Tag Archives: NIH

FASEB report makes recommendations for animal research regulations

On October 24, a group of professional scientific organizations released a set of groundbreaking recommendations entitled, “Reforming Animal Research Regulations: Workshop Recommendations to Reduce Regulatory Burden.” This report is the result of an April 17, 2017 workshop organized by the organizations: The Federation of American Societies for Experimental Biology (FASEB), the Association of American Medical Colleges (AAMC), and the Council on Governmental Relations (COGR), with assistance from the National Association for Biomedical Research (NABR). The goal of the April workshop was “to provide actionable recommendations for promoting regulatory efficiency, animal welfare, and sound science.

The workshop was convened, in part, in response to the 2016 passage of the 21st Century Cures Act (Cures), which directs leadership of the National Institutes of Health (NIH), the United States Department of Agriculture (USDA), and the Food and Drug Administration (FDA) to “complete a review of applicable regulations and policies for the care and use of laboratory animals and make revisions, as appropriate, to reduce administrative burden on investigators while maintaining the integrity and credibility of research findings and protection of research animals” within two years of the bill’s enactment (which occurred on December 13, 2016).

The recommendations in the report are directed to federal agencies that are involved in the oversight of federally funded animal research, particularly the NIH and the USDA. The recommendations stem from the workshop’s identification of requirements that demand significant administrative effort without demonstrating enhanced animal welfare. Thus, the recommendations consist of steps that agencies and Congress can take to reduce these inefficiencies.

A Veterinary Technician works with rodents

The aim of the report is to find ways of maintaining animal welfare while reducing administration

Speaking or Research applauds the thorough and thoughtful process of deliberation this group of organizations went through, as well as the transparency provided in the report. We believe that such transparency will allow for a public discussion of the system and of the potential for improvement. Here, we provide a high-level summary of the recommendations. The full report and set of recommendations are freely available at FASEB’s website.

The Major Recommendations are geared toward several major governing and oversight bodies: 1) The Executive Office of the President and Congress, 2) Both the NIH and USDA, and 3) the NIH and USDA separately.

1. Recommendations to The Executive Office of the President and Congress

The Executive Office of the President (EOP) and the Office of Management and Budget (OMB) should consolidate animal research oversight under a single Federal office or entity with one primary set of regulations and guidance documents. A committee of experts engaged in animal research, comprised of institutional administrators, Institutional Animal Care and Use Committee (IACUC) members, investigators, and veterinarians, should be invited to assist with this consolidation effort.

The EOP and OMB should require at least a 60-day comment period on the merits and impact of any proposed policies, guidance documents, frequently asked questions (FAQs), or interpretive rules before they are issued. Final policies and guidance should reflect germane comments received from the regulated community.

Congress should amend part of the Animal Welfare Act (AWA) to require only annual inspection by the IACUC, and should revise the requirement for annual USDA inspection.

2. Recommendations to both the NIH and the USDA

Appoint an external advisory group of experts engaged in animal research, from entities that receive federal research funding, to serve as advisors. The advisory group should include institutional administrators, IACUC members, veterinarians, and investigators engaged in animal research.

Have all Public Health Service (PHS) and USDA regulations, policies, guidance documents, FAQs, and interpretive rules, as well as the process for generating them, reviewed by an external advisory group of the very experts engaged in animal research (from entities receiving federal funding). As above, this group should consist of institutional administrators, IACUC members, veterinarians, and investigators engaged in animal research. This review will ensure that the documents emphasize matters of core importance to animal welfare identified in the regulatory language, and that they are consistent with current scientific and technological knowledge and approaches.

Establish a risk-based process for review of animal research protocols, similar to that which is used for human subjects research. Through a Notice in the Federal Register, NIH and USDA could amend the protocol review requirement to define types of studies that are low-risk, noninvasive, or minimally invasive. These studies could then be subject to less stringent review criteria than higher-risk, more invasive studies.

3a.    Recommendations to NIH

Use the Guide for the Care and Use of Laboratory Animals (Guide) as it was intended – as a guide, not as a regulatory document. IACUC-approved strategies stemming from recommendations in the Guide should not be not be required to be included in semiannual reports to the Institutional Official.

Eliminate the requirement for verification of protocol and grant congruency in the NIH Grants Policy, so as to allow for reasonable advances, discoveries, and other developments in overall research objectives.

Revise NIH guidance regarding prompt reporting to include only those incidents that jeopardize the health or well-being of animals.

Streamline the assurance for animal research. For Category 1 institutions, allow proof of accreditation in lieu of the detailed program description.

3b.   Recommendations to USDA

Revise the relevant section of the AWA to specify IACUC reviews of animal research protocols at least once every three years, and at appropriate intervals as determined by the IACUC. This modification would make review frequency consistent with PHS Policy.

Revise the USDA Animal Care Policy #14 to reflect the language that exists in the AWA and the AWA Regulations (AWR), so that multiple survival operative procedures may be allowed at the discretion of the IACUC and as justified for scientific and animal welfare reasons. This modification will aid the research community in reducing the number of animals involved in research.

Align language in the USDA Animal Care Policy #12 with respect to literature searches with language in the AWR that charges the IACUC to determine “that the principal investigator has considered alternatives to procedures that may cause more than momentary or slight pain or distress to the animals, and has provided a written narrative description of the methods and sources…”

We urge people to read the report and come to their own conclusions. If you have any thoughts on the recommendations made, please do share them in the comment section.

NIH Director reaffirms importance of animal experiments

Francis Collins, Director of the NIH, was interviewed by the Washington Examiner earlier this week. One question asked what he thought about animal research, to which Collins provided a thoughtful and considered answer.

Washington Examiner: PETA came out this year supporting budget cuts to the NIH, saying that cutting testing on animals would achieve significant savings. What can you tell us about where animal testing stands?

Collins: I think NIH is very focused on making sure that animal studies are done in the most ethical way possible, but also very convinced there are things we can learn from animal studies that will help people with terrible diseases that we otherwise can’t quite learn. We are certainly moving a lot of the kind of research that we used to do in animals into other systems, particularly with human cells that can be grown in a laboratory in a fashion that causes no pain to anybody and doesn’t result in such a great need for animals. But animals are still crucial to our understanding of how biology works. Anybody who has looked at the kind of oversight that applies to that I think will be impressed by how much attention goes toward any protocol that we fund that is going to involve animals for research. It has to have veterinarians and members of the public looking constantly at the conditions under which the animals are cared for and how we do everything possible to avoid the creation of unnecessary pain.

No doubt Collins is tired of PETA’s nonsense – in 2015 they wrote letters to all his neighbors in an effort to pressure him to stop the work of an individual researcher. We applaud Collins for defending animal research to the Washington Examiner and hope he continues to protect vital research in the future.

Open letter: Private workshop on the “necessity” of monkey research does not represent broad public interests or the scientific community

This weekend there will be science marches around the globe. Scientists and science proponents will gather to provide a visible sign of support for work that benefits the public, the environment, and the world in innumerable ways. The march has been highly publicized  – rightfully so, because it serves as a reminder that scientific research and scientists can be threatened in a variety of ways that can have consequences with breadth and depth that should be of concern for society as a whole.

This week there will also be another event that has potential for consequences for science and public health. But it is neither a public event, nor one that has been publicized.

The private event is a workshop titled, “The necessity of the use of non-human primate models in research.” The workshop is supported by Johns Hopkins University and is organized by Prof. Jeff Kahn in the Berman Institute for Bioethics, with participants that include philosophers, bioethicists, a leader of the Humane Society of the US, veterinarians, and scientists– all by invitation only (see roster in workshop agenda below). Its stated goals and approach are: “To help address the issues of the use of NHPs in research, we are convening this working group to examine the science, ethics, and policy aspects of the use of NHPs in biomedical and behavioral research and testing, with the goal of identifying consensus findings, conclusions, and recommendations. The focus of the working group will be to evaluate the current and potential future uses of NHP models, drawing on the approach used in the 2011 IOM Report “Chimpanzees in Biomedical and Behavioral Research: Assessing the Necessity” (IOM, 2011).

The group lists as their objective: “The product(s) of the working group process will be a report or series of reports based on the working group’s expert analysis, which will include principles and criteria for assessing the necessity of the use of NHPs in research.” (emphasis added)

Detail is here: Animal Working Group Meeting 1 Briefing Book

In other words, the working group, privately convened, is intent on replicating the 2011 IOM process applied to chimpanzees in order to produce their own principles and criteria for assessing nonhuman primate research broadly. This process should cause grave concern for scientists and for the public who rely on research conducted with nonhuman primates.

The scientific community has publicly weighed in on the necessity of primate research. Most recently, the National Institutes of Health convened a working group to consider nonhuman primate research and concluded “that the oversight framework for the use of non-human primates in research is robust and has provided sufficient protections to date.” Similarly, a letter from over 400 scientists, including Nobel Laureates, rejected a claim from notable public figures that neuroscience research with non-human primates is no longer useful. The hundreds of scientists argued that, “primate research was still critical for developing treatments for dementia and other debilitating illnesses.” (https://www.theguardian.com/science/2016/sep/13/brain-experiments-on-primates-are-crucial-say-eminent-scientists)

Consideration of the ethical justification for research and of the care for animals in research occurs at many levels and in public space. Public health, including the interests of patients and of society as a whole, is integral to those decisions. The scientific community provides expert knowledge about what types of studies are needed for progress in the basic understanding of biology, brain, behavior, and disease and also about how to move forward with new prevention, intervention, and treatment to address health challenges. Funding agencies, such as the National Institutes of Health, are charged by the public to make decisions about science and do so through a process that involves multiple layers of expert review. Federal agencies also oversee research and standards of care for humans and animals involved in studies and provide opportunities for the public to comment on standards and to benefit from decisions.

The private workshop has the appearance of being secretive while also directly opposing the processes in place for responsible public decision-making. As such, it appears to be yet another attempt to influence decisions about science without adequately representing either public interests or the breadth and depth of expertise in the scientific community. Without adequate scientific representation the workshop conclusions cannot be taken as adequately representative of the current state of scientific knowledge. Without adequate representation of the public agencies that safeguard societal interests in scientific and medical progress the workshop conclusions cannot be taken as representative of fact-informed, balanced consideration of research.

Finally, without consideration informed by understanding the fundamental characteristics of the scientific process, the workshop conclusions will only reflect an agenda biased to reach a particular conclusion. As it is framed, it appears that the question of “necessity” is one that cannot account well for the role of basic research, of uncertainty, and of the difference between decisions based in a particular set of values and decisions about the best scientific course of action to answer questions and advance understanding of human and animal health.

For all of these reasons, the reports emanating from this private workshop must be critically examined with healthy skepticism, rather than taken as an authoritative account. We remain concerned that the products of a workshop will serve to advance an agenda that is harmful to public interests in scientific research.

[Note:  If you would like to sign on to this letter please add your name to the comments].

Signatories,

Christian Abee, DVM, DACLAM, Professor and Director, Michale E. Keeling Center for Comparative Medicine and Research, Univ. of TX MD Anderson Cancer Center

Jeremy D. Bailoo, PhD, University of Bern

Allyson J. Bennett, PhD, University of Wisconsin-Madison (Member and former chair, American Psychological Association Committee on Animal Research Ethics)

Michael J. Beran, PhD, Psychology Department and Language Research Center, Georgia State University

James Champion, Morehouse School of Medicine

Julia A. Chester, Ph.D., Associate Professor, Department of Psychological Sciences, Purdue University

Linda C. Cork, D.V.M, Ph.D, Emeritus Professor of Comparative Medicine, School of Medicine, Stanford University  (Senior member of the National Academy of Medicine;  Diplomate of the American College of Veterinary Pathologists)

Robert Desimone, Ph.D., Director, McGovern Institute for Brain Research at MIT, Doris and Don Berkey Professor of Neuroscience

Doris Doudet, PhD, University of British Columbia

Marina Emborg, MD, PhD, Associate Professor, Department of Medical Physics; Director, Preclinical Parkinson’s Research Program, Wisconsin National Primate Research Center, University of Wisconsin-Madison

Lynn Fairbanks, PhD, Emeritus professor, Department of Psychiatry & Biobehavioral Sciences, Semel Institute, UCLA

Charles P. France, Ph.D., Professor, University of Texas Health Science Center-San Antonio

Patrice A. Frost, D.V.M, President of, and signing on behalf of, the Association of Primate Veterinarians

Michael  E. Goldberg, MD,  David Mahoney Professor of  Brain and Behavior in the Departments of Neuroscience, Neurology, Psychiatry, and Ophthalmology
Columbia University College of Physicians and Surgeons,  and Senior Attending Neurologist, New York Presbyterian Hospital. (Past chair, Society for Neuroscience Committee on Animal Research)

Katalin M. Gothard, MD, PhD, Professor of Physiology, The University of Arizona

Kathleen A. Grant, PhD, Professor, Oregon National Primate Research Center

Sherril Green, DVM, PhD, Professor and Chair, Department of Comparative Medicine, Stanford Medicine

Nancy L. Haigwood, PhD, Director and Professor, Oregon National Primate Research Center, Oregon Health & Science University

Keren Haroush, PhD, Assistant Professor, Department of Neurobiology, Stanford University

William D. Hopkins, PhD, Professor of Neuroscience, Neuroscience Institute, Georgia State University

J.David Jentsch, PhD, Professor of Psychology, Binghamton University

R. Paul Johnson, MD, Director, Yerkes National Primate Research Center

Joseph W. Kemnitz, Ph.D., Professor, University of Wisconsin-Madison

Robert E. Lanford, PhD, Director, Southwest National Primate Research Center, Texas Biomedical Research Institute

Kirk Leech, Executive Director, European Animal Research Association

Jon Levine, PhD, Director, Wisconsin National Primate Research Center; Professor of Neuroscience, University of Wisconsin-Madison

Alexander Maier, Ph.D., Assistant Professor, Department of Psychology, Vanderbilt University

Juan Carlos Marvizon, PhD, Adjunct Professor, David Geffen School of Medicine at UCLA

Earl K. Miller, Ph.D., Picower Professor of Neuroscience, The Picower Institute for Learning and Memory and Department of Brain and Cognitive Sciences at the Massachusetts Institute of Technology

John H. Morrison, PhD, Director, California National Primate Research Center, Professor, Department of Neurology, School of Medicine, University of California Davis

Michael Mustari, PhD, Director, Washington National Primate Research Center and Research Professor, Department of Biological Structure, University of Washington

J. Anthony Movshon, University Professor and Silver Professor, Center for Neural Science, New York University

William T. Newsome, Harman Family Provostial Professor, Stanford University, Vincent V.C. Woo Director, Stanford Neurosciences Institute
Investigator, Howard Hughes Medical Institute

Melinda Novak, PhD, Professor of Psychological and Brain Sciences, University of Massachusetts Amherst

Kimberley A. Phillips, PhD, Professor of Psychology and Co-Director of Neuroscience, Trinity University; Affiliate Scientist, Southwest National Primate Research Center, Texas Biomedical Research Institute

Peter J. Pierre, PhD, Behavioral Services Unit Head, Wisconsin National Primate Research Center, University of Wisconsin-Madison

Dario Ringach, PhD, Professor of Neurobiology and Psychology, University of California Los Angeles

Marcello Rosa, PhD, Professor of Physiology, Monash University, Melbourne, Australia

James Rowlett, PhD, University of Mississippi Medical Center (Chair, American Psychological Association Committee on Animal Research Ethics)

Mar Sanchez, PhD, Associate Professor of Psychiatry and Behavioral Sciences, School of Medicine; Yerkes National Primate Research Center, Emory University (Chair, Society for Neuroscience Committee on Animal Research)

Jeffrey D. Schall, Ph.D., Bronson Ingram Professor of Neuroscience, Department of Psychology, Department of Ophthalmology & Visual Sciences, Director, Center for Integrative & Cognitive Neuroscience, Department of Psychology, Vanderbilt University

Igor I. Slukvin, MD, PhD, Wisconsin National Primate Research Center, University of Wisconsin-Madison

David A. Washburn, PhD, Professor of Psychology, Georgia State University

Robert Wurtz, PhD, Scientist Emeritus, National Institutes of Health

 

Public dialogue about US research chimpanzee retirement: Unanswered questions

Growing concerns about NIH’s plan for retired research chimpanzees summarized in a WIRED article last week continue to provoke more questions than answers. These questions fall into three general areas discussed below. In many cases, they are questions that could stem simply from a lack of transparent, public information. One example of this is found in the reported deaths of nine chimpanzees within 18-months of transfer to the federal sanctuary, Chimp Haven. Whether the number of deaths is higher than expected given the age, health, and average mortality rates for chimpanzees is unclear and has not been addressed with public, factual information about what happened to those nine animals.

Similarly missing is information needed for serious consideration and public dialogue about the plan for relocating chimpanzees; continuing research with retired chimpanzees; and the processes and standards in place for chimpanzee care, external oversight, and public transparency across different types of facilities. Rather than addressing these questions, some have instead simply dismissed “the lab community” as unfair critics of the federal sanctuary (for example, Chimp Haven’s CEO).  That response fails to answer what should be common concerns not only across the many communities that care about chimpanzees, but also more broadly to the public that ultimately provides support for the animals, the research, and the policies that set the framework for decisions that govern chimpanzee care across the many facilities in which they live.

Three sets of questions—largely unanswered—that are integral to informed, serious, public consideration of the future of US chimpanzees are summarized below. They are:

Photo credit: Kathy West

Photo credit: Kathy West

  • Chimpanzee health and well-being: Is everything that can be done to ensure the best care, health, and well-being of the chimpanzees being done?
  • Research:  Should federally-supported retired research chimpanzees within sanctuaries be involved in research?
  • Decisions and evidence: What is the process for decision-making?  How are conflicts of interests handled?  What kind of evidence supports the decisions about chimpanzee health and well-being?

1)  Chimpanzee health and well-being: Is everything that can be done to ensure the best care, health, and well-being of the chimpanzees being done?

First and foremost are questions about the animals’ health and well-being.  The primary question here is whether relocation is the best option for all of the chimpanzees. A number of posts here have provided detail about the issue. The main consideration is whether decisions about the transfer of chimpanzees from their current homes to a new home are adequately informed to ensure the best outcome for each animal. Of particular concern is whether there is a process for examining previous outcomes in order to identify whether changes are needed.

The latter is exactly why the deaths of 9 of 13 chimpanzees transferred from the National Center for Chimpanzee Care (Bastrop) to the federally-supported sanctuary, Chimp Haven, continue to raise questions.  The questions are not—as has been repeatedly emphasized—about the quality of care at Chimp Haven. Nor are they about population-level mortality analysis as was conducted and reported in a yet-to-be-reviewed manuscript posted by a scientist at NIH (see below for further discussion). Rather, as would be the case in most facilities that operate under federal license or registration with the USDA,  the question is whether the circumstances surrounding those deaths has been reviewed carefully and thoughtfully in order to inform future practices and decisions in a way that minimizes future risk and ensures the best outcomes for the chimpanzees. For example, it would be logical to ask whether the circumstances surrounding the deaths were examined by the USDA, or whether NIH commissioned, or requested, any evaluation of the deaths. This would be common procedure in any facility subject to USDA oversight.

Chimpanzees in research, zoo, and sanctuary facilities

Chimpanzees in research, zoo, and sanctuary facilities

Consideration of decisions about relocation goes far beyond these nine deaths, however. There are a number of factors that inform concerns about the plan to transfer chimpanzees from their current homes. Among them: 1) the animals’ age and health; 2) the consequences of relocation, including disruption of existing social groups and separation from long-time environments and caregivers, introduction into novel environments, with novel caregivers, and chimpanzees; 3) the time-span over which the transfers will occur.

All of these factors underlie questions about the end result of the recently announced plan to move all NIH-owned and supported chimpanzees to Chimp Haven over the next 10 years. As summarized by a commenter on our previous post:

“I have read with bewilderment the recent NIH announcement about their plan to retire the remaining chimpanzees housed at Alamogordo, Bastrop and Southwest Foundation and the press release from HSUS applauding the plan and their appreciation of all the effort by Dr. Collins and NIH have made to implement the plan. Why should anyone be excited about this plan? From what I read, their plan is attrition. For presumably the next 10 years, NIH is going to watch and monitor the chimpanzee mortality rate at Chimp Haven and fill the vacancies with chimpanzees currently residing at APF, Bastrop and then Southwest (the NIH preferred order). How can attrition and replacement be considered a reasonable and humane retirement plan by either the research community or animal welfare advocates?”

2) Research: Should federally-supported retired research chimpanzees within sanctuaries be involved in research? 

The announcement of a partnership with the Lincoln Park Zoo, funded by a private agency (Arcus Foundation), apparently part of broader effort to promote research with chimpanzees at the federally-funded retirement facility raised a host of questions. On the one hand is the obvious question about why chimpanzees retired from research should be the source of fundraising in order to conduct research (see here). The very definition of sanctuary and what differentiates a sanctuary from a zoo or a research facility was also raised by the announcement (see here).

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Photo credit: Kathy West

There are many who do support ongoing behavioral, psychological, cognitive, genomic, neural and other noninvasive research. This is the very same conclusion that was reached by the Institute of Medicine committee that reviewed the necessity of chimpanzee research (see report here). But the announcement of a research program at Chimp Haven raised many questions about how the research conducted there now, and in the future, will be overseen. For example, in contrast to well-established and transparent practices for decisions about NIH, NSF, or other federally-funded research, there appears to be little public information about the process for research approval and conduct of research at Chimp Haven.

The broad questions surrounding research at Chimp Haven are whether information about the review, oversight, and transparency of research projects is available and where it can be found. Moreover, the announcement that the sanctuary intends to recruit scientists and more research raises questions about whether there should be further consideration and open dialogue about whether the processes put into place by the private facility are appropriate for research conducted with animals who receive 75% of their support from federal sources.

Questions include: What is the process for deciding whether, and which, research projects are conducted with federally-supported chimpanzees within the sanctuary? What are the mechanisms for external oversight, transparency, and ethics review of the research proposals? How are perceived and actual conflicts of interests handled? The answer to these questions at present appears to be that Chimp Haven has a review board that operates as an Institutional Animal Care and Use Committee (IACUC) for the facility. In general though, there is not enough information about process to inform serious and thoughtful consideration. For example, among other questions, it is not clear that the facility has a scientific merit review or a mechanism to guard against conflicts of interests or to promote equitable access.

3)  Decisions and evidence: What is the process for decision-making?  How are conflicts of interests handled?  What kind of evidence supports the decisions about chimpanzee health and well-being?

A third set of questions that have become of increasing concern as events, decisions, and announcements about chimpanzee retirement unfold surround processes for decision-making. Again, the issue here is about unanswered questions in response to community concern and public interest. The two previous points highlight a number of questions rooted in “process.” Most recently, the issue of what kinds of evidence should be used to inform decision-making was put into sharp relief by the appearance of an analysis of chimpanzee mortality across dedicated research centers and the federal sanctuary. That report was posted online, ahead of peer-review or publication in a scientific journal, and the day before NIH’s announcement that all NIH-owned chimpanzees would move to Chimp Haven over a 10-year period.

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Photo credit: Kathy West

While it may not be entirely clear to those outside the scientific community, the online article had not been subjected to review – either via comments online, in an open-access venue, or by expert peer-review. Peer-review  is normally conducted by scientific journals and is part of online publication as well.  Peer review is an important part of the scientific process. In brief, the purpose of such review is to identify potential flaws in the study design, analysis, or interpretation of the data. The process of review then requires the author to address criticisms. In some cases, the criticisms are rebutted and the paper improved by clarifications. In other cases, the criticisms cannot be rebutted because the study, analysis, or interpretation is flawed.

What is important to remember is simple. Confidence in the conclusions of a study, particularly one for which criticisms have been raised and not yet addressed, should be measured accordingly. Yet, already the conclusions of this article have been cited as “proof” for a position about relocating chimpanzees. For example, in a posting from the Jane Goodall Institute:

“As animal transfers are sometimes considered potentially harmful, it is satisfying to note it was found that there is no proven link between relocation and premature death of captive chimpanzees.

In fact, the article cited does not substantively address the claim. Rather, as chimpanzee research expert, Professor William Hopkins, points out, “the analyses performed in the study are not designed to test for a “link” between relocation and premature death. As others have noted, this would require an analysis of the mortality rate of chimpanzees transferred to Chimp Haven be compared with age-sex matched apes that are not transferred. These kinds of comparisons that are necessary to make these inferences are absent in the paper as it is currently written.”

Thus, not only do a number of questions and criticisms of the article remain unanswered, but it is also true that the mortality analysis does not address the fundamental point for which it is being cited as supporting. What the analysis does appear to show is that many – perhaps most—of the retired chimpanzees are likely to die before they are transferred. From data presented in Figure 4 of the paper, it appears that roughly 20% of the chimpanzee population would be predicted to die within 3 years and that less than 40% will be alive in 9 years. By extension, of the animals who are now slated to move within the 10 year period announced by NIH, it could be the case that only 30% will be alive at that point. Again, however, conclusions based on this analysis should be viewed with caution. Nonetheless, if this interpretation were true then it would seem that the majority of chimpanzees will, in fact, remain in their current homes for a substantial amount of time. In turn, several considerations and new discussions of alternatives might be raised– as they were in comments that we will return to in a subsequent post.

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Chimpanzees at NCCC. Photo credit: Kathy West.

Furthermore, the NIH plan and discussion surrounding it has yet to reveal how the mortality analysis will inform decisions at the level of the individual chimpanzee. Given that age is nearly certain to be the biggest mortality predictor, the question is whether the oldest animals will be the least or the most likely to move first? In the NIH plan, age is ranked ahead of existing social group as a consideration for priority in relocation to sanctuary. The question there is – given social groups are generally comprised of animals of mixed ages—will groups be prioritized for movement based on the age and health of the oldest members?

Decisions about the priority order for moving chimpanzees are undoubtedly incredibly difficult and must account for complicated sets of factors. Whether there should be transparency in those decisions, at the level of the individual animals, is one of the main questions that arose in discussion of the deaths of 9 NCCC chimpanzees transferred to the federally-funded sanctuary. It arose for the simple reason that Chimp Haven’s CEO, in defending her facility, raised pointed questions about the decision to transfer particular animals. She claimed:

“…the selection of the individuals to be transferred was not made by Chimp Haven, or even The National Institutes of Health, but by the laboratory itself.  In fact, Chimp Haven has never had a say in selecting any individuals for retirement despite the fact that we have advocated for such a role to ensure that these retirement transfers were best planned and operated. So one might reasonably question why several of the transferred chimpanzees were placed on “quality of life” watch prior to transfer. Or why most of the transferred chimpanzees were well beyond the median life expectancy for the species.”

Whether this is true or not cannot be easily – if at all– discerned by the public. Why? Because the process of decision-making is mostly not transparent in public view. As a result, competing claims cannot be fully evaluated with any serious, thoughtful consideration by members of the public, nor by the media, policy-makers, or members of the research, sanctuary, and zoo communities. Nor does it appear that there is any mechanism for unanswered questions to be addressed. There are many things that are troubling about the situation. From the perspective of dialogue and community efforts to guide decisions in the best interests of the animals’ health and well-being, research, and public support, the continuing lack of response to questions or perceived criticism is among the largest of the obstacles to progress and understanding.

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Photo credit: Kathy West

Summary.  One of the goals of Speaking of Research is to provide a place for public dialogue about ongoing events, perspectives, and consideration of animal research. We hope that the questions posed above might help move the dialogue forward with answers to questions that remain unaddressed and information that can fill gaps in public knowledge. In turn, the answers may help provide a better understanding of the situation and a more thoughtful, broad public consideration of the future for retired chimpanzees and for chimpanzee research.

Speaking of Research

What is science?

We learned today from an NIH announcement about a new plan by the federal agency to relocate and transfer all of the NIH-owned chimpanzees to the federally-funded sanctuary, Chimp Haven, by 2021 or later. The announcement was quickly the subject of announcements and proclamations of victory by PETA, HSUS, and some associated with Chimp Haven.

For others, in light of the concerns raised about the death of 9 of 13 chimpanzees transferred to Chimp Haven recently and subsequent calls for a thoughtful examination of these cases—at least a review of what might be done to minimize future risk—the announcement was troubling.

PETA on nih chimp announce 08.11.16It does appear that NIH either shared, or was at least responsive to the need to address, the concerns that were expressed about the consequences of relocation on the chimpanzees’ health and welfare. That is evidenced by the fact that NIH did undertake an analysis of mortality rates at Chimp Haven and the research centers that house NIH chimpanzees.  That is as it should be – scientists use data to inform decisions.  No problem there. NIH conducted the analysis on the basis of data requested from each of the centers. It also appears that they referenced the findings of the analysis in their decision.  So what’s the problem?

It appears that the only evidence of the mortality analysis is a non- reviewed paper that was posted just yesterday to a website (Biorxiv) by the study author, NIH’s Dr. Michael Lauer. tweet bioRxiv 08.11.16That paper may be viewed here. After even a cursory review and analysis of the Lauer paper, many questions are raised about both the methods and the conclusions drawn from the results.  Just a few of the issues or potential problems that an academic reviewer might raise are listed below. Others may read the paper and have different impressions or questions.The data includes 764 chimpanzees; 314 died during the 7 year median follow-up. The author states that: “The analyses were conducted to inform NIH’s plans to retire its surviving chimpanzees.”

To see NIH use data from an unpublished, non-peer reviewed manuscript as a basis for their decisions is incredibly disheartening. It defies the very premise and basis on which the scientific process works. Science doesn’t accept as fact those data and findings that are presented on the internet and that have not been properly vetted through the peer review process.  Image Biorxiv 08.10.16 LauerBut before turning to questions about the paper, let’s be clear on a critical point:  The questions and critiques raised here would be raised regardless of the conclusions of the paper and regardless of the direction of NIH’s decision. The questions raised here are at the heart of how science is used to inform decisions and judgments.  

In other words, what would we conclude if NIH had used a non-reviewed paper to suggest that relocation was a threat to chimpanzee well-being and that the chimpanzees should be retired in place?  The same criticism would hold.  The issue is about the conduct of science and how it should be shared and viewed in decision-making. In this case, it is particularly important because of the close relationship between the findings and decisions that have immediate and real impact. Furthermore, in a time where scientific rigor and reproducibility are the subject of a great deal of concern and discussion, it is even more troubling to see that the results of an unreviewed paper posted only yesterday in public  view are the basis for an announcement made today.

That means that there was no opportunity for a broader public consideration, for thoughtful analysis, for viewing the data, for asking questions about the approach, methods, analysis, interpretation of results, and conclusions.  Thus, we post here some initial questions and comments about the unpublished and unreviewed paper from several scientific reviewers. We hope others read the paper (here) and offer their comments, or offer additional insight into the approach, analysis, and conclusions.

To be clear, these comments are not designed to advocate for or against the transfer of chimpanzees to Chimp Haven. Nor are they designed to judge the quality of care the animals receive after arriving there. Rather, they are designed to illustrate the fact that decisions about the welfare of captive chimpanzees that are being made by NIH appear to be based on data and analyses that are arguably flawed, at least as presented in the current draft of the Lauer paper.  Dr. Lauer might have excellent responses and answers to these critiques, which may then validate the claims in the current paper.

And, that is the point: the data will then have been subjected to critical peer review, the bedrock of the scientific method. It is disappointing, and frankly, stunning, that NIH appears to have accepted these results without proper peer review. Making captive chimpanzee retirement and movement decisions based on these findings seems premature and foolish.  Sadly, that may lead to unnecessary deaths of chimpanzees. NIH is clearly committed to sending their chimpanzees to Chimp Haven; if that is the mandate, then why try to justify the decision based on methods and analyses that have not been subjected to the normal scientific peer review process?  That ultimately raises more questions than answers and stands to further confuse the public view of how science works and how claims should be evaluated.

Finally, we would also note that the data does not appear to be publicly available. In other words, while the un-reviewed article is in public view and its conclusions appear to have informed the decisions the data is not in view and cannot be evaluated or analyzed by scientists or others who are independent of the decisions and the centers involved.

Below are just a few issues, or potential problems, that any reviewer might point out.

  • The first part of the study was aimed at addressing mortality rates in chimpanzees housed at Chimp Haven compared to other facilities (Bastrop, Southwest Foundation and Alamogordo Primate facility). The author reported that age and sex had strong effect on mortality rates whereas location had only moderate effects. In point of fact, the influence of location was not a trivial effect based on the results presented in Table 2 but rather a statistically significant one.  The author seems to want to minimize the significance of the location effect because the overall p-value (p=.0173) was close to the significance level adopted in their analysis.  The effect for Chimp Haven was far below that, at p=.005. The problem, however, is that the argument for adjusting alpha as reported by the author was because they had 6 predictor variables, they therefore they increased alpha to control for possible Type I error. There are a number of issues here. First, it is not clear how the authors dummy coded the location variable. Second, even if there were 6 predictor variables, there were also more than 700 subjects in the study and thus whether the author had adequate power to guard against Type I error (and thus needed to adjust alpha below the traditional < .05) is not entirely clear without presentation of effect size or further rationale. In turn, to state that sex and age had strong effects and location had a moderate effect on mortality is simply not supported by any statistics other than the p-levels.
    Maynard at MD Anderson.

    Maynard at MD Anderson.

    The paper reports: “The strongest predictor, by far, of mortality was
    age (as calculated to be on January 1, 2005), followed by male sex and location. Older age predicted higher mortality (adjusted hazard ratio comparing animals 30 years versus 17 years 2.23, 95% CI 1.91 to 2.61); males also had higher mortality (adjusted hazard ratio 1.50, 95% CI 1.20 to 1.88). Location was only marginally associated with mortality (Wald c2=10, df=3, P=0.017). Compared to Chimp Haven, mortality was lower at APF (adjusted hazard ratio 0.65, 95% CI 0.48 to 0.88), while it was similar at Bastrop (adjusted hazard ratio 0.84, 95% CI 0.60 to 1.16) and almost identical at SNPC (adjusted hazard ratio 1.00, 95% CI 0.71 to 1.39).”

  • The second part of the paper was designed to examine the influence of relocation/transfer on mortality rates in the different chimpanzee populations. This aspect of the study is likely in response to recent reports of higher-than-normal rates of mortality in chimpanzees transferred to Chimp Haven but sadly neither the design nor data analysis allow for any meaningful conclusions to be drawn.  Specifically, there is no control or comparison group. According to the author, at Chimp Haven (CH), chimpanzees die as they get older and this isn’t due to factors such as when they arrived at Chimp Haven, the season of year, etc….but these analyses are irrelevant. What one would want to know is what the mortality rate is for chimpanzees that get transferred to CH compared to either: 1) chimpanzees that stay at their original facility and don’t transfer; or 2) mortality in chimpanzees that transfer INTO CH from a lab compared to mortality rates of chimpanzees that are transferred FROM CH to another facility or 3) mortality rates of chimpanzees that have been transferred INTO another sanctuary (e.g., Save the Chimps).  The second situation does not occur; however, the 3rd situation could be analyzed. Furthermore, there is a 4) mortality rates of chimpanzees that transferred FROM other facilities and INTO Bastrop.  None of these comparisons were made in the paper though they are necessary to make inferences about the effect of transfers on the quality of care and mortality. Thus, this entire part of the paper addressing the effects of transfer on mortality is fundamentally flawed. Of course, it is also recognized that in addition to the analyses, appropriate balancing of covariates that relate to the mortality for each of these four comparisons may be difficult, post hoc; however, the alternatives and limitations should be a feature of a carefully considered conclusion and discussion.
  • For the Chimp Haven sample, why were non NIH-owned chimpanzees excluded from the mortality analyses? Chimp Haven has taken chimpanzees from other facilities such as Ohio State, Yerkes and New Iberia. If the question is not about mortality rates at a given facility, but rather the effect of transferring individuals from established housing conditions, why exclude any individuals? Further, were the non NIH-owned chimpanzees included in the sample size census within Chimp Haven? In other words, in Table 1, it indicates that the Chimp Haven had 273 chimpanzees. Is that all the chimpanzees at CH, or only those that are NIH-owned? A reviewer might guess is that these numbers are based on the entire sample of chimpanzees at Chimp Haven but it is far less clear on the mortality numbers (107). Moreover, peer review would surely point out that the methods are not sufficient for reproducibility.
  • In Table 2, the most relevant comparison (at least in relation to the current issue, the transfer of NIH chimpanzees to CH) is starkly missing. Specifically, for location, Chimp Haven needs to be the reference group, so that comparisons of transfer from all other sites can be made. This is particularly strange as the text lists Chimp Haven as the reference group and interprets the data in this regard. If the point of this analysis is to inform the decision to transfer the animals to CH, vs retire-in-place, then the comparisons should be made with CH as the reference group so that we can see how it truly stacks up against leaving the animals where they are.

 

 

 

 

Heat or light? An Analysis of Chimp Haven’s Message

Earlier this week the president of Chimp Haven, Cathy Willis Spraetz, issued a rebuttal to “a number of articles and blog posts focusing on the retirement of federally-owned chimpanzees to Chimp Haven.” She identifies the goal of the open message as a response to address the “concerns and resistance from some in the laboratory community,” whom she described as increasingly direct and vocal.

Spraetz is correct that there are increasingly direct and vocal questions about the retirement of federally-owned chimpanzees. But rather than focusing on the serious and challenging questions that have been raised, or on the repeated calls for the communities involved to have a more thoughtful, fact-informed consideration of the topic, she instead frames the issue as a polarized situation in which the “laboratory community” is unjustifiably criticizing Chimp Haven. To do so, she provided a series of misinterpretations and inaccuracies of the articles and blog posts. We respond to some of those below, but also encourage people to read her letter in its entirety and to read recent posts and articles in order to evaluate the claims Spraetz makes. More importantly, we continue to urge people to step back from polarization and instead identify what information is needed and what considerations and actions should be taken in order to make the best decisions that balance the chimpanzees’ health and wellbeing.

The first issue the letter poses is that the Chimp Haven CEO, Spraetz, failed to include links to the original articles she aims to rebuke. That is problematic because the omission of the original sources prevents readers from reading what she interprets as “accusations” (Spraetz’s term) and forming their own opinions. Whether accidental or deliberate, such omission is irresponsible and should be corrected in the posting on the Chimp Haven site.

The omissions, in addition to the framing and language in the letter, do nothing to further thoughtful dialogue on the topic at hand – the welfare of retired research chimpanzees. What it does is distract from serious consideration with a fueling of the “Us vs. Them” rhetoric. In this case, the “Them” is the “laboratory community,” one that Spraetz seems to cast as unconcerned about chimpanzees’ health and welfare. Unfortunately many may buy into this message. Why? Because rather than taking a thoughtful look at the animals’ care, conditions, and actual outcomes, it is easier to simply argue that “labs” are bad and “sanctuaries” are good.

I encourage interested readers to take the time to thoroughly read the Spraetz piece and the sources that inspired her message. Here, I address Spraetz’s message piece by piece (as I did on Twitter) and clarify the ways in which it distorts quotes and makes inferences that simply are not true. By reading the original sources that Spraetz described, it is clear that blaming Chimp Haven – or the excellent behavioral and care staff – for the deaths of the chimpanzees that were relocated there several months ago is not the focus. Rather, the focus in on better understanding and consideration of what happened to recently relocated animals – a consideration that should inform future decisions.

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In fact, Dr. Buckmaster did not write that the chimps “’suffered and died’ because of their transfer to Chimp Haven.” This claim distorts the “suffered and died” quote by taking it out of context. Rather, Buckmaster wrote:

“In a blog posted in 2013, the CEO of the Humane Society of the United States congratulated his followers for their hard work, reinforcing their effort by stating that criteria put forth by a NIH working group made it clear that “not one laboratory could be considered ethologically appropriate” for chimpanzees. This is not true. In fact, many of our chimps would fare better if they were allowed to retire in place. And several of these precious creatures have already suffered and died because the NIH would not allow them to do so.” (emphasis added; Lab Animal, Vol. 45, No. 7, p. 271).

Buckmaster made an argument for retirement-in-place; she did not claim that Chimp Haven was responsible for the chimps’ deaths.

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There are several inaccuracies here. The first inaccurate statement, “invasive research with this species,” implies that until NIH’s November 2015 decision to “retire all federally owned chimpanzees,” all research was invasive in nature. In fact, since 2012, the facility from which these particular chimps retired conducted no biomedical research but only conducted observational studies.

Ironically, recently Chimp Haven proudly announced that it has entered into a partnership with Lincoln Park Zoo that will enable similar observational research, and that may also include biomedical research.

Another inaccuracy is the accusation, “…we cannot allow this community to disparage the quality of care we provide…or to question our organization’s dedication to our mission…”

This is followed shortly by the statement that Buckmaster “is able to so clearly judge the quality of Chimp Haven.” In reading and re-reading the articles that Spraetz refers to, one sees that there is not a single instance of any article or post author questioning the quality of care at Chimp Haven or Chimp Haven’s dedication. The sole instance is a commenter on the blog. In fact, the word “quality” does not appear once in Buckmaster’s article, and appears only once in Speaking of Research’s article on the partnership in the concluding sentence:

“Conducting research is compatible with both high quality care and with truly valuing what the animal contributes to new knowledge that benefits individuals, the species, and the future.”

Likewise, the word “dedication” does not appear either in Buckmaster’s article or in Speaking of Research’s article on the partnership.

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First, Buckmaster does not quote Dr. Abee at all in her article. Rather, Abee was quoted in this article from December 2015 in which, again, the focus is on making the argument for retirement-in-place. Further, Spraetz’s quote of Abee is taken out of context. Abee’s entire quote reads:

“I don’t mean this as a criticism of Chimp Haven, but we uprooted them, took them from their family groups, we moved them cross country, we put them in unfamiliar settings with caregivers who didn’t know them, and four died,” Abee said. “We would not have anticipated those four to die if they had stayed here.”

So Abee made a point not to criticize Chimp Haven and to make it abundantly clear that he had issue with the transfer itself.

Second, underscoring the statement, “the labs themselves made such decisions when they selected which chimpanzees to send” suggests that if the labs had “chosen” these particular chimps to leave at a later time, their outcomes may have differed. In fact, most of the chimps that died were very old. Research shows that involuntary relocation in old age is stressful (and a new paper shows that relocation of lab chimps to a sanctuary resulted in chronic stress and behavioral changes). Thus, it is possible that it would not have mattered when these chimps moved; their fates may have been the same. But that is unknown right now and is a question that can only be answered by examining what happened to the animals that have transferred, including those 9 of 13 who died. It is exactly this kind of review—based in facts, actual records, and expertise—that is called for in order to inform future decisions. An unwillingness to do so – and to share these with the public and others who have interest – undermines confidence that everything that can be done is being done to protect the animals.

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The statement, “The anonymous blog author questioned the partnership…” is another misrepresentation. Any reader can see that Speaking of Research actually clearly explained why such research would be warranted. In fact, Spraetz’s explanation for the research sounds a lot like Speaking of Research’s:

“It may seem odd that a sanctuary—a place whose justification and primary goal is to provide chimpanzees with care—has a need to evaluate the effect of visitors on the animals’ welfare. However, although the sanctuary is not open to all members of the public on a daily basis, it does appear to have extensive public visitation and education programs that presumably results in a need to evaluate the effect of visitors on the animals.”

Moreover, the blog author goes on to state, “the sanctuary offers a resource that zoos cannot for studies that are adequately powered to test scientific hypotheses.”

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This statement as a whole is not supported by any of the articles to which Spraetz refers. No author has made a accusations toward Chimp Haven’s care, and certainly no attacks on it have been made in these articles. The conversations have been focused on the issue of transferring the chimps versus allowing them to retire-in-place, on the bigger questions about what defines sanctuary and research,  and what is needed for a serious, thoughtful, and balanced consideration to inform decisions going forward.

Spraetz’s comment is precisely the kind of statement that leads to inflammatory reactions and further divides the people who have the same goal: the optimal conditions and highest quality of life for the chimpanzees.

Spraetz did have it right in one part of her message: the relationship between the lab and sanctuary communities has dissolved. But for her to distort the conversation by making claims that the laboratory community disparages the quality of care at Chimp Haven and attacks Chimp Haven’s operations in a public message is irresponsible. It actually exemplifies her quote from earlier in the message: “It’s an unfortunate characterization of our organization, which is based less on facts and more on rhetoric and mischaracterizations.”

CH message image 9By not providing the original references, which clearly show that the laboratory community is focused on the issue of transferring the animals, not the quality of care at Chimp Haven, Spraetz permits most readers to take her statements at face value. This then leads to unproductive and at times hostile dialogue in forums like Facebook, which do nothing to promote chimpanzee welfare.

Furthermore, for Chimp Haven to do nothing to counter the hostile and false statements made by its supporters – and for Chimp Haven to even go so far as to “Like” comments on Facebook that falsely describe laboratory researchers as “torturing animals” and calls them “A-holes” – seems completely incompatible with the goal of public education. It is this behavior that raises additional questions. That includes questioning why, given their public education goals, Chimp Haven does not take the responsibility to provide accurate counter to wrong statements and accurate information to support education and dialogue.

CH response tweet imageAmanda M. Dettmer

Sanctuary, Zoo, Lab: Name Games or Core Differences?

The announcement of a research partnership between Lincoln Park Zoo (Chicago) and Chimp Haven (a federally funded sanctuary for NIH retired chimpanzees) has led to increased dialogue, particularly in regards to what this means for the chimpanzees’ well-being and importantly, the kinds of activities that a sanctuary is allowed to engage with the animals under their care. We previously covered some of this issue, with concerns raised about the the deaths of 9 chimpanzees recently transferred to the Chimp Haven sanctuary (see here and here). In light of continued planning for relocating chimpanzees, the central focus has been on the question of whether the deaths have resulted in serious consideration and thoughtful review to identify any changes that could reduce future risks and best protect other animals’ health and wellbeing.Maynard

The recent announcement of a zoo-sanctuary “research partnership” has again prompted the question of the impact on the relocated chimpanzees’ well-being. Moreover, subsequent discussion has also illustrated a number of areas where facts and solid public information about the transparency and oversight of such research may be critically lacking. The discussion also highlights issues at the core of ethical consideration of chimpanzees. They are issues that not only play a role in decisions about where the chimpanzees should live, and in what activities they should take part; more fundamentally, they are issues that define what is meant by sanctuary and what is meant by research. That definition is central to informed and productive dialogue.

@2016 AJ Bennett comparison table research zoo sanctuary Table 1In many cases it appears that there are widely divergent views of what defines a sanctuary and what is meant by research. This is why, in part, the recent announcement of the Chimp Haven-Lincoln Park Zoo partnership was surprising to many. Particularly surprising was a statement by the sanctuary’s Chair of the Board of Directors that indicated the facility hopes to recruit scientists to bring research funds to the sanctuary in order to continue their research that has been truncated by federal decisions to retire research chimpanzees.Science - David Grimm 7.28.16

In various promotional materials about the new partnership between the zoo and the sanctuary the emphasis was on how the program might benefit understanding of chimpanzees and assist with animal care and conservation goals. At the same time it rapidly became evident that enthusiasm from the zoo and its chimpanzee program director, Dr. Stephen Ross, partially reflects benefits gained from access and use of the large sanctuary chimpanzee population, including research opportunities unavailable in the zoo. Others also appeared to see this use of the sanctuary chimpanzees as appropriate and justified. For example, the zoo’s press release about the partnership includes a congratulatory statement from the Humane Society of the United States (HSUS), a group opposed to NIH’s previous chimpanzee research:

“This important partnership between an accredited zoo and an accredited sanctuary is further evidence that we are in the midst of a new, compassionate era in our treatment of chimpanzees,” says Wayne Pacelle, president and CEO of The Humane Society of the United States. “Chimpanzees are amazing animals, and these two organizations are helping to define how best to learn from them, educate about them and most importantly, to care for them.”

Increasing public interest in the ethical justification for zoos

HSUS’ position on the ethical justification for keeping chimpanzees in zoos is not readily apparent, and their statement stops short of endorsing the zoo itself, or the perpetuation of captive chimpanzees via breeding in captivity (something that is banned in research centers and sanctuaries). Yet, others have raised similar questions well before the most recent decisions about NIH-funded chimpanzee research (see, for example, Jamieson, 1985; Regan, 1995)– though with significantly less media coverage. Furthermore, serious and thoughtful consideration of the different uses and human interactions with apes continues well beyond the simple and polarized messages that sometimes dominate the recent public portrayals of the issue  (for example, Norton, Maple, & Hutchins, 1995; Gruen, 2014; Bennett & Panicker, 2016; and many others cited within these references) .

Discussions about the role, ethical justification, and necessity of housing chimpanzees in research, zoo, and sanctuary facilities have arisen not only because of the retirement of NIH chimpanzees. Rather, societal consideration of zoos has also increased over time. Most recently, the tragic death of Harambe, a gorilla at the Cincinnati Zoo, along with the closure of the 140 year old Buenos Aires zoo, and movement away from keeping elephants in zoos, have sparked much public dialogue.

The tone of reflection is evident in a number of the titles of articles, op-eds, and blog posts. For example:

The ethical justification for keeping chimpanzees in zoos merits serious and well-informed consideration as it forms the foundation of societal decisions. The same kind of consideration is already mandated for research with animals, including chimpanzees, in the US and elsewhere.  In both cases, the public dialogue and public interests are served by providing facts about the animals’ care and treatment, but also by full and balanced presentation of the justification itself.

Intersections between research, zoos, and sanctuaries

Speaking of Research typically focuses solely on animal research and on animal testing rather than other interactions and uses of animals by humans, including zoos, entertainment, and private ownership.  In the case of chimpanzees, however, the intersections between research, zoos, and sanctuaries are now at the forefront of many of the debates, decisions, personal, and the societal deliberations.

There are a number of reasons for this intersection. Among them: the movement of research chimpanzees to sanctuaries and zoos; the fact that US decisions about research chimpanzees has resulted in a likely shift of research opportunities to zoos and other types of facilities; and, most recently, the new partnership between a federally-funded chimpanzee sanctuary and a zoo.  At the same time, the new standards of care and housing for chimpanzees adopted by one federal agency, the NIH, has raised questions about whether the same standards should be extended to all chimpanzees (for further information and discussion see previous posts “Where should US chimpanzees live?” and “Chimpanzee retirement: Facts, myths, and motivation”).

What are the defining characteristics of a sanctuary?

One of the core issues in this debate is: “What should be the defining characteristics of a sanctuary?”   For some people, the central characteristic is only that the animals receive the best possible care to protect their health and well-being. However, as we have written about previously, this characteristic is not exclusive to sanctuaries. Excellent and humane care can be provided in other settings, including research facilities (for further discussion see: “Can we agree? An ongoing dialogue about where retired research chimpanzees should live”).where us chimpanzees live 07.13.16

For other people, the very concept of sanctuary means that the animals are not used as instruments to achieve any human goal, or to meet any human need. And, moreover, that the animals’ dignity and autonomy receive highest consideration. For example, in an edited volume, “The Ethics of Captivity,” philosopher Lori Gruen says: “There are some captive contexts, such as true sanctuaries, where the goal is not just to promote the well-being of the individuals that live there but to also recognize their dignity and treat the residents with respect” (p. 244). She argues in particular that animals should be provided with the opportunity to choose who to spend time with, other animals or observers, and be able to escape others’ gaze. She also contends that:

“Certain features of current captive practices are fundamentally dignity denying. For example, sending prisoners far away from their families or breaking up social groups in zoo settings denies the most basic choices in addition to disrupting social bonds. Such moves can only be justified if they are clearly in the best interests of the captive, not to serve institutional ends” (p. 245).

In a more recent article, Gruen (2016, “The End of Chimpanzee Research,” Hastings Report) writes in opposition to retiring NIH chimpanzees in the dedicated research facilities in which they currently live. She argues:

“Humans, regardless of gender or gender expression, race, ethnicity, ability, and so on, deserve respect. And I believe respect is also owed to chimpanzees. We make sense of our experiences and values through our relationships with others, and when we are instrumentalized in those relationships, our worth, our interests, and the meaning of our experiences is undermined. This is also true in the case of chimpanzees. … Advocates for chimpanzees oppose retirement in place due to this fundamental difference in [human, our emphasis] values—the ethos of a sanctuary respects the choices and dignity of the animals as opposed to that of a laboratory, where animals are used as tools.” [emphasis added]

What defines the sanctuary ethos and “using animals as tools”?

For many viewing and discussing the current situation, it is the argument about ethos and the degree to which the chimpanzees are “used as tools” that pose challenges to dialogue. One reason is that the terms are not clearly defined or operationalized in a way that allows people with a range of perspectives, experiences, expertise, and philosophical positions to be certain they are discussing the same thing.

For example, it is not entirely clear what behaviors and care practices would provide evidence of an “ethos” that “respects the choices and dignity of the animal.” Ironically, it would also seem that in order to provide an understanding of choice and dignity from the animals’ perspective, detailed scientific research on the animals themselves is needed, where the animals are used as tools to achieve the goal of improving the health and wellbeing of other chimpanzees.

No clear line is apparent that would indicate how we might define all of those cases in which chimpanzees are “used as tools.” For instance, while there may be relatively widespread agreement that chimpanzees used in entertainment are being “used as tools,” there may be far less agreement that chimpanzees in zoos fall in the same category. Similarly, whether noninvasive research qualifies as using chimpanzees “as tools” is also likely to be a point of disagreement. Noninvasive research spans studies of chimpanzees’ cognition, language, puzzle-solving, theory of mind, but also their preferences for various foods, housing, or care strategies, their response to human visitors, and any number of other topics  about which hypotheses can be made and tested with experimental, observational, and other scientific approaches.

The justification for any of this work can readily and reasonably be made in terms of benefits for the animals themselves, for the species, for human understanding, for society. Nonetheless, a reasonable case might also be made that noninvasive research is an instance of using the animals “as tools” because the work can lead to scientific publications, positive publicity and reputational enhancement for institutions and individuals, to satisfaction of human curiosity, and also to new knowledge that benefits animals—but animals other than those participating in the study.

Chimpanzees in research, zoo, and sanctuary facilities

Chimpanzees in research, zoo, and sanctuary facilities

The question of whether noninvasive research—the only type currently allowed in NIH-funded or supported research—is an instance of using the animals as instruments for human goals is not the only one. Moving chimpanzees away from their stable social groups, long-time and familiar homes and caregivers, and into a novel setting labelled “sanctuary,” may also qualify as “using the animals as tools.” In this case, the disruption of the animals’ lives and movement to sanctuary may serve as a tool to make humans “feel better” with potentially little added benefit to the animals themselves (see also K.S. Emmerman, in The Ethics of Captivity, edited by L. Gruen, Oxford University Press, 2016).  It is for this reason that many focus on the outcome – in terms of relative benefit and relative risk to the animals’ health and welfare—in order to make judgments about whether moving the animals is really in the animals’ best interests.

Is the Chimp Haven partnership with Lincoln Park Zoo consistent with the “true sanctuary ethos”?

It is partially for all of these reasons that the recent announcement of a research partnership between Lincoln Park Zoo and the federally-funded sanctuary was surprising to many. It was a surprise because many assumed that chimpanzees retired from research would not then serve in research – and, particularly, that they would not be viewed as a resource for the facility’s fund-raising via fees exchanged for research opportunities. The latter appears to be exactly the rationale expressed by the director of the facility and her collaborators in an abstract for presentation at the upcoming scientific meeting (Spaetz, Taylor, & Fultz, 2016):

“With recent decisions ensuring the retirement of additional chimpanzees, sanctuaries may provide an optimal place for behavioral research with the potential for large sample sizes, a variety of enclosures, and on-site support. A future goal for the sanctuary community is to become self-sustaining. In order to do this, sanctuaries must explore different options including fees for researchers and visiting scientists who hope to continue to study the chimpanzees.”

Perhaps it is not surprising that Chimp Haven has taken this approach. It is similar to that of the Pan African Sanctuaries Alliance (PASA) described by another primatologist, Professor Brian Hare at Duke University. For example, on the advantages of sanctuary-researcher partnerships: “Successful research programs in African sanctuaries will provide researchers with an alternative to more traditional laboratories that do not offer the high quality living environment that are found in Africa. African sanctuaries in turn will become the preferred research venue given their many advantages for non-invasive research.”

At the same time, researchers are described as a resource and benefit to sanctuaries:

“Sanctuary apes can benefit from additional resources provided by researchers through research fees (e.g. for management costs or improvements for research), equipment (e.g. computers, veterinary equipment, etc.) or expertise (e.g. disease screening and other veterinary work). The resources of researchers that never made it to Africa before will be spent in ape range countries to aid in maintaining the high level of care found in African sanctuaries.”

In many ways, Hare, Ross, and others who have advanced sanctuaries and zoos as a viable—and  “ethical”—alternative for science aimed at better understanding chimpanzees appear to share with other scientists an understanding of the value of research in terms of benefits to humans, animals, society, and the environment. They also realize that as dedicated research facilities continue to reduce the number of chimpanzees they house, and eventually house none, sanctuaries – along with zoos – will have “cornered the market” for primatologists, comparative psychologists, biologists, neuroscientists, and others with expertise and interest in scientific research that can answer basic science questions and those relevant to animal health and wellbeing.

There are key differences between the African sanctuary system and Chimp Haven, however. Most primary among them is that PASA exists to care for animals orphaned in Africa as a result of poaching and other human activities and that have no other place to go that can provide for their care. By contrast, for many of the chimpanzees slated to be moved from their current facilities, away from their stable social groups and long-time caregivers in dedicated research centers, Chimp Haven is not the only option.

PASA exists to care for animals and not to create additional animals that are dependent on human care and must be maintained in captive settings. By contrast, Lincoln Park Zoo and others actively seek—through breeding programs— to create more animals that must then be maintained in captive settings. Thus, while one program explicitly seeks to reduce the number of chimpanzees that require human care in captive settings, the other perpetuates the practice.

For zoos, many argue that conservation and education goals provide an ethical justification for maintaining the animals in captivity. Others reject the argument. For example, in an article titled “Shifting Toward an Ethics of Sanctuary,” Gruen argues the logical point: “But holding animals captive has no necessary connection to conservation as there are many successful organizations that engage in conservation efforts that do not hold any animals captive.”

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Photo credit: Kathy West

Unresolved questions

A number of questions are likely to remain active points of discussion both within the scientific community and more broadly. They include:

  • Whether continued scientific research should occur—including questions about: what types of work have merit and are justified; who should conduct the work; where it should be conducted; how it should be conducted and supported.
  • How these decisions should be made in absence, or outside of, the well-established and fairly transparent processes for expert and competitive scientific review that has occurred for proposals to NIH and NSF. This is a specific concern for the federal sanctuary that houses federally-owned chimpanzees supported largely by federal funds.
  • Whether retirement in place is the best option for some research chimpanzees.
  • Whether or not sanctuaries should conduct research.
  • Whether or not the federally-funded sanctuary should partner with a zoo.
  • Whether or not zoos should house chimpanzees at all.
  • Whether all chimpanzees in the US should receive the same standards of care as those mandated by the NIH.

In review of those questions and recent events, it is also clear that better dialogue might be facilitated by specifying what is meant by sanctuary. To the extent that research occurs in the federal sanctuary and the sanctuary is used to serve the goals of zoos, it is not at all clear that the term “sanctuary” has the common meaning that appears in public view. That is a problem for a number of reasons. Among them, when it comes to public dialogue and public decisions – both relevant to the federal funding that flows to Chimp Haven* – it is important to be clear about what retirement to sanctuary means and about how it is different from continuing to care for the animals in the facilities in which they currently live.

(*Federal funds provide 75% of the costs for maintaining NIH-owned chimpanzees at Chimp Haven, in 2015, according to NIH, this was $2.77 million. Chimp Haven currently appears to have a $12.9 million federal contract and over $30M in federal funds were invested in facility construction, chimpanzee transfers, and care. There are a number of other chimpanzee sanctuaries in the US, these sanctuaries are not currently part of the federal system and do not appear to be eligible for federal funds.)

Comparison of key features of research, zoo, and sanctuary facilities

The tables accompanying this post (above and below) outline some of the key features that are associated with different types of facilities, some of which may affect animals’ care and others that affect research. The tables cannot account for variation across every facility, but rather shows the typical case for research and zoos, what is known about the federally-funded sanctuary, and what would appear to be the case for a “true” sanctuary as it is defined by Gruen and others. Provision of choice is held up as a central defining element of sanctuary care. Thus, the second table focuses on elements of choice – or autonomy – that are central to the daily lives of animals living in a range of captive settings. As illustrated in both tables, there is a great deal of overlap between the various types of facilities.

Comments that can help further refine this work towards common understanding of the language used in discussion of chimpanzees in the US are welcome. We will return to this topic in the future, with analysis of the information in the tables, comparisons across facilities, and the implications for decision-making about chimpanzees.

Allyson J. Bennett

@2016 AJ Bennett comparison table research zoo sanctuary Table 2