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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 UCSF's Treatment of Primates


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

7/17/07

Dr. Robert Gibbens, Director,
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, San Francisco. 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, San Francisco with respect to the following experimental protocols and specific primates.
The protocols in question are:

Neural Control of Eye Movement; Cortical Plasticity System, which I believe to be the work of Stephen Lisberger.

Neural Correlates of Sensorimotor Adaptation in macaque Cortex.

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

For the first protocol (Neural Control of Eye Movement) The search terms used for this project were monkeys and fluid restriction, alternatives and fluid restriction, alternatives and alternatives & monkeys. First, to address the species used in this research it would be necessary to use the latin species name macaca, which in pubmed generates over 51,000 listings. Since this research is relevant to eyes, it might be better to use terms like vision (macaca and vision generate 1862 hits in pubmed), or even using the name of the research protocol, a search on macaca and cortical and plasticity generates 100 hits. Clearly, this researcher did nothing to prevent unnecessary duplication.
For the second protocol (Neural Correlates of Sensorimotor Adaptation) Macaca and sensory yields 82 publications, macaca and sensorimotor yields 17 publications. Macaca and cortex and motor yields 89 publications. Clearly, these investigators have not demonstrated that their research is not unnecessarily duplicative.

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. 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, these experiments are 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.

For the first protocol (Neural Control of Eye Movement)
Primate mmu30531 had 14 surgeries in the space of five years.
Primate mmu31394 had 7 surgeries the space of three years
Primate mmu29678 had 10 surgeries in the space of 4 years

For the second protocol (Neural Correlates of Sensorimotor Adaptation)
Primate 33059 had 5 surgeries within nine months.
Primate mmu31314 had 5 surgeries within 3 years

Therefore, records for all primates used in these protocols should be examined to determine if any unapproved surgeries have been performed. Additionally, many of these primates came from the University of California, Davis and it is unknown if any surgeries were performed on these animals before they arrived at the University of California, San Francisco. Please look into this possibility.

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.

Additionally, it is very clear from the records for several of the primates used at UCSF that ongoing pathological conditions may have seriously compromised the value of the research in which they were used beyond repair. These primates are MMU30531, primate 33059, and primate MMU31314. Records for all of these animals reveal ongoing bacterial infections lasting as long as 8 months.

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 UCSF has filed blatantly dishonest documents with the USDA.

Additionally, it is apparent from communications between the USDA and UCSF that you have questioned this institution about this issue before. I would respectfully request that you take regulatory action against this facility since, despite your correspondence of 2004, UCSF again filed an erroneous report with the USDA during 2005.

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

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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