April 15, 2020: USDA settlement

Biomedical and behavioral research with nonhuman animals is overseen in the United States by two federal agencies, the United States Department of Agriculture, which enforces the Animal Welfare Act and the National Institutes of Health’s Office of Laboratory Animal Welfare (OLAW). The USDA conducts regular inspections of institutions and facilities that house research animals, including the University of Wisconsin-Madison. The university also sends reports to OLAW when problems occur in animal care or treatment. Within the university, animal care and research are monitored by institutional animal care and use committees, veterinarians, and others. In 2016, the USDA began an investigation of animal care at UW–Madison. UW–Madison and USDA recently reached a settlement over violations the agency alleges occurred at the university between 2015 and early 2019. The settlement, which resolves the investigation, includes a $74,000 fine.

The USDA’s investigation included examination of alleged violations that had been previously cited in inspections by USDA veterinary medial officers, and most had first been reported by the university to OLAW.

Research with animals is an important way — and in many cases the only opportunity — to answer crucial questions about basic biological processes and to ethically study diseases with often devastating consequences for humans and animals. UW–Madison researchers and veterinarians are committed to improving human and animal health and well-being. The university is committed to responsible and ethical research conducted with the help of skilled veterinarians and the oversight of campus committees, outside accreditation organizations, and state and federal agencies.

UW–Madison scientists and animal care staff strive for laboratories that produce important knowledge and treatments in an environment that is safe and error-free for both researchers and animals. When staff commit errors and equipment fails, the university doesn’t accept those incidents as unpreventable, instead we improve and refine work processes and procedures and upgrade the equipment we use.

The USDA settlement — see the settlement here (PDF) — lists these citations:

9 CFR 2.38(f)(1) Miscellaneous: handling

USDA investigators noted 22 times from 2015 to early 2019 in which monkeys were injured after staff errors or equipment failures allowed animals to exit their enclosures. Most of the injuries were the result of the monkeys interacting with other monkeys through the mesh walls of still-secured neighboring enclosures. In many cases, treatment included surgery — some procedures were partial amputations of fingers or toes or the tongue — but USDA veterinarians repeatedly noted both prompt treatment and recovery of the animals in inspection reports.

In the course of research and routine care for monkeys, UW–Madison animal care staff transfer monkeys from one enclosure to another for many reasons — such as cleaning and maintenance of animal surroundings and the toys and manipulatable devices they are provided for enrichment, to receive care from veterinarians, and for participation in research projects. These transfers, which involve working latches and doors and large and nimble animals, are the most common time for a monkey to exit its enclosure. In the roughly four-year period covered by USDA’s review, one UW–Madison facility performed more than 299,000 transfers of monkeys, with 18 exits that resulted in injuries that required veterinary care — less than one for every 16,000 transfers.

That rate is vanishingly small, but the university’s goal and responsibility is to prevent all monkey exits and injuries. UW–Madison staff care deeply about animals, and continuously work to minimize the potential for errors by improving transfer techniques and training. After each incident, animal care workers undergo renewed hands-on training and practice aimed at identifying and correcting errors in procedures and techniques. Circumstances are reviewed to find lasting solutions where possible.

Since 2013, these efforts have resulted in improvements, including refinement of housing enclosures, installation of additional and improved locks, and reconfiguration and redesign of transport equipment. Regular checks are performed to make sure doors are secured, including a duplicate check in many cases. Animal behaviorists identify and work with animals that are particularly difficult to transfer, using positive reinforcement. As a result, the rate of monkey injury incidents is declining.

USDA also noted a mouse that, in October 2018, was found caught between parts of its enclosure. The animal had died, likely due to lack of oxygen. The enclosure materials may have warped over time to create a gap into which the mouse squeezed, according to the USDA report. It was the first time an animal had been lost in this manner in the lab. Extra inspection procedures were instituted to ensure the fit of enclosure materials, preventing repeat injuries.

9 CFR 3.81(a)(3) Environment enhancement to promote psychological well-being: social grouping

UW–Madison animal care and research staff make extensive efforts to safely house rhesus macaque monkeys in social groups. Behaviorists, veterinarians, and animal care staff work together to monitor all social groups for signs of incompatibility. Despite vigilance and management of social groups, there are occasional injuries from aggression between monkeys.

On Dec. 28, 2015, a monkey was found dead in its social group housing due to injuries presumably inflicted by an older monkey. The monkey that died was already recovering from injuries acquired in a Dec. 24 altercation with the older animal — injuries for which the monkey had received prompt and responsive treatment by a veterinarian. The veterinarian had returned the animal to its social group after treatment, a decision that weighed risk of further injury against the risk of housing the animal without its partners.

After the initial injuries, the animal was observed daily by caretakers and others, none of whom noted additional aggression, injury, or cause for removing the animal from its group. Nonetheless, on Dec. 28 the monkey was found dead. USDA inspectors in 2016 issued a citation because they disagreed with the veterinarian’s assessment and believed the injuries the monkey received Dec. 24 provided enough evidence of incompatibility to preclude the animal’s return to social housing.

9 CFR 3.83 Watering

Each monkey in the care of the university has access to drinking water, and those water systems are to be checked daily by animal caretakers to ensure that access. However, during four days in December 2015, a line supplying water to three rhesus monkeys became disconnected, and the failure was not discovered by staff attending to the water system.

It is unclear how long during those four days the animals were without water, and they did not show outward signs of dehydration during the daily monitoring performed by caretakers and other staff. But when the fault in the supply line was discovered, and the monkeys examined, the sodium levels in their blood were higher than normal. That is a symptom of dehydration, and all three began treatment for dehydration. Sadly, one of the monkeys did not improve with the therapy, and was humanely euthanized by veterinarians. The two other monkeys fully recovered. Personnel changes were made following the loss.

9 CFR 3.12(a) Facilities, general, structural strength

Two ground squirrels were able to exit their enclosure when it was not properly latched. Only one was recovered.

All staff that interacted with ground squirrels went through additional training on securing the enclosure covers, and the lab added a daily visual check of each animal. Enclosure covers were reinforced with a second layer of material, live traps were added to the squirrel room, and covers to potential room exits were improved.

9 CFR 3.129(a) Feeding

On Jan. 25, 2016, UW–Madison staff found a mouse dead in a laboratory enclosure. Another mouse living in the shared enclosure was found to be weak and unhealthy and was euthanized. Records revealed the food containers for the mice had not been refilled properly.

The laboratory had not previously experienced any similar incidents, but the unfortunate loss of the mice led to several changes in lab operations. The lab added staff and refined training and tracking of mouse care. Campus oversight groups increased the frequency of visits to monitor the lab’s animals, and required more stringent record-keeping of the lab.