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Draft Principles and guidelines for the care and use of non-human primates for scientific purposes submission

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First Name: 
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De Groot
Option 1 - Online comments
General comments on section/paragraph of the draft NHP Guidelines: 
Role and structure of this document
  • The NHMRC advises that a ban on the importation of primates for research purposes “is outside of this review” however they do state (on page 5 of the consultation) “Great apes must not be imported from overseas for use for scientific purposes.” If they can mandate this for great apes then they should do so for all non-human primates. Long distance transportation of these animals causes further suffering over and above what they will endure in Australian research labs. Furthermore, despite the requirements that imported animals must be captive-bred, it cannot be guaranteed that they will not be derived from wild stock, resulting in broken family and social groups, and stress of capture.
  • The NMRC states that great apes are "the closest species to human beings with the most advanced social and behavioural skills." The policy states that "The use of great apes for scientific purposes in Australia is permitted only when their use: (i) will not have any appreciable negative impact on the animals involved, e.g. observational studies activities already being undertaken for management or veterinary purposes. (ii) will potentially benefit the individual animal and/or their species." Considering there is little difference between great apes and other primates in their capacity to suffer, their cognitive abilities and well-developed social structures, the protections afforded for great apes should be extended to all other primates.
  • The NHMRC acknowledges that “The complex and highly social behaviour and advanced cognitive capacity of many non-human primates make it difficult to adequately provide for their needs in a captive environment ore research setting.” At the conclusion of their use they state “Retirement must be considered as an option if suitable in terms of the health and temperament of the animal, and space is available at a facility that can meet their specific physical, social and behavioural needs.” Currently, there is no sanctuary for retired lab animals.  If the use of primates has been funded by the NHMRC then the NHMRC and/or research institution must take responsibility to ensure that the wellbeing of these animals is guaranteed for the remainder of their natural lives. These animals deserve a dignified retirement in return for their suffering.
  • “NHMRC is particularly interested in your views on the need for notification to NHMRC of specified activities involving the care and use of non-human primates.” It is absolutely essential that all use of primates is reported to the NHMRC and that a full database is established to monitor all aspects of their use. This is to ensure there is no repetition of experiments between institutions and that every possible avenue has been explored regarding the sourcing of alternatives. This should be overseen by an expert panel and not left to the decision–making of institutional animal ethics committees which operate independently, are unlikely to have full disclosure of all primate use in Australia and will unlikely be fully conversant of the availability of non-animal alternatives.

Page reviewed: 16 September, 2016