Petition for Rulemaking 

U.S. Department of Agriculture 

May 7, 2014 

To Establish Criteria to Promote the Psychological Well-Being of Primates as Required by the 

Animal Welfare Act (7 U.S.C. § 2143(a)(2)(B)), Including Adopting the “Ethologically 

Appropriate Environments” Accepted by the National Institutes of Health with Respect to All

Primates Used in Research 

Darla at Fauna Sanctuary © NJWight
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Table of Contents 

1. Introduction .................................................................................................................... 3 

2. Description of Petitioners .............................................................................................. 6 

3. Current Regulations Addressing the Psychological Well-Being of Primates ................ 7 

A. The Animal Welfare Act .................................................................................... 7 

B. Amendment Mandating a Minimum Standard to Promote the 

Psychological Well-Being of Primates .............................................................. 8 

C. Current Standards are Unenforceable .............................................................. 10 

4. NIH Actions Promoting Psychological Well-Being .................................................... 19 

A. Institute of Medicine Conclusions ................................................................... 19 

B. Council of Councils Working Group on the Use of Chimpanzees in NIHSupported Research ......................................................................................... 19 

C. NIH-Accepted Recommendations for Chimpanzees ....................................... 20 

5. Adverse Effects on the Psychological Well-Being of Primates Due to the Lack of 

Concrete Standards ...................................................................................................... 33 

A. Introduction ...................................................................................................... 33 

B. Manifestations of Psychological Distress ........................................................ 35 

C. Examples of Nonhuman Primate Suffering ..................................................... 42 

6. Adverse Effects on Scientific Results and Validity ..................................................... 46 

7. Conclusion ...................................................................................................................48 

8. Literature Cited ............................................................................................................ 51 

 
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1. Introduction

The New England Anti-Vivisection Society (NEAVS), the North American Primate Sanctuary 

Alliance (NAPSA), the Laboratory Primate Advocacy Group (LPAG), and the Animal Legal 

Defense Fund (ALDF) petition the Secretary of the United States Department of Agriculture 

(USDA) to exercise its authority under the Animal Welfare Act (AWA) (7 U.S.C. § 

2143(a)(2)(B)) to promulgate clear standards and definitions to promote the psychological wellbeing and appropriate ethological environments for primates used in research. The AWA 

provides that “[t]he Secretary shall promulgate standards to govern the humane handling, care, 

treatment, and transportation of animals by dealers, research, facilities, and exhibitors;” and that 

such standards “shall include minimum requirements...for a physical environment adequate to 

promote the psychological well-being of primates.” (7 U.S.C. § 2143(a)(1) - (2)(B)). 

Current implementing regulations, 9 C.F.R. § 3.81 et seq, allow facilities to develop their own 

“plan” for environmental enhancement “adequate to promote the psychological well-being of 

non-human primates.” Id. To fulfill this requirement of the AWA, the regulations further 

provide that “[t]he plan must be in accordance with the currently accepted professional standards 

as cited in appropriate professional journals or reference guides.” Id. Unfortunately, this current 

requirement is so vague that it lacks any enforceable definition of how to evaluate if such a plan 

is actually effectively designed or implemented in a way that promotes the primates’ 

psychological well-being. While some additional guidance is provided regarding social grouping, 

environmental enrichment, special considerations, restraint devices, and exemptions (see 9 

C.F.R. § 3.81(b) - (e)), importantly, a lack of concrete, measureable, and enforceable definitions 

and criteria within the regulations has resulted in almost no meaningful regulation of the 

psychological well-being of primates used in research, and a lack of congruent application across 

facilities. For the reasons stated herein, the USDA must take action to promulgate enforceable 

standards and criteria to promote the psychological well-being of primates. 

On June 26, 2013 the National Institutes of Health (NIH) accepted recommendations of an NIHconvened Council of Councils (CoC) concerning the “ethologically appropriate environment” for 

chimpanzees used in NIH-funded research – e.g. “captive environments that do not simply allow 

but also, importantly, promote a full range of behaviors that are natural for chimpanzees.” (78 FR 

39741 (July 2, 2013)). The new NIH recommendations are based on scientific evidence and 

expertise from some of the world’s leading experts on chimpanzee well-being. These 

recommendations present a substantiated and clear definition of key components of what is 
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minimally necessary to promote the psychological well-being for primates – i.e. environmental 

enhancement, access to the outdoors, and opportunities for choice and self-determination. With 

this Petition, we urge the USDA to adopt these same, species appropriate standards as the 

“minimum requirements” for a “physical environment adequate to promote the psychological 

well-being” of all primates used in research. (7 U.S.C. § 2143(a)(2)(B)). 

As explained by former USDA Animal and Plant Health Inspection Service (APHIS) Deputy 

Administrator Dale Schwindaman, the USDA and NIH have a history of working “together to 

ensure harmonized animal welfare requirements by those two agencies,” such as the initial 

implementation of the 1985 amendments to the AWA and the Interagency Research Animal Care 

Committee. (Schwindaman, 2011; USDA, 1989). The AWA itself stresses the importance of this 

relationship by providing that the Secretary of Agriculture “shall consult with the Secretary of 

Health and Human Services” prior to issuing regulations. (7 U.S.C. § 2145). 

As a matter of consistency, and to promote harmonization of regulatory approaches to the same 

problems, NIH’s newly accepted recommendations for ethologically appropriate environments 

for chimpanzees provide standards that should be adopted by the USDA for chimpanzees and 

provide a baseline that should be adopted with appropriate modifications for all primates held in 

laboratories. 

As discussed herein, the past two decades have provided ample evidence that clearer, 

enforceable standards are imperative for the USDA to fulfill its statutory mandate of promoting 

and protecting the psychological well-being of primates. As APHIS’s Animal Care’s Primate 

Environment Enhancement Team concluded 15 years ago: 

[E]ducational efforts alone are not sufficient to gain compliance. There 

always exist some facilities that must be compelled by enforcement. . . 

Fairness in government requires that if regulations exist, they are enforced 

uniformly and consistently. . . In order for minimum standards to be 

enforceable, the standards must have definition and structure. It must be 

clear to all facilities when violations occur and enforcement action is 

necessary. The concept of minimum criteria has been useful in 

government regulations because it objectifies what is unacceptable and 

increases fairness. 

(Animal and Plant Health Inspection Service, 1999, emphasis added). 
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The necessity of the AWA’s mandate to promote the psychological well-being of primates was 

clear to Congress when it passed this 1985 amendment; it is even clearer today given the 

overwhelming body of scientific evidence that has been amassed over the last 30 years as to the 

psychological capabilities and needs of primates, our ethical responsibilities towards them, and 

the implications of psychological well-being for scientifically valid research results. Currently, 

primates often develop pathological behaviors and suffer severe stress due to confinement, little 

or no social or mental enrichment, a complete lack of control over their environments, and living 

in an artificial environment where stressors are ever-present, unpredictable, and create learned 

helplessness given the animals’ complete inability to deter, escape, or fight off harm or hardship. 

There is a wealth of information concerning the psychological well-being of primates that was 

not available at the time the USDA regulations for psychological well-being were drafted in 

1991. The NIH’s new recommendations for chimpanzee environments provide a valuable and 

readily available starting point for the USDA to amend Section 3.81 of the AWA regulations to 

upgrade the “minimum requirements” for a “physical environment adequate to promote the 

psychological well-being of primates.” (7 U.S.C. § 2143(a)(1) – (2)(B)). 
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2. Description of Petitioners

The New England Anti-Vivisection Society (NEAVS), founded in 1895, is a Boston-based, 

national animal advocacy organization dedicated to ending the use of animals in research, 

testing, and science education. Through research, outreach, education, legislation, litigation, and 

policy change, NEAVS advocates for replacing animals with modern alternatives that are 

ethically, humanely, and scientifically superior. 

The North American Primate Sanctuary Alliance (NAPSA) is an alliance of sanctuaries 

which meet the standards of care and accreditation set forth by the Global Federation of 

Sanctuaries, and includes Fauna Foundation, Center for Great Apes, Chimp Haven, Chimps Inc., 

Chimpanzee Sanctuary Northwest, Jungle Friends Primate Sanctuary, Cleveland Amory Black 

Beauty Ranch, and the Primate Rescue Center. 

The Laboratory Primate Advocacy Group (LPAG) is comprised of individuals representing 

more than 60 years of experience working with nonhuman primates. Current human members 

have worked in 18 laboratories, zoos, field sites, and sanctuaries. 

Animal Legal Defense Fund (ALDF) is a non-profit corporation founded in 1979 to protect the 

lives and interests of animals through the enforcement of laws enacted to protect animals, and 

through the provision of information to others desiring to protect the lives and interest of 

animals. Based in Petaluma California, ALDF has approximately 100,000 members nationwide, 

including lawyers, law professors, law students, and other individuals interested in protecting the 

lives and interests of primates. 

 
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3. Current Regulations Addressing the Psychological Well-Being of Primates

A. The Animal Welfare Act 

Congress has recognized the increasing need to protect animal welfare through regulation over 

the past five decades. Initially known as the Laboratory Animal Welfare Act (P.L. 89-544), the 

AWA is the first and predominant federal law regulating animals in research. Originally enacted 

in 1966, the law was narrowly focused on curtailing the buying and selling of stolen dogs and 

cats. The statute also directed the Secretary of Agriculture to “promulgate standards to govern 

the humane handling, care, treatment, and transportation of animals by dealers and research 

facilities,” defining “animals” as dogs, cats, monkeys, guinea pigs, hamsters, and rabbits. 

However, in the original Act, the USDA’s regulatory authority was limited to activities that 

occurred “pre-research.” (Adams & Larson, 2012). 

The AWA was amended numerous times in an attempt to “strengthen enforcement, expand 

coverage to more animals and activities, or curtail practices viewed as cruel, among other 

things.” (Cowan, 2012). The 1970 amendment expanded species coverage to include “any live or 

dead dog, cat, monkey (nonhuman primate mammal), guinea pig, hamster, rabbit, or such other 

warm-blooded animal, as the Secretary may determine is being used, or is intended for use, for 

research, testing, experimentation, or exhibition purposes, or as a pet...” (7 U.S.C. § 2132(g), 

Pub. L. 91–579). The amendment also required a standard requiring “the appropriate use of 

anesthetic, analgesic, tranquilizing drugs, or euthanasia...” (7 U.S.C. § 2143(a)(3)(A), Pub. L. 

91–579). The 1976 amendments formally named the statute the “Animal Welfare Act” and 

expanded coverage of the Act in various ways, including to animals in transport and dogs used 

for hunting, security, or breeding purposes. (Pub. L. 94–279). 

Further amendments largely aimed to increase standards and protections for animals, including 

1990 amendments to prevent the buying and selling of stolen pets (see Pub. L. 101–624); 2002 

amendments to expand animal fighting prohibitions (see Pub. L. 107–1711

); 2007 amendments to 

prohibit animal fighting activities (see Pub. L. 110-22); and, 2008 amendments to increase fines 

for violations (see Pub. L. 110–246). 

 

                                                           

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 The 2002 amendment also excluded AWA coverage for birds, rats, and mice bred for research purposes. 
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However, the 1985 amendments to the AWA are considered the most comprehensive, 

“provid[ing] major changes regarding the scope and breadth of USDA’s jurisdiction over animal 

welfare in the laboratory, testing of animals, animals used in higher education (e.g., not food or 

fiber related courses), animals on exhibit and captive marine mammals.” (Adams & Larson, 

2012). Among other critical modifications, the 1985 amendments mandated standards to 

minimize pain; exercise requirements for dogs; the establishment of Institutional Animal Care 

and Use Committees (IACUCs) to oversee animal care and use; the consideration of alternatives 

to animal use when experiments involved pain, suffering, or unnecessary duplication; and 

“minimum requirements” to “promote the psychological well-being of primates.” (See Pub. L. 

99-198 § 1752). 

B. Amendment Mandating a Minimum Standard to Promote the Psychological 

Well-Being of Primates 

The 1985 AWA amendment provided: 

(1) The Secretary shall promulgate standards to govern the humane 

handling, care, treatment, and transportation of animals by dealers, 

research facilities, and exhibitors. 

(2) The standards described in paragraph (1) shall include minimum 

requirements-- 

(B) for exercise of dogs, as determined by an attending veterinarian in 

accordance with the general standards promulgated by the Secretary, 

and for a physical environment adequate to promote the psychological 

well-being of primates. 

(Pub. L. 99-198 § 1752(a)(2)). 

Regarding the psychological well-being of primates, Montana Senator John Melcher, DVM, who 

championed the 1985 AWA amendment, commented: 

I have seen the types of cages used in many facilities to house primates. 

These cages are not much wider than the average shower stall and there is 

hardly enough room to allow the animal to stand erect. Under the new 

provisions, I think we are not only providing humane treatment of these 
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animals, but assur[ing] more confidence in the results in the experiments 

they are used in. 

(Kulpa-Eddy et al., 2005, emphasis added). 

As Jodie Kulpa-Eddy, an APHIS veterinarian, Sylvia Taylor, a former APHIS Field 

Specialist, and Kristina Adams, a USDA Animal Welfare Information Center 

Technical Information Specialist, wrote in 2005: 

The purpose of the 1985 amendments was to set the bar higher. For 

example, the writers knew they wanted to see more primates in larger 

complex cages, housed together with other primates, receiving more 

mental and physical stimulation, and behaving in a more normal manner. 

(Kulpa-Eddy et al., 2005, emphasis added). 

The USDA finalized implementing regulations for the AWA’s psychological well-being mandate 

in 1991. (See Exhibit 1). The regulations require that “Dealers, exhibitors, and research facilities 

must develop, document, and follow an appropriate plan for environment enhancement adequate 

to promote the psychological well-being of nonhuman primates,” and that the “plan must be in 

accordance with the currently accepted professional standards as cited in appropriate 

professional journals or reference guides, and as directed by the attending veterinarian.” (9 

C.F.R. § 3.81). They require that “the environment enhancement plan must include specific 

provisions to address the social needs of nonhuman primates of species known to exist in social 

groups in nature” and the “physical environment in the primary enclosures must be enriched by 

providing means of expressing noninjurious species-typical activities.” (9 C.F.R. § 3.81(a) – (b)). 

The regulations additionally state that those primates “that show signs of being in psychological 

distress through behavior or appearance,” infants and young juveniles, those who are on a 

protocol requiring restricted activity, those housed completely alone, and great apes of a certain 

size require “special considerations.” (9 C.F.R. § 3.81(c)). There is no additional information on 

what such “special considerations” must be. 

Therefore, in contrast to other USDA standards that mandate enforceable requirements – see e.g., 

9 C.F.R. § 3.5(a) “The ambient temperature must not fall below 45°F (7.2°C) for more than 4 

consecutive hours when dogs or cats are present, and must not exceed 85°F (29.5°C) for more 
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than 4 consecutive hours when dogs or cats are present”2 – the only concrete requirement for the 

psychological well-being of primates is the existence of the requisite “plan.” There are no 

specific minimum requirements defined, nor is there any requirement that the facility’s plan even 

be reviewed and approved by the USDA, or, for that matter, that the plan even be submitted to 

the agency.3

C. Current Standards are Unenforceable 

The lack of defined and enforceable minimum standards for the psychological well-being of 

primates has had consequences at odds with Congress’s intent in enacting the AWA and 

subsequent amendments. Valarie Stanley, University of Maryland Francis King Carey School of 

Law professor and former senior staff attorney at the Animal Legal Defense Fund, recounted at a 

USDA sponsored symposium that, although the flexibility for regulated facilities resulting from 

a lack of clearly defined minimum standards was intended to allow facilities to provide the best 

possible care for the animals it has accomplished the opposite result. As she explained: 

What we've said is there needs to be very specific standards so that all 

regulated entities provide at least the minimum of what is required. Even 

under such a scenario, everyone is free to provide and do more for their 

animals, but when you have a situation where you have so much 

flexibility, it actually can result in nonenforcement of the Act. I 

understand there was one License C who told a veterinarian who was 

inspecting him, “You know, with regard to this plan for the psychological 

well-being of primates, there's nothing you can do to me because there's 

nothing in those regulations that tell me what I have to do. So as long as I 

have a plan, that's all that counts and you can't take any other action 

against me.” And I'll bet you that attitude is widely held, especially when 

there are no prosecutions of violations of that requirement. That message 

is out there that you can do whatever you want as long as you have a plan 

on paper. 

(Stanley, 1996). 

                                                           

2 See also, e.g., 9 C.F.R. § 3.6 “(A) Each primary enclosure housing cats must be at least 24 in. high (60.96 cm); 

(B) Cats up to and including 8.8 lbs (4kg) must be provided with at least 3.0 ft2

 (0.28 m2); (C) Cats over 8.8 lbs (4 

kg) must be provided with at least 4.0 ft2 (0.37 m2)...”, 3

 As a result, these plans also are not generally available for public scrutiny under the Freedom of Information Act. 
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In 1989, the USDA informed the public that “[W]e believe that upon promulgation of a final rule 

to amend part 3 [the psychological well-being regulations], all regulated entities will have 

adequate guidance in complying with the Act.” (United States Department of Agriculture, 1989). 

However, several APHIS inspector surveys conducted since the regulations were promulgated 

have demonstrated that this intention has not been borne out. 

The first APHIS survey of inspectors in 1993 noted grave dissatisfaction with the enforceability 

of the regulations. As reported by Kupla-Eddy et al.: 

 One-third of inspectors responded that they were unable to distinguish 

compliance from violation, or enforce these two standards. 

 Nearly half of the respondents believed that exemptions to social grouping 

were being claimed by facilities for “convenience” rather than legitimate 

health or protocol reasons. 

 The majority of respondents believed that the requirement for “special 

considerations” for certain primates had failed to generate the needed 

increase in enrichment or other intervention for these animals. 

 More than one-third of respondents indicated they were dissatisfied with 

how research facilities were implementing primate enrichment. 

 All respondents said that at least half of the research facilities they were 

assigned to inspect were still generally single-housing primates. 

(Kulpa-Eddy et al., 2005). 

A December 1996 USDA/APHIS survey of inspectors similarly revealed that approximately 

45% of inspectors expressed the opinion that it was unclear what facilities needed to do in their 

enrichment plans to be in compliance with the regulations, and nearly 50% of inspectors said that 

criteria were not adequate for enforcement purposes. (Kulpa-Eddy et al., 2005). 
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The 1996 survey noted a significant “lack of clarity and specificity in the standards.” 

(Animal and Plant Health Inspection Service, 1999). In response, APHIS 

recommended improving regulations regarding psychological well-being by: 

 developing guidelines to provide more structure to the existing standards; 

and 

 requiring facilities to demonstrate through documentation continued 

effectiveness of their primate enhancement plans. 

(Animal and Plant Health Inspection Service, 1999). 

In 1996, APHIS acknowledged that the regulations regarding the primate environmental 

enrichment criteria (in Section 3.81) were sowing “confusion among the regulated public 

concerning on what basis they will be judged by inspectors as meeting or not meeting the 

requirements.” (See 64 FR 38145, 38146 (July 15, 1999), emphasis added). 

APHIS conducted follow-up inspector interviews in 1997. The results published in 1999 

revealed similar complaints about the unenforceability of the regulations – i.e., inspectors 

expressed their view that “the standards contain few solid criteria on which an inspector can 

judge the content of a plan as ‘in compliance’ or ‘out of compliance’” and they “had concerns 

about Agency support for particular interpretations or judgment because of the vague language 

and nature of the performance standard.” (Kulpa-Eddy et al., 2005, emphasis added). Another 

problem was the difficulty in proving actual implementation of an enhancement plan, and the 

report noted that inspectors recommended clearer requirements for documentation of 

implementation. Id. 

In the 1997 interviews, again inspectors noted that too many primates were unnecessarily singlehoused. (Kulpa-Eddy et al., 2005). Inspectors also noted that some facilities considered 

enrichment plans adequate simply with the provision of “one perch, one rubber toy, and a few 

grapes now and then for each singly caged primate.” (Kulpa-Eddy et al., 2005). Some facilities 

only made efforts to fulfill one need for psychological well-being, such as the provision of 

limited treats, while neglecting other species’ needs, such as social companionship and agency 

(Kulpa-Eddy et al., 2005). 
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As April Truitt, the Executive Director of the Primate Rescue Center explains: 

Monkeys require a variety of species-typical enhancements to their 

environments and enrichment measures. For their psychological wellbeing to not suffer, monkeys cannot be provided with just one 

enhancement or enrichment to their environment, rather their 

psychological well-being must be addressed through multiple avenues... 

Currently, the USDA regulations regarding psychological well-being for 

primates are not sufficient to provide for the well-being of primates. 

Licensees are not required to enrich primates’ environments by addressing 

multiple or specific needs of each species, thereby condemning many 

primates to live out their lives in barren, lonely, and/or substandard 

environments. 

(Declaration of April Truitt, Exhibit 2 at ¶ 5, 7, emphasis added). 

In 1998, the National Research Council (NRC) issued a report entitled The Psychological WellBeing of Nonhuman Primates, which discussed the essential ingredients required for the 

psychological well-being of nonhuman primates, including social companionship; opportunities 

to engage in species-typical behaviors, postures, and locomotion; freedom from pain or distress; 

and positive interactions with human caregivers. (U.S. National Research Council 1998). 

The following year APHIS’s own Animal Care’s Primate Environment Enhancement Team 

concluded: 

The Animal Welfare Act was intended to promote the psychological wellbeing of nonhuman primates, not just prevent abnormal behaviors from 

occurring . . . most inspectors feel the lives of primates have been 

improved some, but that overall not enough is being done to provide a 

‘physical environment adequate to promote the psychological well-being 

of primates’... Put in a constructive way, facilities should be required to 

enhance the environment of nonhuman primates in a way that promotes 

the expression of a wide variety of positive, normal behaviors. Prevention 

is better than treatment, in mental health as in physical health ... The 

USDA's obligations under the Animal Welfare Act include requiring 

standards aimed at prevention of problems. 
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(Animal and Plant Health Inspection Service, 1999, emphasis in original). 

In response, APHIS issued a Draft Policy to implement these recommendations. (Draft Policy, 

64 FR 38145 (July 15, 1999), Exhibit 3). The Draft Policy included five general elements that 

APHIS considered “critical” to environments that adequately promote the psychological wellbeing of nonhuman primates: (1) social grouping; (2) social needs of infants; (3) structure and 

substrate; (4) foraging opportunities; and (5) manipulanda – i.e., objects that can be moved, used, 

or altered in some manner by the primate’s hands. (64 FR 38147, 38149). The Draft Policy also 

cited “novelty,” “sensory stimulation,” and “control over the environment” as important 

elements of any environment to promote the psychological well-being of primates. (64 FR 

38149). Despite these recommendations and the results of the agencies’ own internal surveys, the 

USDA’s 1991 regulations have yet to be updated. Accordingly, the regulations still provide 

significant – unenforceable – leeway in how facilities meet the psychological well-being 

requirements. 

In addition to the issue of unenforceability, there are numerous other significant problems 

resulting from the absence of crucial definitional language in the current regulations. Further, the 

enrichment plans are not publically available and the wide variety of plans among facilities can 

lead to disharmony of plans. The regulations for psychological well-being can be easily, even 

entirely, circumvented. 

Social housing is an area where the inability of the current language to meet the goals of the 

1985 psychological well-being amendment is especially apparent. As explained by Kulpa-Eddy 

et al.: 

From the Federal Register discussions up to and including the final rule, 

one can see that social grouping was meant to become the default housing 

scheme...Prolonged single caging does not promote well-being, especially 

when it is started at an early age. In one modified preference test, the value 

level of social companionship was so high that primates chose it in lieu of 

food. 

(Kulpa-Eddy et al., 2005). 
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Chance French, current Sanctuary Manager of Jungle Friends Primate Sanctuary with experience 

at multiple primate sanctuaries, concurs with this assessment: 

I have been working with primates for over ten years and can say with 

absolute certainty that primates who have been species isolated or lacking 

in enrichment, be they from labs or ex-“pets”, show higher levels of stress 

and exhibit atypical and self-injurious behavior. These primates are also 

harder to socialize, which, unfortunately, can lead to a continuation of the 

negative effects of species isolation. Special care and attention are 

required to ensure a healthy psychological state for these monkeys. I have 

seen first-hand that although harder to socialize, once monkeys who have 

been species isolated are able to be with their own kind, their 

psychological health improves dramatically. 

(Declaration of Chance French at ¶ 5, Exhibit 4). 

However, unfortunately, social housing is not consistently the default standard. Regulations 

implementing the AWA’s command for “minimum requirements” to insure “a physical 

environment adequate to promote the psychological well-being of primates.” (7 U.S.C. § 

2143(a)(2)(B)), do not require that primates always be housed in compatible social groups – they 

only specify that individually housed nonhuman primates must be able to see and hear nonhuman 

primates of their own or compatible species, unless the attending veterinarian determines that it 

would endanger their health, safety, or well-being. (9 C.F.R. § 3.81(a)(3)). This extremely broad 

interpretation of the concept of “social housing” simply cannot adequately meet nonhuman 

primates’ social needs, which include and are dependent upon touch as one of the primary 

sensory social experiences by which primates communicate and comfort themselves and each 

other. Thus, while primates are known to bond through their cages if this is their only

opportunity for social interaction, this completely unnatural world thwarts the animals’ natural 

needs and behaviors. As explained by Ned Buyukmihci, VMD, a veterinarian with 41 years of 

experience, “meaningful social contact is the core requirement [for psychological well-being] 

that can then be enhanced by other forms of enrichment.” (Declaration of Ned Buyukmihci, 

VMD at ¶ 8, Exhibit 5, emphasis added). 
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“This juvenile male rhesus macaque shows a behavioral distress reaction to permanent confinement in a barren cage. 

He bit his upper arms, wrists and thighs 636 times during a 60-minute video recording.” (Reinhardt, 2008). 

Photo courtesy of Reinhardt, 2008. 

Years after the passage of the 1985 AWA amendment for psychological well-being, inspectors 

still believed that too many primates were unnecessarily single-housed, resulting in “maladjusted 

primates that were passed from facility to facility because of their aberrant behavior.” (KulpaEddy et al., 2005, emphasis added). 

Indeed, a 2011 review demonstrated that studies reporting the amount of time monkeys lived in 

single cages did not significantly change after the passage of the AWA amendment. (Jonathan 

Balcombe, Ferdowsian, & Durham, 2011). Two independent surveys of primate facilities in the 

U.S. demonstrated that in both 1994 and 2003 only about one-third of primates lived with one or 

more companions and two-thirds lived alone. (K. C. Baker, Weed, Crockett, & Bloomsmith, 

2007; Reinhardt, 2008). Another 2003 study documented that 362 rhesus macaques were housed 

individually at the New England Regional Primate Research Center (NERPRC), and of those, 

321 exhibited abnormal behaviors such as pacing and self-injury. (Lutz, Well, & Novak, 

2003). In 2010, it was reported that 70% of more than 4,000 cynomolgus (also known as crabeating or long-tailed) and rhesus macaques housed at six facilities live alone. (Reinhardt, 2010 

pp. 122). 

Unfortunately, this great preponderance of the single-housing of primates remains the case. Over 

approximately a two-year period from 2010 through 2012, at least 25 instances of single-housing 

identified as “unjustified” by inspectors, including the solitary housing of juvenile primates, were 

noted in inspection reports at various facilities, including prestigious universities, such as 
17

Harvard, Georgetown, and Johns Hopkins, and large companies, such as Merck, Covance, and 

Shin Nippon Biomedical Laboratories (SNBL). (See Inspection Reports for Harvard Center for 

Comparative Medicine Site 001 on July 31, 2012 (Exhibit 6), Georgetown University Site 001 on 

May 26, 2011 (Exhibit 7), The Johns Hopkins University Site 003 on May 22, 2012 (Exhibit 8), 

Merck Sharp & Dohme Corporation Site 005 on April 6, 2011 (Exhibit 9), Covance Laboratories 

Inc. Site 003 on March 2, 2012 (Exhibit 10), and SNBL Site 002 on July 10, 2013 (Exhibit 11)). 

In fact, a July 2011 USDA inspection report for SNBL noted that approximately 83% of the 

primates were single-housed without documented exemptions. (See the Inspection Report for 

SNBL Site 001 on July 13, 2011, Exhibit 12). 

According to Kendra Buchanan, LVT, the lead veterinary technician at Jungle Friends Primate 

Sanctuary and a former laboratory veterinary technician, “In my experience, it was common for 

researchers to come up with excuses to avoid the socialization of primates...” (Declaration of 

Kendra Buchanan, LVT, Exhibit 13 at ¶ 5). 

The vast majority of primates at SNBL are single-housed. 

Photos courtesy of People for the Ethical Treatment of Animals, 2011.

Thus, in 2011, at the NIH-sponsored Symposium on Animal Welfare and Scientific Research, a 

participant lamented the obvious – that the housing for primates has not changed in decades: “If 

you show a picture of a primate cage from 40 years ago and a primate cage now, it’s basically 

the same: it’s all metal with a perch added.” (“Animal housing facilities discussion. Proceedings 

of the symposium on animal welfare and scientific research: 1985-2010,” 2011).
18

Clear standards, such as those requiring social housing, would be far easier to enforce and clearer 

to understand, and would help to guarantee that the most basic psychological and behavioral 

needs of these animals are met. 

Setting concrete standards modeled on NIH’s ethologically appropriate environment 

recommendations for chimpanzees, along with concrete criteria for signs of psychological wellbeing and distress, would go a long way to fulfilling the original intent of the 1985 Amendment 

and help enforce this important mandate for a “physical environment adequate to promote the 

psychological well-being” of primates used in research. 

Confinement at the University of Washington. 

Photo courtesy of Stop Animal Exploitation Now, 2012.

 
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4. NIH Actions Promoting Psychological Well-Being

A. Institute of Medicine Conclusions 

In December 2010, at the request of NIH, and in response to Congressional inquiry, the Institute 

of Medicine (IOM), in collaboration with the NRC, convened the Committee on the Use of 

Chimpanzees in Biomedical and Behavioral Research to consider the necessity of the use of 

chimpanzees in NIH-funded research. The Committee completed its report, Chimpanzees in 

Biomedical and Behavioral Research: Assessing the Necessity, in December 2011. The Report 

concluded that “most current research use of chimpanzees is ‘largely unnecessary’ and that any 

future research be guided by a set of principles and criteria.” (National Institutes of Health 

Division of Program Coordination, Planning, and Strategic Initiatives, 2013, emphasis added). It 

introduced the concept of “ethologically appropriate physical and social environments” (Institute 

of Medicine, 2011) – meaning “captive environments that do not simply allow but also, 

importantly, promote a full range of behaviors that are natural for chimpanzees.” (See 78 FR 

39741, 39743 (July 2, 2013)). 

B. Council of Councils Working Group on the Use of Chimpanzees in NIHSupported Research 

In response, the NIH Council of Councils (CoC) formed the Working Group on the Use of 

Chimpanzees in NIH-Supported Research to advise NIH on implementation of the IOM findings. 

NIH requested that the Working Group develop a plan to implement the IOM’s guiding 

principles and criteria for chimpanzee research, analyze the current use of chimpanzees in 

research, assess the placement and size of chimpanzee populations, and review the potential for 

future use of chimpanzees in research. (Council of Councils Working Group on the Use of 

Chimpanzees in NIH-Supported Research, 2013). The Working Group submitted its final report 

to the CoC in January 2013. 

The Working Group recommendations – unanimously approved by the full CoC – concluded that 

any and all theoretical potential future use of chimpanzees must be subjected to a strict 

independent oversight committee to assess whether their use is acceptable, critical, and meets 

IOM guidelines – including housing in an ethologically appropriate environment. 
20

The CoC submitted the report to NIH, and, on June 26, 2013, after considering public comments, 

the NIH accepted nearly all of the CoC’s recommendations, including nine of 10 

recommendations regarding ethologically appropriate environments. These recommendations 

provide concrete minimum standards for environments in which chimpanzees are held, including 

specific physical and social parameters. 

C. NIH-Accepted Recommendations for Chimpanzees

In support of the need for ethologically appropriate environments, the Institute of Medicine 

explained: 

Chimpanzees live in complex social groups characterized by considerable 

interindividual cooperation [cooperation between individuals], altruism, 

deception, and cultural transmission of learned behavior (including tool 

use). Furthermore, laboratory research has demonstrated that chimpanzees 

can master the rudiments of symbolic language and numericity, that they 

have the capacity for empathy and self-recognition, and that they have the 

humanlike ability to attribute mental states to themselves and others 

(known as the “theory of mind”). Finally, in appropriate circumstances, 

chimpanzees display grief and signs of depression that are reminiscent of 

human responses to similar situations. It is generally accepted that all 

species, including our own, experience a chronic stress response 

(comprising behavioral as well as physiological signs) when deprived of 

usual habitats, which for chimpanzees includes the presence of 

conspecifics and sufficient space and environmental complexity to exhibit 

species-typical behavior. Therefore, to perform rigorous (replicable and 

reliable) biomedical and behavioral research, it is critical to minimize 

potential sources of stress on the chimpanzee. This can be achieved 

primarily by maintaining animals on protocols either in their natural 

habitats, or by consistently maintaining with conspecifics in planned, 

ethologically appropriate physical and social environments... 

(Institute of Medicine, 2011, emphasis added). 

These conclusions also apply to other species of nonhuman primates for which extensive studies 

have shown high levels of psychological abilities and needs. (See e.g., Bekoff, Allen, & 
21

Burghardt, 2002; Bekoff & Sherman, 2004; Bekoff, 2003; Bradshaw, Capaldo, Lindner, & 

Grow, 2008, 2009; Capaldo & Bradshaw, 2011; Ferdowsian et al., 2011; Marino, 2002; 

Tomasello & Call, 1994). 

Further studies of mammalian brains elucidate the complexity and overlap of primate brains. 

(Bradshaw et al., 2008, 2009; Capaldo & Bradshaw, 2011). For example, other nonhuman 

primates such as macaques, that are commonly used in research, share many cognitive abilities 

(M. Kavanagh 1984 pp.13); have active minds (Shumaker & Beck, 2003 pp.24); have inquisitive 

natures (Shumaker & Beck, 2003 pp.24); are inventive (M. Kavanagh, 1984 pp.173); are 

sociable (Cawthon Lang, 2005; M. Kavanagh, 1984 pp.169; Redmond, 2011 pp.13, 111; 

Maestripieri and Hoffman, 2012); have caring relationships (Redmond, 2011 pp.9); make and 

use tools (Shumaker & Beck, 2003 pp.118,121); have a culture (M. Kavanagh, 1984 pp. 173; 

Redmond, 2011 pp.13, 20); have complex emotions (Shumaker & Beck, 2003 pp.147); analyze 

past results, imagine different outcomes, and experience regret (Melnick, 2011); appear to 

understand others’ perceptions, thoughts, and feelings (Santos, Nissen, & Ferrugia, 2006); and 

have a sense of justice and fairness (Brosnan, 2006, 2013). 

According to Brian Hare, Ph.D., a biological anthropologist at Duke University, who testified 

before the IOM, “Most of what you know about great apes is also true about monkeys.” (Keim, 

2013). Accordingly, like chimpanzees, the well-being of other nonhuman primates is dependent 

upon a social and complex environment, foraging opportunities, outdoor access, access to 

vertical dimension, and choice and self-determination, among other things (Chamove, Anderson, 

Morgan-Jones, & Jones, 1982; Kavanagh, 1984; Redmond, 2011; Reinhardt, 2008). (For more 

background information, see exhibits 14 – 21.) Therefore, because other nonhuman primates 

share many of the characteristics that the IOM and NIH believe warrant greater protections and 

the provision of ethologically appropriate environments for chimpanzees, these other nonhuman 

primates are, borrowing the words of NIH Director Dr. Francis Collins, also worthy of “special 

consideration.” (National Institutes of Health, 2011). Therefore, all laboratories should be 

required to provide all nonhuman primates such basic ethologically appropriate environments, 

with modifications specific to each species. 

Indeed, applying species-appropriate standards based on the NIH-approved recommendations for 

ethologically appropriate environments for chimpanzees to all primates used in research will 

help USDA meet one of its originally stated aims: “To administer and enforce one uniform body 

of regulations at all research facilities regulated by the Act [AWA].” (USDA, 1989). 

Accordingly, these recommendations, as discussed below, should be adopted for chimpanzees as 
22

stated below and accepted by NIH, and, with appropriate modifications, for all primates held in 

laboratories as the “minimum standards” necessary to promote the psychological well-being of 

primates, within the meaning of the AWA. (7 U.S.C. § 2143(a)(1) - (2)(B)). 

NIH-ACCEPTED RECOMMENDATIONS FOR CHIMPANZEES HELD IN 

CAPTIVITY AND THEIR APPLICATION TO ALL PRIMATES 

Set forth below are those NIH-accepted recommendations that should be applied to all primates 

used in research, as further explained in the discussion following each recommendation. 

NIH-accepted recommendation 1: Chimpanzees must have the 

opportunity to live in sufficiently large, complex, multi-male, multifemale social groupings, ideally consisting of at least 7 individuals.

Unless dictated by clearly documented medical or social 

circumstances, no chimpanzee should be required to live alone for 

extended periods of time. Pairs, trios, and even small groups of 4 to 6 

individuals do not provide the social complexity required to meet the 

social needs of this cognitively advanced species. When chimpanzees 

need to be housed in groupings that are smaller than ideal for longer 

than necessary, for example, during routine veterinary examinations 

or when they are introduced to a new social group, this need should 

be regularly reviewed and documented by a veterinarian* and a 

primate behaviorist.4

Discussion 

In its acceptance of this recommendation, the NIH stated that it “also believe[s] that 

housing chimpanzees in larger groups has the potential to offer greater social complexity 

and more environmental stimuli than housing them in smaller groups. At the same time, 

the agency believes that chimpanzee facilities should evaluate individual chimpanzees to 

determine their suitability for successful integration into larger social groups...The NIH 

believes that the recommendation is sufficiently flexible and permits facilities to adjust 

                                                           

4

 This recommendation also states that “[t]he Working Group defines a ‘veterinarian’ as a licensed, graduate 

veterinarian with demonstrated expertise in the clinical care and welfare of nonhuman primates (preferably 

chimpanzees) and who is directly responsible for the routine clinical care of the animal(s) in question.”
23

the sizes of research chimpanzee social groups as necessary, as long as these facilities 

support any downward adjustments with proper documentation and regular reviews by a 

veterinarian and a primate behaviorist. (National Institutes of Health, 2013 pp.6; Exhibit 

22, emphasis added). 

Accordingly with very few exceptions, all primates should be socially housed. The only 

exceptions to social housing being those nonhuman primates who are known to be 

solitary in nature and those very few who would be adversely affected by such an 

arrangement due to their independently documented physical, behavioral, or social state. 

Even orangutans, which have classically been thought of as a solitary species in the wild, 

benefit from social housing in captivity (Orangutan Husbandry Manual, Chicago 

Zoological Society). 

For example, rhesus macaques are the primate species most commonly used in scientific 

research. In the wild, macaques live in large troops that can include up to 200 animals. In 

captivity, rhesus macaques who are paired with at least one other individual show a 

significant decrease in abnormal and anxiety-related behavior compared to isolated 

individuals (Baker et al., 2012). 

The critical need for social housing is supported by APHIS’ 1999 Draft Policy, the 

accreditation standards of the American Zoological Association (AZA), and the standards 

of the Global Federation of Animal Sanctuaries (GFAS). 

In the 1999 Draft Policy, APHIS stated that: 

According to our research, primates are clearly social beings and social 

housing is the most appropriate way to promote normal social behavior 

and meet social needs. In order to address the social needs of nonhuman 

primates under §3.81(a), the plan must provide for each primate of a 

species known to be social in nature to be housed with other primates 

whenever possible...Housing should maximize opportunities for a full 

range of species-appropriate contact, except that reproduction may be 

limited or prevented entirely. 

(64 FR 38147). 
24

Similarly, the AZA standards for exhibitors state that: 

All animals must be housed in enclosures and in appropriate groupings 

which meet their physical, psychological, and social needs. Wherever 

possible and appropriate, animals should be provided the opportunity to 

choose among a variety of conditions within their environment. Display of 

single animals should be avoided unless biologically correct for the 

species. 

(AZA 2013 Accreditation Standards and Related Policies 1.5.2, Exhibit 23). 

GFAS concurs: 

Animal group composition shall be appropriate for the species and 

sufficient to meet their social and behavioral needs in terms of size, age 

and sex structure based upon the natural history of the species housed... 

(2009 GFAS General Animal Care Standards (I)(o)(i)(b)(iv), Exhibit 24). 

NIH-accepted recommendation 2: Chimpanzees must be housed in 

environments that provide outdoor access year round. They should 

have access to natural substrates, such as grass, dirt, and mulch, to 

enhance environmental complexity. 

Discussion

In its acceptance of this recommendation, NIH stated that it “believes that research 

chimpanzees need year-round access to natural substrates and the outdoors to enhance 

their environmental complexity.” (National Institutes of Health, 2013 pp. 9). This 

recommendation should apply to all nonhuman primates, subject to the temperature and 

environmental needs of the species, whose psychological well-being would be greatly 

improved by year-round access to the outdoors. It is supported by GFAS standards which 

state that “[a]ll animal enclosures shall provide animals access to, and choice between the 

indoor and outdoor portion of their enclosure unless otherwise advised by the 

veterinarian/animal care manager.” (2009 GFAS Operational Standards (f)(8)(a)(ii), 
25

Exhibit 25). Even for tropical species, such as marmosets and tamarins, outside 

enclosures can be equipped with heating lamps or easy access to heated indoor spaces 

when temperatures drop to freezing or below. 

NIH-accepted recommendations 3: Progressive and ethologically 

appropriate management of chimpanzees must include provision of 

foraging opportunities and of diets that are varied, nutritious, and 

challenging to obtain and process. 

Discussion

APHIS’ 1999 Draft Policy highlighted the importance of foraging for primates, and both 

a nutritionally and psychologically-appropriate diet. APHIS’ 1999 Draft Policy explained 

that: 

In the wild, nonhuman primates spend a significant proportion of their 

time foraging for food. ‘Working’ for food is one of the most frequently 

found species-typical activities for nonhuman primates. Captive 

nonhuman primates that are not provided with enough time-consuming 

foraging tasks may self-mutilate, over-groom, or become aggressive. As 

part of enriching the physical environment [ ], the plan should provide for 

each primate to have, on a daily basis, some type of time-consuming 

foraging opportunity...The diet for each primate should contain a variety 

of tastes, smells, and textures. 

(64 FR 38149). 

The AZA standards further state that “[t]he institution should have a written nutrition 

program that meets the behavioral and nutritional needs of all species, individuals, and 

colonies/groups in the institution. Animal diets must be of a quality and quantity suitable 

for each animal’s nutritional and psychological needs.” They further provides that “[t]he 

institution should assign at least one person to oversee appropriate browse material for 

the animals.” (AZA 2013 Accreditation Standards and Related Policies 2.6.2 - 2.6.3). 
26

Likewise, GFAS standards provide that “animal diets shall be of a quality, quantity and 

variety suitable for each animal’s nutritional and psychological needs...Where 

appropriate, fresh browse and produce shall be provided daily as dietary supplements and 

enrichment for the animals.” (2009 GFAS General Animal Care Standards (I)(o)(ii)(a)). 

NIH-accepted recommendation 4: Chimpanzees should have the 

opportunity to climb at least 20 ft (6.1 m) vertically. Moreover, their 

environment must provide enough climbing opportunities and space 

to allow all members of larger groups to travel, feed, and rest in 

elevated spaces. 

NIH-accepted recommendation 5: Chimpanzees must be provided 

with materials to construct new nests on a daily basis. 

Discussion

Cages should provide nonhuman primates sufficient space and complexity to carry out 

varied behaviors. In its June 2013 announcement, NIH stated that it agrees that 

“sufficient square footage is needed for chimpanzees to travel, patrol, coexist in social 

groups of 7 or more members, and sometimes separate from others...” (National 

Institutes of Health, 2013 pp. 7). All nonhuman primates need space for these and similar 

species-specific behaviors. 

The AZA standards likewise provide that “[a]ll animal enclosures (exhibits, holding 

areas, hospital, and quarantine/isolation) must be of a size and complexity sufficient to 

provide for the animal’s physical, social, and psychological well-being; and exhibit 

enclosures must include provisions for the behavioral enrichment of the animals.” (AZA 

2013 Accreditation Standards and Related Policies 10.3.3, emphasis added). 

APHIS recognized the importance of these recommendations in its 1999 Draft Policy, 

which provided that: 

The most basic components of the physical environment are the enclosure 

structure (its size, shape, and design) and the substrates within it (flooring, 

bedding, and furnishings, including perches, nest boxes, etc.). In order to 
27

promote psychological well-being for nonhuman primates, primary 

enclosures for housing and/or exercise need to be of adequate shape and 

design, and have adequate furnishing, to accommodate species-appropriate 

behaviors by all inhabitants. Each primate should be able to, at a 

minimum, engage in: 

1. Species-typical postures and positions for resting, sleeping, feeding, 

exploration, and play; 

2. Species-typical locomotion; and 

3. Social adjustments... 

(64 FR 38148). 

The GFAS standards similarly require that “[a]ll animal enclosures shall be of a size and 

complexity sufficient to maximize the animal’s physical, social and psychological wellbeing.” (2009 GFAS Operational Standards (f)(8)(a)(i), emphasis added). GFAS provides 

that “enclosed areas shall be equipped in accordance with the needs of the animals with 

bedding material, branch work, burrows, nesting, hide boxes, pools, appropriate 

substrate, and vegetation and other enrichment materials designed to aid and encourage 

normal behavior patterns and minimize any abnormal behavior.” (2009 GFAS General 

Animal Care Standards (I)(n)(ii)(iv)). In addition, it highlights the necessity for adequate 

space for natural behaviors observed in the wild for the species and for diversity and 

complexity. 

NIH-accepted recommendation 6: The environmental enrichment 

program developed for chimpanzees must provide relevant 

opportunities for choice and self-determination. 

Discussion

Enrichment is a necessity for the well-being of social, intelligent captive animals. 

APHIS’ 1999 Draft Policy outlined several aspects of enrichment, including 

manipulanda, novelty, control over the environment, and sensory stimulation. The Draft 

Policy stated: 
28

The plan should provide individual primates with the opportunity to 

exercise control over some aspects of their environment. Complex objects 

or environments that can be altered or controlled by the animals provide 

them with enhanced opportunities to utilize their cognitive abilities. 

Examples of control include opening doors and peep holes, moving 

indoors or outdoors, and influencing the temperature and lighting in the 

cage, as well as avoiding noxious stimuli. 

(64 FR 38149, emphasis added). 

The AZA standards likewise provide that the “institution must have a formal written 

enrichment and training program that promotes species-appropriate behavioral 

opportunities,” and that the plan “should include the following elements: goal-setting, 

planning and approval process, implementation, documentation/record-keeping, 

evaluation, and subsequent program refinement.” (AZA 2013 Accreditation Standards 

and Related Policies 1.6.1). 

NIH-accepted recommendation 7: Chimpanzee management staff 

must include experienced and trained behaviorists, animal trainers, 

and enrichment specialists to foster positive human–animal 

relationships and provide cognitive stimulation. Given the importance 

of trainer/animal ratios in maintaining trained behaviors, a 

chimpanzee population of 50 should have at least 2 dedicated staff 

members with this type of expertise. Positive reinforcement training is 

the only acceptable method of modifying behaviors to facilitate animal 

care and fulfillment of management needs. Training plans should be 

developed for each animal, and progress toward achieving established 

benchmarks should be documented. 

NIH-accepted recommendation 8: All personnel working with 

chimpanzees must receive training in core institutional values 

promoting psychological and behavioral well-being of chimpanzees in 

their care. These institutional core values should be publicly 

accessible. 
29

Discussion

These recommendations should apply to all nonhuman primates held in captivity. 

NIH-accepted recommendation 9: Chimpanzee records must 

document detailed individual animal social, physical, behavioral, and 

psychological requirements and these requirements should be used to 

design appropriate individualized chimpanzee management in the 

captive research environment.

Discussion

The USDA should adopt a system to measure individual primates’ psychological wellbeing. Much as the psychological state of non-verbal humans can be assessed, studies 

have shown that the psychological state – including depression and post-traumatic stress 

– can also be diagnosed in nonhuman primates. (Bradshaw et al., 2008, 2009; Capaldo & 

Bradshaw, 2011; Ferdowsian et al., 2011; McKinney, Suomi, & Harlow, 1971; Shively, 

Laber-Laird, & Anton, 1997). 

For example, GFAS requires psychological well-being assessments that document the 

behavioral and psychological well-being of each animal, and include information on 

specific measures taken to ensure the welfare of individual animals. (GFAS, 2009). 

GFAS standards provide that: 

Measures assessed will include: species appropriate behavior, interaction 

with other animals, the animals’ ability to respond appropriately to 

variable environmental conditions, physiological states, developmental 

stages, and social situations as well as adverse stimuli...Stereotypic 

behavior, self injurious behavior, inappropriate responses to various 

stimuli may be evidence of compromised well being and must be 

investigated and a plan to address the concerns must be developed...The 

absence of negative behaviors shall not be accepted as sole evidence of 

well being...A copy of the welfare report shall be kept in the animals’ 

permanent file. 
30

(2009 GFAS General Animal Care Standards (I)(o)(iv)(b), Exhibit 24). 

The scientific literature has analyzed and identified signs of stress, including the cluster 

of symptoms known as “post-traumatic stress disorder.” (Bradshaw, 2008). Psychological 

malady in nonhuman primates can be diagnosed in a similar manner as applied to 

humans. The fields of human psychology and psychiatry have defined behaviors 

indicative of mental disorders that allow for numerous possible diagnoses, as outlined in 

the Diagnostic and Statistical Manual of the American Psychiatric Society. Diagnostic 

and observable criteria apply to humans both able and unable to verbally articulate 

specifics regarding their psychological state. 

Even among verbal humans, there are varying degrees of being able to describe one’s 

state of being. Practitioners in the fields of social work, psychology, and psychiatry learn 

how to assess not only what is said, but the individual’s other behaviors, and set a course 

of therapeutic intervention for symptomatic relief or improvement regardless of the 

patients’ verbal ability to describe their symptoms. A similar set of diagnostic criteria 

should be developed for nonhuman primates. Such criteria can provide a clear picture of 

the animals’ psychological well-being or degree of psychopathology. 

In fact, this area of diagnosis and intervention now comprises a relatively new, and 

expanding, branch of veterinary medical specialization and board-certification called 

“veterinary behavior.” (See American College of Veterinary Behaviorists, n.d.). Indeed, if 

the diagnosis and treatment of animal psycho-behavioral disorders can be successfully 

applied to domesticated cats and dogs, they certainly can also be applied to captive 

primates in labs, who are far more similar to humans. 

Indeed, in light of the sparse availability of specific and clearly defined information on 

what constitutes psychological well-being in nonhuman primates, USDA should develop 

and employ a scale similar to the Global Assessment of Functioning Scale (Exhibit 26) 

used to assess human functioning and improvement. Thus, laboratories should be 

required to assess primates on their arrival at the lab and periodically thereafter. If such a 

scale, coupled with behavioral manifestations of clearly defined indicators of 

psychosocial stress, indicate that an individual primate is suffering, an appropriate 

intervention must be required. If that intervention fails to result in a meaningful 

amelioration of symptoms so that the animal can live in a state of psychosocial 

equilibrium, the primate must be sent to a sanctuary for psychological rehabilitation. 
31

Unfortunately, many research facilities are not familiar with the increasing scientific literature 

regarding psychological well-being, enrichment, and ethologically-appropriate environments for 

nonhuman primates. Employees may lack knowledge of “normal” behavior and psychosocial 

needs of different primates, making the identification of pathologies difficult. For example, if 

several primates in the same facility are exhibiting stereotypic rocking or moving in incessant 

circles, employees may misinterpret this as “normal” behavior, rather than a well established 

indicator of stress or psychosis. (Hugo et al., 2003; Brune et al., 2006). 

According to current USDA regulations, an environmental enhancement plan "must be in 

accordance with the currently accepted professional standards as cited in appropriate 

professional journals or reference guides, and as directed by the attending veterinarian." (9 

C.F.R. § 3.81). However, the actual plans may vary significantly from facility to facility, and 

may not be implemented, partially due to a lack of knowledge in individual institutions and/or an 

institution’s inability to stay current with respect to primatological studies of both captive and 

free-living primates. Current education requirements for veterinarians in laboratories require 

little training in animal behavior and/or enrichments, especially specifically related to nonhuman 

primates. Even the American College of Laboratory Animal Medicine (ACLAM) training 

program does not mention animal behavior or enrichment training. (See American College of 

Laboratory Animal Medicine, n.d.-b – “Experience should involve rodents, rabbits, primates, and 

other species that fairly represent the current practice of laboratory animal medicine, and must 

include participation in the following: disease diagnosis, treatment, and prevention; clinical and 

diagnostic pathology; administration of the institutional animal care and use program; 

interaction with investigators; and animal resource management.” (emphasis added).5 

Veterinarians are required to receive substantially less training and education regarding 

enrichment, psychological well-being, and ethologically appropriate environments than animal 

behaviorists such as Associate Certified Applied Animal Behaviorists (ACAAB), Certified 

Applied Animal Behaviorists (CAAB), and Veterinary Behaviorists. A far more efficient, 

harmonized, and effective system would use the consolidated knowledge of experts as the basis 

for enforceable minimum standards for psychological well-being – as was done with respect to 

the NIH-accepted recommendations for chimpanzees – thus reducing the burden on individual 

institutions to keep up with this highly specialized field of literature. 

                                                           

5

 While animal care makes up 24% of the ACLAM examination, enrichment and species-specific husbandry are 

only two of thirteen topics included in the animal care section. (American College of Laboratory Animal Medicine, 

n.d.-a). 
32

One reason often offered for the lack of more specific regulations for psychological well-being 

and environmental enrichment is the difficulty of developing and applying minimum standards 

for different species and for diagnosing psychological maladies in nonhuman species. However, 

the NIH’s new recommendations for environments for chimpanzees, APHIS’ 1999 Draft Policy 

on Environment Enhancement for Nonhuman Primates, and current literature on the 

psychological well-being of nonhuman primates all demonstrate that minimum standards can and 

should be identified for the betterment of animal well-being and scientific research. Therefore, 

including such minimum requirements in the psychological well-being standard will also benefit 

individual labs that are unable to stay informed about the expanding and extensive information 

concerning these issues. 

 
33

4. Adverse Effects on the Psychological Well-Being of Primates Due to the Lack of 

Concrete Standards

A. Introduction 

All species experience stress, whether it is the result of natural or man-made environments. It is 

well established that nonhuman primates have psychological capacities (mental, emotional, and 

other faculties of subjective experience) such as maternal behavior, facial recognition, moral 

development, play, sexual behavior, fear, aggression, stress and emotion regulation, empathy, 

love, and grief. (Narvaez, Panksepp, Schore, & Gleason, 2012; Panksepp, 1998). Theoretical and 

empirical studies document that brain structures and processes governing consciousness, 

cognition, emotions, sense of self, and other faculties are shared among vertebrates. (Bradshaw 

& Sapolsky, 2006). Patterns of thinking, feeling, and behavior that are shaped through 

relationships, and the associated brain structures affected by trauma (i.e., cortical and subcortical 

areas of the right brain, including the right orbitofrontal cortex, anterior cingulate, amygdala, 

hippocampus, and posterior areas of the right hemisphere) are also consistent across species. 

(Capaldo & Bradshaw, 2011). The key point is the now undeniable proposition that nonhuman 

primates suffer physically and psychologically when subjected to conditions that cause 

comparable suffering in humans (e.g., forced confinement, social and physical deprivation, 

being subjected to procedures without willing consent, torture, threat of death or injury, etc.). 

Indeed, nonhuman primates have been used for decades to explore the effects of environmental 

stress on mind and behavior. (See Shapiro, 1998). Experiments and testing comprise not one 

source, but multiple sources, of physical and psychological stressors. Thus, nonhuman primates 

in captivity routinely sustain one or more traumatic events: premature separation from biological 

and cultural context (i.e., separation from their natural physical, cognitive, emotional, social, and 

cultural environment); attachment disruptions; inadequate care-giving; prolonged deprivation; 

and, in cases of biomedical experimentation, highly invasive psychophysiological insults. 

Laboratory confinement and experimentation are well known to cause severe stress and 

abnormal mental states and behaviors in animals used for research. (Brune, Brune-Cohrs, 

McGrew, & Preuschoft, 2006; Morgan & Tromborg, 2007). 

This unfortunate fact of life for research primates is acknowledged by the IOM, which stated that 

“[i]t is generally accepted that all species, including our own, experience a chronic stress 

response (comprising behavioral as well as physiological signs) when deprived of usual 
34

habitats...” (Institute of Medicine, 2011, emphasis added). Common laboratory routines, such as 

handling, moving and cleaning cages, and blood collection, cause rapid, pronounced, and 

statistically significant elevations of physiological stress indicators such as heart rate, blood 

pressure, and a variety of hormone levels (including cortisol), indicating significant fear, stress, 

and distress. (JP Balcombe, Barnard, & Sandusky, 2004; Meijer, Sommer, Spruijt, van Zutphen, 

& Baumans, 2007). 

In addition, nonhuman primates live in constant fear and uncertainty about if and when they will 

be subjected to an experimental procedure. In the book Why Zebras Don’t Get Ulcers, 

neuroscientist and former member of the IOM Committee on the Use of Chimpanzees in 

Biomedical and Behavioral Research, Robert M. Sapolsky, Ph.D., discusses the “anticipatory 

stress response” for which there is evidence in a number of species such as humans, great apes, 

elephants, dogs, and others. Due to prior adverse experiences, individual animals become hypervigilant, anticipating the recurrence of those experiences – much like adopted dogs that have 

suffered previous traumas flinch when approached by people. These individuals have learned 

from those experiences to identify risks of harm, and to facilitate their own safety, healing, and 

ability to get back to living their lives. (Sapolsky, 2004). 

Nonhuman primates also undergo capture from research cages6; separation from their social 

group and isolation prior to procedure; restraint (“squeeze cage” and stereotaxic devices); 

various organ (including brain) biopsies; injection of potentially allergenic dyes, viruses, 

radioactive, and other substances; and other invasive procedures. This is followed by postprocedure stress: confusion and fear associated with sedation recovery, pain, and nausea from the 

procedure, isolation, and other debilitating stressors associated with serious surgeries and 

medical procedures.7

 This “direct” stress is compounded by other traumatic events and by 

standard laboratory housing conditions that impose unnatural levels of confinement, and that 

commonly deprive, limit, or severely alter the occupants’ opportunities to engage in essential, 

varied, expansive, and self-determined natural behaviors. 

Captivity comprises a fundamental stressor that undermines well-being because of the loss of 

agency – the ability to make choices surrounding one’s life and needs. (Herman 1992). Because 

primates possess inquisitive brains and a strong need for stimulation and investigation, sensory 

                                                           

6

 For example, marmoset monkeys resolutely try to avoid capture from their research cages, during which they 

“easily become stressed and agitated and can cause harm to themselves.” Such routine capture “has been associated 

with increased cortisol, signs of distress and decrease in other hormones in various nonhuman primate species.” 

(Williams, Poole, Katos, & Hilmas, 2008). 

7

 Some brain, cognitive, and behavioral studies are also associated with some of the same steps and procedures. For 

examples, see Kerr, Grayden, Thomas, Gilson, & Burkitt, 2013; Kobayashi, Schultz, & Sakagami, 2010; Ma & He, 

2010. 
35

and motor deprivation in barren and uncontrollable laboratory environments constitutes a major 

stressor. (Brune et al. 2006). The physical conditions of laboratories are harsh and unyielding 

relative to the socio-ecological and psychological conditions to which primates have naturally 

evolved. Prime stressors include physical (e.g., small concrete or metal cages, limited types of 

nutritious, non-endemic food, loud noises), social (e.g., lack of natural family groups, changing 

labs and loss of companions, isolation), and psychological (e.g., boredom and lack of appropriate 

stimulation) stressors; maternal deprivation; and uncertainty, pain, and fear when anesthetized 

and forcibly subjected experiments. In many cases, social interaction with other members of their 

own species and the stress relieving comforts primates can and do provide each other are not 

possible. (Hurst, Barnard, Tolladay, Nevision, & West, 1999; Olsson & Dahlborn, 2002). This 

irregular or lack of regular safe social support (i.e., intra- and inter-facility moving as well as 

moving from the pet or entertainment industry to laboratories), in situations where these traumas 

occurred, constitute additional stressors. 

B. Manifestations of Psychological Distress 

Laboratory conditions and experiences involving diverse experimental procedures and frequent 

anesthetics commonly lead to acute and long-term mental and physical breakdown. As such, 

stress can result in both psychological damage as well as severe physiological consequences for 

an individual. Different species and individuals of any species have different stressors, variable 

ranges of stress to which they are able to adapt, diverse spectra of tolerance, and dissimilar 

manifestations of excessive stress. There are, however, commonalities that transcend species, 

and the inability of an individual to adapt to repeated and/or chronic stress leads to allostatic 

overload (excessive wear and tear on the body). Symptoms of such psychological trauma are 

diverse, including self-mutilation, stereotypic and other abnormal behaviors, post-traumatic 

stress disorder, learned helplessness, diarrhea, and infant mortality. 
36

Igor was used in research at the New York Laboratory for Experimental Medicine and Surgery in Primates 

(LEMSIP). He developed the habit of self-mutilation at the sight of other gibbons and was kept behind black 

Plexiglas for many years. In 1987, Igor was the last of several gibbons sent to sanctuary at the International 

Primate Protection League (IPPL) by this lab. At sanctuary, he stopped self-mutilating. He now is an especially 

gentle gibbon and very active considering he is more than 50 years old. 

(Declaration of Shirley McGreal, Ph.D. at ¶ 5, Exhibit 27). Photo courtesy of IPPL. 

Arun Rangsi was born in a lab using young gibbons in viral cancer experiments at the University of California. He 

was removed from his mother shortly after his birth and raised with a swinging wire surrogate. This drove him 

insane, and he started to self-mutilate by head-banging. He also had frequent bouts of pneumonia and dysentery. 

When the lab lost funding from the National Cancer Institute, it no longer wanted Arun Rangsi. He was sent to IPPL 

in 1981, and, after much care, he stopped head-banging. (Declaration of Shirley McGreal, Ph.D. at ¶ 4, Exhibit 27). 

Photo courtesy of IPPL.
37

Betty, a rhesus macaque, has lost hair due to compulsive self-mutilation. (Reinhardt, 2008). 

Photo courtesy of Reinhardt, 2008.

Nonhuman primates in laboratories are known to develop self-injurious, stereotypic, and other 

abnormal behaviors in response to laboratory conditions and experimentation. Examples include 

over-grooming or hair-pulling to the point of injury or permanent damage or scarring to skin or 

follicles, hitting and/or biting one’s self, banging one’s self against the cage, pacing, twirling, 

rocking, back-flipping, swaying, eye-covering, self-clasping, repetitive circling, and digitsucking. (Bayne et al., 1991; Bourgeois, Vazquez, & Brasky, 2007; Brune et al., 2006; Goosen, 

1981; Lutz et al., 2003; Mallapur & Choudhury, 2003; Rommeck, Gottlieb, Strand, & McCowan, 

2009; Roy, 1981; Declaration of Ned Buyukmihci, VMD at ¶ 4, Exhibit 5). Abnormal behaviors 

are those that are not normally seen or are not habitual or customary in nature. (Brune et al., 

2006). 

According to Ned Buyukmihci, VMD, a veterinarian with 41 years of experience: 

In every research institution with which I was involved, I observed first 

hand considerable stereotypical and other aberrant behavior...[abnormal] 

behaviors were more marked and more frequently seen in individuals who 

were singly housed. They indicated maladaptation of the individuals to 

their environment...I have never seen these behaviors in wild non-human 

primates of any species nor have I observed them in individuals who were 
38

born in captivity in a sanctuary environment where housing was either 

free-range or expansive and heavily enriched. 

(Declaration of Ned Buyukmihci, VMD at ¶ 4, 6, Exhibit 5). 

Walsh, Bramblett, and Alford (1982) stated that abnormal behaviors “present[ ] a pattern of 

chimpanzee behavior radically different from that described for wild chimpanzees by van 

Lawick-Goodall [1968]...Abnormal behavior may thus be the result of pushing the 

chimpanzee’s species-typical behavioral plasticity beyond the limits of what can be 

accommodated without the development of psychopathology.” (Walsh, Bramblett, & Alford, 

1982). While referring to chimpanzees, this statement also is applicable to other primates. 

According to Debra Durham, Ph.D., an animal behaviorist, “Like chimpanzees, monkeys exhibit 

behavioural and psychological pathologies when kept in a laboratory environment.” (Submitted 

comments regarding European Union Directive 2010/63). 

Stereotypies (captivity-induced excessive repetitive movements) are abnormal behaviors and are 

generally considered pathological (maladaptive) and “are the desire for stimulation...and the 

desire for security...A variety of stereotypies may develop to counter boredom by providing 

some kind of controllable stimulation in an otherwise barren and uncontrollable environment.” 

(Brune et al., 2006; Brüne, Brüne-Cohrs, & McGrew, 2004). Stereotypies have been compared to 

“obsessive–compulsive disorder (OCD) spectrum of disorders in humans, particularly those 

involving stereotypic motor symptoms (such as stereotypic movement disorder)...Insofar as they 

may represent a response to the traumatic stress of captivity...they arguably fall on the spectrum 

of posttraumatic stress responses.” (Hugo et al., 2003; Brune et al., 2006). 

Self-injurious and other abnormal behaviors are indicators of frustration, uncertainty, anxiety, 

and psychological stress (K. Baker & Aureli, 1997; Garner, 2005), and some can result in severe 

tissue and muscle damage, lacerations, and dismemberment. (Bourgeois et al., 2007). Reinhardt 

(2010) reports, “In humans [hair-pulling] is classified as a mental disorder, causing clinically 

significant distress, and occurring in the context of depression, frustration, boredom, or other 

emotional turmoil. If hair-pulling is associated with similar mind states in nonhuman primates, it 

seems reasonable to conclude that the cause of this behavior deserves more attention and 

potential cures explored.” (Reinhardt, 2010 pp. 168). He also writes that self-injurious biting 

continues to be a common behavioral problem in laboratories. 

In an article on abnormal behaviors, Corrine Lutz, Arnold Well, and Melinda Novak, of the New 

England Regional Primate Research Center and the University of Massachusetts concur, stating 

that there is a “relatively high incidence of stereotypies and SIBs [self-injurious behaviors], 
39

particularly in macaques...” (Lutz et al., 2003). Another study of 188 rhesus macaques housed at 

the New England Regional Primate Research Center showed that approximately 30% of the 

monkeys engaged in self-biting or self-wounding. (Novak, 2003). Regarding macaques, 

commonly used in research, a NIH Office of Laboratory Animal Welfare publication, for 

example, states, “It is well-known that raising a macaque alone, without [housing with] other 

macaques of the same species, will result in that animal expressing a pattern of abnormal 

behaviors that can become self-destructive. Even the behavior profiles of adult animals housed 

alone can degenerate into these abnormal behaviors, which may include repeated pacing, 

circling, or somersaulting; hyper-aggression; depression; and self-injurious behavior, including 

hair plucking or self-biting.” (Bayne, 2005 pp. 47). 

Conditions in laboratories, including confinement and lack of autonomy, can also lead to a 

phenomenon known as “learned helplessness” – the extreme passive reaction of an individual 

who has come to learn that he or she cannot change the environment and, therefore, must endure 

an aversive situation because avoidance attempts are futile. (Brune et al., 2006; Solomon, 

Ginzburg, Mikulincer, Neria, & Ohry, 1998; Wortman & Brehm, 1975). “Repeated exposure 

especially to unpredictable and inescapable stress can lead to learned helplessness in humans and 

nonhuman species, a state that is characterized by anxiety, inactivity and neophobia, as well as 

chronically increased cortisol values.” (Reimers, Schwarzenberger, & Preuschoft, 2007). 

Examples of learned helplessness in laboratories include mothers freely handing over their 

babies to humans and an unnatural over-dependence on laboratory staff. Learned helplessness 

and dependency has been demonstrated in humans (Gatchel, Paulus, & Maples, 1975; Gatchel & 

Proctor, 1976; Thornton & Jacobs, 1971), including in prisoner of war research (e.g., Solomon et 

al., 1998) and in research on victims of physical and psychological assault (e.g., Peterson & 

Seligman, 1983). Helplessness has been proposed to be part of a vicious cycle that disturbs 

coping mechanisms in a variety of situations because it inhibits responding to an aversive 

environment and, therefore, produces emotional disturbances. (Solomon et al., 1998). 
40

 Conditions in labs include severe confinement, including in stereotaxic devices (pictured). 

(L) Photo courtesy of Reinhardt, 2008. 

Gastrointestinal problems are another symptom of stress, are common in nonhuman primates in 

labs, and can be chronic, severe, and intractable. (Hird, Anderson, & Bielitzki, 1984; Lewis, 

n.d.). Chronic diarrhea may cause significant pain, dehydration and associated problems, and 

even death if not treated properly. Studies have shown chronic diarrhea to be significantly 

associated with stress. (Chang, 2011). Co-morbidity with mood disorders such as anxiety and 

depression is common, with accumulating evidence indicating a role for a maladaptive stress 

response in irritable bowel syndrome (IBS). (O’Malley, Quigley, Dinan, & Cryan, 2011; 

Sapolsky, 2004). Further, it is known that changes in gastrointestinal function are mediated by 

stress-induced secretion of corticotropin-releasing factor, and associated inflammation and 

immune activation are implicated in the generation of IBS symptoms (O’Malley et al., 2011), 

and also in significant increases in visceral sensitivity. (Kanazawa, Hongo, & Fukudo, 2011). 

Other manifestations of gastro-intestinal problems include anorexia and weight loss. 

Finally, infant mortality is associated with chronic stress in nonhuman primates in labs and 

indicates poor welfare. Laboratory captive-bred nonhuman primates are often prematurely 

weaned or taken from their mothers by coercion or force at infancy, bottle fed by one or more 

humans, and experience irregular peer socialization and little to no adult same-species interaction 

during infancy/childhood. Studies have shown that “[i]nfant mortality can be related to parenting 

behavior in many primate species.” (Bloomsmith et al., 2003). Infanticide has been seen in the 

wild at times of socio-ecological stress. In the laboratories, the stress of captivity could also be a 

factor. (Capaldo & Peppercorn, 2012). 

While sanctuaries are able to alleviate the psychological harm caused in laboratories 

for the small number of primates who are rescued, unfortunately these severe injuries 
41

can never be completely erased. Thus, the prevention and minimization of such 

injuries is critical. As explained by Gloria Grow, Founder and Director of the Fauna 

Foundation, home to many primates retired from laboratories: 

Despite their many years living a sanctuary life, the time spent at the 

laboratory has forever scarred them, and they still suffer, psychologically, 

behaviourally and physiologically. All the primates at Fauna display some 

form of abnormal behaviour. Some pace, circle, and spin; are shy, 

nervous, and flee frantically when people approach or walk into the room; 

some cover their eyes with their hands; some carry/hold inanimate objects 

close to their chest refusing to give them up; some masturbate with 

inanimate objects while showing no interest in or ability for normal sexual 

interaction with conspecifics; some show unprovoked aggressiveness 

towards conspecifics and/or an inability to respond appropriately to 

normal circumstances; others display phantom limbs, leading to selfinjurious behaviours like self-biting and other stereotypic behaviors that 

can be triggered by any change in their environment, no matter how 

positive, when new people approaching, or in response to other 

unidentifiable stimuli to which they react with excessive vigilance and 

terror. These traumatic injuries, while vastly mitigated by the safety and 

stimulation of life in sanctuary, are unfortunately at best dormant, 

continually threatening to be re-stimulated. 

 (Declaration of Gloria Grow at ¶ 4, Exhibit 28). 

In summary, the key criteria for promoting the psychological well-being of primates must be an 

absence of behavioral or affective symptoms of stress, trauma, and/or accompanying physical 

maladies of a psychogenic nature. If an animal in a lab continually exhibits such symptoms, then 

the lab is not operating in a way that promotes the psychological well-being of the primates in its 

care. Again, such symptoms include, but are not limited to, stereotypic behavior, self-mutilation, 

post-traumatic stress disorder, learned helplessness, withdrawal and depression, persistent 

diarrhea, infant mortality, hyper vigilance, anorexia, and excessive aggression. 

A proactive approach to promoting the psychological well-being of these primates is imperative. 

As the APHIS Animal Care's Primate Environment Enhancement Team succinctly explained, the 

claim that laboratories’ “environment enhancement programs are adequate because there are no 
42

distressing behaviors or appearances of ill health with [the] primates. . . is a short-sighted view 

since waiting to improve a minimally enriched environment until a primate starts showing signs 

of psychological distress was not the intent of the Animal Welfare Act.” (Animal and Plant 

Health Inspection Service, 1999). The Team stated that the intent of the AWA was “to provide 

nonhuman primates with the opportunity to express a wide range of non-injurious, speciesappropriate behaviors” and “to re-emphasize attention to adequate environmental conditions 

before abnormal behaviors develop.” (Animal and Plant Health Inspection Service, 1999). 

The USDA must actively address the AWA mandate for a standard to promote the psychological 

well-being of primates. Unfortunately, the current lack of clear, enforceable minimum standards 

to accomplish this objective has contributed to the proliferation of severe maladaptive behaviors 

and other psychosocial and cognitive symptoms in nonhuman primates that are held in captivity. 

C. Examples of Nonhuman Primate Suffering 

The lack of any meaningful psychological well-being standard has permitted the prolonged, 

significant, and unnecessary suffering for thousands of primates held in U.S. labs. Unfortunately, 

because the vast majority of cases involving the disregard for the psychological well-being of 

primates in labs are not publicly documented, the examples provided here are just the tip of the 

iceberg. 

Recent examples of psychological distress, for which none of the facilities appear to have been 

fined or faced disciplinary action from the USDA,8 include: 

 A February 2012 inspection report for Virginia Commonwealth University notes, 

“Numerous animals in the primate colony participating in protocol AM10123 have areas 

of hairloss on their bodies, possibly due to overgrooming. In nonhuman primates, 

overgrooming can be an indicator of psychological distress. There is not sufficient 

evidence that personnel have fully recognized and addressed this problem.” (Exhibit 29). 

 A September 2011 inspection report for Washington University School of Medicine 

notes, “There were two adult, male macaques (‘Mason’ and ‘George’) with excessive hair 

loss on their arms. ‘Mason’ was missing approximately 85% of the hair from the front 

                                                           

8

 These inspection reports and additional violations can be found using the Animal Care Information System Search 

Tool at <http://acissearch.aphis.usda.gov/LPASearch/faces/CustomerSearch.jspx>. 
43

half of his forearms. Documentation from 25 July 2011 noted that he was ‘plucking’ so 

his enclosure was changed back to a previous orientation (horizontal as opposed to 

vertical) in an attempt to decrease his stress. There was no documentation since that date 

showing the animal received any special attention with regards to the enhancement of his 

environment, although his behavior was still resulting in hair loss. ‘George’ was missing 

approximately 95% of the hair from the front half of his forearms. A clinical record 

documented that he was ‘plucking’ but there was no treatment plan to correct the 

behavior. There was no evidence that either of these animals was provided with any 

additional enrichment beyond the standard enrichment that all the adult macaques in the 

room were receiving. Hair plucking is a common sign of distress in nonhuman primates 

which may decrease with enhanced psychological enrichment.” See Exhibit 30 for the 

report and USDA photographs of the macaques’ living conditions. 

 A July 2011 inspection report for the University of Kansas Medical Center states that 

there were “two animals with excessive hair loss...Neither animal was currently under a 

treatment plan at the time of the inspection.” See Exhibit 31 for the report and USDA 

photographs of the primates’ living conditions. 

 An August 2010 inspection report for Drug Research Laboratories in Pennsylvania states, 

“The environment enhancement plan for the facility states that the animals will receive 

some type of fresh fruit or vegetable daily. The plan is not being followed. According to 

the enrichment logs reviewed the 16 animals are only receiving fresh produce twice a 

week.” (Exhibit 32). 

 A July 2010 inspection report for Boston University states, “Protocol AN-14560, which 

has been closed since Dec. 2009, used Nonhuman Primates (NHPs) that were housed 

individually in isolation chambers which provided limited inter- and intra-species 

interaction with light cycle changes which for 3 month periods included constant dim 

light. Two animals were reported as having behaviors indicating psychological distress in 

their health records and behavioral assessments in the form of hair plucking (2/06 and 

11/07) and various stereopathic displays (10/06-4/08). Based on the facility’s Plan for 

Environmental Enrichment for NHPs these animals should have been put on special 

enrichment or removed from the study.” (Exhibit 33). 

 A July 2010 inspection report for the University of Nebraska Medical Center notes, “At 

least one singly housed, nonhuman primate (Animal #70193) was observed to somersault 
44

at least six times, then rock back and forth numerous times, then somersault at least six 

times during the inspection. These stereotypical behaviors are indicative of psychological 

distress, and therefore the facility must provide this animal with special attention 

regarding environmental enhancement. According to the facility’s Nonhuman Primate 

Behavior Management Program, primates showing signs of psychological distress will be 

placed on ‘special enrichment protocols’ which will provide ‘increased positive social 

interaction with human caretakers on a daily basis, and increased environmental 

stimulation and variation.’ The facility was unable to present documentation that this 

animal was receiving additional environmental enhancement.” (Exhibit 34). 

 A November 2009 inspection report for the University of California, Davis notes, 

“Animal 34313 had an extensive history of medical issues including gastrointestinal (GI) 

problems, numerous injuries, and self-injurious behaviors (SIB), and yet it was placed on 

four studies before being euthanized. The animal was placed on the fourth study despite 

the progressive worsening of medical and behavioral problems that lead to unnecessary 

discomfort, distress and pain to that animal. The animal was sedated 15 times between 

the third and fourth studies. Veterinary staff questioned the suitability of the animal for 

study on 11/5/07, noting moderate hair loss of the arms and legs with a few scars they 

suspected were caused by biting or hair picking, as well as a history of gastritis. Between 

that date and the date the animal was placed on a fourth study on 2/11/08, the medical 

record noted two episodes of vomiting, a suspected hole in the trachea, and self injurious 

behavior that prompted the staff to sedate the animal for examination due to blood in the 

cage. On 1/30/08 staff found excessive blood in cage. The 7.2 kilogram animal was 

sedated and found to have an approximately one centimeter laceration to the penis. The 

facility began pharmacologic intervention of the SIB on 2/7/08, four days prior to starting 

the fourth study. The animal continued the SIB over the course of the study. The animal 

was sedated an additional 16 times between the beginning of the fourth study on 2/11/08 

and 8/13/08, primarily for study purposes. On 8/8/08 staff noted that the ‘Monkey 

appears to become agitated during observations. Agitation appears to lead to increase 

mastirbatory behavior thus causing the bleeding observed.’ Pharmacologic treatment was 

changed after this entry and on 8/13/08 the bleeding reoccurred. The animal was sedated, 

a one centimeter laceration of the penis was sutured, and the animal’s hands were 

bandaged to keep it from further self-mutilation. The animal removed one of the 

bandages and bleeding at the site continued to be noted in the record intermittently. The 

facility decided to euthanize the animal a few days after the end of the fourth study. 

According to the daily observations, the condition of the animal had not worsened just 
45

prior to euthanasia and appeared to be in similar condition at the end of the study as it 

was at the beginning of the study.” (Exhibit 35).

 
46

5. Adverse Effects on Scientific Results and Validity

Chronic stress and psychological suffering not only severely impact primates’ well-being, but 

also impair their physiological suitability for research. The severe stress that laboratory life 

imposes on primates and the physiological responses to such psychological, cognitive, and social 

stress confounds research data and calls into serious question the validity of any research results. 

This section discusses how the physical manifestations of stress can adversely affect research 

results. For further details, please see Exhibit 36. 

The stress experienced by primates undeniably adversely affects the experimental results derived 

from such research. (Balcombe et al., 2004). The impact of stress on immunological and 

inflammatory responses is critical, as these alterations exacerbate and compound crucial immune 

differences that already exist between humans and other animals. (For a discussion and 

references see Bailey, 2011; Baldwin & Bekoff, 2007). 

For example, genomic duplication is one of the most significant causes of genetic variation 

among primates (Armengol, Knuutila, Lozano, Madrigal, & Caballin, 2010), and at the root of 

many aspects of diversity between and within species. It differentially affects many human and 

chimpanzee genes involved in immune and inflammatory responses. (Perry et al., 2008). Indels 

(genomic insertions and deletions) also affect major histocompatibility complex (MHC) genes 

that are critical to immune responses and are associated with differences in the handling of 

various infections including HIV, hepatitis B and C viruses, and the malarial parasite 

Plasmodium falciparum, as well as in differing susceptibility to autoimmune diseases. 

Additionally, the greater abundance of inhibitory Siglecs in chimpanzees dampens chimpanzee 

immune responses relative to humans, which may be further impaired as a result of 

psychological stress. This may explain species differences in diseases that involve 

immunopathology, including HIV, hepatitis C, asthma, psoriasis, and rheumatoid arthritis. (Soto, 

Stein, Hurtado-Ziola, Hedrick, & Varki, 2010). 

Published literature warns, for example, that “animals subjected to the environmental changes 

that occur during transportation...react with changes in their physiology, such as body weight, 

plasma hormonal levels, heart rate and blood pressure changes...When measurements of 

physiological parameters are performed using conventional measurement techniques, the results 

must be interpreted with caution as these conventional techniques also have effects on the 

animals.” (Capdevila, Giral, Ruiz de la Torre, Russell, & Kramer, 2007). Most important, 
47

“Suffering in animals can result in physiological changes which may increase the variability of 

experimental data.” (Capdevila et al., 2007; National Research Council Committee for the 

Update of the Guide for the Care and Use of Laboratory Animals, 2011). 

Kozorovitskiy et al. (2005) showed how “environmental complexity influences the structure and 

biochemistry of adult nonhuman primate brains.” The authors reported that “the structure of the 

adult primate brain remains highly sensitive even to modest levels of experiential complexity. 

For adult primates, living in standard laboratory housing may induce reversible dendritic spine 

and synapse decreases in brain regions important for cognition.” 

Many scientists are well aware of the effects of psychological suffering on research, and have 

cautioned against disregarding such impacts. (See, e.g., Brenner, Cohen, Ader, & Moynihan, 

1990; Mason et al., 1968; Roberts, Soames, James, Gill, & Wheeldon, 1995). Yet, although the 

negative effects of pain, stress and distress, and their adverse influence on study outcome have 

all been acknowledged, such effects are nevertheless often either not reported or underreported in 

published scientific papers. (Reinhardt & Reinhardt, 2000). 

 
48

6. Conclusion 

As set forth in this Rulemaking Petition, the Secretary has the authority and responsibility under 

the AWA to issue defined criteria for the environmental enrichment and psychological wellbeing of nonhuman primates. This Petition requests that the Secretary perform the following 

actions: 

1) Include in AWA implementing regulations the NIH-accepted recommendations for 

ethologically appropriate environments for chimpanzees as accepted by NIH; 

2) Adopt clear regulations for ethologically appropriate environments for all primates using 

NIH’s recommendations for such environments for chimpanzees as a baseline, with 

species-specific modifications for other primates, and; 

3) Adopt regulations for determining how and when chimpanzees and other primates exhibit 

psychological distress and what “special attention” must be brought to bear to ameliorate 

these symptoms. 

As also explained, if an animal in a lab continually exhibits these symptoms, then the lab is not 

operating in a way that is in compliance with the AWA requirement for a “physical environment 

adequate to promote the psychological well-being” of such animals. (7 U.S.C. § 2143(a)(2)(B)). 

If repeated violations occur and maladaptive behavior(s) continue unresolved, the primate 

exhibiting such behavior(s) should be removed to the care of a sanctuary where it can be 

psychologically rehabilitated. 

As stated by APHIS’s own Animal Care Primate Environment Enhancement Team, “USDA 

inspectors have found that many current enhancement programs are narrow and address only one 

or two aspects of the animal’s life. To correct this problem, USDA must stimulate the addition of 

diverse environmental elements that can promote a wider repertoire of species-appropriate 

behavior.” (Animal and Plant Health Inspection Service, 1999). 

As further explained by Lynn Cuny, Founder and President of Wildlife Rescue & Rehabilitation, 

“Since the primates at Wildlife Rescue who were formerly in labs all come from legally 

sanctioned settings, and since so many arrive in poor psychological condition, it is apparent that 

present regulations and/or enforcement are inadequate to meet the animals’ psychological and 

behavioral needs. Both observation and an abundance of scientific studies of primate cognitive, 

emotional, psychological, and social characteristics reveal that the conditions which they 
49

experience in laboratories are consistently contrary to their nature and innate needs.” 

(Declaration of Lynn Cuny at ¶ 6, Exhibit 37, emphasis added). 

As discussed in this Petition, there is precedence for interagency cooperation between NIH and 

USDA to implement the AWA. The adoption of NIH’s ethologically appropriate environment 

guidelines for all primate species would help rectify the current problems with implementation 

and enforcement of regulations, and assure that research facilities are meeting the 1985 AWA 

mandate that the agency issue standards to promote the psychological well-being of primates. 

Implementing specific minimum standards to enforce the AWA’s mandate for psychological 

well-being would be in the best interest of the primates, USDA inspectors, laboratories, research, 

and the public, which expects and relies upon the USDA to effectuate the AWA mandate. 

Newton at Fauna Sanctuary © NJWight

 
50

Respectfully submitted by: 

New England Anti-Vivisection Society 

333 Washington Street, Suite 850 

Boston, MA 02108 

North American Primate Sanctuary Alliance 

3435 NE 45th Street, Suite G 

Portland, OR 97211 

Laboratory Primate Advocacy Group 

1326 Hepburn Avenue #1 

Louisville, KY 40204 

Animal Legal Defense Fund 

170 East Cotati Avenue 

 Cotati, CA 94931 

 
51

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