Two statements were particularly comical: “We do not make excuses …,” and “we take responsibility…”.
His column seemed to have two goals: 1. Give an excuse for a few of the many problems noted by the USDA and OLAW, and 2. Scold local media for quoting the inspection reports.
He claimed that “early news coverage misrepresented” the problems, apparently trying to make readers believe that the federal inspectors’ written reports did so as well since the language from the reports was a key element in local media coverage.
Let’s look at his excuses for the violations and compare them with the USDA report and the regulations the inspectors cited them for violating. You can read the USDA report here.
1. His excuse for the inspections:
In December, the U.S. Department of Agriculture and the National Institutes of Health Office of Laboratory Animal Welfare (OLAW) performed a routine inspection of the UW-Madison animal program. USDA is required by law to inspect all research institutions at least once per year. OLAW visits several institutions each year.The USDA inspection was officially a “Routine Inspection.” This is noted on the inspection report itself. But the inspection was far from routine. Typical “Routine Inspections” routinely find few violations. The reasons for finding few violations are many, but a large one is that inspectors commonly arrive alone and stay for a few hours or a few days at most. In this case, a team of inspectors was at the university for two weeks.
“Routine Inspection” reports routinely amount to a page or two in length. A September 2009 UW-Madison “Routine Inspection” of “All Campus Sites” is just over a page in length, and an April 2009 “Routine Inspection” of “All Campus Sites” is a single page. The December 9, 2009 inspection that Sandgren says was a “routine inspection” is ten pages long. That’s not routine.
Sandgren says that OLAW visits “several institutions each year.” But he should have said, OLAW visits only a few institutions each year, and usually, only if they suspect serious problems. USDA and OLAW showed up at the same time. That’s not routine.
2. His excuse for the reasons for the inspections:
That is the point of inspections: to provide us with an independent evaluation of our program. The findings prove extremely helpful in our own efforts to continually improve.Actually, the point of the inspections is to monitor compliance with federal regulations and to cite violations. Independent evaluations are provided by the American Association for Accreditation of Laboratory Animal Care International (AAALAC), a private, nonprofit organization that accredited organizations, like most of the animal-using colleges at the university, claim is the “Gold Standard for animal care and use in science.”
The fact that the inspectors found so much wrong that this accredited institution itself could not see doesn’t say much for the institution’s effort to improve.
Insiders allege that the joint inspection was stimulated by multiple complaints to OLAW and USDA from animal care staff. There is no way to confirm this, but if it’s true, that’s not routine either.
3. His excuse for the dirty surgical suite:
USDA found inadequately cleaned areas in one of 10 surgical areas examined. The rest looked great. The outlier is now clean, and everyone using it knows they better keep it that way.Nowhere in the report does it say that other surgical suites “looked great.”
What is implied when he says: “The outlier is now clean, and everyone using it knows they better keep it that way”? Do researchers at the university have to be ordered to maintain a sterile surgical environment? What does it imply about their concern for the animals they are operating on or even their basic understanding of germ theory? What does it say about the competence of RARC and the animal care and use committee whose job it was to insure compliance with the federal regulations who allowed the surgical suite to become and remain dirty?
The inspectors reported that they inspected the surgical suite after it had been cleaned and found rusty equipment (which makes it very difficult if not impossible to adequately clean), hair clippings on a table, drips/splatter residue on a wall, an excessive accumulation of dirt on the air vents, and dark colored material on the front drawers of an anesthesia machine. And yet, the university claims that its research and science and animal care is cutting-edge. Blather.
4. His excuse for not requiring researchers to explain how they ascertained that there are no less- or non-painful alternatives:
Our current animal use application reminds applicants to “make sure the proposed procedures cause the least possible stress to animals,” and requires them to confirm that they have done so. We will now also require a narrative description in the application of how this requirement was met.The inspectors wrote: “There is nothing to indicate that the principal investigators had considered alternatives to potentially painful procedures that may cause more than momentary or slight pain and/or distress to the animals in the written narrative.”
Sandgren says, “We will now also require a narrative description in the application of how this requirement was met.”
But USDA Policy# 12 requires:
a written narrative description of the methods and sources used to consider alternatives to procedures that may cause more than momentary or slight pain or distress to the animals;The university stopped referring researchers to this policy sometime after 2008. He should have said they the university will go back to requiring a narrative.
His excuse for the dogs not receiving veterinary care:
The animals in this study were being monitored by veterinarians, who were treating their patients as they recovered from surgery. The error was in failing to inform our laboratory animal veterinarians about the animals’ condition so that they too could participate in patient management. That communication problem is now fixed.Because this study (#V01296) was taking place at the vet school (that’s what the V stands for), it was veterinarians who were directly responsible for causing the dogs’ health problems in the first place. In all likelihood, the dogs were being experimented on by Milan Milovancev, DVM, and/or Jonathan McAnulty DVM, and/or Ellison Bentley, DVM, and/or Richard Dubielzig, DVM, and or Annette Gendron-Fitzpatrick, DVM. Saying that the dogs were being monitored by veterinarians is like saying that the humans experimented on by the Nazis were being monitored by doctors. In neither case would it be anything but odious to call the victims “patients.”
There was a communication problem. The inspectors noted that three dogs and other animals had severe health problems and that there was no record that the attending veterinarian had been notified. They went on to say that:
It is the responsibility of the research facility and research staff to have a mechanism of direct and frequent communication to ensure that problems of animal health and/or behavior are conveyed in a timely manner to the attending veterinarian for evaluation and assessment to ensure the health and well-being of the animals.Sandgren says: “We do not make excuses for any of the problems. We take responsibility for them all.”
Sandgren’s column is a short laundry list of excuses for many problems. He says they are sorry and will try to do better. He also says they take responsibility for the problems. Exactly how do they do that? Will people lose their jobs? Will salaries be cut? What does “take responsibility” mean?
A postscript: Sandgren tries to take media to task for misrepresentative reporting, but most of the reports said that USDA had twenty violations. This was subsequently mentioned by university animal research defenders as "only twenty" violations. Sandgren didn't correct that error in his column. Look at the report. There were twenty different kinds of violations.
In fact, conservatively, there are close to a hundred individual violations; count them up yourself. Looked at this way, media reporting did Sandgren and his crew a favor.