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Response to the Physicians Committee for Responsible
Medicine Petition for Administrative Action
April 8, 2011

Physicians Committee for Responsible Medicine
c/o Mark Kennedy, Associate General Counsel
5100 Wisconsin Avenue, NW, Suite 400
Washington, DC 20016

Dear Mr. Kennedy:

The National Institutes of Health (NIH) has reviewed the March 3, 2011, Petition for Administrative Action submitted to NIH Director Dr. Francis Collins by the Physicians Committee for Responsible Medicine (PCRM). 
Your petition alleges that the decision to transfer 14 chimpanzees to the Southwest National Primate Research Center (SNPRC) in San Antonio Texas was an arbitrary and capricious act in violation of the federal Administrative Procedures Act.  You request that the 14 chimpanzees be returned to Alamogordo Primate Facility (APF).  The information you provided and your requested action have been carefully considered and reviewed. 

We want to remind the Committee that animals used in federally-supported research benefit both human and animal health, and that all animals used in federally-funded research are protected by laws, regulations, and policies to ensure they are used in the smallest numbers possible and with the greatest commitment to their comfort.  All NIH-supported institutions housing chimpanzees, including SNPRC and APF, recently were subject to a site visit by the Office of Laboratory Animal Welfare (OLAW), Office of Extramural Research, NIH and most were conducted in conjunction with Animal Care (AC), Animal and Plant Health Inspection Service (APHIS), United States Department of Agriculture (USDA).  The report dated August 6, 2010, concluded that “the institutions were found to be in compliance with the PHS Policy and the quality of care and commitment to the psychological well-being of the chimpanzees and other nonhuman primates was high.”  https://grants.nih.gov/grants/guide/notice-files/NOT-OD-10-121.html

With regard to the chimpanzees housed at the APF and the decision to move them to SNPRC, the following information is provided with respect to your petition.

  1. Since the establishment of the APF chimpanzee facility, the animals housed there have been supported by NIH’s National Center for Research Resources (NCRR) as a research reserve colony.
  2. There has been an increase in unused space at NIH chimpanzee facilities as a consequence of a breeding moratorium initiated by NCRR in 1995 because of financial restrictions.
  3. The contract that supports the care for the chimpanzees at the APF located on Holloman Air Force Base is due to expire in May of 2011. 
  4. The Use Permit (included as conditions of the contract with Charles River to operate APF) between the Air Force and NIH only permits behavioral observation research to be performed at APF.  Animals needed for other types of research must be moved to another facility and, once removed, animals cannot be returned to APF.
  5. In anticipation of the expected change in facility capacity, in 2006 NCRR began its analysis to develop a long-term plan for the care and maintenance of the animals that would take into consideration cost containment and the availability of the animals for research studies.
  6. The decision to move animals from APF to a facility at the SNPRC is part of this long-term plan.  The cost to NCRR of the contract with APF is significantly higher per animal than the cost at other larger federally funded facilities
  7. In keeping with the long term plan regarding the maintenance of federally owned chimpanzees, NCRR worked with the chimpanzee facility directors on cost effective renovations so that SNPRC could accommodate all animals currently housed at APF.  The plan considered the research environment as well as the cost of ongoing care for the lifetime of the animals. 

In December 2010, well after the 14 chimpanzees mentioned in your petition were moved, the NIH requested the Institute of Medicine (IOM) study mentioned in your petition.  The purpose of the IOM study is to assess the current scientific need for chimpanzees in biomedical research.  The NIH has determined that the chimpanzees currently located at APF will remain there pending the conclusion of the IOM study. 

The NIH has reviewed and discussed the action requested by PCRM in the March 3, 2011, petition. As shown above, NIH followed a systematic and thoughtful process regarding the movement of chimpanzees from APF to SNPRC.  As such, the decision to transfer 14 chimpanzees to SNPRC was not arbitrary and capricious.  The PCRM petition for action is respectfully denied.
Deputy Director for Extramural Research
National Institutes of Health


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