f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 117 [Entry Date] 04/18/2011 at 09:34:56 AM [Affiliation] Organization [Organization Name] Primates Incorporated (primatesinc.com) [Organization City and State] Madison, WI [Comments] 
Comment 1: Purpose of comment: To discuss and encourage retirement of animals from research by discussing case studies of success stories and methodology from researchers who already are retiring primates and other animals such as cats and dogs under their care Given the fact that several researchers over the years have taken the initiative to plan to retire the primates under their care to sanctuaries, and adopt out dogs and cats involved in non-terminal studies, I am surprised that I could not find a discussion on primate retirement or laboratory animal adoption anywhere in The Guide. I used to be a primate researcher for five years – while I worked there, I discovered how intelligent the rhesus monkeys were. I believe there are enough similarities between monkeys, chimps, and humans, that the monkeys deserve the same respect and accommodations as chimpanzees, including funding for their retirement whenever a retirement scenario arises. I wrote the NIH several years ago about primate retirement and they told me they take primate retirement "very seriously". The reality is that the NIH only takes the retirement of chimpanzees seriously – not all primates. There is funding only for great ape retirement through the CHIMP Act, and inquiring about funding for retiring other primates (or even bringing up the possibility of retiring primates) can be frowned upon by senior management, and employees are easily intimidated and forgo the retirement option. Additionally, a research veterinarian told me that the NIH is using the 3Rs to justify continued re-use of primates over retiring them to reputable sanctuaries; they argue that retiring a monkey goes against the 3Rs. I believe this to be a negative interpretation of the 3Rs and think there needs to be a fourth R added to the 3Rs to avoid future confusion: Reduction, Refinement, Replacement, and Retirement Admittedly, there are some sanctuaries that have had their problems – largely because of underfunding and lack of funding available for animal retirement. If funding is available from the research facility, it is for transportation and to build an enclosure, and the sanctuary is left providing and paying for the lifetime care of the monkeys which could likely cost $5 per day. Additional consideration to providing funding for the first year of care would be a drastic improvement and would ensure the monkeys would receive the quality care, space, and enrichment a sanctuary is supposed to provide. A quality primate sanctuary can be found if it is accredited by The Global Federation of Animal Sanctuaries or The American Sanctuary Association. Given the fact that there are researchers who are taking the initiatives to retire primates under their care, sanctuaries have and will continue to serve as a vital retirement resource. As we continue to discover how smart primates are (e.g. we have recently confirmed Rhesus monkeys are self-aware), we need to start respecting them more by providing them with retirement options after their time in research. If primate researchers are justifying the use of monkeys because of their similarities to humans, shouldn't the monkeys be considered for primate retirement as chimpanzees are? Sanctuary anecdotal evidence suggests abnormal behavior is drastically reduced if not relieved completely when a monkey is retired to a sanctuary with appropriate space, vegetation, social, and enrichment options. Primates who are not able to be rehabilitated through enrichment, social housing, or medication in the laboratory should be given a chance at primate retirement where research procedures are not present and the environment is much more accommodating to producing naturalistic behaviors. The primates with persistent abnormal behavior should not be re-used in studies – and especially not put in invasive terminal studies as a final way to use them. Please consider the brain chemistry involved in abnormal behavior and that using monkeys displaying abnormal behavior in brain chemistry studies should be discouraged and is likely an overlooked variable. The humane option is to treat monkeys with persistent abnormal behavior by giving them a chance at a more spacious, enriching, peaceful, and naturalistic environment. Indeed all primates, are deserving of primate retirement. Please encourage the retirement of primates (or at least discuss retirement as an option) when the primates are not used in terminal studies or need special accommodations. And please extend the CHIMP Act to cover all primates. Thank you for your time and consideration. Comment 2: Please discuss primate retirement as a part of any animal-welfare training classes.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals