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Letter from Stephen R. Kaufman, M.D., Commenting on the 2005 USDA Inspections Report at Charles River Laboratories 

I am commenting on the 2005 USDA reports which you provided to me relevant to inspections at the Charles River Laboratories facility in Wilmington, MA. These reports reveal some very serious problems at this facility regarding reporting to government regulators, care to animals, and animal use in scientific procedures. Overall, it is my opinion that the violations of federal regulations that occurred at this facility demonstrate callous disregard for animal welfare, which undermines scientific data.

Inadequate animal care and housing not only cause unnecessary animal suffering, they also endanger human health by producing unreliable data.

Taken together, these issues render experiments at this facility questionable, at best.

Some examples from the USDA reports will suffice to illustrate my concerns. The report dated 7/25/06 cites a protocol in which animals were subjected to orbital sinus bleeds. This protocol was listed as not causing pain or distress, though the USDA inspector clearly believed this was inaccurate and had previously cited this protocol for claiming that this procedure is painless. This USDA report also cited 5 different drug testing protocols for failure to report the pain/distress of the animals involved. In other words, these tests were reported by Charles Rivers Laboratories as not causing pain or distress. In four of these five, animals died as a consequence of the drug, and in one experiment 18 animals were killed and another 18 needed to be euthanized. Clearly these experiments caused pain/distress, but Charles River Laboratories did not acknowledge this.

The same USDA report lists rabbit #9565 as having a potentially broken leg. The rabbit's injury was not officially diagnosed for over 24 hours, at which time the rabbit was euthanized. This rabbit was allowed to suffer for an unnecessarily long period. Additionally, Charles River Laboratory's IACUC documentation listed this rabbit as not needing treatment and not suffering any pain or discomfort.

Rabbit #1595 was listed as not experiencing pain or distress despite the fact that this rabbit had a loss of 16% of the body weight and did not eat for 5 days. Just a few days later the overall condition of this rabbit required euthanasia. Again, Charles River Laboratories claimed that this rabbit experienced neither pain nor distress.

Similarly, a USDA report dated 1/25/05 criticized a protocol that involved procedures that were likely to kill animals. Charles River Laboratories listed the experiment as causing neither pain nor distress.

An USDA inspection on 7/21/05 reported 48 dogs in one room in which the flooring had caused varying degrees of inflammation, including lesions that oozed a mucopurulent (pus) fluid, clearly indicating infection. This situation was obviously inhumane for the 48 dogs in this enclosure, and it would potentially compromise any research project in which these dogs were used, because the poor animal care introduced uncontrolled variables, including bacterial infection.

Inspection reports from other dates list incidents of animals with open sores, hair loss, and other veterinary issues that were undiagnosed. These reports also discuss problems with enclosures, food receptacles, sanitation, etc. All of these matters are potentially serious and can affect both the quality of the lives of the animals within this facility and the validity of the science performed there.

Any compassionate person would be troubled by experiments in which the USDA had concerns about animal pain and distress but were listed by the researchers as causing no pain or distress. For these experiments, Charles River Laboratories had no plans to alleviate animal suffering, nor was there
any evidence that researchers sought less painful alternatives.

The ethical concerns also give rise to scientific concerns. If researchers are blind to obvious animal suffering, will they record all relevant data thoroughly and accurately? Importantly, inadequate animal welfare standards greatly compromise the applicability of any data to humans.

Extrapolating data from animals to humans is tenuous at best, and inadequate animal welfare standards add uncontrolled variables, which greatly reduces the likelihood that the data will reliably apply to humans.

Stephen R. Kaufman, M.D.

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