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
Introduction
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.
Summary
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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