogt et al 2011). What’s more, there is good evidence that cooperative animals make for less stressed out research subjects, and stress is a known confounder in animal research (Coleman 2010).
There is no morally significant difference between the dogs discussed by Berns et al, or the chimpanzees discussed by Matsuzawa and Altevogt et al, and such nonhuman primates as baboons, macaques, or marmosets. The NIH should ensure that, moving forward, the cooperation of nonhuman primates is required when using them in NIH-funded research.
Altevogt, B.M., Pankevich, D.E., Shelton-Davenport, M.K., and Kahn, J.P. Chimpanzees in biomedical and behavioral research: assessing the necessity. Washington, D.C.: National Academies Press, 2011.
Berns, G.S., Brooks, A.M., and Spivak, M. Functional MRI in Awake Unrestrained Dogs. PloS One 2012; 7(5): 1-7.
Coleman, K. Caring for Nonhuman Primates in Biomedical Research Facilities: Scientific, Moral and Emotional Considerations. American Journal of Primatology 2010; 71: 1-6.
Matsuzawa, T. Sociocognitive Development in Chimpanzees: A Synthesis of Laboratory Work and Fieldwork. In Cognitive Development in Chimpanzees. Matsuzawa, T., Tomonaga, M., and Tanaka, M., eds. Tokyo: Springer-Verlag Tokyo, 2006: 3-33.
I encourage you to restrict the use of primates in harmful, non-therapeutic biomedical research for the reasons that harmful, non-therapeutic biomedical research shouldn’t be allowed on human beings: it is harmful to the subject of the research, it is not in their benefit – it is an attempt to “use” one for the potential benefit of another, they do not and would not consent to it, and we would not agree to it, if we saw from their perspectives. In short, every powerful reason to not allow harmful experimentation on non-consenting human beings also applies to non-human primates. Given that, research on them should , at least, be seriously restricted or, ideally, outright banned, for ethical reasons.
Associate Professor of Philosophy, Morehouse College
In 1966, Henry Beecher called attention to common ethical problems associated with human research at the time. His publication, “Ethics and Clinical Research,” in the New England Journal of Medicine, helped lead to major advancements in the area of human clinical research ethics and medicine. Like Beecher was, I am an anesthesiologist. I care deeply about my patients and their potential involvement in research. I’m grateful that we have acceptable moral standards to guide the conduct of human research today. I am also concerned about the suffering of animals. Nonhuman primates are autonomous and intelligent individuals. NIH needs to better examine the ethics of using these sentient beings in research, and problems with their use, as Beecher did for human research fifty years ago. An increasing number of physicians and scientists are calling attention to problems with translating nonhuman primate research to human clinical scenarios. This has major implications for patient care. Viable, more ethical, predictive alternatives exist. NIH should focus on supporting the implementation of these alternatives, and developing other more valid and reliable human-centered research models. For humane, scientific, and medical reasons, NIH needs to move away from using nonhuman primates as non-consenting vulnerable research subject.
Nik Kulkarni, MD
As Dr. John Gluck points out in his recent Opinion Editorial in The New York Times, in 1974, a federal commission was formed to develop ethical principles for human research.  In contrast, no similar, comprehensive and principled effort has addressed the use of animals in research – despite the large body of science showing how animals can suffer physically and mentally. To address this gap, Dr. Gluck, Dr. Tom Beauchamp, many other colleagues, and I worked on a multi-disciplinary National Science Foundation grant exploring the limits of existing animal research guidelines, as well as potential solutions.  Results were reported in multiple publications, including a special issue of Theoretical Medicine and Bioethics called Rethinking the Ethics of Research Involving Nonhuman Animals.  One of the articles, authored by primatologist Dr. Agustin Fuentes and myself, addressed the imbalance between the harms of research involving nonhuman primates and deprivation of benefits to them. We concluded much of the laboratory research conducted today has inadequate standards, leading to significant physical, psychological, and social harms to nonhuman primates.  Several other articles in the series examine how widely recognized bioethical principles could better inform decisions about the use of animals, including nonhuman primates, in research.  I urge you to consider factors such as these in your deliberations.
Please see the following links for reference:
1. Peer-reviewed scientific evidence shows that many animals, including but not limited to nonhuman primates, certainly the 100,000+ monkeys now held in NIH-funded and other US laboratories, live complex family lives marked by intelligence, social acumen, and emotional response to events including individual stress and others’ deaths. When animals are housed singly and/or undergo procedures especially but not only in level C, D, and E experiments, they are consciously prone to physical and emotional suffering. 2. NIH’s research-proposal review should be updated to include full ethical consideration explicitly and directly among its primary concerns along with scientific value. 3. NIH emphasizes the existing layers of federal regulation and oversight that govern animal research. We know, however (e.g., L.A. Hansen, 2012, “Institution animal care and use committees need greater ethical diversity” Journal of Medical Ethics 39(3); 188-190), that the bar to gain approval to experiment on primates (and other animals) is low; that when research proposals are considered across rather than only within institutions approval rates go down significantly, suggesting a role for local approval bias; and that IACUCs as currently constituted are “highly skewed” towards animal researchers and institutional veterinarians who have “vested interests in continuing animal research.” These problems were evident with biomedical research on chimpanzees at NIH, which in 2011 was deemed “unnecessary” by an independent Institute of Medicine review– yet which for years prior had been approved and funded. 4. In conclusion, taking concrete steps to ensure better committee diversity/ transparency of oversight of ethical processes should become a top priority.
Barbara J. King, PhD, Emerita Professor, Dept. of Anthropology, College of William and Mary
John Gluck, an emeritus professor of psychology at the University of New Mexico, wrote an op-ed for the New York Times entitled, “Second Thoughts of an Animal Researcher.” He mentions the upcoming NIH symposium in the essay:
On Wednesday, the N.I.H. will hold a workshop on “continued responsible research” with these animals. This sounds like a positive development. But as someone who spent decades working almost daily with macaque monkeys in primate research laboratories, I know firsthand that “responsible” research is not enough. What we really need to examine is the very moral ground of animal research itself.
The ethical principle that many of us used to justify primate experiments seemed so obvious: If you are ethically prevented from conducting a particular experiment with humans because of the pain and risks involved, the use of animals is warranted. Yet research spanning the spectrum from cognitive ethology to neuroscience has made it clear that we have consistently underestimated animals’ mental complexity and pain sensitivity, and therefore the potential for harm. The obvious question is why the harms experienced by these animals, which will be at least similar to humans, fail to matter? How did being a different member of the primate grouping that includes humans automatically alter the moral universe?
In the case of chimpanzees, the N.I.H. finally concluded that the harms did matter. The question now is, are there morally significant differences between the great apes and other primates?
The whole piece is worth a read!
This comment from the NIH post was forwarded to me, and several of the points raised seemed in line with some of the concerns I’ve been seeing:
People for the Ethical Treatment of Animals (PETA) asks that the National Institutes of Health (NIH) take immediate action to ensure that its September 7, 2016, workshop on the use of nonhuman primates in NIH-funded biomedical and behavioral experimentation will fulfill the mandate explicitly outlined in the Consolidated Appropriations Act, 2016 and requested by U.S. members of Congress. If the workshop will serve only to maintain the status quo, NIH will be squandering a critical opportunity to strengthen protections for nonhuman primates and eliminate studies that aren’t contributing to the body of useful scientific knowledge. NIH Director Dr. Francis Collins has himself acknowledged the need for additional scrutiny of primate research proposals, and NIH bioethicists have called for restricting primate research. In light of the controversial maternal deprivation and psychopathology experiments on infant monkeys that had for more than 30 years received approval from the National Institute of Child Health and Human Development oversight body and been carried out at NIH’s facility in Poolesville, Md., Congress added language to the Consolidated Appropriations Act, 2016 that called on NIH “to conduct a review of its ethical policies and processes with respect to nonhuman primate research subjects, in consultation with outside experts, to ensure that it has appropriate justification for animal research protocols.” In January, members of Congress wrote to Dr. Collins to request his “personal involvement in ensuring that this review is productive and comprehensive.” In his February 17, 2016, response, Dr. Collins stated that the NIH would “convene a workshop in the summer of 2016 to review the ethical policies and procedures associated with the conduct of … research [with non-human primates]” and confirmed that this meeting “will include outside experts in animal health and welfare, to ensure that NIH has the appropriate policies and procedures in place for conducting research with non-human primates.” Yet the recently posted draft agenda for the workshop appears to show a disregard for the original directive of the Consolidated Appropriations Act. It appears that the first of the two sessions, “State of the Science of NIH-Supported Research Involving Non-Human Primates,” focusing on questions such as “How do non-human primates uniquely contribute to our understanding of basic biological processes and disease states?” and “What are the emerging scientific opportunities and/or public health needs for which non-human primate research models may be required?,” will be fully dedicated to extolling the use of nonhuman primates in experiments—something that is entirely outside the review mandated by the Consolidated Appropriations Act. The second session, “Oversight of NIH-Supported Research Using Non-Human Primates,” which includes as one of three group discussion questions “How does the current oversight framework address ethical and welfare concerns using non-human primates in NIH-supported research?” would appear to be an effort to legitimize the false notion that current practices are adequate to protect nonhuman primates used in experimentation. These are issues the panel should address: Primates are used in studies with little or no public health implication and that are unlikely to translate to humans and/or for which alternatives exist. Primates are subjected to painful experiments, sometimes without pain relief. Standard laboratory housing for primates lacks sufficient space, meaningful cognitive stimulation, and adequate social contact, causing significant psychological and physical distress. Thousands of primates are singly-housed, often without adequate scientific or veterinary justification. We suggest that the NIH rules instituted to reform chimpanzee experimentation may address problems with all nonhuman primate research. Specifically, NIH’s chimpanzee research criteria state that (1) knowledge gained must be necessary to advance public health, (2) no other research model could be used, and the research cannot be ethically performed on humans, and (3) the animals used must be maintained either in ethologically appropriate environments or natural habitats. We therefore ask that you take immediate action to radically revise the current agenda to bring it in line with the mandate of the Consolidated Appropriations Act and the request of the members of Congress. We also ask that you release the names of the workshop participants. If fair and balanced, this workshop can help ensure that primate experimentation rules are updated to reflect the current science on animal welfare, research translation, and non-animal methods.