The joint letter from the Council on Governmental Relations (COGR) and the Association of American Universities (AAU), dated August 3, 2015, presents comments on a petition urging the United States Department of Agriculture (USDA) to introduce specific ethologically appropriate standards for nonhuman primates in research settings. The letter responds to requests that the Animal Welfare Act (AWA) regulations be amended to require research facilities to provide environments that more closely align with the natural behavior of these primates, setting explicit minimum standards. COGR and AAU argue that current regulations are already effective in promoting the psychological well-being of nonhuman primates and are regularly updated according to prevailing professional standards and oversight by institutional and federal entities.
The associations reference data from the Association of Primate Veterinarians indicating high rates of social housing for primates in research facilities, with minimal single housing, which is strictly reviewed and regulated. They contend that the proposed regulatory changes are unnecessary, would impose unwarranted costs, and might hinder or prevent essential primate research. COGR and AAU assert that determinations about the appropriateness of environments should continue to rest with attending veterinarians and institutional oversight, rather than being dictated by new federal standards targeting research facilities specifically. The letter concludes by urging the USDA not to proceed with the proposed rulemaking, cautioning that such changes would primarily serve anti-research agendas and undermine biomedical research without a substantive scientific basis for reform.
