October 19, 2010

Dr. Elizabeth Goldentyer
USDA/APHIS/AC
920 Main Campus Drive, Suite 2000
Raleigh, NC 27606

Dr. Goldentyer,

I am contacting you today in reference to the recent inspection reports for Harvard Medical School (14-r-0019). This facility is clearly violating section 2.36 Annual Report (b)(7). This section states that 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, or interpretation of the reaching , 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.”

As you know, this requirement is to be fulfilled by listing animals in Column E of the Annual Report filed by each facility. USDA records available online for the Harvard Medical School reveal that this facility has not listed any non-human primates in this category from 2005 – 2009, a five year period. However, if you read the attached documentation, written by the researchers at the Harvard Medical School’s Primate Research Center located in Southborough (MA), then you will clearly see that this is not accurate and that, in fact, this report is fraudulent and has been fraudulent for at least 5 consecutive years. In all likelihood these reports have been fraudulent for longer periods due to the lifespan of the two projects in question.

Two research projects which are active at Harvard clearly allow non-human primates to experience unrelieved pain. James K. Rowlett is the Principal Researcher for one such project. It subjects primates to electric shock as an aversive stimulus. And so, if this administration of electric shock has any effectiveness whatsoever, then this is clearly an experiment which involves unrelieved pain/distress.

The second project involves primates who are so severely distressed by captivity that they engage in self-injurious behavior. This project purposely stresses animals who have already been diagnosed with SIB (self-injurious behavior), causing their SIB to increase. It demonstrates “increase in self-biting behavior, as well as evidence of sleep disturbance” (see attached documentation). This is another incident of what is clearly an experiment involving unrelieved pain.

Taken together, these two projects have caused unrelieved pain in 26 non-human primates. Therefore, this is clearly a violation of section 2.36 listed above.

I officially request that you initiate an immediate investigation of these incidents and that you levy the largest fine allowable by law against Harvard Medical School. And please consider this document to be both an Official Complaint against Harvard as well as a FOIA request for all documents relevant to the investigation of this complaint. This is to include all inspection reports, correspondence, photos, etc.
I strongly urge you to take the most severe action allowable under current law against the Harvard Medical School. It is clear that the pain of animal experimentation cannot be mitigated if those performing the studies refuse to admit that it even exists.

I look forward to hearing from you in the near future about the fate of this facility.

Sincerely,

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

See Also:
Harvard Medical School
Group files complaint vs. Southborough animal research lab - 20 Oct 2010
19 Oct 2010 - Federal Complaint filed Against Harvard for Electric Shock Experiment; Group Names Charles River, Harvard, MIT, McLean to ’Worst Labs’ List
Federal Complaint filed Against Harvard for Electric Shock Experiment
MELINDA A. NOVAK - Grant Project - 2010
JAMES K. ROWLETT - Grant Project - 2010

We welcome your comments and questions