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Letter from Dr. Marjorie Cramer regarding SNBL February 17, 2007 Dear Mr. Budkie, I have reviewed the USDA inspection report provided by you on SNBL
USA, Ltd dated July 13, 2005. I believe that the most important fact that this report illustrates
is that, in spite of supposedly protective animal welfare laws, members
of institutional animal care and use committees (IACUCs) can ignore the
law very easily by simply asking for an exception, these exceptions
being allowed by the law itself. As the inspection report demonstrates,
this was done several times by SNBL in the period of time preceding the
report. I would like to make the following observations on the report: A study was mentioned in which a “highly toxic substance” was
injected into non-human animals, species unspecified. The substance is
not identified, nor is the frequency and duration of the injections, so
the possibility of injection site pain, irritation or necrosis cannot be
evaluated properly, nor can systemic effects such as nausea, vomiting or
diarrhea. However, it defies rational thought to believe, as the
experimenters did in this case, that such an experiment would cause not
pain or stress and that therefore no relief need be given (as is
required under the animal welfare act.) One of the animals in this study was noted to have been kept in the
study (i.e. received more injections of the toxic substance) in spite of
animal protective guidelines to the contrary. This animal was noted to
have lost 32% of his/her body weight, and had diarrhea, dehydration,
lack of appetite and lethargy (all stressful), skin lesions and a
necrotic tail lesion (both painful). No relief was given and in addition
the animal was fed by gavage. The specific method of gavage (enterostomy
or naso-gastric tube) is not mentioned but either would be both painful
and stressful. While naso-gastric tube gavage is sometimes indicated
medically, it is noteworthy that it may also be referred to as “force
feeding” and is a widely used method of torture of humans. The animal
went on to lose 41% of his/her body weight and was finally euthanized.
According to the USDA inspectors this animal “…was in poor condition for
an entire month and…suffered needlessly and excessively as a result…” A situation is described in which 110 marmosets (a type of monkey)
were received by the facility. Animal welfare law provides for minimal
cage size for various animal species. In this case, the animals were
already stressed and sick upon arrival at the facility but,
nevertheless, were housed in pairs in cages that were smaller than the
minimal size for marmosets. After some elapsed time, an employee noted
that the many of the animals had been injured fighting with each other.
The animals continued to be housed in the too-small cages for some time
before a cage size exemption was requested and granted, apparently
perfunctorily since the small cage size was undoubtedly contributing to
the fighting and stress and a high death rate (10 animals were found
dead in the cages and 9 had to be euthanized.) It was noted that no
medical treatment given during this time period. The USDA inspector made
the following comment: “It is very difficult to determine from the
methods used by this facility to make and keep medical or treatment
records if this group of distressed animals received adequate veterinary
and supportive care. Several of the animals that [sic] died had
incomplete records or none that gave any useful information.” The above mentioned situations bespeak a very poorly run and grossly
negligent facility, where animal welfare was observed more by ignoring
than by observing it. In addition, it was noted that the facility only
had a part-time veterinarian 3 days per week and no written program of
veterinary care in spite of laws requiring it. Medications were expired,
a situation which should not occur in a properly run operating room. All
that is required to avoid this is to assign an employee to check just
once a month to discard and reorder expired medications. One animal
managed to get his/her arm caught in a cage mechanism, which bespeaks
negligence on the part of the animal caretakers, and finally the cages
were noted not to have been sanitized in over 2 weeks, something which
speaks for itself. In summary I can only express extreme concern that such a facility as
this is allowed to exist in spite of severe criticism from the
inspectors. I can see no evidence that any concern for the welfare of
the experimental animals exists at the facility in even a rudimentary
fashion in spite of supposedly strict laws regulating experimental
animal laboratories. It is certainly open to question how valid any of
the experimental results could possibly be in light of the poor animal
care, shoddy record keeping, lack of diligence about medication
expiration dates, and poor veterinary care. Sincerely, Marjorie Cramer, MD, FACS
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