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Articles and Reports

Letter of Complaint to USDA about Animal Cruelty at Duke and Wake Forest

1081-B St. Rt. 28 PMB 280
Milford, Ohio 45150

18 June 2007

Dr. Elizabeth Goldentyer
920 Main Campus Drive
Suite 2000
Raleigh, NC 27606

Dr. Goldentyer,

I am contacting you regarding a matter of the utmost urgency and importance. I have recently obtained information regarding two research facilities: Wake Forest University and Duke University, both in North Carolina. Two documents which are excerpts from recent research projects at these universities are attached to this email.

The attached procedures, published in medical journals, describe brain mapping projects which are underway at Duke and Wake Forest. Several USDA regulations are relevant to specific concerns about these research projects.
The first 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.

These research projects, at both universities, seriously restrict the amount of time during which water is available to the primates used in these experiments. I would like to request that you examine all logs for the primates used in the research of Michael Platt and Heather Dean at Duke University as well as the primates used in the research of Terrence Stanford at Wake Forest University to determine whether these animals have received adequate access to water as is required by the Animal Welfare Act.
Additionally, these experiments are 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.
Due to restraint, and potential individual housing, the primates used in 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
special attention are the following:

(1) Infants and young juveniles;

(2) Those that show signs of being in psychological distress through behavior or appearance;

(3) Those used in research for which the Committee-approved protocol requires restricted activity;

(4) Individually housed nonhuman primates that are unable to see and hear nonhuman primates of their own or compatible species;

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. The Animal Welfare Enforcement Report for Fiscal 2005 & 2004 show no primates for the entire state of North Carolina experiencing unrelieved pain and distress. It is obvious that both Wake Forest and Duke Universities have filed blatantly dishonest documents with the USDA.

Therefore, I am filing an official complaint against these universities and asking that the health and welfare of all primates used in the research of Michael Platt and Heather Dean at Duke University as well as the primates used in the research of Terrence Stanford for the last two years, as well as the annual reports of Duke and Wake Forest be examined in full detail to determine if any violations of the Animal Welfare Act have occurred.

I would also request that you provide me with the results of this investigation when it is completed.


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


Duke University Primate Experiments

Wake Forest Primate Research Grant Funding - 2005 - PDF Format

Wake Forest Primate Experimentation Procedures

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