Here is my comment for the NIH after seeing their draft agenda:
I am writing to express my concern that the draft agenda for the NIH workshop is structured in a manner that fails to comply with Congress’s request. In the original Appropriations Bill Report, Congress asked for the NIH to “conduct a review of its ethical policies and process with respect to nonhuman primate research subjects, in consultation with outside experts, to ensure that it has appropriate justification for animal research protocols.” Asking for a review of procedures to ensure that they have appropriate justification clearly suggests that the workshop needs to address the following question: “are current animal research protocols with primates ethically justified?”
However, the current workshop format is structured in a manner that does not attempt to answer that question. Rather than asking what the appropriate ethical principles underlying primate research should be, the workshop simply asks for a description of what the current policies are and a description of the veterinary science that was used when those policies were first put in place. Moreover, by asking “how” these procedures address welfare concerns, the report assumes, without discussion, that such concerns are addressed, rather than asking if they are addressed, which is what Congress requested.
If the NIH wishes to be in compliance with Congress’s request, the workshop should devote significant amounts of time to discussing different ethical perspectives on primate research, in conjunction with current evidence about primate cognitive and affective capacities, including evidence from studies of primates in their natural environments.
I will also note that the original request from Congress made it clear that they wanted this review to be conducted in conjunction with trained ethicists. While I have heard that at least a couple ethicists have been invited to participate in the discussion, it seems to me that the format of the workshop has been designed in a manner that will minimize their ability to contribute their expertise.
The NIH published a draft agenda for the workshop, which can be found here.
The workshop kicks off with a session titled, “State of the Science of NIH-Supported Research Involving Non-Human Primates.”
It then will hold a discussion on the following questions:
- Why and how does a researcher decide to use a non-human primate model?
- How do non-human primates uniquely contribute to our understanding of basic biological processes and disease states?
- What are the emerging scientific opportunities and/or public health needs for which non-human primate research models may be required?
The only thing resembling a discussion of ethics, from what I can see, is the afternoon session discussion the following questions:
- What are the policies and processes in place regarding the ethical use of non-human primates in NIH-supported research?
- How does the current oversight framework address ethical and welfare concerns of using non-human primates in NIH-supported research?
- What is the laboratory and veterinary science evidence base underlying current welfare standards and practices?
NIH’s workshop to consider current policies and practices related to oversight of research involving nonhuman primates is a step in the right direction. The published plan in which NIH pledged to “catalyze powerful innovations, including molecule cross-coupling methods … and human 3D organoid technologies that will be better than animal models” must become a reality in the very near future.
It is the recommendation of the staff, faculty, and medical board of directors of Center for Healthcare Education, Inc. that:
- All primate experimentation be eliminated and replaced with computer/stem cell or other models for non-living animal research
- Researchers be vetted for their motivation for participation – the suffering imposed on any living creature should not be without impunity. This should also include vetting of veterinarians, many who are only looking to build their resumes and/or find gainful employment making the animal’s comfort and physiological needs secondary to their own.
- The FDA’s requirements for animal experiments be eliminated or significantly be culled back.
Any animals used in experimentation be given the same protection as humans, i.e., IRB evaluations and full disclosure to the public with 24/7 live cameras on each animal both in its cage during awake, sleep, feeding, and other physiological care. Additionally, video observation of the actual experimentation including the use of chemical and physical restraints, impairing the animal with alcohol/drugs via forced nasogastric tubes, injections, sample taking, and the euthanasia as well as during the necropsy of the animal. The clandestine “behind closed doors” must stop.
Cindy Tait, EMT-P, RN, PHN, MPH
Director, Center for Healthcare Education, Inc.
I am pleased that the NIH is convening a workshop on primate research. I ask that the workshop organizers consider including an agenda item related to the retirement of nonhuman primates to sanctuaries after they have been used in research. I have long been troubled by the fact that in nearly all protocols involving primates, the animals are euthanized—even in cases where the animals’ tissues will not be harvested for analysis following the experiments. It seems that euthanasia is carried out as a matter of expedience, without consideration to the fact that the primates involved could be retired to a sanctuary. At sanctuaries, monkeys would be permitted to enjoy the rest of their days living in socially and environmentally enriched environments, just being monkeys. While relocating nonhuman primates to sanctuaries after they have served in research is the ethically appropriate action in cases where there is no scientific justification for euthanizing the animals at the termination of the experiments, this approach also benefits the morale of laboratory staff and researchers. Grant proposals should include funds for the eventual retirement of monkeys; and the NIH should develop policies aimed at ensuring that costs associated with retiring monkeys to sanctuaries are included in allocated grants.
Kerwin, A. M. (2006). Overcoming the barriers to the retirement of old and New World monkeys from research facilities. Journal of Applied Animal Welfare Science, 9(4), 337-347.
Dr. Nora J. Johnson, MBA, MS, Psy.D., University of Pennsylvania
Integral to a discussion on the ethics of primate research is consideration of ethical concerns related to the purchasing of primates and the retirement of primates (the “before and after” aspects of research). Thousands of primates are imported each year from what have appropriately been termed “monkey factory farms” in southeast Asia; monkeys are also captured from the wild in Mauritius. These monkeys spend days in transport, enduring considerable stress as they are held in small crates and their food and water intake is restricted. Research has documented that it takes months for the monkeys’ physiological systems to return to baseline levels (1, 2). Once these monkeys arrive at our shores, they are warehoused in facilities like Primate Products, Incorporated, where the NIH’s own investigation (following a PETA investigation) uncovered serious noncompliances with federal guidelines—including inadequate veterinary care and failure to conduct surgeries aseptically. A discussion on ethical use of primates should certainly be concerned with the primate transport pipeline and the primate supplier’s history with respect to animal welfare.
1. Honess, P. E., Johnson, P. J., & Wolfensohn, S. E. (2004). A study of behavioural responses of non-human primates to air transport and re-housing. Laboratory Animals, 38(2), 119-132.
2. Kagira, J. M., Ngotho, M., Thuita, J. K., Maina, N. W., & Hau, J. (2007). Hematological changes in vervet monkeys (Chlorocebus aethiops) during eight months’ adaptation to captivity. American journal of primatology, 69(9), 1053-1063.
Dr. Hanan Bassyouni, MD, Clinical Assistant Professor, Faculty of Medicine, University of Calgary
The work done by the NIH and the Institute of Medicine (IOM) in scrutinizing the scientific necessity of continuing to use chimpanzees in biomedical and behavioral research revealed that harmful intramural and extramural research continued to be approved, funded, and conducted for years even though there were alternative methods in virtually every area where chimpanzees were being used invasively. The NIH and IOM reviews of chimpanzee research effectively underscored serious limitations in the current animal research review system. This same problem of impoverished review processes currently exists in the oversight of experiments involving other animals—resulting in the approval, funding, and execution of harmful experiments on animals where other methods might have been used. Reviews of protocols involving nonhuman primates should be more rigorous and standards for evaluating harms and benefits should be raised. Important articles have been written on this aspect of oversight (1, 2, 3) and these should be discussed in the NIH’s workshop on oversight of research involving nonhuman primates and steps should be implemented to reform oversight of primate research.
1. Wendler, D. (2014). Should protections for research with humans who cannot consent apply to research with nonhuman primates? Theoretical medicine and bioethics, 35(2), 157-173.
2. Ferdowsian, H., & Fuentes, A. (2014). Harms and deprivation of benefits for nonhuman primates in research. Theoretical medicine and bioethics, 35(2), 143-156.
3. DeGrazia, D., & Sebo, J. (2015). Necessary conditions for morally responsible animal research. Cambridge Quarterly of Healthcare Ethics, 24(4), 420-430.