In March 2015 QAD sponsored a special “What is Queen’s Hiding?” event for Freedom of Information Day, calling on Queen’s to release information about the numbers and types of animals used in research at Queen’s, and the nature of the experiments conducted on them. The University continues to refuse to release this information. However, the University Veterinarian was prompted to organize a workshop of research administrators from across Canada, as well as PR experts from Oxford University and other institutions that have faced scrutiny and criticism concerning their practices and governance around animal research. After attending this workshop, Dr. Stephen Archer (Head, Department of Medicine) wrote a blog discussing the calls from QAD and other groups for greater transparency, and the lessons he learned from the workshop on how to respond to such requests. While the blog represents Dr. Archer’s personal views, not official University policy, we believe it is representative of a more general mindset amongst research administrators, and hence is worthy of careful analysis.
Although intended as a defense of the University’s system of governing animal research, Dr. Archer’s blog is in fact a testament to its inadequacies. This response will focus on four general areas of concern: claims regarding transparency, research ethics, scientific rigour, and governance.
Dr. Archer says that his “blog attempts to provide some transparency around the use of animals in research requested by animal rights groups, including a local organization, Queen’s Animal Defence.” The information QAD has requested includes: How many animals, of which species, does Queen’s use for research and education purposes each year? (This would include not just animals used in actual procedures, but animals used in breeding facilities; animals used to train researchers in killing techniques; animals killed because they are surplus, or the wrong size, and so on.) The information requested also includes general descriptions of the kinds of research being conducted on animals – not proprietary information that risks academic freedom – but general information that would allow the public to understand the broad nature and purposes of the research being conducted. Year by year statistics would also allow the public to see if Queen’s is in any way meeting its commitments to reduce and replace the use of animals in research. Dr. Archer’s blog offers no information, or “transparency” of this kind.
So what does his blog offer? As Dr. Archer sees it, the purpose of openness and transparency is to “demystify” animal experimentation, to ensure that the public is “educated regarding the benefits derived from this enterprise”, and to ensure that research using animals continues to be “conducted in an environment where society is polarized” because “for the foreseeable future the value of animal based research is unassailable”. Dr. Archer seems to have confused the concept of “transparency” with the concept of “spin” (or PR).1 He thinks that Queen’s should dole out carefully filtered information to the public, not to allow them to develop a critical understanding of the case for or against animal research, but rather to assuage their growing anxieties about it.
To this end, he provides a one-sided discussion celebrating the ‘successes’ of research (most of it very dated), which provides little insight into contemporary scientific or ethical debates around the use of animals in research. On the one hand, he exaggerates the benefits of animal research: if a treatment for human disease is developed which used animals somewhere along the line, then animal research must be credited with the success, regardless of whether it was crucial to that development or might have been replaced by a non-animal approach. On the other hand, he attributes the costs – such as the thousands of ‘cures’ for cancer and stroke derived from animal studies which have failed human clinical trials – as the result of sloppiness (“sloppy science and overstatement of results”, leading to “flawed conclusions”), not to any deeper problems with the very premise of biomedical science that focuses on developing ‘animal models’ for human disease. This rosy picture of animal research is at odds with a growing body of evidence – published within the leading medical journals – which suggests that the successes of animal research have been systematically exaggerated, and the costs and failures systematically ignored. Dr. Archer does not discuss any of this evidence.
This, then, is Dr. Archer’s conception of “transparency”: it is not about revealing the numbers, types and goals of animal experimentation taking place, so that members of the public can judge for themselves whether animal research is being governed in ways that accord with public values. Rather it is about crafting a PR message to sell to the public about the benefits of animal research; a message that is at best one-sided, and at worst contradicted by growing evidence. It’s disturbing that the ideas of open and transparent inquiry fundamental to a democratic society should be so easily distorted in this way. After all, scientists are supposed to conduct their own experiments with an open mind about the status of any given hypothesis, seeking out and testing it against evidence which might disprove it, and then sharing the results widely in order to allow others to challenge, test and disprove. We need a similarly open and robust debate about the ethical and political questions at stake in animal-based research.
Ethics & Science
Dr. Archer claims that “Queen’s University has strict policies to ensure the care of animals in research and enforces adherence to a policy that reduces, replaces and refines the use of animals (the 3Rs), as feasible.” The policies to which he alludes are the guidelines established by the Canadian Council on Animal Care (CCAC), which claims to act as an independent voice “in the interests of the Canadian people”, but in fact has no democratic mandate or oversight. It is controlled by animal researchers, and its stated goal is to “support members [i.e. researchers] and participants in their activities”, and “to generate a nation-wide conversation and enhance the general consciousness of Canadians surrounding ethics and care in animal-based science”. This involves identifying “key messages” and “speaking with a clear and unified voice”. Once again, the goal is spin, not critical discussion.2 Indeed, the CCAC conducted an internal review in 2013 which issued a scathing report, describing the system as operating in a “governance vacuum”, with “significant structural deficiencies”, and concluding that the “CCAC seems to be governing to keep animals in science rather than reducing or refining the need” (cited in Janara, p. 666).
It’s true that Queen’s claims to be committed to the 3Rs, but there is simply no mechanism for monitoring, measuring or enforcing the commitment to replace animals in research, either by the CCAC, or its local arm, the University Animal Care Committee (UACC). As Dr. Archer notes, when the UACC reviews an experimental protocol, it is “scrutinized to ensure pain is minimized, anesthesia is adequate, endpoints are humane and sample size is no larger than required for appropriate statistical analysis of results”. Note what is not scrutinized. Does this research repeat studies that have been conducted elsewhere? Does it address the many concerns that have been raised (in peer-reviewed scientific journals) in recent years about the problems in applicability/translation to humans of research based on animal models? Does it address the many concerns which have been documented (in peer-reviewed scientific journals) concerning the widespread failure of animal studies to meet even basic criteria of scientific reliability and validity? Does this research address a matter of profound importance to human health? Is the researcher fully informed about alternatives to the use of animals and their possible applicability to his/her area of inquiry? If the researcher has harmed and killed animals in previous research, did it deliver the social benefits that were promised (as measured, for example, by citations of the work, or development of new drugs or treatments which have passed human clinical trials)?3
Queen’s claims to be committed to replacing the use of animals in research, but in fact the number of animals used is almost certainly on the rise. (The latest Canada-wide statistics report a dramatic increase. Queen’s doesn’t release its own stats.) Queen’s claims to be committed to the use of alternatives “as feasible”, in Dr. Archer’s words. However, the university doesn’t even subscribe to the leading journals on alternatives to animal use. And it recently turned down a major private donation to establish a Centre for the Development of Alternatives (similar to existing centres at John’s Hopkins, Harvard, St Mary’s London, Konstanz and elsewhere). In other words, the Queen’s research community doesn’t want to be involved in the development of alternatives, and it sees no need even to be informed about them.
A recent (peer-reviewed) meta-review of neuroscience research using non-human primates (NHPs) – including the kinds of research performed at Queen’s – came to devastating conclusions about the willful ignorance and tunnel vision of researchers, and the superficiality of their claims of benefit for their research. It is worth quoting in detail:
“NHP experiments – in neuroscience, as well as in many other areas of biomedical research – are conceived, funded and conducted on the basis of a general assumption of human relevance and eventual benefit. This default position is maintained superficially, on the basis of opinions of those who practise NHP research, and anecdotal claims of worth that fail to withstand scrutiny, or which, at the very least, are controversial” … “In defending their practices and in condemning any criticism (or even questioning) of them, many NHP researchers overstate the human relevance of neuroscience research, involving NHPs, its contribution to human neuroscience in the past, its current necessity, and its likely future contribution, with little or no substantiation. At the same time, there is a gross understatement of the contribution of human-based research to neuroscience, the significance of what this has achieved, the powerful and ever improving performance of non-invasive methods, the scope of what can be done in humans (both non-invasively and invasively), and the significance of species differences between monkeys and humans. This defence of NHP neuroscience, based on an inflated portrayal of its importance alongside undervalued and denigrated alternatives to it, is consequently poor and misleading.” (pp. 62-63)4
We see many of these rhetorical strategies (anecdotal claims of benefit, overstatement of benefits, gross understatement of the role of alternatives) in Dr. Archer’s blog. Meanwhile, Queen’s continues to use thousands of animals in research, including hundreds of monkeys for neuroscience experiments. For example, in a recent study at Queen’s5, 4 female monkeys (on hormonal replacement therapy after removal of their ovaries) were given skull injections of pancreatic peptide (YY3-36), an appetite suppressant, to see how their food intake would be affected through the course of simulated menstrual cycles over extended months. Some of the monkeys ate half of what is required to maintain a healthy weight. In another experiment6, 3 female monkeys were surgically implanted with a head restraint to enable monitoring of eye movement, immobilized in restraint chairs, and required to perform hours of repetitive visual tasks. They were trained and ‘motivated’ to do the task by being denied access to fluids except as a reward for performance. Before doing the visual task they were administered with the drug methylphenidate to assess its effect on working memory and motivation.
These examples are typical of the kind of research conducted at Queen’s. Dr. Archer makes the misleading claim that “The reality of drug approval (in the USA and Canada) is that extensive preclinical study in multiple animal species is legally required prior to entering clinical trials in humans”. This is true, but it is quite irrelevant to understanding much of the research conducted at Queen’s, which has nothing to do with preclinical testing. It is basic research, conducted, as the authors of the ALTA study note, “on the basis of a general assumption of human relevance and eventual benefit” which is “maintained superficially”, and fails “to withstand scrutiny”. Nobody is “legally requiring” Queen’s researchers or anyone else to conduct this research. Researchers do these experiments because this is what they are trained to do, this is what their peers reward by way of grant proposal approvals, and this is how they get the publications which advance their careers (regardless of whether or not they are ever cited). This process requires that scientists show that they have framed a novel hypothesis, and an experimental protocol to test that hypothesis. It does not require that scientists make any case for the significance or relevance of their work beyond this identification of a knowledge gap. As Dagg and Seidle argue, ending this animal-based research wouldn’t result in a loss of meaningful knowledge, but rather would free up millions of dollars to be directed towards “effective [human-based] clinical research” (p. 211).
The experiments described above involve monkeys who have lived their whole lives in labs (some are 12-14 years old), often in isolation (although monkeys are a profoundly social species), deprived of every normal activity that monkeys engage in (climbing a tree; enjoying the sun or rain on their face; playing, fighting, grooming or comforting friends, caring for babies), subjected to invasive procedures, dosed with powerful non-therapeutic drugs, and denied food and water for extended periods of time. While it’s true that between experimental procedures, these animals are, as Dr. Archer notes, “housed in facilities that are clean”, and are often cared for by lab technicians who care about them, there is nobody with power or responsibility to raise any difficult questions about why these studies are being conducted, and whether or how they can possibly be justified.
Dr. Archer notes that animal experiments are overseen by the University Vet, who can stop experiments if they go off the rails. However, the Vet is part of the system, not an advocate for animals. Indeed the Queen’s Vet is himself an animal researcher, who recently published a study on a new procedure for surgically implanting receptor plates in monkeys’ heads to facilitate the attachment of metal halos to hold the equipment necessary for performing electrophysiological recording experiments.7 The equipment is described as “practical and useful”, given “the stability, simplicity, immediate usability, and low profile” of the device. Testing this device required keeping the monkeys in social isolation for 6 months so that they wouldn’t injure each other with the metal halos, while the stability of the implants was assessed. Undoubtedly, if monkeys are to spend their days immobilized in restraint chairs, with metal halos implanted in their heads to hold cameras while they perform constant repetitions of visual tasks in order to ‘earn’ access to the water they need for survival, then it may be better for them to have more easily accessed implant plates which grow permanently attached to their skulls instead of the other methods which are unstable, and prone to infection causing chunks of the monkeys’ skulls to die and fall off, leading to death. Such an innovation may be (partly) motivated by a desire to spare monkeys from intense trauma, and may indeed marginally improve ‘animal welfare’. But attention to ‘welfare’ in this situation has nothing to do with ethics, or scrutiny of the purpose, value and justification for subjecting monkeys to such lives in the first place.
If researchers themselves are unable or unwilling to adopt an impartial perspective on the scientific or ethical merits of animal-based research, and if the role of the UACC and its commitment to the 3Rs are mere window-dressing – what does an alternative governance system look like? One obvious route is suggested by Dr. Archer’s blog. He notes the historical importance of the Helsinki Declaration on ethical principles for medical research involving human subjects, instantiating principles such as consent (direct or through guardians) for invasive research, and requirement of direct clinical benefit for individuals undergoing invasive or harmful procedures. Combined with the Hippocratic oath (first do no harm), these basic principles are at the core of ethical biomedical inquiry and practice.
Beyond these basic ethical principles, how should animal-based research be governed in a democratic society? Who should judge the social value of medical research using animals? Who should make decisions regarding its costs and benefits, and how are these to be assessed? How should research be governed to ensure that it is conducted in the public interest, and not in the interest of professional researchers and the biomedical industry? How should these decisions be held accountable to the public?
Notice that all of these questions are central to the governance of research involving human subjects, and we have transparent regulatory structures in place to ensure that they are. Furthermore, Queen’s has many experts working on such questions central to ethics, political philosophy, and democratic theory who work on issues of open and transparent governance, and its foundational role in a democratic society. (Unfortunately, they weren’t invited to offer their expertise at the workshop.) The first step is for Queen’s to create an independent body to review the existing regulatory framework, and to propose a new framework based on sound ethical and democratic principles of independent oversight and regulation, open access to information, evidence-based decision-making, and genuine public consultation and participation.
1. A recent article in the Queen’s Journal suggests that this may represent a larger problem amongst Queen’s administrators, who prefer to hoard and manage information, rather than sharing it to ensure open and accountable governance.
2. For a detailed critical analysis of the CCAC’s history and role, see Laura Janara (2015), “Human-Animal Governance and University Practice in Canada”, Canadian Journal of Political Science 48/3: 647-673.
3. For research demonstrating that biomedical research studies conducted in Canadian Universities have negligible citation rates and scholarly impact, see Anne Innis Dagg and Troy Seidle (2004) “Levels of Citation of Nonhuman Animal Studies Conducted at a Canadian Research Hospital.” Journal of Applied Animal Welfare Science 7 (3): 205–13.
4. Jarrod Bailey and Katy Taylor, (2016) “Non-human Primates in Neuroscience Research: the Case Against its Scientific Necessity” (ALTA 44: 43-69).
5. Papadimitriou, Maria, Alicja Krzemien, Philip Hahn and Dean Van Vugt (2007) “Peptide YY3-36-induced inhibition of food intake in female monkeys”, Brain Research 1175: 60-65.
6. Oemisch, Mariann, Keven Johnston and Martin Paré, (2016) “Methylphenidate does not enhance visual working memory but benefits motivation in macaque monkeys”, Neuropharmacology 109: 223-235.
7. Azimi, Kousha, Ian Prescott, Robert Marino, Andrew Winterborn, and Ron Levy(2016) “Low profile halo head fixation in non-human primates” Journal of Neuroscience Methods 268:23-30. This is just one of countless experiments conducted at Queen’s and elsewhere to develop ‘a better mousetrap’ when it comes to permanent implants in monkeys’ heads.