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Letter of Complaint About New Iberia Research Center to USDA Director

1081-B St. Rt. 28 PMB 280
Milford, Ohio 45150
513-575-5517
www.saenonline.org
10/16/09
Dr. Robert Gibbens
Director, Western Region
USDA/APHIS/AC
2150 Centre Ave.
Building B, Mailstop 3W11
Fort Collins, CO 80526-8117
Dr. Gibbens,
I am contacting you today regarding documents in my possession which
are relevant to the New Iberia Research Facility, which is connected to
the University of Louisiana, Lafayette (72-R-0007).
As you know, section 2.33 of the Animal Welfare Act requires that
research facilities provide adequate veterinary care for animals:
2.33 b) Each research facility shall establish and
maintain programs of adequate veterinary care that include:
(1) The availability of appropriate facilities, personnel, equipment,
and services to comply with the provisions of this subchapter;
(2) The use of appropriate methods to prevent, control, diagnose, and
treat diseases and injuries, and the availability of emergency, weekend,
and holiday care;
(3) Daily observation of all animals to assess their health and
well-being; Provided, however, That daily observation of animals may be
accomplished by someone other than the attending veterinarian; and
Provided, further, That a mechanism of direct and frequent communication
is required so that timely and accurate information on problems of
animal health, behavior, and well-being is conveyed to the attending
veterinarian;
(4) Guidance to principal investigators and other personnel involved in
the care and use of animals regarding handling, immobilization,
anesthesia, analgesia, tranquilization, and euthanasia; and
(5) Adequate pre-procedural and post-procedural care in accordance with
current established veterinary medical and nursing procedures.
The veterinary record for Primate #A3V027 states: “Emaciated animal
with a severely inflamed colon that was tube-like and thin-walled
(almost transparent).” The record also states: “Very thin animal on long
term treatment for diarrhea and poor condition, not responding. Animal
continued to lose weight.” Statements of this nature raise serious
doubts as to whether this animal received adequate treatment and whether
euthanasia should have been performed much earlier. This physiological
changes noted in the post mortem record for this primate do not happen
quickly, meaning that this primate was allowed to become severely
debilitated.
Primate A6V053 is described similarly. “Very thin animal with a
tube-like colon with only a few shallow sacculations remaining.” And
“Juvenile animal on treatment for 7 weeks for enteritis and poor
condition. Animal was not responding to treatment and continued to lose
weight and was subsequently euthanized.” This animal was allowed to
suffer for an extended period of time before appropriate euthanasia was
administered.
Again, Primate Ax83 shows a similar situation. “Adult female on clinical
treatment for enteritis and poor condition for six weeks with no
improvement. She continued to lose weight and was euthanized.” And “Very
thin animal with a thin-walled, distended, tube-like colon with no
sacculations.” The significant erosion of the colon indicates long-term
disease. This animal was allowed to decline past a point where
euthanasia should have been administered to prevent unnecessary pain and
suffering.
Primate 97P015 continues on in this same mode. This twelve year old
monkey is described as being “ . . . on treatment for poor condition –
very thin, generalized alopecia.” And “Very thin animal, no fat stores.”
Similarly to the other animals, this monkey should not have been allowed
to reach a point of such severe debilitation that there was no body fat
present whatsoever. This primate had a recorded weight of 9.35 kg
(roughly 20.6 lbs) on June 14, 2007. The body weight had decreased to
8.5 kg by June 11, 2008. By January of 2009 his weight had plummeted to
6.3 kg (roughly 13.9 lbs), which represents an overall decrease of over
32%, with the majority of this decline occurring in the six months from
June of 2008 to January of 2009. This is a precipitous drop.
These are the animals that received treatment for their illnesses.
Others were, due to lack of observation, apparently not treated at all.
Several primates are described in government reports as “down,” which
can only be taken to mean that they were first diagnosed when they had
collapsed due to illnesses.
Several other primates at this facility are of serious concern. Primate
(A5E037) is listed as “Thin, laying down in crib” the presenting
diagnosis on July 25, 2008. In other words, the staff of this facility
didn’t realize that this animal was ill until he/she collapsed in an
enclosure. Two other primates (A7E043, A7E046) are similarly listed as
just “down,” again indicating that they were diagnosed at the point of
collapse.
I am also very concerned about the high number of wounds and traumatic
injuries that are reported at this facility. The number of injuries is
so high, and the frequency of traumatic injuries is so often, that I
believe situations exist at this facility which violate these sections
of the animal welfare act:
2.33 (b) Each research facility shall establish
and maintain programs of adequate veterinary care that include:
(1) The availability of appropriate facilities, personnel, equipment,
and services to comply with the provisions of this subchapter;
(2) The use of appropriate methods to prevent, control, diagnose, and
treat diseases and injuries, and the availability of emergency, weekend,
and holiday care;
And:
2.31 (d) IACUC review of activities involving
animals. (1) In order to approve proposed activities or proposed
significant changes in ongoing activities, the IACUC shall conduct a
review of those components of the activities related to the care and use
of animals and determine that the proposed activities are in accordance
with this subchapter unless acceptable justification for a departure is
presented in writing; Provided, however, That field studies as defined
in part 1 of this subchapter are exempt from this requirement. Further,
the IACUC shall determine that the proposed activities or significant
changes in ongoing activities meet the following requirements:
(i) Procedures involving animals will avoid or minimize discomfort,
distress, and pain to the animals;
In one three month period a colony within this lab is listed as
having primates with 15 traumatic injuries. On Febuary 18, 2007 primate
A7V006 is listed as having peritonitis as a result of a wound
(untreated?). On February 8, 2007, primate AX84 is listed with severe
trauma. Primate A8V049 is listed with a cause of death of trauma.
Primate AX82 is listed with hyperthermia after fighting. Primate A4V039
is listed with “severe colitis/shock from trauma.” Primate A6V073 is
listed with “septicemia of unknown origin” and A8V025 is listed with
“pneumonitis, septicemia.” Septicemias do not appear out of nowhere.
These cases should have been diagnosed and treated in a more timely
manner. It is clear that not enough is being done to prevent injuries to
the primates within this facility. Traumatic injuries occur regularly
and are occasionally even fatal. Adequate measures have obviously not
been taken to prevent these traumatic injuries, and the pain, discomfort
and distress of these animals was not minimized or avoided.
Additionally, it is clear that disease is extremely common at this
facility. Enteritis occurs extremely frequently within this facility and
is a substantial cause of both morbidity and mortality. Depending on
which sub-colony is examined, and what time of year is examined,
enteritis can constitute as much as 80% of all clinical disease, and
this condition can have a death rate as high as 42%.
Primate A2V016 was listed with a “severe strangulating intussception.”
I have provided a large amount of documentation which has been obtained
through the freedom of information act. I believe that the documents
which I have obtained delineate clear violations of these regulations
and I hereby officially request an investigation of these issues.
It is clear that the staff of NIRC systematically ignores illnesses in
primates often allowing them to be diagnosed only when they have reached
a very serious level, sometimes causing collapse. Also, it is clear that
in many instances the treatments which are offered (especially relevant
to enteritis) are either done incorrectly, or are insufficient to have a
meaningful impact.
Overall, the animals and incidents discussed indicate inadequate
observation of these animals and inadequate treatment, if not veterinary
negligence. Therefore I request that you initiate an investigation of
the animal care at this facility and take action to levy the most
substantial fine allowable under current federal regulations. I also
request that you immediately suspend any projects which involve repeat
violations.
I look forward to hearing of the results of your investigation as soon
as possible. Please consider this a FOIA request for the results of your
investigation (all documents generated as part of your investigation
(including correspondence, emails, inspection reports, photos, etc.),
made under the federal Freedom of Information Act, 5 U.S.C. sec. 552.
Sincerely,

Michael A. Budkie, A.H.T.,
Executive Director, SAEN
Attachments:
Project 8735 2007-2008
Monthly Reports - 2007
See: University of Louisiana,
Lafayette, LA
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