Scientists Center For Animal Welfare

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Retirement for Laboratory Chimpanzees

1. The Scientists Center for Animal Welfare (SCAW) expresses its support for the concept of retirement of laboratory chimpanzees as outlined in NRC 1997, but SCAW has several concerns over specific clauses found in HR 3514 (Chimpanzee Health Improvement, Maintenance and Protection Act). SCAW is a non-profit, educational association of individuals and institutions whose mission, in part, is to promote the humane care, use and management of animals involved in research, testing and teaching.

2. SEC.481C.(d.2.A) of HR3514 proposes an absolute prohibition of research on chimps placed in the sanctuary program. Although we agree with the NRC report finding that there is a surplus of chimps at the present time, there is no way to predict that this surplus will continue and the situation might occur where there are not enough chimpanzees to fill the needed research proposals. In addition, as these animals age they probably will develop conditions that could be analogous to human conditions and these aging animals could be helpful to explore diseases and other conditions that affect the aging human population. In the present wording of the Bill there would be no way to set up experimental protocols to appropriately study these diseases or use new, experimental therapies. Even in humans with severe diseases, such as Alzheimer’s, it is possible to obtain permission to conduct research, which may aid these people or provide information that would help others. SCAW believes that these animals should be made available for research after an appropriate review process. Since these animals are retired and deserve special consideration, this research should be well justified and be limited to non- or minimally invasive techniques such as MRI, PET scanning, ultrasonography, and the taking of blood or hair samples. It is important to note that these procedures are routinely conducted at times of biannual physical examinations and cause no pain or distress. Furthermore, the NRC Chimpanzee report states on page 18 that more research should be conducted in basic biology and medicine of chimpanzees in order to make them better models of newly emerging diseases. Furthermore, the report states that animals that have been used previously to study a variety of diseases (such as HIV and hepatitis viruses) are the preferred model for studying new viruses. Animals not needed today and placed in long-term care facilities would seem to be the ideal subject for some critical research, increase our knowledge of diseases and processes of aging and would, at the same time, preserve naïve animals for other critical research and for breeding.

3. SEC.481C.(d.2.D) specifies that these chimpanzees be cared for in accordance with the Animal Welfare Act (AWA). SCAW is concerned, however, that this provision does not go far enough in that there is no requirement for inspections by any of the agencies that monitor, regulate, or report on animal welfare. This concern comes from the fact that many non-profit organizations that run animal shelters do not meet even the minimum standards established under the AWA or NIH policy. We would suggest that in order to give the public confidence that these animals are cared for properly, these sanctuaries be regulated and licensed under the AWA which would include regular inspections by the USDA. In addition, we are proposing that these sanctuaries be required to be evaluated by an independent peer review system. This is in agreement with a similar recommendation of the NRC report Chimpanzees in Research: Strategies for Their Ethical Care, Management, and Use (NRC 1997).

4. SCAW agrees that chimpanzees should be housed in species-normal, demographically diverse, compatible social groups. In the wild and in captivity, these groups consist of males, females, juveniles, and infants. However, we agree that pregnancies should be prevented, but we do not agree that breeding should be curtailed (as stated in SEC. 481C. (d.2 E)). Social-sexual interactions are a normal part of the social life of chimpanzees and should not unnecessarily be restricted. The goal should be to control pregnancy. This can be relatively easily accomplished by vasectomizing the males and/or tubal ligation or use of Norplants(R*) in females. In either case, sexual activity can be sustained.

5. SCAW believes that provisions G, H, and I of section 481C (d2), are inconsistent and unworkable. Part G requires that chimpanzees be monitored for the purpose of detecting diseases of public health importance. Part H requires that chimpanzees posing such threats be contained according to CDC standards. Part J prohibits the release of chimpanzees from the system. It is inconceivable that animals known, or determined, to shed viruses such as HIV or HCV would be housed in sanctuaries. Animals known to be a public health risk should remain in appropriate biomedical facilities, or be returned to a biomedical facility if later determined to be a risk to personnel or to other animals in a sanctuary. The public health risk, and the extremely high cost of providing suitable biocontainment facilities within the sanctuary, is neither logical, humane, nor fiscally responsible.

6. Provisions should be clearly included in the Bill for the acceptance of privately owned and government owned animals. Furthermore the definition of eligible sanctuaries needs to be broadened to include all facilities that after review and inspection currently comply with the AWA.

7. The scientific expertise for the management of these animals should lie within NIH. Therefore they are the best qualified to decide the selection of the sanctuary and the management of these animals should be overseen by NIH.

8. In summary, we feel that although the chimpanzees selected for these sanctuaries may make no current or foreseeable contributions to biomedical research with the rapid advances in biomedical technologies, these animals may prove to have a high value to the scientific community. Their future availability for reassignment to research as stated above is important to biomedical advances that benefit society.

9. SCAW urges Congress, the public, and NIH to work together to establish a sanctuary system that provides optimal captive housing for the greater good of many chimpanzees while allowing flexibility for public safety and ultimately human health.