The National Health and Medical Research Council (NHMRC) of Australia is consulting the public on new guidelines for the care and use of non-human primates for scientific purposes. The closing date for submissions is Friday, 8 May 2015, 5:00pm.
I have just submitted my comments. Here is my submission:
Re: Public consultation on the draft principles and guidelines for the care and use of non-human primates for scientific purposes
Thank you for the opportunity to comment on the above document.
First of all, I wish to state that I am opposed to the use of animals in teaching and research on ethical and scientific grounds.
However, I wish to make the following comments in response to the draft document:
Pages 2 – 3. The NHMRC is particularly interested in feedback on proposed changes to notification requirements to its Animal Welfare Committee (AWC). The requirements that would be removed are:
- Exemption from the AWC regarding housing of non‐human primates for periods longer than six weeks without access to an outside enclosure.
- Notification to the AWC of the importation of non‐human primates which is subject to Commonwealth regulation.
- Inspection by the AWC of facilities where non‐human primates will be housed and used.
I am against the removal of these requirements, because they weaken the existing protections and extend self-regulation. Self-regulation is not sufficient to protect the animals effectively, and a central overview is important. It is crucial that all use of primates is reported to the NHMRC and that a database is established to monitor all aspects of their use.
In addition, I encourage you to establish a national data base for all animal research to inform the public and to insure research is not duplicated. Such a database is mandated in the European Union. The EU requires the publication of nontechnical summaries of all animal research projects minus any trade secrets or information that could identify researchers or institutions. Researchers in the EU provide this information, and Australia should follow their lead.
The draft document notes that “Great apes must not be imported from overseas”, yet it is proposed to even drop the requirement to notify the AWC of the importation of other non‐human primates. If we have breeding facilities here in Australia, why import non-human primates thereby subjecting them to considerable stress during transport? As stated above, ideally we should ban the use of all non-human primates for scientific purposes, but if this does not occur, then at least stress and suffering should be minimised.
Points 2 and 5
Great apes and other non-human primates are treated differently by the new draft guidelines, suggesting that “the use of great apes (gorilla, orang‐utan, chimpanzee and bonobo) raises even greater ethical concerns than that of other non‐human primates”. The use of great apes for scientific purposes is only permitted when it “will not have any appreciable negative impact on the animals involved” or when it “will potentially benefit the individual animal and/or their species”. This conveys stronger protection than the previous guidelines issued in 2003, and I commend this change.
Considering there is little difference between great apes and other primates in their capacity to suffer, their cognitive abilities and well-developed social structures, the protections granted to great apes should be extended to all other primates.
Many of the purported protections are ambiguous and ultimately meaningless. For example:
- Point 15. “The capacity for the particular species of non-human primate involved to experience pain and distress must be taken into account when making decisions about the possible impact of procedures or conditions on the wellbeing of an individual non-human primate”. — “Taking into account” is unspecific and can mean anything.
- Point 16. “When non-human primates are supplied to a project approved by an institutional AEC, the animals must be obtained from an established Australian breeding colony unless another source is approved by the AEC”. — It would be more honest to say that the AEC can approve any type of sourcing of non-human primates.
- Point 25 (i).“Australian‐bred non‐human primates must not be exported unless … for a specific purpose. Examples of specific purposes would be maintenance of genetic diversity or provision of overseas researchers with a model of a primate disease”. — “A specific purpose” can be found easily.
Point 28. The draft document notes that the 3Rs need to be applied at all stages. In regard to the first R (i.e. Replacement) I’d like to point out that many countries have dedicated research centres for the development and validation of non-animal research methods. These centres receive government support and funding. This is not the case in Australia. It would be appropriate for the NHMRC to demonstrate a similar commitment.
In summary, in the absence of a ban on the use of all non-human primates for scientific purposes, I propose the following:
- Extend the protections granted to great apes to other non-human primates.
- Start a national database for all animal research. This could follow the EU example.
- Many countries have government-supported dedicated research centres for the development and validation of non-animal research methods. Australia needs to catch up and contribute to the development of effective and ethical research methods that do not involve the use of animals. The NHMRC is the appropriate body to advance and support this.
- At present, Australia does not have a facility for “retired” primates. We need a sanctuary for non-human primates in Australia, and the NHMRC should fund such a sanctuary.
If you feel strongly about the protection of non-human primates used in research and teaching, I encourage you to make a submission. It doesn’t have to be a long document. Feel free to “borrow” from my submission. Further, Humane Research Australia has provided a few pointers that you can use.
Let’s do what we can to improve the lives of animals unfortunate enough to end up in a research institute.