The joint letter from the Council on Governmental Relations (COGR) and the Association of American Universities (AAU) addresses a petition to the USDA requesting the amendment of Animal Welfare Act (AWA) regulations to establish explicit ethologically appropriate standards for nonhuman primates in research facilities. The petition argues that existing regulations allow for excessive discretion by research facilities, potentially compromising the psychological well-being of nonhuman primates, and calls for the USDA to clarify and strengthen regulatory standards. In their response, COGR and AAU contend that current regulations are both adequate and effective, emphasizing ongoing improvements in housing and social environments for nonhuman primates and citing data that the vast majority are socially housed, with rigorous oversight processes in place for exceptions.
COGR and AAU assert that the proposed regulatory changes are unnecessary, lack substantive supporting data, and would result in undue burden and cost for research institutions while targeting well-regulated facilities without scientific justification. They argue that determinations of ethological appropriateness are best left to attending veterinarians in consultation with oversight committees, consistent with existing regulations. The letter concludes by recommending against any rulemaking in response to the petition, suggesting that such actions, absent robust scientific evidence, are more aligned with anti-research advocacy than genuine animal welfare concerns, and would undermine the progress and mission of biomedical research.
COGR and AAU submitted joint comments on the petition to develop specific ethologically appropriate standards for non-human primates in research.
