The APS supports NIH’s efforts to utilize a science-based approach to resolve issues related to future research and care of chimpanzees, President Dr. Susan M. Barman said in a letter to Dr. James Anderson, Director of the Division of Program Coordination, Planning, and Strategic Initiatives. Nevertheless, the APS has reservations about the failure to include individuals familiar with the management of the chimpanzee populations in question in NIH’s Working Group (WG) on the Use of Chimpanzees in NIH-Supported Research. As a result, the APS noted in its comments, the WG report is “deeply flawed.”
The WG was convened in February 2012 in the wake of the Institute of Medicine report, Chimpanzees in Biomedical and Behavioral Research: Assessing the Necessity. The WG’s findings were presented to NIH’s Council on Councils on January 22, 2013. Afterwards NIH requested public comments on the recommendations.
The IOM report was released in December, 2011, after a year-long study. NIH commissioned this study at the behest of Senators Jeff Bingaman (D-NM), Tom Harkin (D-IA), and Tom Udall (D-NM). The IOM then convened a committee charged with assessing the current and future need for public health research with chimpanzees. That panel determined that while the need for such research is decreasing as new research models become available, chimpanzee research in a few areas remains necessary. Some of that research may be phased out with the advent of other research models, but additional needs may still arise in the future.
The IOM findings provided the backdrop for the WG’s efforts. The WG’s recommendations were divided into three sections: Ethologically Appropriate Physical and Social Environments; Chimpanzee Research Colony Size and Placement; and Review Process for Future Proposals to Use Chimpanzees in NIH-Supported Research.
APS noted in its comments on the WG recommendations that issues revolving around the use of chimpanzees in biomedical and behavioral research require “thoughtful balancing of ethical and scientific considerations.” APS expressed support for the decision to maintain some chimpanzees for research “until appropriate alternatives are available.” Using the enhanced criteria for the use of chimpanzees in research as set forth by the IOM, NIH’s WG recommended ending about half of 22 currently-approved chimpanzee research projects. The specific projects to be discontinued were not identified. Nevertheless, APS pointed out that “The grants in question were approved because the objectives were important, the science was meritorious in a highly competitive environment, and chimpanzees were seen to be the appropriate model. Therefore, “the aspects of the research involving chimpanzees should be ended in an orderly fashion, and NIH should facilitate a transition to another research model to fulfill the original goals of the grants.”
APS identified several problems with the WG’s recommendations. These included an “excessive reliance on inflexible engineering standards when performance standards would better serve animal welfare”; recommendations that are “mutually contradictory”; and an “ambitious timetable that would make the recommendations difficult and costly to implement.”
Excessive reliance on engineering standards was evident in the WG’s recommendations for “Ethologically Appropriate Physical and Social Environments” (EASPEs)—a term that the IOM panel had used without defining. The WG said that EASPEs should “not simply allow but also, importantly, [promote] a full range of behaviors that are natural for the species.” It then went on to stipulate that chimpanzees should be placed in multi-male, multi-female social groups of at least 7 individuals with at least 1,000 ft.2 per individual, year round access to indoor and outdoor areas, and 20 ft. of vertical climbing space. The recommendations also specified that EASPEs should offer opportunities for all group members to travel, rest, and feed in elevated spaces, to forage for food, and to have daily access to nest-building facilities.
The APS noted that the American Society of Primatologists had “offered more outcome-oriented guidance regarding the physical and social environment needed to permit the expression of species-typical behaviors.” The APS recommended that NIH “consider alternative means of achieving the objectives of EASPEs.”
The WG recommended retiring several hundred chimpanzees while keeping 50 available for research. However, some of the WG recommendations for this cohort were contradictory. The research population should consist primarily of healthy individuals less than 30 years old. They should be an even mix of males and females, and at least half should be immunologically naïve to infections such as Hepatitis C and HIV. The WG also said that existing social groups should be preserved as much as possible. However, APS pointed out that “given the small number [of chimpanzees] to be designated for the research colony, it is likely that social groups will have to be dissolved.” In addition, if approved research “requires exposure to infectious agents, then the entire social group of each study participant will be exposed, rapidly diminishing the number of immunologically naïve subjects.” Also, over time some of the initial cohort may acquire spontaneous illnesses or otherwise cease to be appropriate research subjects. The WG called for a review to be conducted every 5 years to determine whether the research population was being over- or under-utilized. “The procedure for dealing with underutilization seems obvious enough,” APS noted, “but no mechanism was put into place to recruit additional individuals if 50 are not enough.” The APS therefore recommended that NIH reconsider whether 50 was an appropriate number of chimpanzees to retain for research, and that it institute a mechanism for bringing more animals into the research population if needed.
The WG recommended placing all NIH owned or supported chimpanzees to facilities meeting its definition of EASPEs within 5 years. However, “Given the magnitude of investment needed to construct such habitats, NIH may not be able to proceed without Congressional action,” APS pointed out: “Federally owned or maintained chimpanzees will need continuous care while new construction or the modification of existing facilities takes place so the cost of creating EASPEs will come as an addition to rather than in place of the funds NIH currently spends for housing and support.” Consequently, “it may be difficult for NIH to muster the resources needed to implement the WG’s EASPE recommendations on a 5-year timetable for reasons that are outside of the agency’s control.” For that reason, APS urged flexibility both in terms of the criteria for EASPEs and the timetable for achieving them.