Musk’s Neuralink faces federal probe, employee backlash over animal tests
This is appalling on so many levels.
Content warning following the image.
The article and this writeup are about animal experimentation. I am using some block quotes below that are taken directly from the article, and there are references to animal deaths.
At this point in time, there are still insufficient resources which would allow scientists to completely replace the use of animals in research. However, there are regulations, including the Animal Welfare Act, that guide the humane and appropriate use of animals. I highly recommend learning about the Animal Welfare Act from the USDA’s Animal Welfare Information Center (AWIC). AWIC is part of the USDA’s National Agricultural Library, and the provide plenty of educational materials, training, and support regarding the AWA. I also recommend NIH’s Office of Laboratory Animal Welfare (OLAW) for research; they have a tutorial about the Public Health Service Policy on Humane Care and Use of Laboratory Animals.
Generally speaking, all researchers working with animals should be considering what is known as the 3Rs: replacement, reduction, and refinement. Can you replace the use of animals using, e.g., in vitro methods, organoids, in silico simulations? Can you reduce the number of animals being used in the experiment? Can you refine the method so as to minimize or alleviate any painful procedures, or anything that might cause distress in the animal? Experimentation should never be duplicative; there should be serious consideration as to whether or not an experiment needs to be run at all.
All of this needs to be considered before the scientist even writes a protocol and discloses exactly what procedures they will be using. To support the consideration of the 3Rs principles, the Animal Welfare Act requires that the researcher writing the protocol conduct a literature search for alternatives.
From AWIC’s website:
The Animal Welfare Act (AWA) regulations require principal investigators (PIs)/scientists to consider alternatives to procedures that may cause more than momentary or slight pain or distress to the animals. They must provide a written narrative to their Institutional Animal Care and Use Committee (IACUC) that describes the methods and sources (e.g. the Animal Welfare Information Center) used to determine that alternatives were not available (9 C.F.R. § 2.31 (d)(ii)(2022)). Additionally, PIs/scientists must also provide written assurance that their activities do not unnecessarily duplicate previous experiments (9 C.F.R. § 2.31 (d)(iii)(2022)).
The institution’s Institutional Animal Care and Use Committee (IACUC) reviews the protocol, as well as the literature search and written narrative, before approving the implementation of the protocol in the institution’s animal facility. And that’s not to say that all protocols are automatically approved - there is often further discussion and a back-and-forth between the scientist and the committee prior to approval. For example, if a reviewer isn’t satisfied with the written narrative or the literature search, the reviewer may ask the scientist to consider an alternative procedure.
“U.S. regulations don’t specify how many animals companies can use for research, and they give significant leeway to scientists to determine when and how to use animals in experiments.”
This is true to an extent, but this sentence itself is pretty nebulous. The use of “scientists” here may be encompassing the IACUC. But even then, it is the IACUC’s job to make sure that scientists are using animals appropriately. Most of them take this responsibility very seriously.
“The sources characterized that figure as a rough estimate because the company does not keep precise records on the number of animals tested and killed.”
This goes against AWA best practices… and it’s also just bad science.
“The total number of animal deaths does not necessarily indicate that Neuralink is violating regulations or standard research practices…. But current and former Neuralink employees say the number of animal deaths is higher than it needs to be for reasons related to Musk’s demands to speed research.”
This is why someone on the IACUC should have a statistical background, so as to provide expertise in determining an appropriate sample size.
“Through company discussions and documents spanning several years, along with employee interviews, Reuters identified four experiments involving 86 pigs and two monkeys that were marred in recent years by human errors. The mistakes weakened the experiments’ research value and required the tests to be repeated, leading to more animals being killed”
Repeating and duplicating tests goes against 3Rs principles.
“In September, the company responded to employee concerns about its animal testing by holding a town hall to explain its processes. It soon after opened up the meetings to staff of its federally-mandated board that reviews the animal experiments.”
Presumably, this “federally-mandated board” is the IACUC. I find it very hard to believe that they would open up IACUC meetings to staff more generally.
“some Neuralink employees protested after a manager said that Musk had encouraged them to do a complex surgery on pigs soon. The employees resisted on the grounds that the surgery’s complexity would lengthen the amount of time the pigs would be under anesthesia, risking their health and recovery. They argued they should first figure out how to cut down the time it would take to do the surgery.”
This is an example of refining the procedure to prioritize animal welfare. Clearly, some (if not all) of the scientists are still trying to do the right thing. The article does mention that some employees have already left due to animal welfare concerns. I really feel for the scientists… but I also hope that they seek employment elsewhere if they are in a position to do so.
It remains to be seen what the USDA’s investigations will reveal, or what, if any, disciplinary action will be taken. Sadly, it will take a very egregious, blatant violation for a company that does not receive federal funding to be held accountable. Some of Neuralink’s work was done in partnership with UC Davis. There may be more scrutiny there, as UC Davis receives federal funding and is thus subject to more oversight.
This thread on Twitter is worth a read:
