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Articles and Reports

Follow-up Letter of Complaint to the USDA about AWA Violations at the University of Wisconsin

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


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

Dr. Goldentyer,

I am again contacting you today in reference to the University of Wisconsin, Madison. Upon further examination of additional documentation I believe that it is important that the treatment of several more primates who have been used in experimentation at this facility should be examined.

The care of a primate named Wally brings up several potential violations of the Animal Welfare Act. Records for Wally contain these statements:

4/21/06 “Start Doxycycline . . . request lab contact us when next in chair to obtain culture from cylinder.” This expressed desire to obtain a culture clearly indicates what is presumed to be a bacterial infection in the area of the brain is apparently one of the earliest indications that Wally is ill with a brain abscess. However, this culture is not done until 11/10/06, seven months later.

11/5/06 9:30 AM “According to Care Staff he rejected food this morning. To me he seems confused, significant pale color of face, but still active.”

12:30 PM “Care staff reported that Wally is laying down in the cage. They two times called pager center due to contact vet-on call. Unfortunately, --- ---- suspended and they call me.”

5 PM “Wally is depressed, sitting on cage floor with hunched posture. . . . I was unable to open control syst box in the room. Will come at 5:30 pm to observe Wally and take care of him.”

6:40 PM “Wally is alert, mobile, no interest in treats, prefers a ‘head-down rump-up posture @ Headache?”

11/6.06 10AM 0.7 ml carprofen SQ, 0.3cc Buprenorphin IM. Alert Mobile, sitting in head down Rump up position. Attempted giving doxycycline PO but he spit it out. Will try again this PM after pain meds have taken effect.

3PM 0.3 cc buprenorphine. Head hanging. (NOTE NO DOXYCYCLINE WAS GIVEN)

11-7-06 8:30 AM Still depressed. Sitting on cage floor with head down. 1 more dose of Buprenorphine this a.m. (0.3cc) Will reassess this pm. Continue Doxycycline treatments.

9 am 0.3 ml Buprenorphine SQ

3 Pm Improved but still depressed. 1 more dose Buprenorphine (0.3cc) will re-check in morning. (NOTE NO DOXYCYCLINE OR ANY OTHER ANTIBIOTIC WAS GIVEN)

The record for 11-8-06 do not mention any administration of antibiotics, despite the statement that this primate should be receiving doxycycline. The antibiotics are not given for 3 days and are only resumed on 11/9/06. The primate receives this drug 11/11 and on 11/12. There are no notations of treatment of any kind for 19 days until 12/1 when doxycycline is again administered for 6 consecutive days.

However, during this period (11/28/06) one of the members of the veterinary staff sends a memorandum which says “As you know, Wally has been on continuous antibiotic therapy for some time now due to a brain abscess. He has been on monthly rotations of Doxycycline and Cephalexin. Toward the end of the most recent treatment of Cephalexin (first week of November, 2006), he started to display clinical signs of headache and illness, including depression, slumped/head-down posture and inappetence. He was treated with analgesics, and antibiotic treatment was switched to Doxycycline. After several days his condition improved. It is the veterinary opinion that after a few weeks of Cephalexin treatment the abscess starts to worsen, due to microbial resistance and/or the limited ability of Cephalexin to cross the blood-brain barrier, resulting in the clinical signs of severe headache. . . . Due to the brain abscess and the need for permanent treatment, it may be advisable to make plans to humanely euthanize Wally sometime in the next several months, and replace him on study . . . I know that this can be a difficult and emotional decision, especially with animals that have been an important part of a multi-year study, but for Wally’s best interest this is an option that must be given serious consideration.”

6/16/07 “Care staff reported earlier today off feed.”

11-11-7 “Reported by care staff . . . some bruising on Wally’s left eye.” “Will re-check tomorrow”

11-12-07 “No changes in condition.”

11-13-07 “Periorbital redness/bruising still present no significant changes.”

11-20-07 “Periorbital redness/bruising has been reduced.”

This redness/bruising did resolve itself, however no treatment was given.

12-20-07 “There is some fresh blood in the cage, dry blood on anterior head cap. Will contact DVM.”

An additional notation is made in different handwriting: “No continued bleeding. Head cap margins dry & no (normal). Trauma noted on fingers & toes. Possible result of picking at head cap margin.

1/14/08 “continue standard antibiotic regimen”

Now, more than 14 months after a veterinarian recommended euthanasia for this primate, he is still being used in experimentation, against the written opinion of the veterinary staff. And apparently he is still suffering from an infection, because antibiotic treatment is still underway.

It is clear that this primate did not receive adequate veterinary care, due to the lack of antibiotic treatment for a period of 19 consecutive days, as well as the wanton refusal by staff to euthanize this primate more than 14 months after a veterinarian had advised that humane euthanasia was necessary. This primate also clearly endured substantial pain and distress during this experimentation and was not classified correctly by the University of Wisconsin as being in Column E. Clearly, this is fraudulent reporting, likely for both 2006 and 2007.

The records of Primate AX25, Chip, also show many violations.

7/5/06 his record discloses “Hair piles in bottom of cage.” Nothing is mentioned about providing additional enrichment for this animal that has been singly housed since 5/21/05. Chip has surgery on 7/7/06.

7/10/06 “Report of holding head and decreased threat behavior toward animal care staff.”

7/13/06 “appears slightly depressed . . . depressed behavior possibly related to non-physical issues – boredom, lack of stimulation, depression. . . . scheduled for eye coil surgery tomorrow.”

11/7/06 eye coil surgery

12/22/06 “holding head . . @ ‘headache’ post MRI.”

This primate should have been receiving additional enrichment, and also should have been listed as experiencing pain/distress.

Primate Rh 2288 “Merde” is listed as being housed sigly beginning on 7/28/05. On 5/24/06 a mention is made that he is using both legs, as though this is a new development.

6/8/06: “Thin hair lower legs.”

6/13/06 “Thin hair both legs and Rt. Side.”

And listings like this continue for over a month. However, nothing is said of providing additional enrichment.

7/24/06 “Decreased/sparse muscle mass, especially hind limbs. Somewhat thin.’ However, no treatment is given.

7/31/06 “Thin hair sides and lower legs.”

8/18/06 “Hair is thinning on sides, back an legs now. Asked staff to use coconut for more enrichment. Appetite (decreased) all week.”

8/29/06 “Thin hair legs, sides, and back. Appetite still (down).”

Now there is a gap in the records for almost 6 months. This is clearly improper record keeping. Or, deliberate withholding of information. Suddenly, he appears normal. Then later on 1/14/08 he is listed as “thin.”

There is no evidence that this primate ever received additional enrichment, even though he was singly housed, was ripping out hair over the legs, sides, and back.

Primate Rh 6638 had eyecoil and Cylinder surgery on 11/7/06 the Post Surgery Recovery form lists the primate’s pain category as “abnormal” and “shaking head” and that the surgical wound is “extremely swollen” and “head bleeding, eyes swollen shut.”

11/8/06 “swelling of the lateral muscle – but it was dramatically reduced since just after surgery. . . . he may have difficulty to chew for awhile.”

11/9/06 “significant swelling-edema around head cap. Eyes crusted shut. Not eating.”

11/10/06 7AM “Still depressed not eating & drinking. Eyes shut & crusty. 2:30 PM Still depressed, sleepy. Taking some food & Water. Reacting in pain when head makes contact with cage. Concerned about the buprenorphine adding to depression but still want to manage pain. Will give decreased dose of burpenorphine this PM. 5:30 PM Still sleepy. Would not take apple, etc.”

5/31/07 “Swelling around head cap margin. Inflammation around cap assessed to be within normal limits for the size & nature of the cap.”

It is obvious that the IACUC of the University of Wisconsin failed to minimize the pain and distress of these animals. It is also clear that these animals would have experienced substantial pain and distress and should have been reported as such on the annual report filed by this facility.

It is very clear from this information that the primates at the University of Wisconsin do not receive adequate veterinary care, which should have included timely euthanasia.

I officially request that you initiate an immediate investigation of these incidents and that you levy the largest fine allowable by law against the University of Wisconsin, Madison.

I look forward to hearing from you in the near future about the fate of this facility.


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

Sec. 2.33 Attending veterinarian and adequate veterinary care.

(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;

Sec. 2.36 Annual report.

(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;

(3) The Committee shall inspect at least semiannually all animal study areas and animal facilities of such research facility and review as part of the inspection-- (A) practices involving pain to animals, and (B) the condition of animals, to ensure compliance with the provisions of this chapter to minimize pain and distress to animals.

See also University of Wisconsin, Madison, WI

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