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Articles and Reports

Letter of Complaint About New Iberia Research Center to USDA Director


1081-B St. Rt. 28 PMB 280
Milford, Ohio 45150
513-575-5517
www.saenonline.org 

10/16/09

Dr. Robert Gibbens
Director, Western Region
USDA/APHIS/AC
2150 Centre Ave.
Building B, Mailstop 3W11
Fort Collins, CO 80526-8117

Dr. Gibbens,

I am contacting you today regarding documents in my possession which are relevant to the New Iberia Research Facility, which is connected to the University of Louisiana, Lafayette (72-R-0007).

As you know, section 2.33 of the Animal Welfare Act requires that research facilities provide adequate veterinary care for animals:

2.33 b) Each research facility shall establish and maintain programs of adequate veterinary care that include:
(1) The availability of appropriate facilities, personnel, equipment, and services to comply with the provisions of this subchapter;
(2) The use of appropriate methods to prevent, control, diagnose, and treat diseases and injuries, and the availability of emergency, weekend, and holiday care;
(3) Daily observation of all animals to assess their health and well-being; Provided, however, That daily observation of animals may be accomplished by someone other than the attending veterinarian; and Provided, further, That a mechanism of direct and frequent communication is required so that timely and accurate information on problems of animal health, behavior, and well-being is conveyed to the attending veterinarian;
(4) Guidance to principal investigators and other personnel involved in the care and use of animals regarding handling, immobilization, anesthesia, analgesia, tranquilization, and euthanasia; and
(5) Adequate pre-procedural and post-procedural care in accordance with current established veterinary medical and nursing procedures.

The veterinary record for Primate #A3V027 states: “Emaciated animal with a severely inflamed colon that was tube-like and thin-walled (almost transparent).” The record also states: “Very thin animal on long term treatment for diarrhea and poor condition, not responding. Animal continued to lose weight.” Statements of this nature raise serious doubts as to whether this animal received adequate treatment and whether euthanasia should have been performed much earlier. This physiological changes noted in the post mortem record for this primate do not happen quickly, meaning that this primate was allowed to become severely debilitated.

Primate A6V053 is described similarly. “Very thin animal with a tube-like colon with only a few shallow sacculations remaining.” And “Juvenile animal on treatment for 7 weeks for enteritis and poor condition. Animal was not responding to treatment and continued to lose weight and was subsequently euthanized.” This animal was allowed to suffer for an extended period of time before appropriate euthanasia was administered.

Again, Primate Ax83 shows a similar situation. “Adult female on clinical treatment for enteritis and poor condition for six weeks with no improvement. She continued to lose weight and was euthanized.” And “Very thin animal with a thin-walled, distended, tube-like colon with no sacculations.” The significant erosion of the colon indicates long-term disease. This animal was allowed to decline past a point where euthanasia should have been administered to prevent unnecessary pain and suffering.

Primate 97P015 continues on in this same mode. This twelve year old monkey is described as being “ . . . on treatment for poor condition – very thin, generalized alopecia.” And “Very thin animal, no fat stores.” Similarly to the other animals, this monkey should not have been allowed to reach a point of such severe debilitation that there was no body fat present whatsoever. This primate had a recorded weight of 9.35 kg (roughly 20.6 lbs) on June 14, 2007. The body weight had decreased to 8.5 kg by June 11, 2008. By January of 2009 his weight had plummeted to 6.3 kg (roughly 13.9 lbs), which represents an overall decrease of over 32%, with the majority of this decline occurring in the six months from June of 2008 to January of 2009. This is a precipitous drop.

These are the animals that received treatment for their illnesses. Others were, due to lack of observation, apparently not treated at all. Several primates are described in government reports as “down,” which can only be taken to mean that they were first diagnosed when they had collapsed due to illnesses.

Several other primates at this facility are of serious concern. Primate (A5E037) is listed as “Thin, laying down in crib” the presenting diagnosis on July 25, 2008. In other words, the staff of this facility didn’t realize that this animal was ill until he/she collapsed in an enclosure. Two other primates (A7E043, A7E046) are similarly listed as just “down,” again indicating that they were diagnosed at the point of collapse.

I am also very concerned about the high number of wounds and traumatic injuries that are reported at this facility. The number of injuries is so high, and the frequency of traumatic injuries is so often, that I believe situations exist at this facility which violate these sections of the animal welfare act:

2.33 (b) Each research facility shall establish and maintain programs of adequate veterinary care that include:
(1) The availability of appropriate facilities, personnel, equipment, and services to comply with the provisions of this subchapter;
(2) The use of appropriate methods to prevent, control, diagnose, and treat diseases and injuries, and the availability of emergency, weekend, and holiday care;

And:

2.31 (d) IACUC review of activities involving animals. (1) In order to approve proposed activities or proposed significant changes in ongoing activities, the IACUC shall conduct a review of those components of the activities related to the care and use of animals and determine that the proposed activities are in accordance with this subchapter unless acceptable justification for a departure is presented in writing; Provided, however, That field studies as defined in part 1 of this subchapter are exempt from this requirement. Further, the IACUC shall determine that the proposed activities or significant changes in ongoing activities meet the following requirements:
(i) Procedures involving animals will avoid or minimize discomfort, distress, and pain to the animals;

In one three month period a colony within this lab is listed as having primates with 15 traumatic injuries. On Febuary 18, 2007 primate A7V006 is listed as having peritonitis as a result of a wound (untreated?). On February 8, 2007, primate AX84 is listed with severe trauma. Primate A8V049 is listed with a cause of death of trauma. Primate AX82 is listed with hyperthermia after fighting. Primate A4V039 is listed with “severe colitis/shock from trauma.” Primate A6V073 is listed with “septicemia of unknown origin” and A8V025 is listed with “pneumonitis, septicemia.” Septicemias do not appear out of nowhere. These cases should have been diagnosed and treated in a more timely manner. It is clear that not enough is being done to prevent injuries to the primates within this facility. Traumatic injuries occur regularly and are occasionally even fatal. Adequate measures have obviously not been taken to prevent these traumatic injuries, and the pain, discomfort and distress of these animals was not minimized or avoided.
 

Additionally, it is clear that disease is extremely common at this facility. Enteritis occurs extremely frequently within this facility and is a substantial cause of both morbidity and mortality. Depending on which sub-colony is examined, and what time of year is examined, enteritis can constitute as much as 80% of all clinical disease, and this condition can have a death rate as high as 42%.

Primate A2V016 was listed with a “severe strangulating intussception.”

I have provided a large amount of documentation which has been obtained through the freedom of information act. I believe that the documents which I have obtained delineate clear violations of these regulations and I hereby officially request an investigation of these issues.

It is clear that the staff of NIRC systematically ignores illnesses in primates often allowing them to be diagnosed only when they have reached a very serious level, sometimes causing collapse. Also, it is clear that in many instances the treatments which are offered (especially relevant to enteritis) are either done incorrectly, or are insufficient to have a meaningful impact.

Overall, the animals and incidents discussed indicate inadequate observation of these animals and inadequate treatment, if not veterinary negligence. Therefore I request that you initiate an investigation of the animal care at this facility and take action to levy the most substantial fine allowable under current federal regulations. I also request that you immediately suspend any projects which involve repeat violations.

I look forward to hearing of the results of your investigation as soon as possible. Please consider this a FOIA request for the results of your investigation (all documents generated as part of your investigation (including correspondence, emails, inspection reports, photos, etc.), made under the federal Freedom of Information Act, 5 U.S.C. sec. 552.

Sincerely,


Michael A. Budkie, A.H.T.,
Executive Director, SAEN

Attachments:
Project 8735 2007-2008
Monthly Reports - 2007

See: University of Louisiana, Lafayette, LA

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