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

USDA Complaints

Letter to USDA Regarding Federal Violations of Experiments Performed on Primates at University of Alabama


Stop Animal Exploitation NOW!
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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 because I have obtained information which leads me to believe that experimentation performed on primates at the University of Alabama, Birmingham, has violated several provisions of the federal regulations governing the use of animals in experimentation.

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).”

The use of fluid reward during experimentation, and the accompanying deprivation of water within a research protocol at the University of Alabama, Birmingham, is a serious concern. The recent research protocol titled: FMR Imaging of Eye Stabilization Processes says

“Water access will be restricted to 3 - 5 hours per day in the lab” this limited access to water could potentially be a violation of the watering requirements of Sec. 3.83. Water deprivation of as much as 21 hours per day has the potential to be extremely stressful to these primates as well and so this could violate:

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;

This kind of severe deprivation would clearly cause distress in these animals. Yet, the University of Alabama, Birmingham, has not reported any primates as experiencing unrelieved pain or distress. And so the University of Alabama, Birmingham, has also violated Section 2.36 of the Animal Welfare Act.

Therefore, I am filing an official complaint against the University of Alabama, Birmingham, and asking that USDA/APHIS/REAC immediately investigate this facility to examine the health and welfare of all primates at this facility as well as the reporting of this facility regarding the us of animals in experiments that can potentially cause pain or distress. 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

See Facility Reports/Information: University of Alabama - Birmingham

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