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Official Letter of Complaint to USDA about UCLA's Treatment of Primates
Dr. Robert Gibbens, Director, 7/17/07 Dr. Gibbens, I am contacting you regarding a matter of the utmost urgency and
importance. I have recently obtained information regarding primates used
at the University of California, Los Angeles. These records reveal
extreme situations of abuse and potential violations of federal law. Therefore I would like to request that you investigate the University
of California, Los Angeles with respect to the following experimental
protocols of Joaquin Fuster, including “Haptic Information
processing/Primate Memory”, and any potentially newer protocols
involving this researcher, including the research funded under grant
R01MH072641, INTEGRATIVE APPROACH TO CORTICAL COGNITIVE NETWORKS Sec. 2.31 D, iii “The principal investigator has provided written
assurance that the activities do not unnecessarily duplicate previous
experiments.” For Haptic Information processing/Primate Memory the principal
investigator claims to have done searches on the terms: monkey, parietal
cortex, single cells, memory and/or haptic. Since this project uses
rhesus monkeys the searches should include the term macaca, for which
pubmed turns up over 51,000 listings. Then when parietal cortex is added
to the search, 1292 publication still show up, and when ‘single cell’ is
added 182 publications still arise. Clearly, this researcher did nothing
to prevent unnecessary duplication. The next relevant regulation is: 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. Both of these research projects seriously restrict the amount of time
during which water is available to the primates used in these
experiments. In fact, it discusses time periods of as much as 22
consecutive hours in which the primates will not have access to water.
Therefore, I would like to request that you examine all logs for the
primates used in this research project to determine whether these
animals have received adequate access to water as is required by the
Animal Welfare Act. Additionally, this experiment is likely effected by Sec. 2.31 Institutional Animal Care and Use Committee (IACUC). (x) No animal will be used in more than one major operative procedure
from which it is allowed to recover; Provisions prohibiting the performance of unapproved surgical
procedures are also likely to be relevant to these projects since
devices such as eye coils and recording cylinders often need to be
replaced/relocated due to infection, non-adherence, etc. during
experimentation. Therefore, records for all primates used in this protocol should be
examined to determine if any unapproved surgeries have been performed.
Due to restraint, and potential individual housing, the primates used
in both of these experiments must be evaluated relevant to environmental
enhancement : Sec. 3.81 Environment enhancement to promote psychological
well-being. (b) Environmental enrichment. The physical environment in the primary
enclosures must be enriched by providing means of expressing
noninjurious species-typical activities. (c) Special considerations. Certain nonhuman primates must be
provided special attention regarding enhancement of their environment,
based on the needs of the individual species and in accordance with the
instructions of the attending veterinarian. Nonhuman primates requiring
(1) Infants and young juveniles; It is quite clear that the activity of these monkeys would be
restricted, and so special considerations must be made to allow for
their psychological needs. Lastly, these regulations are likely to be relevant as well: 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; Now, it is quite clear those non-human primates who are confined to
restraint chairs, have limited access to water, potentially limited
environmental enhancement and who have devices literally bolted to their
skulls would experience pain and/or distress. It is obvious that UCLA
has filed blatantly dishonest documents with the USDA. Additionally, communications between the USDA and the University of
California, San Francisco states that: “Please be reminded that you must provide scientific justification
for not listing in Column E those primates at your facility undergoing
up to 22 hours of water restriction. . . . The fact that water restriction (i.e. thirst) is used as a negative
reinforcement motivator indicates some level of distress requiring
relief, and that fact that your researchers are apparently claiming that
only water deprivation for extended periods of time (up to 22 hours)
provides sufficient motivation for use in their studies indicates that a
fairly significant level of distress due to thirst is needed to motivate
the monkeys strongly enough for their purposes/. Scientific literature
indicates that the thirst drive is exceeded in the hierarchy of drives
only by severe pain and air hunger and that a 24-hour period of water
deprivation can cause monkeys to experience elevation of plasma
osmolarity over the threshold for thirst.” Since the research project listed above also deprives primates of
water for 22 hours, then UCLA who lists no primates in column E for the
2004 & 2005 reporting years, must have filed fraudulent reports, based
on the words of the USDA. Therefore, I am filing an official complaint against the University
of California, Los Angeles and asking that the health and welfare of all
primates used in the research projects listed above for the last four
years, as well as the annual reports of UCLA be examined in full detail
to determine if any violations of the Animal Welfare Act have occurred. It is clear that Joaquin Fuster is performing unnecessarily
duplicative research and that this project should be immediately
terminated. It is also clear that UCLA has filed blatantly false reports
with the USDA. Therefore, regulatory action should be taken against this
individual and this facility as soon as possible. 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.,
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