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Stop Animal Exploitation NOW!
S. A. E. N.
"Exposing the truth to wipe out animal experimentation"

Articles and Reports

Official Letter of Complaint to USDA about UCLA's Treatment of Primates


Stop Animal Exploitation NOW!
1081-B St. Rt. 28 PMB 280
Milford, Ohio 45150
saen@saenonline.org
513-575-5517

Dr. Robert Gibbens, Director, 7/17/07
USDA/APHIS/AC
2150 Centre Ave.
Building B, Mailstop 3W11
Fort Collins, CO 80526-8117

Dr. Gibbens,

I am contacting you regarding a matter of the utmost urgency and importance. I have recently obtained information regarding primates used at the University of California, Los Angeles. These records reveal extreme situations of abuse and potential violations of federal law.

Therefore I would like to request that you investigate the University of California, Los Angeles with respect to the following experimental protocols of Joaquin Fuster, including “Haptic Information processing/Primate Memory”, and any potentially newer protocols involving this researcher, including the research funded under grant R01MH072641, INTEGRATIVE APPROACH TO CORTICAL COGNITIVE NETWORKS

Sec. 2.31 D, iii “The principal investigator has provided written assurance that the activities do not unnecessarily duplicate previous experiments.”

For Haptic Information processing/Primate Memory the principal investigator claims to have done searches on the terms: monkey, parietal cortex, single cells, memory and/or haptic. Since this project uses rhesus monkeys the searches should include the term macaca, for which pubmed turns up over 51,000 listings. Then when parietal cortex is added to the search, 1292 publication still show up, and when ‘single cell’ is added 182 publications still arise. Clearly, this researcher did nothing to prevent unnecessary duplication.

The next relevant regulation is:

Sec. 3.83 Watering.

Potable water must be provided in sufficient quantity to every nonhuman primate housed at the facility. If potable water is not continually available to the nonhuman primates, it must be offered to them as often as necessary to ensure their health and well-being, but no less than twice daily for at least l hour each time, unless otherwise required by the attending veterinarian, or as required by the research proposal approved by the Committee at research facilities.

Both of these research projects seriously restrict the amount of time during which water is available to the primates used in these experiments. In fact, it discusses time periods of as much as 22 consecutive hours in which the primates will not have access to water. Therefore, I would like to request that you examine all logs for the primates used in this research project to determine whether these animals have received adequate access to water as is required by the Animal Welfare Act.

Additionally, this experiment is likely effected by

Sec. 2.31 Institutional Animal Care and Use Committee (IACUC).

(x) No animal will be used in more than one major operative procedure from which it is allowed to recover;

Provisions prohibiting the performance of unapproved surgical procedures are also likely to be relevant to these projects since devices such as eye coils and recording cylinders often need to be replaced/relocated due to infection, non-adherence, etc. during experimentation.

Therefore, records for all primates used in this protocol should be examined to determine if any unapproved surgeries have been performed.

Due to restraint, and potential individual housing, the primates used in both of these experiments must be evaluated relevant to environmental enhancement :

Sec. 3.81 Environment enhancement to promote psychological well-being.

(b) Environmental enrichment. The physical environment in the primary enclosures must be enriched by providing means of expressing noninjurious species-typical activities.

(c) Special considerations. Certain nonhuman primates must be provided special attention regarding enhancement of their environment, based on the needs of the individual species and in accordance with the instructions of the attending veterinarian. Nonhuman primates requiring
special attention are the following:

(1) Infants and young juveniles;
(2) Those that show signs of being in psychological distress through behavior or appearance;
(3) Those used in research for which the Committee-approved protocol requires restricted activity;
(4) Individually housed nonhuman primates that are unable to see and hear nonhuman primates of their own or compatible species;

It is quite clear that the activity of these monkeys would be restricted, and so special considerations must be made to allow for their psychological needs.

Lastly, these regulations are likely to be relevant as well:

Sec. 2.36 Annual report.

b) The annual report shall:

(7) State the common names and the numbers of animals upon which teaching, experiments, research, surgery, or tests were conducted involving accompanying pain or distress to the animals and for which the use of appropriate anesthetic, analgesic, or tranquilizing drugs would have adversely affected the procedures, results, or interpretation of the teaching, research, experiments, surgery, or tests. An explanation of the procedures producing pain or distress in these animals and the reasons such drugs were not used shall be attached to the annual report;

Now, it is quite clear those non-human primates who are confined to restraint chairs, have limited access to water, potentially limited environmental enhancement and who have devices literally bolted to their skulls would experience pain and/or distress. It is obvious that UCLA has filed blatantly dishonest documents with the USDA.

Additionally, communications between the USDA and the University of California, San Francisco states that:

“Please be reminded that you must provide scientific justification for not listing in Column E those primates at your facility undergoing up to 22 hours of water restriction. . . .

The fact that water restriction (i.e. thirst) is used as a negative reinforcement motivator indicates some level of distress requiring relief, and that fact that your researchers are apparently claiming that only water deprivation for extended periods of time (up to 22 hours) provides sufficient motivation for use in their studies indicates that a fairly significant level of distress due to thirst is needed to motivate the monkeys strongly enough for their purposes/. Scientific literature indicates that the thirst drive is exceeded in the hierarchy of drives only by severe pain and air hunger and that a 24-hour period of water deprivation can cause monkeys to experience elevation of plasma osmolarity over the threshold for thirst.”

Since the research project listed above also deprives primates of water for 22 hours, then UCLA who lists no primates in column E for the 2004 & 2005 reporting years, must have filed fraudulent reports, based on the words of the USDA.

Therefore, I am filing an official complaint against the University of California, Los Angeles and asking that the health and welfare of all primates used in the research projects listed above for the last four years, as well as the annual reports of UCLA be examined in full detail to determine if any violations of the Animal Welfare Act have occurred.

It is clear that Joaquin Fuster is performing unnecessarily duplicative research and that this project should be immediately terminated. It is also clear that UCLA has filed blatantly false reports with the USDA. Therefore, regulatory action should be taken against this individual and this facility as soon as possible.

I would also request that you provide me with the results of this investigation when it is completed.

Sincerely,


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

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