NAVS Letter to the NASEM Committee

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Dear Chairman Ramos and fellow committee members,

Since 1929, the National Anti-Vivisection Society (NAVS) has been working to end the exploitation of animals in all areas of science. As an engaged party, we quickly noticed the similarity between the charge of the current committee and the committee that convened in 2011 to discuss the necessity of chimpanzee use in research for the advancement of public health.

The committee convened in 2011 acknowledged in their report that, “the committee feels strongly that any assessment of the necessity for using chimpanzees as an animal model in research raises ethical issues, and any analysis of necessity must take these ethical issues into account. The committee’s view is that the chimpanzee’s genetic proximity to humans and the resulting biological and behavioral characteristics not only make it a uniquely valuable species for certain types of research, but also demand a greater justification for conducting research using this animal model.” Ultimately, after weighing all variables including ethical considerations, that committee found that most research being done using chimpanzees was unnecessary.

In this letter to the current committee, NAVS asserts that the same ethical reasoning that was deduced by the prior committee extends to monkeys and prosimians that are still used in research today. To that end, NAVS has suggestions on how the committee can best tackle a charge within which lurks heavy ethical considerations.

The failure of NHP models must be examined when assessing questions of necessity. 

As stated, the committee will, “examine the present state of biomedical research studies relying on nonhumane primate models, including a landscape analysis of scientific opportunities and contributions to human health advancements.” Concerns of bias and an incomplete analysis arise when surveying the “use landscape” of NHPs and only looking for successes. Failures of NHP models are equally important when assessing questions of necessity and should be wholly examined as part of a quality harm-benefit analysis.

Increased collaboration among NHP researchers is just as important as collaboration between NHP researchers and those who utilize new approach methodologies (NAMs)

There exists further concern that the committee will explore, “ways to increase coordination and collaboration between researchers who use nonhuman primates and those who use new approach methodologies,” but not ways to increase collaboration and coordination among researchers who use NHPs. Lack of information sharing among researchers is a well-known roadblock to better adherence of the 3Rs that guide the use of animals in science and advancing scientific progress. Added to the current charge should be a concerted effort to look at ways that NHP researchers can increase collaboration and information sharing.

During the COVID-19 pandemic, after China stopped exporting NHPs for research, laboratories in the United States had to collaborate to use the monkeys they had more efficiently. In one example, some labs held control animals while others held experimental animals, effectively reducing the number of animals that needed to be used because numerous labs had access to the same control group. This collaboration reveals that scientists can creatively reduce the number of animals used in research by increasing collaboration and brings about questions of why this type of collaboration was not happening pre-COVID. It appears that normal practices, i.e., practices during times when there is not a perceived shortage of NHPs, don’t live up to the scientific communities purported commitment to minimize the number of animals used. The committee needs to examine further opportunities for collaboration among NHP researchers to maximize adherence to the 3Rs. 

New Approach Methodologies should replace, not compliment, NHP use once validated

On the topic of NAMs, the way in which they are regarded and described in the committee’s scope raises concerns about the committee’s commitment to a thorough and honest review of NHP use. Spelled out right in the name, new approach methodologies are supposed to be just that, a new approach. Yet, the committee will work to identify “opportunities for new approach methodologies to complement or reduce reliance on research with nonhuman primates.” NAMs are hardly deserving of the designation “new approach” if the goal is to simply use them to complement standard use of NHPs. Similarly, it would not be 3Rs compliant to continue to use NHPs in areas where NAMs have been developed and validated.

Committee members who use NHPs in research need to have their conflicts of interest labeled and disclosed

Lastly, and as was shared in our letter concerning committee composition sent on April 15, 2022, there arises an ethics issue in the way the committee foregrounds conflicts of interest. From a research ethics perspective, it is concerning that NHP users are not identified as having a conflict of interest. Every scientist on the committee who uses NHPs in their research, or if they partner with someone who uses NHPs in research or work in a lab that uses NHPs, has a conflict of interest when assessing “areas of emerging science that may benefit from nonhuman primate research models.”

As is, only members with a financial interest in NAMs, of which there are far fewer members compared to those who use NHPs, are identified as having a conflict of interest. Along with our recommendation of increasing the number of committee members with expertise in NAMs, we suggest a detailed description of all conflicts of interest, to include:

  • Identifying all members who currently use NHPs in research or who have used NHPs in the last five years.  
  • The amount of NIH grant money members have received to conduct research using NHPs in the last five years.
  • All affiliations with institutions that use NHPs in research.
  • Personal and professional relationships with scientists who use NHPs in research.

What we do to NHPs in research will always matter morally. The purported scientific justification for using NHPs in research is their similarity to humans, and thus, the possible benefits to humans. That justification needs thorough and continuous scientific evaluation that keeps pace with scientific developments, including the development of alternatives to using NHPs and other nonhuman animals. We thank the committee for taking on this charge to evaluate the current landscape and future needs of NHPs in scientific research and hope to see a more balanced charge as the committee’s work progresses.

With respect,

Meredith Blanchard
Senior Manager of Advocacy and Policy