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From 16 March 2003 Issue

Questioning the USDA

The Animal Welfare Enforcement Report (AWER -- now called the Animal Welfare Report) is a document that the Secretary of Agriculture files annually with the President of the Senate and the Speaker of the House of Representatives. The accuracy of this report is crucial to the evaluation of the overall condition of animals in areas covered by the Animal Welfare Act (AWA), such as research and testing. The report is also used to discuss trends in areas such as experimentation. When discussions of the use of animals in experimentation begin, statistics from the AWER are often used as a starting point.

Is animal experimentation increasing or decreasing? The only source for such statistics is the AWER. The USDA issued the 2001 AWER late in 2002. Initial examinations of the report made it quite apparent that significant discrepancies existed between the statistical portion of the report for 2001 and similar portions of the fiscal 2000 report. These discrepancies are most obvious in the area of the use of primates in experimentation. These statistics are broken down by state, and initial examinations brought up discrepancies in many states. However, as the 2001 AWER was examined more closely it was quite clear that major errors had been made.

The Animal Welfare Enforcement Report for fiscal 2000 listed overall U.S. primate use in experimentation at 57,518 with 52,031 being used in non-federal facilities and 5,487 used in federally owned laboratories. The initially reported totals for primate experimentation in fiscal 2001 would have been welcome, if they were accurate. USDA/APHIS initially reported 49,382 as a national total with 5544 being used in federal labs and 43,838 used in non-federal labs.

These totals seemed to show a substantial decrease (14%) in primate usage. A decline of 8136 seemed too good to be true. Where did it come from? Federal use of primates actually increased (slightly – 57), so this was not the source of the drop. A state-by-state examination of the statistics seemed to be in order. The logical place to begin was in states where the largest numbers of primates were traditionally used.

Louisiana contains several large primate labs (i.e. -- the National Primate Research Center at Tulane with 6766 primates experimented on in 2000 & the University of Southwestern Louisiana at New Iberia with 6204 primates experimented on in fiscal 1998) and at least one moderately sized laboratory. (LSU – 112 primates used in 2000). A previous state total for primate use in Louisiana had been 8092 (fiscal 2000). The 2001 AWER reported Louisiana state total of 2913 does not seem to be credible since all of the aforementioned facilities are still receiving NIH funding for the projects that used primates in fiscal 2000.

Maryland has always contained many facilities which use large amounts of primates (i.e.Johns Hopkins University). For fiscal 2000 facilities in Maryland used 5460 primates. The initially reported 2001 total for Maryland was 2503. After SAEN (Stop Animal Exploitation NOW!) contacted USDA/APHIS and questioned the initial total it was revised upward to 6062. The initial error for this state was 58.7% of the final total.

Primate usage in Georgia is always high as a result of the presence of the Yerkes Primate Research Center at Emory University. The Georgia total for 2000 was 3601. The initially reported total for 2001 was 3310. This total was revised upward to 4930 after SAEN contacted USDA/APHIS. The correction was almost half of the original total.

The District of Columbia is typically not a large user of primates in experimentation, utilizing only 480 in 2000. However, the initially reported number for 2001 was 31. This total was later revised upward to 371. This was a ten-fold error, and the number may still be too low.

Primate use in Puerto Rico was reported to be 2015 in 2000. The AWER of fiscal 2001 lists primate use in Puerto Rico to be 35. Puerto Rico is the home of the Caribbean Primate Research Center, and this facility continues to be funded up to the present day.

Primate use in Arkansas is not typically high, using only 140 in fiscal 2000. However, the 2001 AWER reported primate use in Arkansas at 0. After SAEN contacted the USDA this statistic was revised up to 56, but this number is still believed to be too low.

The AWER lists the experimental use of 63 primates in the state of Oklahoma. The University of Oklahoma Health Sciences Center (UOHSC) is the recipient of NIH grant #RR12317. This grant funds the Baboon Research Resource Program. The progress report for this grant, filed with the NIH on 7/31/01 lists experimentation within the program on 94 primates during the reporting period. It also discusses supplying 24 other primates to separate projects at UOHSC. This report also discusses providing 11 baboons to the Oklahoma Medical Research Foundation for use in NIH-funded experimentation. The potential total for Oklahoma becomes 129 primates, not 63 as was originally reported.

The AWER of 2001 reports 18 primates used in experimentation in Colorado. However, a USDA/APHIS inspection report dated 2/28 – 3/1/01 lists a primate inventory at the University of Colorado Health Sciences Center at 98.

There were significant drops in several other states including Texas and North Carolina. These drops were partially corrected by USDA/APHIS after SAEN questioned them. However, the funding (i.e. by the NIH) of primate research in these states does not appear to have decreased. And these states contain major primate laboratories (TX -- the Southwest Regional Primate Research Center in San Antonio, the University of Texas facilities in various cities; NC -- the Primate Research Center at Duke, Wake Forest, etc.). It is believed that these statistics may still be inaccurate.

Are the Labs Honest?

Since it has become apparent that the USDA has difficulties managing the data provided by laboratories regarding animal experimentation, the next logical step was to examine the data that labs provide to the USDA. However, if this information was to be examined critically then an outside source of information was necessary. This independent source of data also deals with the use of primates in experimentation.

The National Primate Research Center system is comprised of eight laboratories that as a whole experiment on tens of thousands of primates every year. These eight laboratories are affiliated with these research facilities: Harvard, Oregon Health Sciences University, Tulane, University of Wisconsin (Madison), University of Washington (Seattle), Emory University, University of California (Davis), and the Southwest Foundation for Biomedical Research.

These facilities are required to file annual reports with two federal agencies – the United States Department of Agriculture (USDA) and the National Institutes of Health (NIH). The Animal Welfare Act requires all active research facilities to file reports with the USDA, and all grant recipients are required to file annual progress reports with the NIH.

These reports have several things in common. One requirement is that the number of animals used by the Primate Centers is reported to both agencies. The USDA report can include animals used in experimentation that is part of the facility (i.e. the University of Washington) that may not be a part of the Primate Center. So, the USDA report can have totals larger than the NIH report, because the USDA report may cover labs that are not part of the Primate Center. However, every primate used in one of the Primate Centers must be reported to the USDA.

For this comparison totals for both experimentation and breeding/conditioning from both the NIH and USDA reports are used.

When these reports are compared, several things become apparent. The most obvious fact is that the numbers don’t match. In the case of Tulane, Emory, the University of California, and the University of Wisconsin, the USDA numbers are larger, or the same, so we cannot say that anything is amiss there. However, Harvard, the University of Oregon, the University of Washington, and the Southwest Foundation for Biomedical Research have all reported more primates to the NIH than to the USDA. It appears that these facilities have all violated the Animal Welfare Act (AWA) by inaccurately reporting their primate use to the USDA or the NIH.

Specific examples of these discrepancies abound within these laboratories. Harvard has already been shown to have misreported their primate use in 1998, and this has been confirmed by USDA correspondence. Harvard reported the use of 336 primates to the USDA in 1998, 2054 in 1999 and 2119 in 2000. However, this same laboratory reported 1810 primates to the NIH in 1998, 2337 in 1999 and 2826 in 2000. For a 3-year period Harvard reported 6973 primates to the NIH and 4509 to the USDA for a discrepancy of 2464.

Several of the other Primate Centers fared no better. The Oregon Health Sciences University (OHSU) reported 2914 primates to the NIH in 1998, while reporting 2359 to the USDA (a difference of 555). In 1999 OHSU reported 2612 to the USDA but reported 3543 to the NIH (a difference of 931). OHSU reported 3437 primates to the NIH in 2000, but reported 2119 to the USDA (a discrepancy of 1318). The total discrepancy for the three-year period from 1998 – 2000 is 2804. The Southwest Foundation for Biomedical Research (SWFBR) reported 4201 primates to the USDA in 1999 while reporting 4806 to the NIH (a difference of 605). In 2000 the SWFBR reported 4693 primates to the USDA, but they reported 4777 to the NIH (a discrepancy of 84). The officials at the SWFBR had a 2-year discrepancy of 689 primates.

The University of Washington, Seattle has done no better. For the three-year period from 1998 – 2000 the UW reported 1228, 3075, and 1122 to the USDA (totaling 5425). For the same years the UW reported 2324, 2632, and 2541 (totaling 7497) to the NIH, for a difference of 2072. The potential inaccuracies contained in the reports by Harvard, the Oregon Health Sciences University, the Southwest Foundation for Biomedical Research, and the University of Washington (Seattle) are significant from the point of view of the overall accuracy of the Animal Welfare Enforcement Report. The facilities that make up the primate center system reported (during fiscal 1999) 36% of the primate use for the entire country. And when only 4 of these facilities have 3-year reporting discrepancies totaling over 7200 primates, then the integrity of the statistics on primate usage must be questioned, and thereby the entirety of the Animal Welfare Enforcement Report.

Conclusion

It is quite apparent that the reporting system which is used as part of the regulation of the use of animals in research is seriously flawed. The fiscal 2001 Animal Welfare Enforcement Report, as filed with the Speaker of the House of Representatives and the President of the Senate, is seriously flawed. The statistics for primate usage are substantially skewed so as to indicate a major reduction in the use of primates in experimentation. The facts of the situation are that no reduction took place, and that there may have actually been an increase, though it is currently impossible to tell.

An examination of documents filed by major primate laboratories with the National Institutes of Health has revealed major discrepancies between these documents and reports filed by the same facilities with the USDA/APHIS. It is entirely possible that officials within these laboratories have purposely filed fraudulent reports with the USDA/APHIS. These discrepancies are sufficient to cast doubt on the entirety of the reporting system, especially when they are combined with other potential erroneous reporting which has been discussed relative to the fiscal 2001 AWER.

The reporting system for animal experimentation is in serious need of an overhaul. At no time from 1992 to the present has the USDA been able to obtain reports from all research facilities in the U.S., with the high for non-reporting facilities reaching 128 in 1997. Yet, the USDA/APHIS website does not list any instances of facilities receiving a fine or official warning for non-reporting.

The current system of reporting does not even cover all animals. The totals listed in the AWER ignore animals confined within a research or breeding facility that are not currently being used in experimentation (i.e. animals being held for breeding, conditioning, etc. that are not yet part of an experimental protocol). This allows a significant number of animals to go uncounted, and unreported. These animals may comprise as much as 40% of the laboratory population for some species.

The reporting process must be overhauled if animal experimentation is ever to be regulated, or even understood. At the present time we do not have any accuracy regarding the number of primates that are confined within research facilities. And though only primate statistics have been examined in detail, there is no reason to assume that information regarding any other species would be any more accurate. Information from other sources indicates that animal experimentation as a whole is probably increasing. Until the process for tracking animal experimentation is made much more accurate, we will have no way of knowing the truth.

What You Can Do:

1. Write to these government officials to demand an investigation into the reporting of animal experiments in the US:

Senator Thad Cochran, Chair
Senate Agriculture, Nutrition and Forestry Committee
113 Dirksen Senate Office Bldg
Washington, DC 20510-2402
senator@cochran.senate.gov

Representative Bob Goodlatte, Chair
House Agriculture Committee
2240 Rayburn House Office Bldg
Washington, DC 20515
agriculture@mail.house.gov

Ann M. Veneman, Secretary of Agriculture
U.S. Department of Agriculture
Washington, DC 20250
agsec@usda.gov

PhyllisFong,
USDA Inspector General
Room 9-E Jamie Whitten Bldg
1400 Independence Ave SW
Washington, DC 20250
Phyllis.Fong@usda.gov

2. Go to the SAEN website at www.saenonline.org to read the full text of our report and to see our letter to the Secretary of Agriculture.

Stop Animal Exploitation NOW!
PMB 280
1081-B St. Rt. 28
Milford, Ohio 45150

513-575-5517
saen@att.net
www.saenonline.org 

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