Bioethics Forum Essay
Missing from NIH Primate Research Ethics Review: the Ethics
Scientists acknowledge biological, behavioral, and psychological similarities between human and nonhuman primates; hence their use as proxies in biomedical research. At the same time, primates are denied many ethical considerations and basic protections afforded to humans participating in research. The National Institutes of Health recently had an excellent opportunity to consider the moral arguments for and against various practices in primate research, but, unfortunately, it failed to take these arguments seriously.
There are more than 100,000 primates currently in U.S. government, university, and private laboratories, many of whom are exposed to traumatic and invasive procedures from birth. Many primates are subjected to maternal separation and deprivation, and standard laboratory housing for primates lacks sufficient space as well as opportunities for meaningful stimulation and social interactions. Recent analyses of primate research facilities show that thousands of primates are singly housed without adequate scientific justification. Primates are infected with deadly diseases and subjected to painful procedures and experimental surgeries, sometimes without pain relief. These practices cause the animals significant physical harm and psychological distress, resulting in widespread abnormal, stereotypical, and self-injurious behaviors. Adding insult to injury, the results of experiments on primates have a dubious record of translation to humans.
In late 2015, in response to high-profile “concerns about the scientific and ethical justifications for maternal deprivation studies involving baby monkeys being conducted in . . . NIH funded laboratories,” U.S. Congress mandated that in 2016 the NIH “conduct a review of its ethical policies and processes with respect to nonhuman primate research subjects, in consultation with outside experts, to ensure it has appropriate justification for animal research protocols.” This was a unique opportunity to reassess our current frameworks in light of recent advancements made in ethics, ethology, and particularly in our understanding of primate cognition and emotions.
In May 2016, the NIH announced plans for a one-day workshop stating their intention to “convene experts in science, policy, ethics, and animal welfare” to “explore the state of the science involving non-human primates as research models and discuss the ethical principles underlying existing animal welfare regulations and policies,” a description consistent with the Congressional request. Unfortunately, once the agenda was released, it was clear that the event would be dedicated to essentially describing current primate research rather than considering its ethical justification. The lineup of speakers included no ethicists or bioethicists, despite the fact that the NIH houses one of the premiere bioethics departments in the world, and employs a leading animal ethicist. Many experts in ethics and primate cognition expressed concerns about the lineup and other deficiencies publicly in the months leading up to the event.
The workshop, whose title indicated a foregone conclusion, “Ensuring Continued Responsible Research with Non-Human Primates,” was held on September 7, 2016. Present were 47 individuals invited by the NIH. Only three of these people were ethicists. They were asked to participate only as discussants, and none of them were given speaking slots. Those who were not invited—despite repeated requests that the event be open to the public—were able to live stream the event via the NIH website.
The event was a celebration of primate research. In addition to opening remarks by NIH director Francis Collins, who commented on primates’ valuable contributions to science, there were 10 presentations; five that discussed the state of science and alleged benefits of primate research and five that uncritically outlined the current oversight process.
Only one talk discussed an ethical framework that could be used for the evaluation of primate research. In that presentation, Ernest Prentice, who explicitly noted that he was not an ethicist, suggested that animal research was justified by “cost-benefit analysis.” Prentice, who is a vocal proponent of primate research and in charge of his university’s animal research program, said that he preferred the term “cost” over “harm” because he did not like the negative connotations of “harm,” but we will use the term harm as it more accurately reflects the relevant public concerns about primate research.
As an event that was specifically mandated by Congress to examine the ethical justification of primate research, the presentation of only one ethical view is clearly inadequate. Harm-benefit analysis, most closely associated with consequentialist reasoning about ethics, is only one among many different ethical views that are discussed in animal research ethics. There was no discussion at the workshop of other ethical views open to the possibility that certain actions might be wrong in virtue of violating autonomy or inflicting great harm. Moreover, just as science is evolving, new theorizing in ethics has introduced ideas that are relevant to research on primates, such as discussions of the ethics of captivity and considerations of whether primates have the capacity to dissent to research, but these ideas were also not discussed.
Though the esteemed ethicists in the audience of the workshop have written extensively about non-consequentialist ethical perspectives, the composition of the workshop panel and particularly the fact that the ethicists were not given speaking roles only allowed for brief pleas for more extensive ethical discussion. The three ethicists in the audience attempted to offer comments to steer the conversations towards ethics during the open discussion periods. The majority of animal experimenters and other sympathizers in attendance inevitably drowned them out.
Importantly, even by the standards of harm-benefit analysis, the workshop dramatically failed in the task mandated by Congress. Prentice suggested that animal research is justified if the harms imposed to animals are balanced by potential benefits to human health. It follows then that a genuine attempt at justification would make an effort to assess the harms that occur in primate research, such as those mentioned above, since doing so is necessary for weighing harms against benefits. Yet, despite numerous talks highlighting potential human health benefits of primate research, there was no discussion throughout the entirety of the workshop of any of the potential harms to the animals.
Merely describing the benefits of an action does not qualify as a review of its ethical justification. In fact, an argument could be made that precisely what sets ethical behavior apart from living purely in accordance with self-interest is the fact that living according to an ethical perspective means that there are some constraints on what actions we should take even when those actions have benefits. There are many experiments that could be conducted, on children, on prisoners, on pregnant women, that could have potential benefits for society, but which we as a country nevertheless deem wrong.
At the end of the event, it became clear that any critical assessment of primate research was unwelcome and would be minimized by the workshop organizers. The NIH scientist who was responsible for organizing the workshop concluded the event by summarizing the public comments that were submitted through the NIH website before and during the workshop. She explained that the comments covered 11 general themes, five of which were supportive of continued primate research. However, a close examination of all 281 comments submitted shows that only 14 of them (fewer than 5 percent) were in any way supportive of primate research. In fact, the majority of comments opposed primate research for ethical reasons, were concerned about the workshop’s biased participants and lack of allotted presentations on alternatives, and/or suggested more stringent restrictions for primate research.
Here’s why this matters. In 2015, for scientific, legal, and ethical reasons, invasive biomedical research on chimpanzees was essentially banned in the U.S. This followed reviews by the National Academy of Sciences and the NIH that determined the NIH’s ongoing chimpanzee research was “unnecessary,” that the existing animal research oversight system failed, and that standard laboratory conditions were insufficient to ensure the psychological well-being of chimpanzees. The same problems still exist for other primate research and the NIH is refusing to address it.
Congress asked the NIH to review the ethics of primate research, but the NIH failed to do so. There is an urgent need for such a review in light of changing societal views, current science on animal welfare, research translation failures, and the availability of alternatives to primate research.
Stacy Lopresti-Goodman, PhD, is the director of the honors program and an associate professor of psychology at Marymount University in Arlington, Va. Adam Shriver, PhD, is a Fellow at the Center for Neuroscience and Society at the University of Pennsylvania.