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Letter of Complaint to the USDA about AWA Violations at the University of Wisconsin
25 June 2007 Dr. Elizabeth Goldentyer Dr. Goldentyer, I am contacting you regarding a matter of the utmost urgency and
importance. I have recently obtained documents from the laboratory at
the University of Wisconsin, Madison. These documents raise serious
doubts as to adherence to Animal Welfare Act (AWA) regulations by the
staff of this facility. Therefore I am lodging an Official Complaint
against this facility and I am requesting that you initiate an
investigation immediately. This complaint lists the specific animals with reference to which
section of the AWA the documentation reveals violations. A 4 year old female crab eating macaque monkey (cy0122) who died on
11/3/05 was found to have foreign body lodged in the intestinal tract.
This object had been in place long enough to have caused tissue
necrosis. This incident may be a violation of Sec. 2.33 Attending
veterinarian and adequate veterinary care. (3) Daily observation of all
animals to assess their health and well-being; Adequate veterinary assessment of this primate should have revealed
the presence of this foreign object. The presence of � . . . 20 cc of a
light red, clear, serous fluid� and a �6 cm rent� in the intestinal
tract should have been diagnosed. Apparently this situation existed for
a significant period of time because the small intestine had
�multi-focal, transmural necrosis.� Similarly, a 1 year old female marmoset (cj1146) was euthanized on
7/13/05. This animal is described as: �The left leg is mildly, diffusely
swollen with the subcutis being thickened, gelatinous and glistening
(edema). The left quadriceps muscle has a 2 mm, circular hole surrounded by
moderate hemorrhage on the distal lateral portion. A hard sharp material
slightly protrudes from the opening (fractured bone, presumptive.� This marmoset had a tibial fracture and later developed an epiphyseal
fracture as well. Proper preventative care and treatment after the
initial fracture should have prevented the second fracture. This is
clearly another incident of a violation of Sec. 2.33 Attending
veterinarian and adequate veterinary care. Additionally, a female rhesus monkey (r87095) apparently died of
�peritoneal and uterine rupture during delivery with subsequent sepsis.
The sepsis was most likely the cause of death of this animal.� Again,
adequate veterinary observation should have prevented the development of
sepsis. Clearly, the veterinary staff should have been aware of this
monkey�s pregnancy and should have been observing her closely enough to
have been able to prevent sepsis. A 14 year old female rhesus monkey (r90153) died on 4/6/05. This
monkey is described: �The second cartilaginous tracheal ring is focally
broken with incomplete perforation of the tracheal wall. Approximately
2ml of blood mixed with froth is present in the upper half of the
trachea. All the lung lobes are collapsed and have multifocal extensive
hemorrhage.� The cause of this situation is said to be �Trauma caused
during intubation.� This incident clearly demonstrates negligence on the part of UW
Madison staff, and demonstrates the utilization of potentially
unqualified personnel which is a violation of: Sec. 2.32 Personnel qualifications: (a) It shall be the
responsibility of the research facility to ensure that all scientists,
research technicians, animal technicians, and other personnel involved
in animal care, treatment, and use are qualified to perform their
duties. This responsibility shall be fulfilled in part through the
provision of training and instruction to those personnel. A 22 year old female rhesus monkey (r82062) died on 10/26/04 with a
�Severe focal cerebral excavitation, with mild multifocal surrounding
parenchymal fibrosis, left parietal lobe, brain.� And �The cerebral
excavitation was most likely secondary to liquefactive necrosis post-headcap
placement.� This is clearly another incident of a violation of Sec. 2.33
Attending veterinarian and adequate veterinary care. Rhesus Monkey r94075, who is classified as an experimental death,
died with �Severe multifocal chronic tract formation with fibrosis and
mild multi-focal chronic meningitis and choroid plexitis, cerebrum,
hypothalamus, meninges.� This animal represents another incident of a
violation of Sec. 2.33 Attending veterinarian and adequate veterinary
care. Three marmosets cj0549, cj0475 and cj0543 are all listed with serious
skin conditions such as: �Severe focally extensive full thickness
necrosis with regionally extensive mild subacute paniculitis, skin
(implant site). Marmoset cj0549 is also listed as �On the back over the
mid-spine is a 5 mm long, full thickness skin wound from which one end
of a 2 cm capsular implant protrudes.� Clearly these primates suffered severely as a result of the
experimentation in which they were used as did all of the primates
listed in this complaint. However, the University of Wisconsin does not
report any primates as being used in potentially painful or stressful
experimentation without anesthesia. It is obvious that these animals
experienced pain/distress, and yet no primates are reported in Column E
for the UW, Madison. This is a clear violation of 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;
Many other primates fall into this category as well. For example,
rhesus monkey r01033 who had �Severe multifocal to coalescing chronic
active pneumonia . . .� and r01035 who also had �Severe diffuse chronic
active pneumonia . . .� Due to the information contained in the necropsy reports listed
above, I would also like to request that all experimental protocols
involving the placement of headcaps or spinal implants be investigated,
as well as the health and monitoring of all primates used in these
protocols. These projects should be investigated thoroughly, with regard
to all aspects of the Animal Welfare Act. It is clear that the documentation for the animals listed above
indicate a widespread pattern of negligence, inadequate veterinary care,
and deceitful reporting of experimental procedures at the University of
Wisconsin, Madison. All of these issues After examining the animals and
procedures at this facility I am confident that your regulatory staff
will find substantial AWA violations. I request that you immediately
implement proceedings to prosecute the University of Wisconsin, Madison
to the fullest extend that the law allows. 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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