Scientific purposes: all activities conducted with the aim of acquiring, developing or demonstrating knowledge or techniques in all areas of science, including teaching, field trials, environmental studies, research (including the creation and breeding of a new animal line where the impact on animal wellbeing is unknown or uncertain), diagnosis, product testing and the production of biological products.
Under the Australian federal system, responsibility for animal welfare rests with the states, and all states and territories have incorporated the Code – not always to its full extent – under their animal welfare or animal research laws. This is acknowledged in the new “Principles and guidelines for the care and use of non-human primates for scientific purposes”:
On some issues, this document represents an aspirational standard which may not currently be supported by state and territory legislation and in which case the state and territory legislation takes precedence.
Positive changes (compared to the previous 2003 policy)
Let’s start with the positives in the new principles and guidelines. By that I mean specifications or requirements that are positive from an animal welfare perspective and that were not included in the previous policy.
Great apes (gorillas, orang-utans, chimpanzees and bonobos) are now afforded greater protection. The document notes that no great apes are held in Australia for scientific purposes.
The only great apes held in Australia are in zoological collections for conservation breeding purposes.
And for entertainment purposes, I would like to add.
Now, the use of great apes for scientific purposes in Australia is permitted only when their use:
i) will not have any appreciable negative impact on the animals involved, e.g. observational studies, activities already being undertaken for management or veterinary purposes
ii) will potentially benefit the individual animal and/or their species.
There hasn’t been any research using great apes for decades in Australia. While this is a positive step, it will not impact any current research. For other primates, hardly anything has changed since the previous policy.
But back to the positives:
Non-human primates that are imported from overseas must be captive bred and must be accompanied by documentation to certify their captive-bred status.
It’s prohibited to tear primates from their wild habitats. Still, young animals are torn from their mothers, and import from breeding facilities overseas involves stress during transport.
Further, the new guidelines specify that retirement at conclusion of the research must be considered. The previous policy noted that the existing breeding facilities “will not generally accept animals that have been used for scientific purposes. In most cases, euthanasia will be the only option.” Does this mean that Australian primate breeding facilities accept now animals after they have been used in research?
Provisions for non-human primates at the conclusion of their use must take into account their long-term welfare. Retirement must be considered as an option if suitable in terms of the health and temperament of the animal, and space and resources are available at a facility that can meet their species-specific physical, social and behavioural needs.
But does the NHMRC anything to ensure rehoming options are available? To my knowledge, the answer is “no”.
According to the new guidelines, breeding facilities are not supposed to breed more animals than are needed for research (Australia has breeding colonies for macaques, marmosets and baboons):
Procedures must be in place at all non-human primate breeding facilities to ensure that the breeding programs are matched to the demand for animals, and to avoid or minimise the production of excess animals. Investigators must discuss their requirements for non-human primates with the management of the supply facility early in the planning stages for the project to assist with management of breeding programs.
The previous policy noted that investigators performing experiments overseas under the auspices of an Australian institution obtain approval from an Australian animal ethics committee, and that this may include the delegation of authority to inspect sites and monitor projects at remote sites. The new guidelines state explicitly that undertaking the experiments overseas must not be a way to bypass the Code:
If a project involving the use of non-human primates is to be conducted in another country, Clauses 2.6.9- 2.6.14 of the Code must be upheld. The conduct of a project in another country should not be used as a mechanism for avoiding compliance with Code.
The new guidelines include a section on reward-based training. It is proposed that using positive reinforcement techniques should be considered part of experimental designs for three reasons:
i) assisting in captive management, by seeking the animal’s compliance with routine husbandry and behavioural training
ii) improving the animal’s welfare, by training to facilitate the conduct of routine procedures without the need for chemical restraint
iii) ensuring the quality of the scientific data collected.
The new requirement for “training methods … not be based on approaches that involve punishment such as pain or psychologically distressing stimuli” appears to be primarily motivated by the intent to improve compliance of the captive animal.
Positive changes (compared to the draft guidelines)
The draft guidelines had proposed that the requirement of notifying the NHMRC’s Animal Welfare Committee (AWC) of primate imports be dropped because importing animals is subject to Commonwealth regulation. However, this proposed change did not go ahead:
The institution should ensure that the AWC of NHMRC is notified of the importation of non-human primates after approval from the institutional AEC has been obtained. For NHMRC funded activities, this requirement is mandatory.
In the section concerned with transport of animals, the following sentence was added:
Transport conditions must be designed to minimise stress (see Clauses 3.2.5–3.2.8 of the Code).
But shouldn’t all conditions – in regard to housing, transport and experiments – be designed to minimise stress?
Serious problems remain
While non-human primates are our closest relatives and genetically the most similar to us humans, does experimenting on these animals really benefit humans? Aren’t there better, more human-relevant research methods? And more importantly, is it morally defensible to subject these highly sentient and cognitive animals to the stress, pain and often death after experimentation?
Overall, the new guidelines do not represent compelling progress. A few baby steps may lead toward slightly improved animal welfare, but the guidelines are still steeped in an outdated paradigm. Even within this paradigm, we can decry the lack of transparency in animal research, non-existent or insignificant benefits for humans and animals, and the NHMRC and its funded institutions’ lack of taking responsibility for the fate of non-human primates after completion of research projects. The NHMRC funds primate breeding colonies, and funding a sanctuary for “retired” primates should be its responsibility, too.
So, what’s new in the new guidelines for non-human primates? Hardly anything that reduces pain and suffering and improves the lives of our closest relatives who are used for scientific purposes.
Together with Sir David Attenborough, Dr Jane Goodall and 19 other scientists, primatologists and animal welfare experts I signed an open letter “Testing on non-human primates in neuroscience research is no longer justifiable”, supporting Cruelty Free International in raising concerns about the controversial use of non-human primates in neuroscience research.
National Health and Medical Research Council. (2016). Principles and guidelines for the care and use of non-human primates for scientific purposes. Canberra: National Health and Medical Research Council, Australian Government.
Helen Marston, CEO of Humane Research Australia, has commented on the new guidelines on her blog: “New guidelines for primate research will not protect our closest relatives”.
Jeory, T., & Stone, J. (2016, 8 September). David Attenborough calls for end to ‘cruel’ brain tests on primates by neuroscientists. Exclusive: Sir David joins 21 signatories to an open letter published in The Independent. The Independent.
Lidbury, B. A. (2016). Medical science has moved on: it’s time to end primate testing. Australian Doctor(17 March).
Bailey, J., & Taylor, K. (2009). The SCHER report on non-human primate research – biased and deeply flawed. Alternatives to laboratory animals : ATLA, 37(4), 427-435.
Bailey, J., & Taylor, K. (2016). Non-human primates in neuroscience research: The case against its scientific necessity. Alternatives to Laboratory Animals – ATLA, 44(1).
Bailey, J., Thew, M., & Balls, M. (2015). Predicting human drug toxicity and safety via animal tests: can any one species predict drug toxicity in any other, and do monkeys help? Alternatives to Laboratory Animals, 43(6), 393-403.
Burm, S. M., Prins, J. B., Langermans, J., & Bajramovic, J. J. (2014). Alternative methods for the use of non-human primates in biomedical research. Altex, 31(4), 520-529.
Chandrasekera, P. C., & Pippin, J. J. (2015). The human subject: an integrative animal model for 21st century heart failure research. American Journal of Translational Research, 7(9), 1636-1647.
Gilbert, S., Kaebnick, G. E., & Murray, T. H. (2012). Animal research ethics. Evolving views and practices: The Hastings Center.
Gordon, N., & Langley, G. (2008). Replacing primates in medical research. An expert report by: Dr Hadwen Trust, FRAME, St Andrew Animal Fund.
Greek, R., Hansen, L. A., & Menache, A. (2011). An analysis of the Bateson Review of research using nonhuman primates. Medicolegal and Bioethics, 1, 3-22.
Taylor, K. (2010). Reporting the implementation of the Three Rs in European primate and mouse research papers: are we making progress? Alternatives to laboratory animals : ATLA, 38(6), 495-517.
Wendler, D. (2014). Should protections for research with humans who cannot consent apply to research with nonhuman primates? Theoretical Medicine and Bioethics, 35(2), 157-173.