In July, veterinary medical officers (VMOs) from the U.S. Department of Agriculture (USDA), which enforces the Animal Welfare Act (AWA), completed an inspection of animal care at the University of Wisconsin–Madison. For three days, USDA reviewed UW–Madison records to investigate alleged violations of the AWA from 2012 and 2013. USDA issued four citations.
USDA’s four citations, and UW–Madison efforts to address the underlying events
While USDA VMOs regularly conduct unannounced inspections of animal research programs at institutions like UW–Madison, the July inspection was the result of allegations made by an Ohio-based animal rights organization called Stop Animal Exploitation Now (SAEN).
Each of SAEN’s 10 allegations was based on self-reports made by UW–Madison to federal agencies and obtained by SAEN through a Freedom of Information Request. UW’s self-reports were submitted to the Office of Laboratory Animal Welfare at the National Institutes of Health (NIH). These reports came immediately after UW-Madison veterinarians and research staff discovered and documented incidents involving research animals. And in each case, NIH officials acknowledged that the university’s investigations and corrective measures were complete and appropriate. An NIH statement regarding SAEN tactics to base complaints on self-reported and corrected events can be found here.
1. 9 C.F.R. § 2.32(c)(1)(ii)
Incident: A USDA review of records showed 36 incidents of non-human primates escaping enclosures during the roughly 18-month period from Jan. 1, 2013, to the inspection. Most escapes were brief and quickly corrected, but five incidents resulted in injury to the animals requiring medical attention to close wounds. Many of the escapes were attributed to human error in securing enclosures and dividers, so USDA cited UW–Madison for “inadequate training in the proper handling and care of animals.”
UW–Madison response: After each escape, staff involved filed an incident report and underwent retraining in animal transport techniques. Veterinarians, animal care staff and research officials have met regularly for several years to discuss animal escapes, continuously refining the procedures for handling non-human primates. Over the 18 months reflected in the USDA review, UW–Madison personnel transferred rhesus monkeys from their primary enclosures at least 91,750 times. The 36 escapes cited by USDA represent a rate of roughly four escapes in every 10,000 animal transfers, with a significant injury in roughly one of every 20,000 transfers. Half of the escapes came during transfers conducted by personnel who had not committed a similar error before or since. While the university strives for zero escapes — and will continue to study and refine its methods — these statistics reflect well on the rigor of UW–Madison training and the skill of university personnel. In the citation, USDA inspectors noted the university had “implemented corrective actions to prevent and minimize escapes.”
1. 9 C.F.R. § 2.32(c)(3)
Incident: A USDA review of records identified an MRI scan of a marmoset in which a veterinary technician did not properly operate an anesthesia machine — a machine different than the one normally used for the procedure. A valve improperly closed led to the death of the marmoset. USDA cited UW–Madison for and employee not “properly trained and familiar with anesthesia equipment.”
UW–Madison response: The technician was suspended and retrained. Primate Center procedures were rewritten to detail the use of appropriate anesthesia equipment, with thorough and redundant checks to ensure safety for the animals. The university reported the death to NIH two days after it occurred, and NIH acknowledged the university’s efforts to prevent recurrence. In their citation, USDA VMOs judged those efforts to be “timely and appropriate corrective actions to prevent the problem from recurring.”
1. 9 C.F.R. § 2.38(f)(1)
Incident: A USDA review of records showed the on Oct. 30, 2013, a rhesus monkey was burned by a malfunctioning heat lamp provided to keep the monkey warm while it was under anesthesia. UW–Madison staff discovered the injury the next day. USDA inspectors note the animal was treated and the lamp discarded. The citation reflects handling of an animal not “done in a manner to prevent trauma and overheating,” and was levied as a repeat occurrence.
UW–Madison response: The injured monkey was placed under a pair of heat lamps during an X-ray procedure in accordance with established methods. Neither of the lamps ever came into contact with the animal, but an apparent injury on its chest was discovered one day after the procedure. The monkey’s injury was treated, and it healed completely. Veterinary staff examined all the heat sources used to keep the monkey warm during its scan, and found that one of the heat lamps was generating an improperly high amount of heat. The lamp — which had been working properly for five months prior to the incident — was discarded immediately. Veterinary personnel added to their equipment infrared thermometers, which will be used repeatedly during procedures to measure skin surface temperatures and ensure that animals warmed by lamps do not overheat, and that heat lamps are working properly. The university reported the burn to NIH shortly after it was discovered. NIH acknowledged the university’s efforts to avoid future injuries, as did the USDA inspectors in the citation.
1. 9 C.F.R. § 3.75(a)
Incident: A USDA review of records identified the deaths of two rhesus monkeys caught in parts of their enclosures. On June 1, 2012, a monkey was discovered with its head caught between a support bar and its enclosure. On June 4, 2013, a monkey was found after its head was caught in a chain attached to an enrichment device hung on its cage. The records showed each animal had been observed as fine and unencumbered about two hours prior to the discovery of its respective death. USDA cited UW–Madison for not ensuring “facilities are designed and constructed in a manner that protect animals against injury or death.”
UW–Madison response: Immediately after the death of the monkey on June 1, 2012, staff stopped using enclosures of the type the monkey was kept in for animals whose heads have grown large enough to become trapped. The enclosures had been in use with monkeys at UW–Madison for three years and hundreds of animals without incident, and the manufacturer had no report of a similar incident in 20 years of employing the support bar used in its equipment. The university notified NIH of the death. And while NIH’s director of oversight concluded no preventative action was likely to have kept the accident from occurring, UW–Madison did change its enclosure usage procedures.
Before June 4, 2013, when the monkey became entangled in an enrichment device, devices of that particular design had been used at the Wisconsin National Primate Research Center about 20,000 times over five years without incident. However, these devices — and all others incorporating long chains — were removed from use until the chains could be shortened to prevent similar accidents. Within nine days, the alterations were complete. Again, the university reported the incident to NIH immediately. NIH agreed that the actions the university took complied with NIH policy, and the USDA VMOs saw them as sufficient to prevent the incidents from happening again.