The joint letter from the Association of American Universities (AAU) and the Council on Governmental Relations (COGR) responds to a USDA request for public comment on a petition proposing amendments to the Animal Welfare Act (AWA) regulations. Specifically, the petition asks for the development of specific, ethologically appropriate standards for nonhuman primates used in research. In their response, AAU and COGR express skepticism regarding the necessity and scientific basis for such regulatory changes, arguing that current standards already adequately ensure the psychological well-being of nonhuman primates, as demonstrated by ongoing compliance and enhancements made in consultation with attending veterinarians and regulatory bodies. The letter cites data indicating the majority of primates are socially housed, with single housing being both rare and subject to rigorous oversight.
The organizations caution that the proposed amendments—requiring new minimum standards for "ethologically appropriate" environments—are unnecessary, potentially costly, and risk hampering valid scientific research without tangible benefit. They assert that existing procedures, including oversight by institutional veterinarians and routine USDA inspections, already fulfill the intent of the law. Furthermore, they argue that regulations should not single out research facilities as distinct from other sectors such as dealers or exhibitors. In conclusion, AAU and COGR recommend against initiating rulemaking based on the petition, warning that such actions, absent robust scientific justification, could undermine biomedical research and inadvertently support anti-research agendas.
