Lovelace Respiratory Research Institute, Albuquerque, NM

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Lovelace Respiratory Research Institute, Albuquerque, NM
Letter of Complaint to USDA - 30 Apr 2012

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April 16, 2012

FROM:
SAEN
1081-B St. Rt. 28  #280
Milford, Ohio 45150
513-575-5517
www.saenonline.org        
 
TO:
Dr. Robert Gibbens
Director, Western Region
USDA/APHIS/AC
2150 Center Ave.
Building B, Mailstop 3W11
Fort Collins, CO 80526-8117

Dr. Gibbens,
 
I am contacting you today because I have received information from a whistleblower connected to the Lovelace Respiratory Research Institute (LRRI).  This source has made me aware of a potentially very disturbing experimental project at LRRI, which may well be violating the Animal Welfare Act.

 According to this whistleblower, LRRI staff are about to launch an experiment which will study blast induced head injury in primates, and a related project may study the relationship between survival of blast injury and post-traumatic stress disorder (PTSD).  The proposed section of this research which will deal with PTSD is scheduled to subject the primates to blast-induced head injury without anesthesia.

 I am concerned about this study for several reasons.  In all aspects of this study non-human primates will be subjected to blast injury.  This issue alone is clearly very distressing, and could give rise to multiple violations of the Animal Welfare Act.  This must be questioned in terms of scientific necessity and in terms of scientific validity.  I am very concerned that all procedures have been totally evaluated to minimize the potential pain/discomfort of the animals, that alternatives have been adequately considered, that this research does not unnecessarily duplicate previous projects involving head injury in primates, and that adequate anesthesia will be used. 

This last concern regarding anesthesia is particularly important because it has been reported to us that the PTSD portion of this experimentation, once begun, will not utilize anesthesia during the blast injury to the primates.  Please address these issues ASAP so that this experiment will not be conducted without proper approval and without making certain that all relevant regulations are followed. (see code sections below).  And if this project is not in compliance with all Animal Welfare Act regulations, I officially request that it be at least temporarily halted.

I am also very concerned about this kind of experimentation at LRRI because this facility has previously been fined for violating the Animal Welfare Act, and because at last report this facility was under a second investigation relevant to the deaths of several dogs at LRRI due to situations which violated the Animal Welfare Act, after having paid a previous fine for killing a non-human primate through negligence.

 I am aware that the initial procedures of this project have begun.  The baseline MRI measurements of the primates, which were to be done pre-blast injury have been started.  Obviously, this matter is of the utmost urgency.  I respectfully request that your office send an investigator to LRRI immediately to determine that this project is being conducted in accordance with all relevant sections of the Animal Welfare Act.  If I can provide you with any additional information please don’t hesitate to contact me.

 I expect that your office will reply to this correspondence within five business days.

 Sincerely,

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

Attachment:

CC: Office of the Inspector General

Sec. 2.31 Institutional Animal Care and Use Committee (IACUC).
 
(8) Be authorized to suspend an activity involving animals in accordance with the specifications set forth in paragraph (d)(6) of this section.
(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;
(ii) The principal investigator has considered alternatives to procedures that may cause more than momentary or slight pain or distress to the animals, and has provided a written narrative description of the methods and sources, e.g., the Animal Welfare Information Center, used to determine that alternatives were not available;
(iii) The principal investigator has provided written assurance that the activities do not unnecessarily duplicate previous experiments;
(iv) Procedures that may cause more than momentary or slight pain or distress to the animals will:
(A) Be performed with appropriate sedatives, analgesics or anesthetics, unless withholding such agents is justified for scientific reasons, in writing, by the principal investigator and will continue for only the necessary period of time;
(B) Involve, in their planning, consultation with the attending veterinarian
or his or her designee;
(C) Not include the use of paralytics without anesthesia;
 
See also:

• LRRI Whistleblower Reveals 'Horrific' Explosive Head Injury Experiment; USDA Confirms Investigation of Watchdog Complaint
  Press Release
• Response Letter from USDA to SAEN - 16 Apr 2012