Dr. Goldentyer,

I am contacting you regarding a matter of the utmost urgency and importance. I have recently been contacted by a whistleblower who has given me very disturbing information regarding the MPI Research (registration number 34-R-0031) facility in Mattawan, MI.

Attached to this letter you will find several internal documents from MPI Research which raise very serious concerns regarding the care and handling of animals at MPI Research. You will also find a previous complaint attached to this letter, which I filed with your office back in 2007.
The documents which have been furnished to me reveal an ongoing pattern of incompetence, negligence and carelessness at this facility.

According to an internal Animal Welfare Concern Report dated 8/1/04 an issue was raised regarding a number of severe injuries to animals at MPI research. These injuries included broken arms, a broken leg, severed toes, and several animal deaths. The document also discusses additional incidents involving lacerated fingers, toes, and tails that occurred during the process of removing animals from cages. The attached printout from the Animal Fracture Database reveals a continuing pattern of injuries from 6/07 – 6/09. During this two year period 16 animals including both primates and pigs had traumatic injuries involving either dislocations (4) or fractured bones (12). Six of these animals had to be killed due to the severity of their injuries.

This high rate of injuries clearly indicates major violations to (at least) 3 sections of the federal regulations governing research facilities. It is obvious that these animals are not being handled properly (section 2.131 handling of animals), that the occurrence of these incidents and the frequency with which they occur indicates untrained and unqualified personnel (Section 2.32). Additionally, the fact that 6 of these injuries were described as “cause unknown” indicates inadequate observation of the animals and potentially inadequate veterinary care.

The relevant sections of the regulations associated with the Animal Welfare Act are cited below.
I find these incidents most disturbing for several reasons. First, the USDA inspection reports for this period (attached) contain no mention of any of these incidents. This may indicate either an inadequate inspection process by USDA staff, or the withholding of information by staff of MPI.

However, I am most upset by these issues because they were a part of our previous complaint. They had clearly existed, as is documented by the internal animal care concern document from MPI. The second animal care document also discusses improper dosing of animals, and problems with many other procedures, which were also referenced in our previous complaint.

The information which we are now providing demonstrates major violations of the Animal Welfare Act at MPI Research ranging from 2004 – 2009. As I mentioned earlier, it is extremely disturbing that none of these issues are addressed within USDA inspection reports for this period. It is also distressing that apparently the USDA investigation resulting from our previous complaint in 2007 was insufficient, or that our complaint was not taken seriously.

Therefore, I am forced to request a new investigation. In this investigation it is imperative that USDA/APHIS/AC examine the records of all primates within MPI Research for traumatic injuries, that all Animal Welfare Concern Reports at MPI Research are examined, and that care be taken to ascertain why none of these issues was discovered before.

I also believe it is essential that these issues be addressed in the most complete manner possible because our previous actions have obviously not been sufficient. Therefore, I am also forwarding this complaint to the Office of the Inspector General within the USDA for their action.

I would also urge you to give MPI staff the opportunity to discuss the operations of this facility with you without repercussions. Clearly many of them have contacted SAEN about their concerns. Apparently they are afraid to contact the USDA due to the potential for repercussions within the workplace.

Dr. Goldentyer, it is imperative this issue be addressed urgently. This facility handled over 3700 primates during 2009 alone. The documentation in our possession covers only the first half of this year, and yet discloses 4 major injuries. How many more happened during the second half of 2009? How many during 2010? I am especially concerned regarding the current conditions at this facility due to recent staff layoffs. If these incidents took place with higher staffing levels existed, what are the conditions now with lower staffing levels? How many more primates have had arms or legs broken or dislocated?

Most importantly, how many injuries could have been prevented if your office had acted more diligently on this issue when it was first brought to your attention during 2007?

I hereby officially request copies of all documents generated by your investigation of this complaint under the federal Freedom of Information Act, 5 U.S.C. sec. 552. Included in this request are all documents, photos, videos, etc.

I will expect your response within 10 business days.

Sincerely,

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

9CFR2.131
 
(b)(1) Handling of all animals shall be done as expeditiously and carefully as possible in a manner that does not cause trauma, overheating, excessive cooling, behavioral stress, physical harm, or unnecessary discomfort.

9CFR2.32

Sec. 2.32 Personnel qualifications.

(a) It shall be the responsibility of the research facility to ensure that all scientists, research technicians, animal technicians, and other personnel involved in animal care, treatment, and use are qualified to perform their duties. This responsibility shall be fulfilled in part through the provision of training and instruction to those personnel.
(b) Training and instruction shall be made available, and the qualifications of personnel reviewed, with sufficient frequency to fulfill the research facility's responsibilities under this section and Sec. 2.31.
(c) Training and instruction of personnel must include guidance in at least the following areas:
(1) Humane methods of animal maintenance and experimentation,
including:
(i) The basic needs of each species of animal;
(ii) Proper handling and care for the various species of animals used by the facility;

9CFR2.33

Sec. 2.33 Attending veterinarian and adequate veterinary care.

(b) Each research facility shall establish and maintain programs of adequate veterinary care that include:
3) Daily observation of all animals to assess their health and well-being; Provided, however, That daily observation of animals may be accomplished by someone other than the attending veterinarian; and Provided, further, That a mechanism of direct and frequent communication is required so that timely and accurate information on problems of animal health, behavior, and well-being is conveyed to the attending veterinarian;

We welcome your comments and questions