The Abuse of Non-human Primates in Federally Regulated Laboratories - October 2011:
Are Non-human Primates Protected from Abuse in U.S. Laboratories?

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The Abuse of Non-human Primates in Federally Regulated Laboratories - October 2011:
Are Non-human Primates Protected from Abuse in U.S. Laboratories?

The use of all animals, including non-human primates, is regulated by the Animal Welfare Act (AWA). This law, enacted in the 1960s, now includes requirements for housing, diet, veterinary care, psychological enrichment, and experimental procedures. This law is enforced by the United States Department of Agriculture (USDA) through the Animal Care division of the Animal & Plant Health Inspection Service (APHIS).

However, questions exist regarding the effectiveness of this law. Is this law even followed? Have U.S. laboratories seriously violated this law involving primates? Do the regulations which arise from this law actually protest non-human primates from abusive practices? Some recent examples of violations are listed below. This is followed by a section that discusses legally allowable “exceptions.”

On section of the Animal Welfare Act that is specific to non-human primates is section 3.81 Environmental Enhancement to Promote Psychological Well-Being. A search of the USDA Animal Care database reveals that in the last 12 months 16 facilities violated the Environmental Enhancement requirements of the Animal Welfare Act.

Examples of Serious Primate Abuse within Registered Research Facilities

A. From USDA Inspection reports

A USDA inspection report dated 8/2/11 cites McLean Hospital (Boston, MA) for an incident in which a primate was found dead after only 10 minutes in an experimental chamber. The lab is cited for insufficient supervision of experimentation, as well as inadequate housing and insufficient environmental enhancement for primates.

A July 19, 2011, USDA inspection report cites the Harvard Medical School five times for violations including unqualified personnel, inadequate supervision of experimentation by the lab’s Institutional Animal Care & Use Committee, and inadequate housing for primates. Several of the citations were directly relevant to a February 2011 incident in which a non-human primate was given an overdose of anesthetic causing irreversible renal failure requiring euthanasia. This is just over a year after a June 9, 2010 incident at a Harvard Medical School facility in which a dead non-human primate was found in an enclosure which had just gone through a cage-washing machine.

A USDA inspection report from May of 2010 reveals an incident during which eight marmosets escaped from a cage at the University of Massachusetts, Amherst (UMASS). While running loose, they pulled an infant marmoset through the bars of a cage which housed another group. The infant died as a result of this incident. UMASS was cited for inadequate primary enclosures. UMASS was cited for several other AWA violations including inadequate supervision of experiments by the lab’s Institutional Animal Care & Use Committee as well as inadequate housing/facilities.

An August 3, 2011, USDA report reveals that improper animal handling at MPI Research (Mattawan, MI) caused severe traumatic injuries to four animals. The injuries to these animals were so severe that no treatment was possible, requiring euthanasia. USDA sources have confirmed that two of these animals were non-human primates.

In an April 27, 2011 USDA inspection report Princeton University is repeatedly cited for experiments that deprive monkeys of access to water. The citations include inadequate functioning by the Institutional Animal Care & Use Committee (a repeat violation), inadequate watering, and the filing of a fraudulent report with the USDA. In an unrelated incident the lab is also cited for inadequately observing a marmoset who was giving birth. Princeton was the target of a scathing USDA inspection report of June 23, 2010. In issuing 13 separate citations against Princeton, the USDA focused on the same highly invasive project which deprives primates of water and implants devices into the skull.

Princeton University has also been the target of a recent whistleblower who disclosed major Animal Welfare Act violations including primate deaths through malnutrition, deaths due to lack of veterinary care, and other primates being killed in a cagewasher. The full statements, as well as leaked photos, are contained in other sections of this report.

A May, 2011, USDA inspection report for the University of Rochester, School of Medicine, and Dentistry reveals citations for depriving several primates of food for extended periods. Primate #940 was starved for 4 days and primate #631 was denied food for two days. The University is also cited for filing fraudulent reports for not listing these animals as experiencing distress. In a news story University staff admitted that the food deprivation was done intentionally and was not part of an experimental protocol.

A June, 2011, USDA inspection report cites Vanderbilt repeatedly for the performance of illegal, unapproved and highly invasive brain surgeries on at least one primate by unapproved and unqualified surgeon(s). The USDA report cites Vanderbilt repeatedly for incidents surrounding experimentation on primate 4414. An unapproved, and botched, surgical procedure was attempted by an unapproved surgeon in September of 2010. Further illegal surgeries and other illegal procedures were performed on the same primate in December of 2010 and April of 2011.

A USDA report dated 5/31/11 cited the University of Louisiana, Lafayette, for: “ . . . deaths of 3 Rhesus monkeys which became trapped in a chute in one of the outdoor breeding colonies. The remains were autolyzed therefore they had been trapped for some time and not properly monitored.”

B. From USDA Official Warnings/Fines

In June of 2011 the Lovelace Respiratory Research Institute of Albuquerque (NM) was fined $21,750 by the USDA for several violations including inadequate housing because an infant cynomolgous monkey had escaped, and another primate became trapped and suffocated.

In March of 2011 the University of Washington, Seattle, paid a $10,893 fine for violations which involved the deaths of three non-human primates, one from malnutrition, and two from infection of cranial implants.

An Official Warning made public by the USDA in July of 2011 revealed that the Weill Medical College of Cornel University killed a non-human primate through lung hyperinflation when a breathing tube was kept clamped during a surgical procedure.

In September of 2010 Northwestern University received an Official Warning from the USDA for a thermal injury (burn) to a non-human primate during a tail amputation procedure.

In July of 2010 Vanderbilt University was fined $8156 for multiple violations of the AWA, including an incident in which an infant galago monkey was found dead in bedding that had been run through a washing machine.

A January, 2011, Official Warning cited the Southern Research Institute for the death of a primate whose head had become caught in a cage.

Oregon Health Science University currently has two open Animal Care Enforcement cases. Case OR09023 is relevant to a primate escape. While case 10002 is of undetermined nature.

C. Exclusion of Primates from AWA Standards

Basic standards for care and treatment are a major part of the Animal Welfare Act (AWA). These standards include frequency of feeding, watering, cage cleaning, social housing, frequency of surgical procedures, etc. However, the AWA also allows animals to be exempted from these standards for ‘scientific’ reasons. And so, animals such as primates can be exempted from requirements for feeding, watering, cage cleaning, social housing, etc. Essentially they can be placed outside the coverage of the law in these areas. Is this done very often? Does it involve a substantial number of animals?

While it would be difficult to answer this question fully, due to the number of laboratories that utilize primates, it is possible to get a snapshot of this situation by examining a relatively small number of the larger primate facilities. The facilities examined are: Emory University, Harvard Medical School, University of Louisiana (Lafayette), the National Institutes of Health, Oregon Health Sciences University, the University of Wisconsin (Madison), and Wake Forest University. Individually, these labs run the spectrum on these issues, but one example should suffice. Emory University exempted 1835 primates from the standards of the AWA. 4 primates were used in painful experiments without anesthesia. 381 primates experienced restraint (i.e. confinement in a primate restraint chair). 1356 primates were singly housed, exempting them from having social contact with members of their own species. 94 primates had restricted access to either food or water. Emory used a total of 2369 primates in experimentation. This means that 77% of the primates used in experimentation at Emory were exempted from the standards of the Animal Welfare Act.

Collectively, these labs experimented on 15,324 primates or 21.5% of the national total, or slightly over 1 out of every 5. These labs exempted 6273 animals (as listed in the exceptions to standard care section of their annual reports) to at least one of the standards contained in the AWA. This could mean that these animals were prevented from having access to food/water for extended periods, or they may have been exempted from socialization, or housing standards, cage cleaning standards, etc. This accounts for 41% of the primates used at these facilities. If this statistic is generalized to the national total then 29,240 primates were exempted from at least one regulation that is part of the Animal Welfare Act. Additionally, USDA national statistics for 2010 indicate that 1395 non-human primates or 2% were used in painful/stressful experiments without benefit of anesthesia. In total, then, an estimated 43% of all non-human primates used in experimentation are legally excluded from at least some level of protection under the Animal Welfare Act.

Who decides on these exceptions? These practices are approved by the Institutional Animal Care and Use Committees which are mandated by the AWA and charged with the responsibility of approving all animal experimentation within a facility. These committees are routinely comprised almost entirely of staff that is employed at the facility at which the experimentation will be conducted. These committees are required to have only one member who represents the views of the community. In other words, the committees empowered to approve protocols which exempt animals from Animal Welfare Act regulations are comprised of employees of the institutions that receive funding to perform the experiments. These individuals have a vested interest in approving experiments because that keeps the federal funding rolling into their employer.

Next: Whistleblower Statements

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