Primate welfare proposals upset experimenters
On 15 July 1999, the US Animal and Plant Health Inspection Service (APHIS), which is part of USDA, published a draft policy (Docket No. 98-121-1) regarding primate welfare. APHIS is charged by law with improving the welfare of captive primates at laboratories, animal dealers' compounds and exhibitors' facilities.
The proposal was not a regulation, just a statement of policy on primate psychological well-being. Besides publishing the proposed policy, a USDA committee prepared a 100-page report entitled Final Report on Environment Enhancement to Promote the Psychological Well-being of Nonhuman Primates.
Such a firestorm of criticism erupted that a final policy has not yet been adopted. In reading the dozens of letters, IPPL finds recurrent phrases, such as that Jane Goodall sees nothing wrong with early separation of young primates from their mothers. To the best of IPPL's knowledge, Jane Goodall never said any such thing. In fact she emphasizes the importance of the mother-infant bond.
Extracts from the APHIS proposals follow.
Social grouping
Primates are clearly social beings and social housing is the most appropriate way to promote normal social behavior...The housing options below are listed in a hierarchy of preference, with group housing being the most desirable plan...
Housing options include:
1) housing in an enclosure with one or more compatible primates. For group-living species, species-typical groupings are strongly encouraged.
2) housing in an enclosure without another compatible primate, but with the animal having the opportunity for continuous visual, auditory, olfactory and tactile contact with another compatible primate...
3) housing without the animal having the opportunity for continuous visual, auditory, olfactory and tactile contact, but with such contact on a periodic basis...
4) housing without the animal having the opportunity for continuous visual, auditory, olfactory and tactile contact with a compatible primate but with daily positive interaction with compatible human care givers...
We consider pair or group housing (option 1) to be the most desirable housing option and we expect this option to be used whenever possible. We consider this particularly important for chimpanzees, gorillas, gibbons and siamangs...
Social needs of infants
Infants should not be permanently removed from the care giving parent(s) before an age that approximates the age of infant independence in nature, except where necessary for the health and well-being of the infant or dam...
The policy discusses alternative ways of rearing infant primates and recommends that infants be exposed to peers and/or adults "of the same or compatible species."
Structure and substrate
Primary enclosures should contain elevated resting structures appropriate for the species...
Primates of species with long tails should be provided with sufficient vertical space to permit normal upright resting postures without restriction of tail position or placement of the tail outside the enclosure or into waste pans.
Foraging opportunities
As part of enriching the physical environment...the plan should provide, for each primate to have, on a daily basis, some type of time-consuming foraging opportunities...
Manipulanda
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| Standard US monkey lab cage |
As part of enriching the physical environment...our research indicates that the plan should provide for each primate to have a variety of portable or moveable items for manipulation available to them...
APHIS also made recommendations for specialized care of primates "in persistent psychological distress" and allowed for exemptions from the policy when approved by a laboratory's Institutional Animal Care and Use Committee (IACUC).
Although the policy was not mandatory, howls of outrage from users of primates deluged APHIS, as well as letters of support from IPPL, the Center for Captive Chimpanzee Care, and other primate-friendly groups. As of writing, a final policy had not been issued.
Leading the critics were the National Association for Biomedical Research and the American Society of Primatologists (ASP). Although ASP has many field primatologists as members, it set up an experimenter-dominated committee to prepare a lengthy critique of the draft policy. Many other commentators copied extracts from these submissions or expressed their approval of them.
EXTRACTS FROM COMMENTS ON THE POLICY
Dr. Shirley McGreal, Chairwoman, IPPL
IPPL agrees that infant primates should not be permanently removed from the care-giving parent(s) before an age that approximates the age of separation in nature.
We would expect purveyors of primates for the pet trade to howl with outrage, as they like to snatch babies at just a few days or weeks old, but we are very disappointed that the American Society of Primatologists (ASP) is howling too, on this point, in a way that would appear to contradict the Society's 1995 White Paper Report on "private ownership of primates."
I am sure that primate pet traders must be thrilled to see ASP facilitate their regular severing of the mother-infant primate bond for commercial gain, usually with devastating outcomes for the babies...
We note, and strongly disagree with, the ASP statement that, "Separation from mother at an age that corresponds to only 25-50% of the completed weaning age (which ASP reports as 12 months in macaques) may have no adverse impact."
It is appalling that professional primatologists who make their careers exploiting primates (and who often raise human children) should make comments such as that it is acceptable for a baby primate to be taken from her mother at 3-6 months old, claiming that it purportedly does no harm to the baby...
There is no mention of the mother's pain at having her baby or a series of babies snatched from her.
Further, in the "Executive Summary," it is stated that regulators have "variability in expertise in nonhuman primate behavior." The same can be said of the regulated entities - which is of course precisely why strict regulations are needed.
Dr. Carole Noon, President, Center for Chimpanzee Care
In Section III, ASP makes an argument using the "reproductive success" criterion for removal of infants at an age that corresponds to 25-50% of the completed weaning age as long as there is a strong social component to subsequent housing.
Using their example of 12 months for rhesus macaques, infants could be removed from mom at three months of age. The strong social component in subsequent housing may be problematic as ASP has acknowledged an existing lack of adequate caging for macaques that can accommodate group housing unless cages are redesigned.
Additionally, endorsing the early removal of infants would seem to facilitate the pet trade. This is particularly puzzling given the White Paper Report, Private Ownership of Primates issued in 1995 by an Ad Hoc Committee of ASP.
The ASP White Paper states, regarding psychological well-being, "This issue is particularly relevant to the removal of infants from their mothers, as early removal can have a devastating psychological impact on the infant - and perhaps on the mother. Nevertheless, this is a standard practice used by many breeders"(Pg. 5)...
I applaud APHIS for revisiting psychological well-being and appreciate the enormous effort that went into the Draft Policy. It is clear from the Final Report that the intent of Congress is not being achieved at regulated facilities.
If ASP's comments are any measure of the biomedical community's attitude it seems unlikely that any kind of "voluntary" compliance will be achieved in the next 8, or 80, years unless USDA changes its strategy regarding regulation and enforcement of the amendment.
National Association for Biomedical Research
The statement that "Infants should not be permanently removed from the care giving parent(s) before an age that approximates the age of infant independence in nature" is very impractical for research settings.
In the wild, infants of many species may stay with mothers until 4-6 years of age. This length of stay is not necessary as Jane Goodall, among others, has found...
American Society of Primatologists
The American Society of Primatologists is willing to assist the USDA in any way the USDA deems relevant to educate individuals across all levels of regulation with the most up-to-date scientific information that is available...
This assistance can take many forms, from staging seminars for regulators, to assisting in the development of an expert panel that might be consulted for unusual or difficult cases...
The cost of implementing some of the recommendations in the Policy may be considered excessive.
Separation from mother at an age that corresponds to only 25-50% of the completed weaning age may have no adverse impact as long as there is a strong social component to the subsequent housing...
We find somewhat ambiguous the paragraph that "Primate of species with long tails should be provided with sufficient vertical space to permit normal upright resting postures without restriction of tail position, or placement of the tail outside the enclosure or into waste pans"... Housing rooms would have to be radically designed to accommodate the larger cages.
Such costs could be enormous...
Fears have been raised that such a rule could either end research with individually housed long-tailed macaques or encourage surgeries that could be detrimental to the animals (e.g. tail docking).
David Martin, DuPont Pharmaceutical Company
The statement that "Infants should not be permanently removed from the care giving parent(s) before an age that approximates the age of infant independence in nature" may be impossible for research settings where the protocol may dictate the age of removal. In the wild, infants of many species may stay with mothers until 4-6 years of age.
This length of stay is not necessary as Jane Goodall, among others, has found...
Molly Greene, University of Texas Health Sciences Center (sounds like someone's plagiarizing somebody!)
The statement that "Infants should not be permanently removed from the care giving parent(s) before an age that approximates the age of infant independence in nature" is very impractical for research settings. In the wild, infants of many species may stay with mothers until 4-6 years of age. This length of stay is not necessary as Jane Goodall, among others, has found...
Susan Iliff, Association of Primate Veterinarians
The statement that "Infants should not be permanently removed from the care giving parent(s) before an age that approximates the age of infant independence in nature" should be changed to state "weaning age." As proposed, the infants of many species would have to be left with the mother for up to 4-6 years of age. This is impractical and unnecessary, as has been documented in scientific literature by scientists such as Jane Goodall...
Douglas Cohn, Albany Medical College, New York
Like many animal facilities ours at Albany Medical College operates with a full staff Monday through Friday with a skeletal crew (i.e. a staff of one) on weekends and holidays...We would suggest that the statement in the Draft Policy that "on a daily basis some type of foraging opportunity" be offered to each primate be amended to "at least five days a week"...
Within our facilities we have nine male rhesus monkeys who have been single caged for most of their lives - up to 15 years in some cases. We have tried to socialize these animals without any success...The evolution of nonhuman primate husbandry from singly caged to pair or group housing is a goal towards which we should be striving, but it cannot be forced upon facilities overnight.
J. Koudy Williams and colleagues, Wake Forest University, North Carolina
We find ambiguous the paragraph that indicates, "Primate of species with long tails should be provided with sufficient vertical space to permit normal upright posture without restriction of tail position." This could be interpreted to mean that long-tailed macaques may need to have cages tall enough so that they can sit on a perch without their tails reaching the floor. A second interpretation is that these animals must have sufficient floor space so that their tails be able to lie straight.
New cages would need to be designed and the cost would be enormous...There is also concern that such a policy would encourage "tail-docking" or other manipulations "to make the monkey fit."
Randall Reed, Toxicologist, Northern Biomedical Research, Muskegon, Michigan
I am a toxicologist with over 20 years experience in Food and Drug Administration mandated safety evaluations of pharmaceuticals. Many of the studies I have conducted involved nonhuman primates (macaques)...
Many of our studies involve surgical procedures and implants, and continuous infusions making multiple housing impossible for safety reasons (pulled sutures), research reasons (severed infusion lines)...
Thomas Rice, Coulston Foundation, New Mexico
Providing nesting materials for species who perform that duty in their natural environment is highly questionable. Nesting has not been demonstrated to be a natural behavior, but more likely to be a nurtured learned behavior...
Marisa Garza Schmidt, Sierra Biomedical, Nevada
Many of the social grouping guidelines would not be feasible for facilities that have limited cage space. It is difficult to establish compatible pairs in a dynamic colony of individually housed animals. In our facility, almost every cage space is occupied and animals must be moved around within the facility often.
For example, in order to move 30 animals into one room for a research study, thirty more may have to be moved out of the selected room to make space available for those coming in. Something of that magnitude occurs at least twice a week in a facility like our's... We recognize that the manner in which animals are moved causes stress, but the nature of our business requires us to have a surplus of animals available for upcoming studies...
George Pucak, Covance Research Products, Pennsylvania
Covance Research Products is one of the largest importers of nonhuman primates in the USA. These animals, by law and professional judgment, require a quarantine period. The definition of "quarantine" is a "strict isolation designed to prevent the spread of disease should it be present"... instituting an enrichment program as defined in the draft is essentially completely opposed to the intent of "quarantine."
Christopher Coe, Chair, Harlow Primate Laboratory, University of Wisconsin
The sentence indicating that "infants should not be permanently removed from the caregiving parent before an age that approximates the age of infant independence in nature" could have many different meanings. For me, that would mean macaques could stay with the mother until 4-6 months of age, but others might use the sentence to suggest that offspring remain with the mother for a year or more...
Beyond the pragmatic and cost problems in instituting many aspects of the proposed enrichment plan, the policy goes on to indicate that there should be both documentation and evaluation of the efficacy of the plan. The documentation would be a burdensome requirement on the staff of most facilities...
Steven Wise, Maryland (not to be confused with animal activist attorney Steven Wise)
I am a primate researcher with over 20 years experience in the study of rhesus monkeys. I am concerned that your staff lacks the necessary scientific experience to develop sensible regulations. It further seems clear that your staff receives inadequate scientific input. Most practicing scientists have limited time to deal with the bureaucracy and limited patience in dealing with the kind of people attracted to such work...
In behavioral experiments with awake, behaving monkeys, the animals work for several hours each day...in my opinion, this activity fulfills the psychological needs described in the draft report.
Howard Hughes, Smith Kline Beecham Pharmaceuticals
Although social grouping may be appropriate for behavioral work or breeding colony management, such groupings are not a suitable means for holding the vast majority of animals used in pharmaceutical research.
John Capitanio, University of California at Davis
I strongly suggest USDA revise their statement that anticipation in experimental manipulations should not be considered "adequate" for enrichment purposes. My experience is that most animals "enjoy" their participation in many different types of experiments, even when there is food or water deprivation. Note that working for food and water under conditions of deprivation is what animals in the field do on a daily basis.
James Moe, Vice-President for Toxicology, Pharmacia & Upjohn, Michigan
In a research environment, it is critical that attending veterinarians and the animal care staff, in coordination with the IACUC and the scientists, should continue to use their professional judgment to create an optimal environment for our nonhuman primates...
While the intent and goals of USDA's proposed policy are laudable, they do not appear to take into account the complexity of the research environment...We believe that the proposed policy, if implemented without revisions, would create a significant burden on our institution, as well as other consequences that run contrary to Congress's expressed intent of decreasing the regulatory burden on research facilities...
Jack Bley, Michigan
Today I work in a pharmaceutical company...In some cases the only resource to meeting these new policies will be animal euthanasia or the elimination of nonhuman primates as research models. Some may even give consideration to tail amputations rather than invest in new cages...
Do not impose additional requirements as an unscientific response to the pressure imposed by "animal rights activists whose obvious purpose if to shut down all animal-based research without regard for the health and welfare of the human population."
Thomas Wolfle, Veterinarian
For 38 years I have worked closely with nonhuman primates and have been instrumental in the development of humane policies for their care and use while in the US Air Force, at the National Institutes of Health, and at the Institute of Laboratory Animal Resources...
...Modify or eliminate the 4 levels of housing...Add euthanasia as a potential way in which to address persistent distress and pain.
Gerald Smith, Eli Lilly Company
A typical Macaca fascicularis less than 10 kg body weight may be 26 inches tall and have a tail length of 18 inches. That size primate would require a minimum perch height of 18 inches and 26 inches of vertical space for a total interior cage height of 44 inches. The current space recommendation for a 3-10 kg primate is 30 inches of vertical space...replacement of cages with a 30 inch interior height will be a significant cost...
IPPL COMMENTS
Even our proof-reader was so upset on reading the comments from primate experimenters that she added a note:
What is the world coming to when we allow ******** like this to have ANY control over the treatment and fate of precious animal lives?
IPPL finds it appalling that any scientist should find it acceptable to keep once free-living monkeys in cages just 30 inches high or even think of chopping off their tails to stuff them into tiny cages.
Many huge drug companies submitted comments. One did not identify itself, but submitted its criticisms through a law firm!
US drug companies often pay their senior officials over a million dollars a year. Yet, any time any attempt is made by government agencies to improve the lives of the primates who help generate these huge profits, we see this kind of firestorm of criticism.
