Neuralink responded to the accusations of violations of the Animal Welfare Act by sharing the details of the research and showing its commitment to animal welfare. The company explained what happens in the research process and talked about the reasons.
Our world is far from ideal, and in order for people to live, we are forced to do the things that are necessary. Currently, all new medical devices and therapies must be trialed on animals before they can be ethically tested in humans, and Neuralink is not unique in this regard. However, the company has faced accusations of violations of the Animal Welfare Act and felt it necessary to explain to people what is happening in the process of its development. Neuralink notes that these accusations come from people who oppose any use of animals in research, although at the moment, unfortunately, there are no other ways to develop medical devices and treatments.
The company wrote that in its early days, it relied on third-party agencies to provide, house, and care for animals while Neuralink built its own in-house animal program. In 2017, the company entered into a partnership with the University of California, Davis’ prestigious California National Primate Research Center (CNPRC) to conduct animal-based research, and worked with them for the next two and a half years.
Neuralink explained that when starting this type of medical research, novel surgeries are typically performed first on animal cadavers and then later in terminal procedures. Cadavers are deceased animals who have been humanely euthanized due to a veterinary decision for a medical concern or euthanized as part of a previous unrelated research study.
Terminal procedures involve the humane euthanasia of an anesthetized animal at the completion of the surgery. Animals that fall into this category have been considered by the veterinary staff to be healthy enough for one anesthetic event but may not have a proper quality of life due to a pre-existing condition. Performing initial surgeries on cadavers and terminal procedures ensures that an animal does not potentially suffer post-operatively in the event the test procedure has an unexpected result.
“We therefore started our first studies at UC Davis using both cadavers and terminal procedures. These animals were assigned to our project on the day of the surgery for our terminal procedure because they had a wide range of pre-existing conditions unrelated to our research.”
Initial work on these procedures allowed Neuralink to develop novel surgical and robot procedures, establishing safer protocols for subsequent survival surgeries. Survival studies then allowed the company to test different generations of implanted devices. The use of each animal was carefully planned and thought to balance scientific discovery with the ethical use of animals, Neuralink said. As part of this work, two animals were euthanized at the scheduled time to collect important histological data, and six animals were euthanized on the recommendation of the UC Davis veterinary staff.
“These reasons included one surgical complication involving the use of the FDA-approved product (BioGlue), one device failure, and four suspected device-associated infections, a risk inherent with any percutaneous medical device. In response we developed new surgical protocols and a fully implanted device design for future surgeries.”
All animal work conducted at UC Davis has been approved by their Institutional Animal Care and Use Committee (IACUC) in accordance with federal law, and all medical and postoperative support, including endpoint decisions, has been overseen by their dedicated and qualified veterinarians.
Neuralink reported that once their own facility was completed, they were able to bring some unimplanted macaques from UC Davis with them. Among them was Pager, who was implanted with a Neuralink device and achieved outstanding brain-computer interface performance while behaving freely and without restraint, as shown in the Monkey MindPong video.
One of the central missions of Neuralink is to design an animal care program prioritizing the needs of the animals, rather than the typical strategy of building for human convenience alone. In 2020, the company opened a 6,000 sq ft vivarium, housing farm animals and rhesus macaques. The vivarium is staffed with caretakers who are passionate about animal well being, which is a central tenet of Neuralink’s philosophy.
Prior to opening its own facility, Neuralink engaged local United States Department of Agriculture (USDA) inspectors to ensure they met and exceeded all requirements of the Animal Welfare Act (AWA). Notably, Neuralink has never received a citation from the USDA inspections of their facilities and animal care program.
In addition, the company recently applied for and received accreditation from the International Association for the Evaluation and Accreditation of Laboratory Animal Care (AAALAC), a voluntary international agency that accredits excellence in animal care. This once again highlights that everything Neuralink does not only meets but exceeds the standards set by the provisions of the Animal Welfare Act (AWA) and the Guidelines for the Care and Use of Laboratory Animals.
The company said it looks forward to the day when animals are no longer needed for medical research. However, for now, society is relying on medical discoveries to cure diseases, prevent the spread of viruses, and create technologies that could change how humans can interact with the world, and scientists are forced to use animals in research. Neuralink promised that it would always strive to surpass the industry standard and never stop asking itself, “Can we do better for the animals?” and never forget that working with animals in research is a privilege. “It is our responsibility as caretakers to ensure that their experience is as peaceful and frankly, as joyful as possible,” the company wrote.
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