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Official Letter of Complaint to USDA about UCSF's Treatment of Primates
7/17/07 Dr. Robert Gibbens, Director, 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, San Francisco. These records reveal
extreme situations of abuse and potential violations of federal law. Neural Control of Eye Movement; Cortical Plasticity System, which I
believe to be the work of Stephen Lisberger. Neural Correlates of Sensorimotor Adaptation in macaque Cortex. Sec. 2.31 D, iii �The principal investigator has provided written
assurance that the activities do not unnecessarily duplicate previous
experiments.� For the first protocol (Neural Control of Eye Movement) The search
terms used for this project were monkeys and fluid restriction,
alternatives and fluid restriction, alternatives and alternatives &
monkeys. First, to address the species used in this research it would be
necessary to use the latin species name macaca, which in pubmed
generates over 51,000 listings. Since this research is relevant to eyes,
it might be better to use terms like vision (macaca and vision generate
1862 hits in pubmed), or even using the name of the research protocol, a
search on macaca and cortical and plasticity generates 100 hits.
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. 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. 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. For the first protocol (Neural Control of Eye Movement) For the second protocol (Neural Correlates of Sensorimotor
Adaptation) Therefore, records for all primates used in these protocols should be
examined to determine if any unapproved surgeries have been performed.
Additionally, many of these primates came from the University of
California, Davis and it is unknown if any surgeries were performed on
these animals before they arrived at the University of California, San
Francisco. Please look into this possibility. 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. Additionally, it is very clear from the records for several of the
primates used at UCSF that ongoing pathological conditions may have
seriously compromised the value of the research in which they were used
beyond repair. These primates are MMU30531, primate 33059, and primate
MMU31314. Records for all of these animals reveal ongoing bacterial
infections lasting as long as 8 months. 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 UCSF
has filed blatantly dishonest documents with the USDA. Additionally, it is apparent from communications between the USDA and
UCSF that you have questioned this institution about this issue before.
I would respectfully request that you take regulatory action against
this facility since, despite your correspondence of 2004, UCSF again
filed an erroneous report with the USDA during 2005. Therefore, I am filing an official complaint against the University
of California, San Francisco and asking that the health and welfare of
all primates used in the research projects listed above for the last two
years, as well as the annual reports of UCSF 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. Sincerely,
Michael A. Budkie, A.H.T.,
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