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Stop Animal Exploitation NOW!
S. A. E. N.
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USDA Complaints

Letter to USDA Regarding Non-Compliance of AWA at Vanderbilt


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

10/12/07

Dr. Elizabeth Goldentyer
USDA/APHIS/AC
920 Main Campus Drive, Suite 2000
Raleigh, NC 27606

Dr. Goldentyer,

I am contacting you today regarding the abysmal record of non-compliance with the Animal Welfare Act at Vanderbilt University (63-R-0005). In the period from the beginning of 2005 - mid 2007 Vanderbilt has amassed 64 separate Animal Welfare Act violations (non-compliances). 14 of these violations were repeat occurrences. The largest single area of non-compliance was the Institutional Animal Care and Use Committee, which had 22 separate violations. The next largest area of non-compliance was Veterinary care, which had 9 separate violations.

It is clear that this facility has an almost total disregard for federal authority and has no consideration for the protection of the animals who are confined there. This is clearly demonstrated by the escalating severity of recent infractions. In January 2007, a rabbit was killed by being run through a cage washer at Vanderbilt while in May of 2007 three cotton rats were killed due to improper handling. Another federal violation report for Vanderbilt describes a primate who was subjected to a painful brain-scrape procedure without benefit of anesthesia or pain relief of any kind.

These infractions demonstrate a level of negligence in animal care and disregard for regulatory authority that is almost unprecedented. Your agency has done an admirable job of documenting this ongoing case of non-compliance. Your inspectors should be praised for their persistence.

However, this facility has reached a level of carelessness that cannot go unpunished. The incompetence and negligence involved in these violations cannot be tolerated. Therefore I must insist that you initiate proceedings for the issuance of the largest possible fine against this facility. In light of the fact that Vanderbilt’s last inspection listed 12 infractions, I would ask that these infractions be the basis of the penalty, which should total $30,000 as the current basis for computation is $2500 per infraction.

Additionally, one specific animal has been repeatedly abused at this facility. Primate R5715F is listed in page 2 of the 6/30/06 inspection. As discussed in the USDA inspection report this unfortunate animal, according to Vanderbilt’s records, was given no water whatsoever on 6/25/06. And on the following day, 6/26/06, she received only 250 ml of juice.

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.

The Guide for the Use and Care of Laboratory Animals from the Institute of Laboratory Animal Resources of the National Resource Council states:

“ . . . animals should have access to potable, uncontaminated drinking water according to their particular requirements.”

According to the Guidelines for the Care and Use of Mammals in Behavioral Research (National Research Council) the fluid needs of non-human primates are extensive:

“ . . . daily fluid consumption in nonhuman primates has been reported at 75 ml/kg BW (Kerr, 1972; Wayner, 1964), 90 ml/kg BW (Wayner, 1964), and 110 ml/kg BW (Evans, 1990).”

Unless this primate is of a size that 250 ml is sufficient, meaning the animal has a body weight of 3.3 kg (approximately 7 lbs), this is a grossly insufficient amount of water for one day, let alone two. The inspection reports other signs of potentially abnormal behavior for this primate:

“The primate appeared more quiet and withdrawn (sitting in the back corner, leaning against the wall) than the other primates to this inspector on the morning of 6/26/06. Based on the lack of records one couldn’t tell if this was normal or abnormal behavior for her. The weight records for the month of June for R571F show a steady decrease the first half of the month then a leveling in the primate’s body weight.”

R571F shows up again in another USDA inspection report dated 12/4/06. In this report we find that “The laboratory records for primate R571F . . . Dated May 21, 2006 shows that laboratory personnel performed a durascrape. The medical record for primate R571F states that on May 25, 2006 that a veterinarian was called on may 24th 2006 regarding the primate “holding head after cleaning. . . . Neither the laboratory record, the medial record or the controlled substance log show that any anesthetics or analgesics were administered before, during or after the cleaning/durascrape procedure.”

According to internal Vanderbilt Medical Center correspondence (included with this letter) issues involving unapproved surgeries on primates in neurological protocols and the harassment of staff for reporting Animal Welfare Act non-compliances took place in 2004. So, it is clear that the staff at Vanderbilt who are connected with neurological research have a total disregard for the law, because they have had ongoing violations of the Animal Welfare Act for at least three years.

Especially in the case of primate R571F, the staff of this facility have demonstrated a clear pattern of ongoing abuse and neglect as well as a callous disregard for federal regulations. Therefore, I officially request that primate R571F be immediately seized and removed from the premises of Vanderbilt and placed in a private sanctuary that is capable of caring for her properly and providing her with the best possible situation for the remainder of her life.
I look forward to hearing of the results of your investigation, and the fate of primate R571F as soon as your work is completed.

Sincerely,


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

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