Full Report: Unrelieved Pain in Laboratory Experimentation on Animals; The 20 Worst Facilities in the U.S.

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Unrelieved Pain in Laboratory Experimentation on Animals; The 20 Worst Facilities in the U.S.

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


One of the main purposes of the Animal Welfare Act is to “to insure that animals intended for use in research facilities or for exhibition purposes or for use as pets are provided humane care and treatment.” The prevention of pain through the use of adequate anesthesia is clearly a commonly accepted part of the concept of “humane treatment.” In fact, the Animal Welfare Act goes on to state that it is necessary for “animal care, treatment, and practices in experimental procedures to ensure that animal pain and distress are minimized, including adequate veterinary care with the appropriate use of anesthetic, analgesic, tranquilizing drugs, or euthanasia.” It was clearly the intent of the framers of this law that pain relief is a necessary part of the use of animals in experimentation.

However, the law also provides for an exception to the use of anesthesia when “scientifically necessary” and “that the withholding of tranquilizers, anesthesia, analgesia, or euthanasia when scientifically necessary shall continue for only the necessary period of time.” And so, many procedures utilized in laboratories commonly involve unrelieved pain.

Reporting of Experiments Involving Unrelieved Pain

During 2009, the most recent year for which information is available, the USDA reports that 76,001 animals experienced unrelieved pain in experimentation. However, this statistic is likely fraught with inaccuracy. For example, the USDA statistics for Maryland disclose the use of 9760 animals in this category. However, when the statistics from individual laboratories in the state of Maryland who used animals in experiments involving unrelieved pain are actually totaled, the total is actually 10,035, an error of 275 animals, or 2.8%. If this were applied to the national total, then a number more in the vicinity of 78,129 is arrived at.

When the reporting of other issues concerning unrelieved pain in experimentation is examined, major inconsistencies are found. For example, the Medical College of Georgia reports a total of 2 primates listed in Column E, for testing involving unrelieved pain. These primates are listed because they experienced restricted/limited access to water. Clearly, severely limiting access to water (or food) could cause distress to an animal, just as it would to a human. However, the examination of report forms for other major laboratories such as Emory, the University of Wisconsin, Wake Forest, Oregon Health Sciences University, etc. All list instances of restricted access to water or food. However, these facilities apparently do not consider this situation to cause unrelieved pain or distress. The current national reported total for primates experiencing unrelieved pain in experimentation is 1711. The primates who have experienced severely restricted access to food or water total over 550 nationally, or an error of non-disclosure for this procedure only of over 32% of the national total. Many other issues involving primates which are commonly only listed as exceptions to standards, and not as unrelieved pain, exist including social isolation (over 1000), restraint chair confinement (over 200), etc. These three procedures alone would total 1750 unreported primates who could be said to have experienced unrelieved pain or distress. This total from only 3 procedures exceeds the reported national total for primates who experienced unrelieved pain/distress. If similar logic is used for all other species, then it becomes clear that the statistics reported by the USDA could be off by as much as 100%. It is also extremely clear the vast inconsistencies exist in the reporting of animals used in this type of experimentation.

Though it is impossible to prove motivation for under reporting of experimental pain in animals, the reason may lie in additional reporting requirements. The Animal Welfare Act requires that if animals are used in experiments involving unrelieved pain that they are not only reported in this category, but that the withholding of pain relief be explained/justified. These explanations usually involve disclosing a significant amount of information about the experimentation being performed as part of the facility’s annual report to the USDA. These reports are now available online and are therefore accessible to the general public. Additionally, using animals in experimentation involving unrelieved pain also requires other additional paperwork and closer scrutiny by approval committees. Therefore, it is in the interest of those who use animals in research to avoid closer public and regulatory scrutiny by denying the painful nature of the experimentation that they are performing.

Which Laboratories use Animals in Experiments involving unrelieved pain?

Nationally, the USDA’s reported statistic for animals used in experiments involving unrelieved pain is 76,001 for 2009, a slight decrease from 2008 of 386 animals. While many laboratories use some animals in projects involving unrelieved pain, the majority of animals that have been reported in to this category are used by relatively few facilities. Examining the use of animals in experiments involving unrelieved pain can be accomplished by examining only a few dozen of the approximately 1000 – 1100 registered research facilities in the U.S. If the focus in narrowed, we can see that only 20 labs account for 69.3% of the national total of animals used in experiments involving unrelieved pain.

The 20 labs under discussion can be seen in a table in Appendix 1. These labs were ranked as the top 20 labs for causing unrelieved pain to animals in experimentation based on two categories. The first is the sheer number of animals in this category. The lab in this top 20 using the most animals in experiments involving unrelieved pain is the Emergent Biodefense lab of Michigan. The second way that these labs were ranked is by percentage. In other words, what is the percentage of animals used in a laboratory in experiments involving unrelieved pain? The lab using the highest percentage of animals in projects involving unrelieved pain is the Aberdeen Proving Ground facility which used 83.7% of all animals at this Department of Defense facility in experiments involving unrelieved pain.

Eight of the twenty most painful labs in the U.S. were part of the Pharmaceutical Industry (Diamond Animal Health, Colorado Serum Company, Novartis, Fort Dodge, Pfizer, Elan Pharmaceuticals, Boehringer Ingelheim Animal Health, and Novartis Genomics). These eight labs accounted for 22,913 animals experiencing unrelieved pain, for an average of 2864 per lab and accounted for 30% of the national total.
The next largest category is facilities engaged in experimentation involving either chemical or biological weapons. This category includes both labs owned by the Department of Defense (Aberdeen Proving Ground and the Army Institute of Infectious Disease) as well as labs that are clearly experimenting in this area (Emergent Biodefense, and Battelle Memorial Institute). These four facilities accounted for 17,428 animals experiencing unrelieved pain, averaging 4357 per facility and accounting for 22.9% of the national total. This is clearly the worst category of all containing the top labs by both percentage and absolute total, Aberdeen Proving Ground and Emergent Biodefense, respectively.

Four colleges/universities make the top 20 (Utah State University, University of Utah, University of North Texas Health Science Center, and the University of Texas Medical Branch, Galveston). The university labs used 7106 animals in experiments involving unrelieved pain, for an average of 1777 per lab and accounted for 9.3% of the national total.

Four private labs made the top 20 (Lee Laboratories, Meriel Limited, the Parkinson’s Institute and Intervet), The four private labs used 5230 animals in experiments involving unrelieved pain, an average of 1308 per lab and accounting for 6.9% of the national total.

Legal Issues

While the use of animals in experiments involving unrelieved pain clearly involves issues of reporting accuracy and morality, it may also involve potential legal issues and violations of federal law. Some of these issues, as already discussed, involve discrepancies as to what causes pain/distress, and the inaccurate/fraudulent reports that may result from denying that procedures such as food or water deprivation can cause distress. However, in many instances other legal issues may arise.

Many of the procedures which involve unrelieved pain also potentially involve animal death. An important part of the Animal Welfare Act, as already cited, involves appropriate use of euthanasia.
The regulations promulgated by the USDA/APHIS/AC as part of the enforcement of the Animal Welfare Act state that:

“Each research facility shall establish and maintain programs of adequate veterinary care that include:
4. Guidance to principal investigators and other personnel involved in the care and use of animals regarding handling, immobilization, anesthesia, analgesia, tranquilization, and euthanasia;”

One laboratory in particular exhibits potential violations of the Animal Welfare Act, Meriel Limited. The 2009 report for this facility discloses that “2258 hamsters experienced weight loss, debilitation, and death” and “4 cats exhibited clinical symptoms consistent with the challenged agent, but died prior to euthanasia.”

It is clear that these 2262 animals were not observed in a timely manner or provided euthanasia, both of which are potential violations of the Animal Welfare Act.

Other legal issues exist regarding the use of animals in experiments involving unrelieved pain. Several of the top 20 facilities in this category are owned by the Department of Defense. Currently, the Animal Welfare Act does not give the USDA authority to inspect facilities owned by other branches of the federal government. In other words, there is no independent oversight regarding the use of animals in labs owned by the Department of Defense or any other federal agency. This is extremely disturbing since many of the most painful experiments, those involving chemical and biological weapons, are performed within military facilities.


The purpose of this report is manifold. The general public often believes out of ignorance that animals used in experimentation are not allowed to feel pain, or that the animals who do actually experience unrelieved pain are very few. A brief examination of the facts in this situation reveals that this is not true. Tens of thousands of animals experience unrelieved pain in U.S. laboratories every year. The number of animals in this category, allow for literally hundreds of animals to feel unrelieved pain every day of the year. In some instances the pain that they experience is part of a fatal process.

Significant evidence exists that the number of animals used in this category is both miscalculated by the USDA and under-reported by laboratories. Therefore it is highly likely that an accurate reporting, coupled with accurate computations by the USDA would reveal a substantially larger number of animals used in experiments involving unrelieved pain, potentially doubling the present total, and possibly reaching over 100,000 animals per year.

The pain experienced by animals in laboratory experimentation cannot be adequately relieved or even assessed if it is denied or dismissed. Therefore, the first steps that must be made in dealing with experimental pain in animals involve both honesty in reporting by laboratories, and accurate disclosure by the USDA. Only then can we move towards the elimination of this pain as well as adequate enforcement of existing laws and regulations.

Appendix 1
(Updated 2/10/11)

20 Most Painful Animal Labs
Facility Dog Cat  Guinea  Hamster Rabbit Primate Sheep  Other  Other Unrelieved Total Unrelieved Points Points Total
      Pig       /Pig Farm   Pain # Used Pain % # % Points
Aberdeen Proving Ground (MD)     6,547     93       6,640 7,929 83.7 19 20 39
Utah State University (UT)     28 4,572           4,600 5,874 78.3 16 19 35
Emergent Biodefense (MI)     7,187             7,187 13,192 54.5 20 13 33
Diamond Animal Health (IA)       3,198           3,198 4,686 68.2 15 16 31
Colorado Serum Company (CO)     1,238 388           1,626 2,807 57.9 9 15 24
University of Utah (UT)     1,504             1,504 2,675 56.2 8 14 22
Lee Laboratories (GA)         1,792         1,792 3,402 52.7 10 10 20
Meriel Limited (GA)   4 14 2,258           2,276 6,525 34.9 13 6 19
Parkinson's Institute (CA)           56       56 74 75.7   18 18
Novartis (IA)     73 2,715           2,788 8,195 34.0 14 4 18
Fort Dodge (IA) 98 85   6,078           6,261 28,883 21.7 18   18
U of North TX Hlth Sci (TX)       394           394 560 70.4   17 17
Pfizer (NY) 190 65 303 5,033 7 9   75 44 5,726 44,008 13.0 17   17
Intervet (DE) 5   373 585 118       25 1,106 2,294 48.2 5 9 14
Batelle Memorial Institute (OH) 4   1,369 102 295 424     74 2,268 7,514 30.2 12 2 14
U of Texas, Galveston (TX)     323 173 112         608 1,134 53.6 1 12 13
Elan Pharmaceuticals (CA)     695             695 1,312 53.0 2 11 13
Army Inst Inf Dis (MD)     621 321 200 191       1,333 3,568 37.4 6 7 13
Boehringer Ingelheim Anml Hlth (MO)       2,235           2,235 11,640 19.2 11   11
Novartis (Genomics) (CA)     384             384 990 38.8   8 8
20 lab Totals 297 154 20,659 28,052 2,524 773 0 75 143 52,677 157,262        

These 20 labs average 2,633 animals per lab experiencing painful experimentation without pain relief of any kind.

An average of 33.5% of the animals in these 20 labs experience unrelieved pain.

These 20 labs account for 52,677 animals experiencing unrelieved pain in experimentation.

This is 69.3% of the national total of 76,001 animals who experienced unrelieved pain during 2009.

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