Scholars Respond to IOM Report on Animal Research

by Tom Beauchamp, PhD
Hope Ferdowsian, MD, MPH
and John Gluck, PhD

Triggered by a Congressional request last year by Senators Udall, Harkin, and Bingaman, the National Institutes of Health (NIH) asked the Institute of Medicine (IOM) to form a committee to evaluate the current and future need (“necessity”) for federally funded research on chimpanzees. The report of this committee was issued today.

The report concludes that recent advances in alternate research tools indicate that use of chimpanzees as research subjects is now generally unnecessary, but it leaves open the possibility that some research may be necessary. It also presents clearer and more specific guidelines than we have seen from federal agencies. It is a clear advance in the clarification and examination of the major issues about necessity.

However, despite the steps forward, the report is superficial in its treatment of the most critical issues in the literature on the use of chimpanzees in research, namely the moral justification of chimpanzee research. Necessity, after all, did not generate the current controversy; that framing is an NIH-filtered reading of the issues. The moral permissibility and moral justification underlies every issue about necessity.

The report starts out on a promising note:

“[T]he 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.” (p. 2)

The report goes on to insist that “the use of chimpanzees should face the most stringent requirements for justification regarding when, if ever, the use of chimpanzees in biomedical research is necessary.” (p. 15)

We concur with the noble sentiment presented here, and we acknowledge that a report that included serious ethical analysis could have been written from this framework. Unfortunately, this report does not itself provide anything approximating a “greater justification” or “stringent requirements for justification.” In this regard, the report makes no serious advance. It never presents a moral justification for conducting research on chimpanzees other than the necessity of their use in order to advance our scientific understanding and to potentially provide benefits to public health. Only human interests play a role in this justification; there is no detailed discussion of the many costs to the chimpanzees as subjects; and, yet, as this IOM Committee correctly notes, the problem of harms to chimpanzees and their moral status is what gave rise to the controversy to which this report is responding.

The following is made a necessary condition—or “criterion”—of the use of chimpanzees in biomedical research: “The research in question cannot be performed ethically on human subjects.” The problem with this criterion is that it begs the most critical issues that ought to have been addressed in the report. The fact that it is unethical to perform the research on humans does not render it ethical to perform the research on chimpanzees, nor does the unavailability of human subjects contribute to the justification of use of chimpanzees. There is a huge gap that the report does not address.

This report inadvertently heightens the importance of this problem. The report repeatedly states how close chimpanzees are to humans in anatomical structure, in cognitive structure, and even in moral capacity to act altruistically. Given that a chimpanzee is as close to a human being as this report correctly indicates a chimpanzee is, it is hard to understand why the same level of protections should not be provided to chimpanzees as are provided to humans. It is disappointing that the report never addresses this central issue.

We note that the report also does not specifically address recent intentions and efforts by the National Institutes of Health to move chimpanzees from the Alamogordo Primate Facility in New Mexico to a private facility in Texas, from virtual retirement to use in invasive research. Again the report does not engage a major issue at the heart of the present controversy that led to the formation of this IOM committee.

As the authors of the IOM study are aware, the United States is the last developed country to permit invasive research on great apes. Almost all other countries have, for ethical reasons, placed significant restrictions or bans on the use of chimpanzees in invasive research.

Chimpanzees are emotionally sensitive and intelligent beings. Chimpanzees are creative, cooperative, and empathic; and they can outperform humans (1, 2) in certain cognitive tasks. Chimpanzees communicate vocally with each other, and some have learned American Sign Language.

Chimpanzees suffer significant harms as a result of their use in invasive research. A laboratory environment does not provide for chimpanzees’ extensive social and personal needs. Even laboratories that provide social housing beyond the standard 5x5x7 foot cage cannot provide anything that approximates a natural life for a chimpanzee. As a consequence, many chimpanzees living in laboratories develop unmistakable signs of post-traumatic stress disorder (PTSD) and depression, similar to symptoms exhibited by humans affected by PTSD and depression. These conditions may go untreated during a chimpanzee’s lifetime of 50 or more years.

Recent articles and editorials in leading scientific journals, including Nature (1, 2), Scientific American, and Science, have highlighted the problems with chimpanzee research, and some editorial boards have called for a ban on invasive chimpanzee research.

As the IOM report points out, existing regulations do not provide adequate protection for these animals. We therefore make the following recommendations:

1. Like children, prisoners, and institutionalized human populations, chimpanzees should be viewed as members of a vulnerable group.

2. The implications of this vulnerable status should be addressed using methods and regulatory rules that are fundamentally similar to those used for children, prisoners, and other vulnerable groups in U. S. federal regulations. This might lead to one or more of the following outcomes: exclusion from research; involvement as research subjects only if there is minimal risk to the subject; or involvement in research when potential benefits to the individual exceed risks for harm to the individual.

For more information about chimpanzees and the debate surrounding chimpanzee research, please visit:

Note: Observations in part derive from from a meeting entitled, “Understanding Harms and Their Risks in Animal Research — The Case of Chimpanzees,” held on October 11 and 12, 2011, which included scholars from fields including ethics, primatology, human and veterinary medicine, biological sciences, and psychology. The meeting was convened as part of a multidisciplinary project funded by the National Science Foundation, with investigators from Georgetown University, Physicians Committee for Responsible Medicine, and The George Washington University.

Contact Hope Ferdowsian, MD, MPH, for further details.