The Comets' opinion on animal testing – 'Transparency, justification and the search for alternatives found to be essential'
The CNRS Ethics Committee has published a new opinion entitled 'Transparence, justification et recherche d’alternatives s’avèrent essentielles' which examines the ethics of animal testing in basic research. The Ethics Committee's chair, Christine Noiville, explains the document's main conclusions.
What is the context for the publication of this opinion of the CNRS Ethics Committee (Comets) on the use of animals for scientific purposes?
Christine Noiville: The CNRS referred this issue to Comets for three reasons. The first is clearly set out in Antoine Petit's referral which stresses that animal welfare is "a growing societal concern". This is not a new concern but it has increased in importance recently, as the work and actions of NGOs and animal rights groups illustrates, particularly as regards laboratory animals. The research communities involved are worried that their work is increasingly being called into question, if not actually attacked. This is unacceptable in a state governed by the rule of law and in which a collective decision has been made to accept the use of animals for scientific purposes under strict conditions. But this is precisely where part of the problem lies – and I'll return to that point because it's central to the opinion.
The second reason is that the issue of animal experimentation is a source of tension between disciplines within the CNRS itself, and specifically between biology, chemistry and the humanities and social sciences. Some would even go so far as to say that even questioning the principle and practices of animal experimentation is a taboo subject. I'd note at this point that, in over 30 years of existence, Comets had never commented on this issue despite it being at the core of ethical questions in research. This is because, as some more 'long-standing' CNRS staff members told me, the subject was too "tricky". I'd like to thank Magali Jacquier, a veterinarian and member of Comets, for agreeing to be the rapporteur for this opinion.
Finally, although the referral does not mention this, the opinion comes at a time when the CNRS is planning a National Primatology Centre (CNP) project to expand the existing centre in Rousset, in the Bouches-du-Rhône region of France. This already houses 300 non-human primates to 'secure' the availability of primates for French academic research laboratories. The project was conceived following on from the Covid crisis in a context of increasing difficulty in obtaining these animals and also of plans to breed primates on French national territory. The primary objective of the expansion is to increase the Rousset centre's capacity to 1800 primates to eventually cover the major part of French academic research's requirements in this area.
However, as might be expected, this 'sensitive' project has led to questions and criticism. The use of primates in scientific procedures raises important ethical questions because of the genetic and anatomical similarities between primates and humans, the empathy primates inspire, their highly developed social skills and the difficulties of responding effectively to their behavioural requirements in a laboratory environment. That's why it was a doubly opportune moment for the matter to be referred to Comets.
What is the ethical and legal framework for animal experimentation in basic research?
C. N.: The law clearly stipulates that animal research is only lawful if it is "strictly necessary". This is also a key ethical criterion and means that the use of animals in science is only acceptable as a last resort, when there's no other option, when the proposed research is scientifically justified and likely to bring benefits that outweigh the harm (suffering, pain, distress) research of this kind causes to the animals involved, and so forth. Comets members adhere to this general position which aims to reconcile the duties we have towards animals (recognised as 'sentient' living beings, with recent discoveries confirming that they possess far richer forms of consciousness than sentience alone) and towards humans (in terms of improving their health and respecting their dignity because, let us recall, biomedical research has to be based on in-depth knowledge and generally involves appropriate experimentation carried out primarily in laboratories, and if necessary on animals).
From an ethical standpoint, the challenge is therefore to reconcile these two requirements in a thoughtful manner and on a project-by-project basis.
Obviously, this is no easy task. Assessing the damages and benefits involves a degree of subjectivity. The expected benefits are more for humans than animals, with the latter generally not benefiting. Evaluating what is strictly necessary involves a variety of sometimes conflicting values. For example, is it really necessary to use captive primates in research that exclusively aims to increase purely fundamental research knowledge about behaviour? Which scientific questions would be considered important enough to make using animals for research strictly necessary? Difficulties like these sometimes lead researchers to lose sight of the fact that compliance with regulations is required (working in an approved laboratory, submitting the project to an animal ethics committee, etc.) in any experimental procedure involving animals but isn't sufficient in itself. The process must also involve thought about a project's objective and the scientific, ethical and societal justifications for using animals. It's not enough to say that researchers would like to do things differently but that the use of animals for scientific purposes remains "indispensable".
This is why Comets considers it important to give full weight to this condition of strict necessity and has provided guidance on how to implement this the most effectively.
I'd like to refer you to the opinion on this point. In short, it sets out a series of tangible recommendations on the duty of researchers, right from their projects' design stages, and of the scientific committees that assess them, to ask these questions and answer them scrupulously – which currently is not sufficiently the case.
Furthermore, at a time when the public is increasingly questioning the use of animals in research, it's necessary for scientific communities that do use animals to think more about the contributions and limitations of their work and also report on the benefits – and conversely the costs to animals – of their work to society.
The use of primates brings up many questions, particularly as regards the planned expansion of the National Primatology Centre. What fundamental questions did Comets wish to ask about this?
C. N.: As we've said, the use of primates in research raises specific ethical questions that are divisive, including within Comets itself because our own recommendations on this subject have led to one of our members expressing a dissenting position.
It is clear that in terms of animal welfare, it's preferable for there to be a breeding project on national territory rather than importing primates on charter planes and then quarantining them. This is all the more so given that the CNRS has announced breeding conditions that meet strict standards, some stricter than those of our European counterparts. But the most important questions concern the actual use of primates in research. For what experiments? What objectives? What level of suffering? How many will ultimately be euthanised? What happens to the others? Above all, many questions are linked to the benefits society might expect from this research which has undeniably led to major medical advances and clearly remains useful, particularly in biomedicine. However, questions are still being asked, including by scientists. What should we think about the legitimacy of certain purely basic research that aims, for example, to study the behaviour of primates in captivity? What about the relevance and usefulness of the 'primate model' for studying human diseases? What should be said about the relationship between the amount of primates used (which is significantly higher in France than in other European countries) and the quality of publications and clinical applications? What resources are allocated to developing alternative methods? How did the CNP project take into account the objective adopted by European countries to reduce the use of primates in research as much as possible? In this regard, it's interesting to note that the public consultation organised before the CNP project often revisited these very questions.
For Comets, this project's acceptability above all depends on the answers to these questions1 . Therefore it's essential for the scientific community to consider and respond to them in a documented fashion. And, of course, the community that uses primates in its research should not be alone in considering such issues. No one reasonably thinks that they take using primates lightheartedly. The ethics group of the Société Francophone de la Primatologie2 places great emphasis on the "compassionate suffering" of researchers working in this field. The fact remains that society is still waiting for impartial answers and this requires pluralistic and contradictory scientific study and thought.
Your recommendations call for more robust justifications of projects, enhanced transparency and increased efforts on alternative methods. How are these levers decisive for the future of public research?
C. N.: Once again, it's essential to make sure that any project involving animals 1) is justified from a scientific standpoint in the sense that the research question involved needs to be robust and also sufficiently important to justify using animals; 2) is expected to provide benefits that outweigh the harm inflicted on the animals; 3) is designed to enable experiments to be carried out in the most respectful conditions for the animals.
It's clear that animal experimentation ethics committees currently have difficulty verifying these criteria and will not be able to do so properly unless scientists themselves scrupulously comply with these requirements when designing or evaluating projects, as I mentioned earlier.
The issue of alternative methods is particularly crucial. For every research project involving the use of animals, it is essential to make sure no similar project has already been carried out elsewhere and, by default, that there are no other ways of answering the scientific question involved. This is the first R in the 'three Rs' rule which aims to replace animal testing with non-animal methods. For example, is it possible to use stem cells rather than experimenting on mice? Is it possible to obtain biological tissue from biobanks, thus avoiding the use or even killing of animals? We're observing growing interest in this subject among scientists. The scientific interest group 'FC3R' was set up specifically for this purpose and also plays a crucial role. However we need to take this much further by providing more funding for FC3R and also by raising awareness of this issue among researchers. For example, Comets recommends that FC3R should continue its work on raising awareness among scientists and funders, particularly the National Research Agency (ANR), and also that all projects should now include a specific section justifying their purpose, the necessity of using animals and the choice of animal models.
Transparency is also central to the Comets recommendations, because although everyone understands that certain information has to remain confidential for business or privacy reasons, the use of animals for research purposes is of growing interest to society, which wants to know how many animals are used, for what reason, with what results, and what happens to them. Although the Gircor – which brings together public and private research stakeholders that carry out scientific animal testing – and the creation of statistical databases have significantly improved transparency, some scientists are still wary of this, fearing that it will expose them to greater criticism. In reality, it's essential to show that it isn't true to imagine that ''anything goes'' in laboratories. Moving beyond transparency, there's also a need to debate the subject openly and question its legitimacy, methods and results, both with society and within the CNRS itself. In particular, it is essential to set up a thematic network involving all the CNRS Institutes concerned by this issue. A fair debate of the issue of the use of animals for scientific purposes is required that takes into account the diversity of scientific viewpoints and disciplines that the CNRS is lucky enough to have within its ranks.
More broadly, what does this opinion say about the role and responsibility of a public research organisation like the CNRS in the context of growing ethical expectations within society?
C. N.: The CNRS has a fundamental role to play in this area alongside other organisations that use animals for academic research like the Inserm, the CEA, the Institut Pasteur, universities, and so on. This should involve raising awareness among researchers, pushing public authorities to allocate more resources to research into alternatives, ensuring complete transparency about what goes on in laboratories, and opening up the subject to debate. The CNRS also needs to serve as a catalyst to make sure that France – which, I'd like to reiterate, is the European country that uses the largest number of animals for scientific purposes – adopts an ambitious roadmap for replacing animals in science including specific details on what can and can't currently be replaced, and clear commitments to future action.
I believe that the CNRS general management has demonstrated that it is aware of all these issues by referring the issue to Comets. I hope, then, that our recommendations will be all the more well received and more widely.