Peggy Cunniff, NAVS

NIH was asked “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[emphasis added].

We have concerns that this intention is not being addressed based on language present in the NIH workshop announcement, which presumes that “the oversight framework for the use of non-human primates in research is robust and has provided sufficient protections to date.”

NIH should not begin the process of review with the assumption that nonhuman primate experimentation is justified.

This workshop was scheduled because a review of maternal deprivation studies, prompted by experts and animal advocacy organizations, resulted in research protocols being modified and procedures eliminated. Congress, in requesting this review, intends that NIH conduct a careful examination of current nonhuman primate use that includes bioethicists and primate behaviorists. This workshop should include an examination of the kinds of research that use primates, current ethical policies and processes, the number and source of primates, the direct and indirect costs, and an examination of alternatives to the use of primates. The statements of all participants, findings and recommendations should be made public.

NAVS recommends that the following experts participate in the workshop:

David DeGrazia

Brian Hare

Steven Ross

Adam Shriver

Thank you for your consideration.

-Peggy Cunniff, National Anti-Vivisection Society

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