Tag: ethics

Andrew Fenton, PhD

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.

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Nathan Nobis, PhD

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

Hope Ferdowsian, MD, MPH

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. [1] 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. [2] Results were reported in multiple publications, including a special issue of Theoretical Medicine and Bioethics called Rethinking the Ethics of Research Involving Nonhuman Animals. [3] 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. [4] 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. [5] I urge you to consider factors such as these in your deliberations.

Please see the following links for reference:

1. http://www.nytimes.com/2016/09/04/opinion/sunday/second-thoughts-of-an-animal-researcher.html?_r=0
2. http://www.nsf.gov/awardsearch/showAward?AWD_ID=1058186&HistoricalAwards=false
3. http://link.springer.com/article/10.1007/s11017-014-9291-7
4. http://www.ncbi.nlm.nih.gov/pubmed/24627264
5. http://petrieflom.law.harvard.edu/resources/entry/special-issue-rethinking-the-ethics-of-research-involving-non-human-animals

Kathy Guillermo comment on NIH Blog

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.

L. Syd M Johnson, PhD

The mandate from Congress was for the NIH to “critically evaluate the ethical policies and processes surrounding all nonhuman primate research” and to do so “in consultation with outside experts, to ensure it has appropriate justification for animal research protocols…” This mandate clearly signals an expectation that the ethics of continuing to use nonhuman primates (NHPs) in biomedical research will be up for debate. In announcing its September 7 workshop, the NIH signals it will not examine the ethics of research with NHPs – which would reasonably include considering whether such research can be justified at all — but will rather maintain the status quo and evade the Congressional mandate with respect to the use of NHPs. This intent is clearly indicated in the blog post “Ensuring Continued Responsible Research with Non-Human Primates,” which maintains that current welfare regulations are adequate, and that the continuation of NHP research should be ensured, based on past (sometimes long past) contributions to science.

The NIH appears unwilling to engage in critical self-reflection or ethical discussion, or to consider the actual meaning of “responsible research.” Given current, well-supported empirical evidence about NHPs, it cannot be responsible or ethical to rely on outdated, poorly informed animal welfare regulations, or to justify NHP research by looking to the past. The NIH must be impartial and forward-looking, both in its science and its ethics, so that it might support the best biomedical research and maintain the highest ethical standards. This mandate is an opportunity for the NIH to do both, by convening ethicists – as the IOM did in its report in its 2011 report on chimpanzees – to participate in honest, impartial discussion of ethical and responsible science involving NHPs.

L. Syd M Johnson, PhD
Department of Humanities, Michigan Tech

Amber Barnes, AAVS

We endorse the request by Congress for the NIH to “review ethical policies and processes for appropriate justifications” for research involving NHPs. We commend the NIH for seriously considering this important matter.

However, we question whether the discussion questions listed in the agenda will adequately address the request to review NIH ethical oversight. In particular, the current questions listed for the second group discussion are factual descriptions that could be covered during the preceding presentation. Questions that elicit more valuable information and international insight, and better align with Congressional intent, should be considered.

We recommend the questions, 1. “What is the global state of ethics and new thinking about animals, and how can we apply this to the use of NHPs in research?” 2. “Given the cognitive abilities of and capacity for suffering in NHPs, is there a need for additional levels of review beyond IACUC and NIH committees to consider ‘justification’?” 3. “Could review by a multi- disciplinary team, particularly ethicists, provide more rigorous assessment?”

Dr. Wolinetz’s blog stated, “periodically reviewing agency policies and processes ensures that this framework (referring to welfare measures) evolves in a manner consistent with emerging scientific opportunities and public health needs.” Yet it must also evolve ethically. Internationally, the field of ethics has made tremendous strides since current policies have been in place. An open discussion and analysis of our evolving ethics and knowledge regarding the cognitive abilities and capacity for suffering in NHPs would be most productive and fulfill the congressional intent.

Amber Barnes, Policy Analyst, AAVS

NIH Publishes Draft Agenda

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?