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 dont 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.
