A number of articles have appeared in the press recently regarding a visit to the National Institute of Immunology (NII), New Delhi, by an inspection team of the Committee for the Prevention of Cruelty in Scientific Experiments on Animals (CPCSEA). The articles were extremely critical of the condition of the monkeys kept in the NII and its use of animals in scientific research. One article stated that the CPCSEA had recommended closure of the primate house at the NII, in effect terminating all research at the Institute involving these animals.
Delhi Science Forum (DSF), a non-profit public interest organisation of scientists, technologists and social scientists working in areas of science and technology policy, is extremely concerned at these developments at NII which are but the latest of a series of similar actions by CPCSEA in different institutions. These actions reveal disturbing trends in the structure and functioning of CPCSEA and also have serious implications for the future of scientific research in India.
DSF designated a three-member team to visit NII and examine the issue covering not only the conditions and use of animals at NII but also the functioning of the CPCSEA. DSF spoke with CPCSEA team members and sought their views but was unable to obtain a copy of the team’s report from either the team or CPCSEA.
Contrary to the allegation that animals are kept in overcrowded enclosures, DSF found that the 207 primates at NII are kept in 13 large outdoor enclosures (5 more are under construction) and additional indoor enclosures for observations and rotation, with small chambers in some outdoor enclosures with provision for heating or cooling depending on season. Enclosures are cleaned four times a day, about an hour after each feeding period. NII also has operating theatres and three full-time veterinarians. Therefore, the animal facilities at NII provide ample space, are in good condition, and are well-maintained.
Against the allegation that over 90% of the monkeys are infected with TB, NII records and DSF’s observations show that only 2 adult monkeys out of 207 have TB, and these, along with one female’s infant, are in quarantine, under observation and treatment. NII records show that all incoming monkeys are quarantined and tested for TB, such testing also being conducted regularly for all the monkeys, with infected monkeys being treated and painlessly put to sleep as per approved procedure if not cured.
Among the more sensational allegations was that the monkeys at NII were undernourished. DSF examined the monkeys’ dietary and nutritional status besides feeding practices at NII. Monkeys at NII are fed four times a day, with special pelletised feeds, channa, bread with vitamin and other nutritional supplements (both additional for pregnant and lactating animals), fruits and vegetables. Monkeys at NII thus obtain more than the internationally recommended standard of 70-100 kCal/kg of bodyweight per day.
NII has Standard Operating Procedures for care of animals and their use in experiments which are monitored and overseen by NII’s Ethics Committee. DSF found not only that conditions and treatment of animals at NII were satisfactory but also that records were basically sound, properly maintained and procedures broadly conforming to international standards were being followed. Of course, there is always room for improvement and NII scientists and managers appeared open and willing to discuss any measures that may be recommended in this regard.
Not all the CPCSEA team members agree with the opinions as reflected in sections of the press and reiterated by some members to DSF. This makes the non-availability of the team report all the more serious and, if action is being taken or contemplated based on such unsubstantiated individual opinions, this raises grave concerns about pre-determined, motivated and biased functioning of CPCSEA.
DSF explicitly recognises the necessity for regulation of use of animals in scientific research to ensure ethical and proper treatment of animals and pursuit of research in accordance with clearly prescribed rules. The fact that the CPCSEA is a statutory body, with rules governed by law, is a positive aspect not only ensuring compliance but also benefiting scientific research and practice. The rules under the relevant Act are also broadly as endorsed by the scientific community in India and abroad.
While the CPCSEA as constituted gives representation to scientific departments and the research community, apart from animal rights activists, in practice and in the manner it functions, the latter have virtually taken over the CPCSEA and its various bodies, and have subverted the statutory body. CPCSEA today appears to act not to regulate the use of animals in scientific research but to completely stop it now and prevent it in future.
Some fundamental defects in the constitution of the CPCSEA under the relevant Act urgently require to be addressed. The NII episode, as well as previous ones at JNU, Indian Institute of Science, AIIMS, National Institute of Nutrition and other research institutions in both the public and private sectors, brings out sharply that the CPCSEA now appears to be functioning as police, prosecutor, judge and hangman, resulting in arbitrariness and lack of transparency and accountability.
The CPCSEA should be overhauled, and its advisory, inspection and other bodies completely reconstituted, with due representation of the scientific community apart from those with concerns for animal welfare. Inspection reports should be shared with the concerned institution for greater transparency, to enable peer review and full participation of research institutions in the regulatory process
CPCSEA should be brought under the ministry of science and technology with proper structures and mechanisms for transparency and accountability
In the case of NII, no action should be taken on the basis of this inspection team’s report since the entire process has been deeply flawed and vitiated.
Finally, DSF calls upon the scientific community to vigorously debate these issues, evolve a consensus and work towards a thorough overhaul and reform of this important regulatory body.
Delhi Science Forum, D-158, Lower Ground Floor, Saket, New Delhi 110017. Email: firstname.lastname@example.org