Urging the NIH to recognize that chimeric should be protected as human research subjects

In 2016, the Animal Legal Defense Fund submitted comments to the National Institutes of Health (NIH) urging the agency to recognize that chimeric and transgenic animals with humanized cognition should be protected as human research subjects, and ensure regular oversight by Institutional Review Boards (IRBs) in all NIH-funded research where enhanced cognitive ability in such animals is a possibility.

Human-animal chimeras are animals containing human cells for research purposes such as researching organ growth and exploring potential therapies for disease. Relatedly, human-animal transgenic research involves introducing a human gene or genetic sequence into animal cells, often to assess the effect of that human gene or sequence on the animal.

The Animal Legal Defense Fund previously petitioned NIH’s parent agency, the Department of Health and Human Services, to adopt similar regulations in December 2013 and April 2015. In September 2015, NIH placed a moratorium on funding human-animal chimera research, but then announced plans to lift the ban while considering changes to its funding policy. The agency requested that the public submit comments on these proposed changes.

More than 22,000 members of the public submitted comments. The funding ban remained in place.