Marolt to Streiffer on Housing

Below is another post from Rick Marolt. I supplied the title. The 'Housing' bit is simply to tag it with a term that will distinguish it from other possible future related posts.

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I have asked Rick Bogle to elevate this comment to a main post because 1) some issues raised in the discussion merit more visibility and 2) I want to encourage other people to participate in the discussion. Many people read this blog. What do you think of these issues? See the original post and comments here.

Rob Streiffer:

Second, I asked whether IACUCs have the authority to address ethics questions. I argued that they do and fail to understand your basis for saying that IACUCs "are constituted by law not to make ethical decisions." To which federal regulation are you referring? At any rate, it is misleading to say I made this claim "without providing evidence," as I cited examples of rules from the U.S. Government Principles which require IACUCs to frequently make ethical determinations about animal housing and about whether the value of the research justifies the harm to the animals. Perhaps you disagree with my argument here, but I did make one.

I cannot tell what statement of mine you think is misleading. I wrote: "The committee claimed, without providing evidence, that they make ethical decisions all the time." I think that statement is true. I see no such evidence in your statement or Sandgren's statement and I do not recall hearing such evidence at the committee meeting. Citing rules that require the ACUCs to do something, which you have done, is not evidence that they actually do it. Saying that the ACUCs do something, which Sandgren has done, is not evidence that they actually do it.

After the ACUC meeting last January, I asked Sandgren for evidence: minutes of meetings where specific experiments were approved, documentation of decisions not to approve an experiment because the benefits were not projected to exceed the costs, and evidence that benefits of completed experiments exceeded their costs. Sandgren was not able to provide such evidence.

Rick Bogle has responded to the point about ACUCs and ethics. Note also that the Animal Welfare Act, which contains the requirement of research organizations to have ACUCs, says: "Such members shall possess sufficient ability to assess animal care, treatment, and practices in experimental research ..." and the responsibilities listed have to do with assessing animal care, treatment, and practices. Members are not required to have expertise in ethics. The words "ethics" and "ethical" do not appear in the AWA. The AWA says nothing about larger ethical decisions such as whether or not experimenting on a given species is ethical, and those are the decisions that I am talking about.

ACUCs exist to ensure compliance with federal regulations concerning the treatment of non-human animals. They operate within a system that assumes that keeping monkeys in cages for their whole lives, giving them diseases, birth defects, and brain damage, and killing them are acceptable actions. (You might say that the ACUCs decide case-by-case when these things are ethical and when they are not. But the ACUCs have approved very many experiments of these kinds, and I am aware of no evidence that the ACUCs ever find such experiments unacceptable or unethical.) There is a deep, underlying assumption that treating monkeys in a certain way -- much differently from how we treat people -- is acceptable. The ACUCs do not question that assumption.

Let's imagine that UW-Madison keeps people in small cages their whole lives and conducts injurious and fatal experiments on them. I question the ethics of experimenting on people. You say "We make ethical decisions all the time about how to house the people and we approve experiments only when we think that the value of the research justifies the harm to the people." Most reasonable people would say that you missed the point. And you're missing the point about monkeys.

I did not mean to say that the ACUCs cannot or should not (or even do not) make ethical decisions, only that ACUCs are constituted primarily to make other decisions. My wording probably could have been better. And, yes, decisions about housing can have an ethical component. But what about a bigger question such as whether or not experimenting on a given species is ethical? That's the question that matters most. And you have argued that the ACUC should not even try to answer it. So all this talk about the ACUCs making ethical decisions is pretty minor quibbling and not very relevant to the bigger issues.

Except ... your statement includes this excellent paragraph:

IACUCs are required by law to prohibit any research that is not in compliance with what are referred to as the U.S. Government Principles. Principle VII requires that “the living conditions of animals should be appropriate for their species and contribute to their health and comfort.” It would thus be within the IACUC’s jurisdiction to prohibit research with a species if they concluded that appropriate housing conditions on campus could not be secured. (Imagine a researcher trying to bring chimpanzees onto a campus that can only secure funding for cages of the size typically used for macaques.) A decision about the appropriateness of housing conditions, which falls squarely within the jurisdiction of an IACUC, can amount to a prohibition on a certain kind of research. An even clearer, second, example comes from Principle II, which requires that “procedures involving animals should be designed and performed with due consideration of their relevance to human or animal health, the advancement of knowledge, or the good of society.” So if an IACUC finds that procedures involving animals do not produce sufficiently important knowledge, then it is within the IACUC’s legitimate authority to prohibit that research.

So let's ignore the bigger issues for a moment and just focus on housing, since you have brought it up. Both you and Sandgren have cited the U.S. Government Principles. Now, there is much evidence that monkeys suffer in their little cages, that they get chronic diarrhea, and that they mutilate themselves out of boredom and isolation. Some people say that the monkeys become neurotic or even go insane. A former UW-Madison veterinarian has written:

Each monkey was kept alone, in a cage that was so small that he/she could not take a few steps in one direction, let alone jump or run in monkey fashion. There was no companion to huddle, groom or play with.

It should be remembered that macaques are primates - just like us - who have an intensive need for social contact and social interaction. Solitary living conditions are similarly unbearable for them as it would be for us.

Most cages were completely barren, offering not even a perch that would have allowed the animals to make use of the arboreal dimension. In the wild, macaques spend most of the day in elevated sites - away from ground predators - and seek the refuge of trees at night.

When kept in cages without a high perch, the animals have no way of retreating to a "safe" place during alarming events, such as when a staff member approaches them. Being cornered in this manner must, indeed, be a very distressing experience for a helpless monkey who associates people with painful and distressing handling procedures.

In order to accommodate as many monkeys in one room as possible, cages were arranged in double-tiers with one row stacked on top of the other. This condemned half of the animals to confinement in a permanently shady, cave-like environment. Needless to say, this was not a living quarter that was suitable for diurnal animals.

The conditions I witnessed were so depressing that most monkeys had developed stereotypic behaviors such as pacing, rocking, bouncing, somersaulting, swaying from side to side, biting parts of their own bodies, pulling their ears, tossing their heads back and forth, or smearing feces on the cage walls. (Viktor Reinhardt, "The Impossible Housing and Handling Conditions of Monkeys in Research Laboratories")

It's impossible to argue that the monkeys' housing is "appropriate for their species and contribute[s] to their health and comfort". (Please don't tell me that the little enrichment that the monkeys receive makes their housing appropriate for their species and contributes much to their health and comfort.) If the ACUCs make ethical decisions all the time about things like housing, when are they going to correct this situation? And if they cannot correct it, isn't it time for a "decision about the appropriateness of housing conditions" that "can amount to a prohibition on a certain kind of research"?

If your argument means anything, this topic will be on an upcoming ACUC meeting agenda and the committee will consult with experts before making a decision.

Let's talk about Principle II, which you brought up. If a utilitarian standard is used, only actual benefits matter, not just knowledge (unless you're going to argue that the satisfaction that a few people get from gaining and having knowledge justifies the suffering and deaths of monkeys). So I would revise your sentence: "If an IACUC finds that procedures involving animals do not produce sufficient benefits, then it is within the IACUC’s legitimate authority to prohibit that research."

Paul Kaufman and Eric Sandgren have said that there is a "low hit ratio" in translating basic science into health benefits, and one survey of 25,000 articles concluded that that hit ratio is just about 0% (W. F. Crowley, Jr., Am J Med 114, 503 - Apr 15, 2003), so there must be a lot of research that should be prohibited.

If your argument means anything, then the ACUCs will identify research that does not produce substantial benefits and prohibit it.

While I'm critiquing the ACUCs, I must note also that they are required to "represent society's concerns regarding the welfare of animal subjects". Evidence that many people and organizations in Madison have deep concerns about experimenting on monkeys became clear during discussion of Resolution 35 on the Dane County Board of Supervisors last summer. But UW-Madison declined, with the help of your statement, to study the ethical issue and it fought hard against Resolution 35. How and when do the ACUCs at UW-Madison represent society's concerns regarding the welfare of animal subjects? (If you, like I, distinguish the main ethical question from welfare issues, note that the scope of Resolution 35 included treatment of monkeys.) Please don't tell me that just having one or two ACUC members come from outside the UW takes care of this responsibility of the ACUCs.



Third, I asked whether UW was obliged to comply with your request. I argued that it was not. Not because I ignored "all the scientific and morally significant findings about monkeys that raise the ethical question," as you mistakenly say I did. To the contrary, I explicitly acknowledged them.

You did indeed mention some scientific and morally significant findings about monkeys. The committee then ignored the implications of those findings when it chose not to study the ethical issues.



The validity of most or all of your other points is clear and I have no disagreement with them. But they are not very relevant to the main issue.