save the primates

S ave The Primates A study of the use of primates in experiments Where they come from Life and death in a typical laboratory The experiments The alternatives

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A study of the use of primates in experiments - Where they come from - Life and death in a typical laboratory - The experiments - The alternatives


Page 1: Save the Primates

SaveThe PrimatesA study of the use of primates in experiments�� Where they come from�� Life and death in a typical laboratory�� The experiments�� The alternatives

Page 2: Save the Primates

All primate species are intelligent, some usetools, others show self-awareness and all aregood at problem-solving. Most live in familygroups, in organised social structures. We areprimates.In order to distance ourselves from our closest relatives, werefer to them as the “non-human primates”, which helps us tojustify their use in laboratory experiments.Yet our primate cousins have proved themselves capable oflearning rudimentary arithmetic; they have demonstratedreasoning; some can speak in human sign language. Theyalso display similar emotions to us, such as affection, angerand sorrow – even empathy. However to argue that our similarities justify their use inlaboratories is to ignore at our peril the fundamental differencesat the cellular, genetic and immune system level – differenceswhich are so important to experimental results. Humans share more than 90% of our DNA with most non-human primates, but nature shows us what a difference thissmall percentage can make. However, whilst our fellowprimates differ in their reactions to chemicals and drugs, weare similar enough to comprehend their suffering.When they are snatched from the wild, caged, confined,

transported; restrained, injected with drugs,force-fed chemicals, deliberately brain

damaged - we know they suffer.Yet despite this, and that

more sophisticatedalternatives to theuse of primates areavailable than everbefore, the numbersbeing used aroundthe world is rising. Over 10,000primates will die

in Europeanlaboratories

this year.

A third of primate species are threatened withextinction. As governments in primate home rangesmake desperate efforts to prevent the poor andhungry eating some species to oblivion, the westernresearch community demands the right to takethese species for unnecessary and unreliableexperiments, when alternatives are available.In the South American forests trappers hunt for owl monkeys,to sell for malaria experiments in Colombia. The frightenedmonkeys are torn from the trees, their freedom, and families.Their forest is replaced by the barren factory-type conditions ofa laboratory; some are isolated – torture for a monkey. The unethical and short-sighted nature of snatching animalsfrom the wild, as well as the suffering it causes, wasacknowledged in EU Directive 86/609/EEC on animalexperiments, over twenty years ago. Nevertheless, anestimated 10% of primates in EU labs still come from thewild. Good intent has not been enough. A clear end tothis trade is needed.We welcome the fact that the European Commission, in theirnew proposed Directive to replace 86/609, initially laid out aclear policy that animals from the wild should not be used inlaboratories. However these good intentions have beenfatally weakened, by allowing unjustified and species“exceptions” to the rule. This is unacceptable.It is of concern that up to now, the scientific debate on the useof primates in research has been defensive, generalised anddominated by inadequate evaluation and support forscientifically advanced replacement techniques. Europe must establish a clear policy to end the use of apesand wild-caught primates, with a phase-out of all primate use,setting a standard for the world to follow.

Snatched from the wild


The monkey suppliers

Page 3: Save the Primates

modern standards of accommodation and care on aforeign supplier. For example, Nafovanny in Vietnam is a huge exporter ofmonkeys to Europe and the USA. It is, of course, well outsidethe jurisdiction of the European Parliament or Member States.Behind an initially smart exterior and whitewashed officebuildings, in 2008 ADI found monkeys in small wire mesh penswith concrete floors and little enrichment. This would fall wellbelow modern zoo standards.At the rear of the facility, monkeys were kept alone, in rustycages under a metre tall - the animals could barely stand up.Some cages were in a state of collapse – leaning atuncomfortable, extreme angles. Yet this facility is approved bythe UK’s Home Office as an official laboratory monkey supplier.

The UK’s Animal Procedures Committee has concluded: “The inspectorate has no jurisdiction outside the UK, andtherefore, where animals are supplied from outside the UK, any

site visits by theInspectorate dependson negotiation andcooperation”. In 2005 the UK’sHome Office stated“before primates canbe acquired from anoverseas breedingcentre it is necessaryfor the Home Office tohave appraised andaccepted the use ofthat centre in order toensure compliancewith the section of theHome Office Code ofPractice for theHousing and Care ofAnimals in designatedBreeding and

Whether wild-caught or captive-bred, the majority ofmonkeys used in Europe are imported from China,Philippines, Vietnam, Indonesia, Mauritius, Kenya,Israel and Guyana. The monkeys endure long,arduous journeys, isolated, trapped in small boxes,fearful. The cynomolgus macaque, the most commonly used speciesof lab monkey in Europe, has been described as the macaquespecies least able to respond satisfactorily to transport.Supply facilities in Europe are mainly holding centres formonkeys who come from thousands of miles away. Forexample, the Noveprim facility in Spain is a doorway to Europefor monkeys from Mauritius, where the supplier is known tosupplement its breeding stock with wild-caught animals. Indeed, the vast majority of primates feeding Europe’slaboratories are offspring born of wild-caught parents (referredto as “F1”). Only the prohibition of the F1 animals will putpressure on suppliers not to regard the world’s wild monkeysas their own resource to harvest. The seven year phase out ofthe use of F1 primates in Europe in the proposed Directive toreplace 86/609 must be fully implemented without loopholes; itwould be preferable for this to be brought forward.In addition to the long journeys, consideration should be givento the standards of care and accommodation for these animalsat the supply source, and whether it is possible to impose

Nafovanny, Vietnam: Small rusting cages havefallen over - with monkeys living inside them.

The monkey suppliers

Chimpanzees are so close to us genetically that somescientists have suggested they be reclassifiedalongside humans. However comparisons of genesand immune systems has shown that this close familyconnection is not close enough for us to rely on theresults of chimpanzee experiments for human safety. The US rushed to use chimpanzees for AIDS research inthe 1980s; it was unsuccessful, research followed adifferent course. This left a huge financial burden and achimpanzee welfare crisis. The world has steadily abandoned the use of apes inlaboratories; in the UK and elsewhere, use of apes hasbeen banned for many years and currently no apes areused in Europe. This leaves only the USA with apes inlaboratories. In 2007 the US NIH ended the breeding ofchimpanzees for research.

In its new Directive on animal research, theEuropean Commission proposed an end toapes in laboratories, but this has beeneroded by an “exception”. Those with avested interest have argued that they maywant to use apes in the future, citing forexample, preservation of endangeredspecies. This is a specious argument, itis not practical, nor is it ascientifically sound concept.There would be no point ofcomparison forlaboratory apes;conservation takes place inthe environment, and the

main threats toendangered apescome from human activity. Apes in experiments

The journeys that monkeys endure before they reachEuropean laboratories or holding centres are extremelylong and frequently mean the animals are confined intransport crates for 30 hours at a time.Left: A monkey peers from a small cage at lab monkeysupplier Nafovanny in Vietnam.

Page 4: Save the Primates

Experiments on primates effectively fall into twobroad groups: academic research which is varied,and regulatory testing – required for products to besold on the market – which are standardised.Most of the monkeys arriving in European laboratories areused in the type of regulatory testing that is carried out atHuntingdon Life Sciences (or HLS). One of Europe’s largest commercial animal testing facilities,HLS is contracted by pharmaceutical, chemical, industrial andother companies to perform toxicology (safety/effects testing)and other tests on their products.This is one of the most secretive areas of animalexperimentation. Permits for regulatory tests are granted in‘groups’ and therefore individual sets of experiments are not

scrutinised in advance by regulators. The reports of the testsare the property of the customer. Such experiments are rarely,if ever, published. Between 2006 and 2008 an ADI/NAVS investigator studied theuse of primates at HLS, which has a capacity for around 500macaque monkeys. This study provides a rare insight into howthese monkeys live and die behind closed doors.On arrival monkeys are placed in a stock colony, with up tofifteen animals in a room little more than two metres wide andtall by three metres long, with a small catching cage, 1 metreby 2 metres tall. There is no natural light. These wild animalswould normally live in trees, in large troops of fifty to onehundred monkeys, and might range over 1.5 kilometres in aday. Their HLS home provides an average of one cubic metreper animal. The monkeys are moved to Unit M12 for experimentation.Some are now confined in cages of roughly one cubic metre.Three of these cages may be linked, with three monkeyssharing the space. Their rich natural habitat now replaced by asingle horizontal bar in each cage. These are the conditions provided by European and UKregulation for over twenty years, where it is acknowledged that,“Primates have high intelligence, most have arboreal habitsand all need complex, stimulating environments.” The failure ofthese regulations to uphold standards, and the gulf betweenhow welfare is perceived inside and outside of laboratories, isapparent from our photographs.It would be difficult to describe the housing at HLS as anythingmore than the bare minimum. This is a wealthy company,providing a service to multi-billion pound/euro companies, yetthese highly intelligent animals are provided with just enough tosustain them before they suffer in tests for products. A monkey was discovered with blood on its face and the endsof the animal’s toes were missing. Some staff suggested thatthe monkey had chewed off its own toes, however ourinvestigator noted that the wounds were clean straight cuts,and concluded that the animal was more likely to have trappedits foot in some part of the cage, sliced its toes off trying to freeitself and then put its foot in its mouth. Missing digits were notconsidered to be an uncommon occurrence.

Supplying Establishments (1995 HC 125) pertaining to theimport of primates” , and: “In effect we will only allow the useof animals from overseas centres we believe produce purpose-bred animals to acceptable welfare standards”. In March 2005 an inspection of the Nafovanny facility in LongThanh identified, “shortcomings in animal accommodation andcare” and the centre was notified that its “status as anapproved centre would cease” once all existing orders forprimates had been filled. By the end of 2005 however, theHome Office had received “reassurances and evidence thatsignificant improvements had been made”, and concluded thatNafovanny could meet the required standard. Permission wasgiven for them to continue to supply to the UK. The evidenceupon which this decision was based, was “unedited videofootage, photographs and reports”. The evidence of our 2008 inspection of Nafovanny wouldindicate that assertions of government control over standardsof welfare at foreign suppliers are more of a public relationsexercise, than enforcement of measures to uphold scientificstandards and animal welfare. In the year up to June 2008, at least 476 monkeys weresupplied by Nafovanny in Vietnam to Huntingdon Life Sciences(HLS) in the UK. The monkeys were flown from Ho Chi Minh to France and thentaken by road to England. HLS understood the journey to takeabout 30 hours. On arrival most monkeys were frightened andhid at the back of the box; injuries from the journey includedabrasions to heads and faces.

Primate experiments

Group housing in the stock unit of HLS. This is asgood as it gets for the monkeys who will betransferred to another unit (right and below) forexperimentation. It looks like an impoverished,unregulated zoo, yet these monkeys will be usedfor products for multi-billion Euro clients by acompany that has announced annual sales of€137million with profits of €31.5million.

A barren metal box replaces a stimulating habitatamong the trees for this monkey. Governmentregulations have failed to deliver the welfare standardsthe public expects.

Page 5: Save the Primates

Monkeys had a range of cutsand injuries from the cages, with several requiring veterinaryattention. Scrapes and scratches from being removed fromcages; a chain being used to secure a cage pierced the cheekof a female, leaving her unable to eat and having to be force fedeach day. Others suffered diarrhoea, nose bleeds, or ate andthen vomited their own excrement.Tests we observed used anything from 4 to 72 monkeys and allinvolved the physical restraint of the monkeys, which clearlycaused them distress. It takes three people to dose a small monkey by mouth. The“catcher” pins the animal’s arms, the “legger” takes the legs,and another feeds a rubber tube down the throat to the animal’sstomach and pumps in the test substance.In other tests the monkeys are strapped down in chairs. Forsome the stress is so great that they suffer rectal prolapse,which is a known indicator of stress in restrained primates.During the study of an incontinence drug, three of the monkeysbeing restrained suffered rectal prolapses, and one being usedto test a drug suffered repeated prolapses. During an oral dosing study, several monkeys suffered fromvomiting and salivation on numerous occasions. Severalproduced black-stained urine on their cage floor. One almostchewed off its whole finger and continued to chew its hand afterthe vet had dressed it. Others showed a range of symptomssuch as tugging at chest skin, pushing their fists into theirmouths, trying to bite through the metal food hopper, pushinglarge amounts of sawdust into cheek pouches, chewing metaland dragging teeth along the bars of the cage. Five days later,some showed signs of twitchy feet, indicating a kind of pins andneedles sensation. Several animals were clearly distressed, yet they were orallydosed as normal and returned to their cages. At around thesame time, a study of the same product was started in rats andresearchers had noticed the rats chewing their feet and eatingsawdust. Almost chewing off a finger is a substantial clinicalsign, so as a result the dose for one group was lowered.This demonstrates how predictions of likely severity can bemisjudged. The new European Directive needs to include anew system to report upon unexpected levels of suffering orother events, in order for improvements in protection of animals. An inhalation study provided another example of how theseverity of a procedure can be misjudged:

Over a period of time three monkeys on an inhalation studydied or had to be killed due to partially collapsed and blockedlungs. Three other animals also collapsed but were revived.After death, it was found that these animals had blackenedlungs. Clearly they would have suffered a great deal. An additional fear and stress for laboratory monkeys is thatthey have the ability to anticipate what is going to happen tothem. In the wild, these monkeys are intelligent, they innovate,learn from each other and pass on skills such as cleaning foodor fishing. Yet at HLS caged monkeys were able to see othermonkeys being strapped down and experimented upon.Some monkeys had an incontinence drug pumped into theirstomach every day for a year. Others were bled multiple timesin a day, or day after day – enduring over eighty bleeds.The ADI/NAVS investigator reported that on the days when theanimals were killed and their bodies studied, the othermonkeys would fall silent.Stress and anticipation are both known to affect the outcomesof experiments and distort results.Documents leaked from another contract testing laboratory,Inveresk in Scotland (ADI/NAVS report, 2005), show that duringtests for an asthma drug, monkeys suffered with liquid faeces;redness of face, lips, feet and hands; swollen penises andscrota; a loss of body tone; low heart rate; hernias; they hadbody tremors and a quiet, hunched appearance.

There is an opportunity to end this suffering andimprove science – governments must not waste it.

Above: A monkey huddles in a cage, the meshfloor designed to collect urine for testing.Right: Monkeys are severely restrained forexperiments. For some the stress is so great thatthey suffer rectal prolapse.

Monkeys are able to watch from their cages (in thebackground) as other monkeys are strapped downand experimented upon.

The full report Primate Testing and the DVD Save thePrimates which feature the investigations reported onhere are available from ADI.

Page 6: Save the Primates

Advances in science and technologyprovide non-animal techniques that arefaster, more accurate and of direct relevance topeople.Animal research on the other hand, is outdated and suffers fromthe flaw that all species respond differently to substances.Studies have shown differences between humans andlaboratory monkeys, on average, a third of the time.This was illustrated when the UK test drug TGN1412 causedterrible, almost fatal, and permanent side effects in humanvolunteers. Yet the drug had been given to laboratory monkeysin doses 500 times that given to the volunteers, without sideeffects. Now many agree that this disaster could have beenavoided by using advanced technology – microdosing.

Microdosing involves giving tiny, safe, doses of new compoundsto human volunteers and samples of blood or urine can then beanalysed by Accelerator Mass Spectrometry (AMS). AMScounts individual atoms – it can detect a liquid compound evenif just one litre of it has been diluted in the ocean.AMS can show how compounds have been absorbed,distributed, metabolised and excreted by the human body. TheEU Microdose AMS Partnership Programme recently comparedmicrodosing data to animal tests. It proved to be 80%predictive of human drug absorption and distribution –significantly more accurate than primate, dog and rodentmodels.Adoption of high-level advanced techniques such asmicrodosing/AMS would allow drug development to beaccelerated, accuracy to be improved, and costs cut.Whilst regulatory testing is the largest area of primate usein labortories, it is one section of the overall testingstrategy for new drugs. Therefore primates could be replacedmore easily than was the case for the EU cosmetics testingban, which was more complex because it needed a ‘start tofinish’ replacement strategy.Primates come at the end of the regulatory testing strategy,along with dogs. They fulfil the requirement for tests on asecond mammal, apart from a rodent.This means that by the time the monkeys were being strappedinto restraint chairs for the experiments we have describedoverleaf, hundreds even thousands, of smaller animals wouldalready have died to test the same product.

If the EU and Member States are to take serious steps toreplace animal tests with advanced technology, then it is vitalthat the animal tests be ended earlier in the programme – to bereplaced by advanced methods based upon human data, suchas microdosing. Industry and regulators, and indeed much ofacademia, are inherently resistant to change, but the reality isthat primates are a poor predictor of human responses.

There are now a range of multi-disciplinary, sophisticated techniquesthat allow the safe and accurateexamination of potential effects onhumans (see list). We have seen howimplementation of the CosmeticsDirective has ensured the validationand implementation of replacements

for a range of tests, and as aresult, how it has dramaticallycut animal use.Implementation of

replacements for primates could signal the start of an evolutionthroughout regulatory testing, towards modern methods. Suchadvanced techniques are good for European science andindustry, good for animals, good for people.

Academic experiments in universities, particulalrly neurologicalresearch, is another large area of primate use. These studiescause extreme suffering and can include implanting electrodesand other equipment into the animals’ heads. Often this so-called ‘fundamental’ research does not describe any potentialapplication for human benefit.Yet, advances in modern scanning techniques such as fMRIand MEG are enabling non-invasive neuroimaging of thehuman brain, providing unprecedented understanding of mentalillness, neurodegenerative diseases, vision, hearing, speech,pain and more. This provides data of direct relevance topatients, who can be asked to describe how they feel.In 2008, a meeting at the European Parliament was presentedwith a comparison of data from scanning studies of humanpatients and electrodes implanted in the heads of monkeys.The same level of data was obtained – yet importantly oneset of data was of direct relevance to people.There are no regulatory requirements for these academicexperiments, so this is a field where replacement could be veryrapid. A different approach would be needed for different fieldsof research, but this couldbe achieved through expertconsultation and afocussed, technical review,managed by theCommission, under thenew Directive.

Replacing primates in commercial testing

Replacing primates

Microdosing in combination with Accelerator MassSpectrometry provides a way of safely assessingnew drugs in humans.

Replacing primates in academia

The latest scanning techniques can enable directstudy of the human brain instead of invasiveexperiments on monkeys.

Page 7: Save the Primates

The benefits of some of these new techniques isthat they can build on and advance existingknowledge, rather than simply starting from scratchin a different species. Here are some examples ofmodern techniques that can save primates, advance

human health, and put Europe at theforefront of science.

Microdosing and Accelerator MassSpectrometry (AMS): Giving safe ultra lowdoses to volunteers combined with precisionanalysis (see Replacing Primates).

Computer analysis, simulation, modellingand more: For example QSARs(Quantitative Structure Activity

Relationships) – a computer modelling system, whichcorrelates a compounds’ structure andproperties with its activity; Derek forwindows (DfW) is an expert knowledgebase computer programme that appliesrules; it predicts a chemical’s toxicityfrom its molecular structure; and Highthroughput screening: This involvesrobotics and sophisticated controlsoftware which rapidly analysescompounds for drug discovery.

Human cell cultures:growing human cellsin the laboratory, sothat they reflect howthey work in the body,and how they respondto test compounds.Specialised cellcultures, such as liver,kidney and brain cellsare being used.

Human tissue cultures:Pharmaceutical companies already useliver tissue to provide biological data andsafety test compounds, because thisavoids the problem that animal test datais not a reliable indicator of likely effectsin humans. (It is only governmentregulations that require use of animals inorder for a product to be approved forsale).

3-dimensional (3D)human tissueengineering can beused for drug testing.The scaffold can bemade from syntheticor natural materials,with differing scientificadvantages. Tissuecan be constructed to

Modern research takes place at the genetic and cellularlevel, where new technology allows greater precision thanever before. The fundamental flaw of animal research (anidea now over one hundred years old), is that eachspecies responds differently to chemicals, drugs or otherproducts. This is because of the biological and geneticdifferences between species. It means that we cannot relyupon the outcome of animal tests. For example:� Non-human primates are distinct from us in the way theyexpress genes in the brain, with even major differencesbetween ourselves and chimpanzees.� Human brains have a folded cerebral cortex (a gyrencephalic brain) whereas smallerprimates, such as the marmoset, have a smooth cerebral cortex (a lissencephalic brain). Thereare anatomical differences between these and evidence suggests functional differences, too.� Lower and higher primates differ from one another by a number of structural features in theirnervous systems and sense organs.� The role of the hippocampus in human memory was complicated by findings from monkeysand other animals, until its role was established in 1986 from human study.� Gout is caused by excess uric acid, which is produced in monkeys, apes and humans, butonly humans get gout.� HIV can infect chimpanzees and rabbits, but does not induce disease. Human beings are theonly species to have been found to be susceptible to HIV.� The way drugs break down and are excreted are similar in monkeys and humans, butmetabolism rates differ radically.� The drug chloramphenicol does not have the adverse effect in monkeys and dogs that hasoccured in humans.� Herpes B virus in monkeys may cause lesions on the face, lips, mouth and body, but theycan carry the virus without suffering the disease. In humans, the disease is rare, but almostalways fatal.� The drug azauracil caused no apparent toxic effects in monkeys; in humans, it produced suchunpleasant side effects that it had to be taken out of use.� Aspirin causes birth defects in monkeys, but has been widely used by pregnant women andhas not been shown to produce any kind of malformation.

recreate whole body systems, suchas the artificial immune system.

Biochips: These show the effect ondifferent cells in the body and howtoxicity is altered when thecompound is broken down(metabolized) in the human body.They provide data quickly and cheaply, including data fordifferent human organs.

Toxicogenomics: This seeks to translate data about geneticvariation and gene expression into an understanding of thebiological systems in organisms, including humans, and theeffects of changes in the systems on health.

Post mortem analysis of tissues donated by patients to allowcellular examination of human disease.

Advanced scanning techniques such as MEG and fMRI fordetailed study of patients (see Replacing primates).

some primate species differences


Page 8: Save the Primates

The European Commission has proposed a new Directive toreplace the 22-year-old EC Directive 86/609/EC governing the use

of animals in research. The new directive is to be discussed in the European Parliament’s Agriculture and Rural DevelopmentCommittee in early 2009. It will then go before the full Parliament, followed by the Council of Ministers. This is the first major revisionin over 20 years and provides an important opportunity to advance animal protection and European science.

In 2007 a group of respected MEPs, Jens HOLM (Sweden,European United Left), Rebecca HARMS (Germany, Greens),

John BOWIS (UK, former Health Minister, European People’s Party), Martine ROURE (France, VP of EP, Party of European Socialists)and Mojca DRCAR MURKO (Slovenia, Alliance of Liberals and Democrats for Europe) tabled Written Declaration 40/2007. 433Members of the European Parliament (55%) signed, and every Member State and political persuasion was represented, including manyprominent Europeans: Michel ROCARD, former French Prime Minister; Anneli JÄÄTTEENMÄKI, former Finnish Prime Minister; LuigiCOCILOVO, Gerard ONESTA, Edward McMILLAN-SCOTT, Miguel Angel MARTINEZ MARTINEZ, Mechtild ROTHE and LuisaMORGANTINI, Vice-Presidents of the European Parliament; Joseph DAUL, President of the EPP-ED Group; Monica FRASSONI,co-President of the Green/EFA Group; Francis WURTZ, President of the GUE/NGL Group; Cristiana MUSCARDINI, co-President of the UEN Group; Linda McAVAN and Pasqualina NAPOLETANO, Vice-Presidents of the PES Group.Written Declaration 40/2007 urges the Commission, the Council of Ministers and the EuropeanParliament to use the revision process of Directive 86/609/EC as an opportunity to:(a) make ending the use of apes and wild-caught monkeys in scientific experiments an urgent priority,(b) establish a timetable for replacing the use of all primates in scientific experiments with alternatives.Although the Declaration took a cautious approach to outlining exactly how primates should be replaced,it is widely acknowledged that for the Cosmetics Directive and action on CO2 emissions, it provednecessary to set targets in order to achieve the objectives.It is of great concern that the Commission has chosen to ignore such a mandate, which isbacked by 80% of European citizens who, in a Commission survey, said that they felt thatprimate experiments were “not acceptable”.

The proposedDirective does not

phase out a single primate experiment. There is no mechanism that would establish aformal review process which could consult, investigate and set timetables for thereplacement of primates. Several well intentioned Articles are undermined by loopholes: Aban on the use of great apes in experiments is undermined by spurious “exceptions”. Aban on the use of wild-caught monkeys and the phase out of F1 monkeys (those born ofwild caught parents) both allow for unjustified “exceptions”.

The following wouldachieve the goals of

Written Declaration 40/2007 and meet with public and European Parliament approval:�� A prohibition on the use of great apes (without exceptions). �� A prohibition on the use of wild-caught monkeys (without exceptions).�� Full implementation of a phase out of F1 monkeys (offspring of wild-caught

parents) (although we favour earlier than the 7 years phase-out suggested in the draft).�� Arrangements to replace the use of primates to be established during bi-annual, thematic

reviews setting timetables or objectives for replacement in specific areas.Proposals to protect all animals:�� Bi-annual reviews of the use of animals in specific tests, implementation of advanced

replacements and other key issues – review every twenty years is too long – it means that the legislation does not keep up with developments in science and technology.

�� Improved transparency and public and scientific scrutiny of experiments.�� Improved regulatory testing scrutiny by governments.�� Compulsory data sharing to prevent duplication (as already implemented under REACH). �� Retrospective review of experiments so that the actual impacts of the experiments are judged, and any unforeseen

suffering is reported. �� Independent ethical, scientific and replacement review of proposals to use animals - before authorisation is given.

Animal Defenders International �� National Anti-Vivisection Society �� Lord Dowding Fund for Humane ResearchMillbank Tower, Millbank, LONDON, SW1P 4QP, UK.

Tel: +44 (0)20 7630 3340 Fax: +44 (0)20 7828 2179 e-mail: [email protected] • •

The Revision of EC Directive 86/609

Written Declaration 40/2007

The Commission Proposals on Primates

Proposals to Save Primates