Sweep, sweep, sweep....
January 4, 2010
To: Deans and Directors
From: Provost Paul M. DeLuca Jr. and Graduate School Dean Martin Cadwallader
Re: USDA report on UW-Madison research animal programsRecently, the U.S. Department of Agriculture (USDA) conducted a routine, unannounced inspection of UW-Madison research programs that involve animals used in research.
The inspection found a small number of instances where the university was not in full compliance with the federal rules and regulations. [Just a "small number" not in "full" compliance... it was nothing... pay no attention...]
The USDA’s response after this inspection indicates that UW-Madison generally is in compliance and the problems identified were not outside the norm for institutions with programs of the size and scope that exist at UW-Madison. [For such a claim to have any merit, DeLuca and Cadwallader would: a) have to show where USDA put this statement in writing (they can't); and b) point to similarly violation-filled inspection reports from other programs of the size and scope of UW-Madison (they can't do this either.) Ergo, blah, blah, blah.]
However, the university takes its responsibilities for the appropriate care and use of all of its research animals with the utmost seriousness and any problem, no matter how small, is of concern. The university is committed to conducting research in a fully compliant manner and the few issues identified in the USDA report are being addressed as appropriate. [The "few issues" include suspended protocols that, apparently, taxpayers continued paying for; approved projects in all schools using animals that sidestepped the required search for non- and less-painful alternatives; deathly ill animals being left without veterinary care; animals uncared for; and dirty surgical areas, to name just a few.]
It is important to note that the USDA report, while identifying areas where the university needs to improve, was for the most part very positive and acknowledged a high level of institutional commitment and transparency. [What report are they referring to? Not the official report that caused Eric Sangren's jaw to "go clunk", apparently.] None of the problems identified by the USDA were of a nature that put any UW-Madison research program or funding at risk. [Well that's a relief. I wonder just how bad things would have to be before any of the funding would be at risk? History suggests that it takes many years of repeat problems and undercover investigating and public exposure before any serious fines or limitations are imposed by NIH or USDA. In animal labs across the country, this is well-understood.]
The institution will take away new lessons from the experience and, coupled with an already extensive internal program of training and compliance, will seek to further improve our program of animal use and care. The university remains committed to the responsible use of animals in research. Animal models remain one of the most important tools in all of biomedical science and continue to lead to important advances that save lives and improve the human condition. [Sing Hallelujah! DeLuca and Cadwallader would have been more accurate and honest if they had said: "Animal models remain one of the most lucrative tools for raising funds to pay our and our friends' rich salaries."]
It is the university’s responsibility and a goal to have no preventable problems with its research activities and we will continue to operate and manage all of our programs accordingly.
Enclosure: Attached is a message from Eric Sandgren to all campus investigators using animals in research. This message will be sent on Tuesday, January 5.
4 January 2010
To Investigators using animals in research:In December, the UW-Madison campus received an unannounced routine inspection by representatives from the NIH Office of Laboratory Animal Welfare (OLAW) and the USDA. USDA was performing their required annual examination of the animal program. OLAW was visiting to clarify several parts of our recently submitted five-year renewal of our Assurance, a document that describes how we operate our animal program. Both groups complimented our openness and assistance during the visit. The USDA inspectors also commented that our program was in overall good shape, and comparable to programs at other large research institutions. [What about that jaw clunking?] They did identify several items they felt require our continued attention, and to address those we will be making a few important changes in how our program functions. The issues with direct application to PIs, some of which have been raised before, are noted below.
1. Protocol submissions will require more detailed information regarding a search for alternatives to painful procedures associated with a study.
2. As good practice dictates, we cannot use non-pharmaceutical grade compounds for animal treatments unless explicitly approved by a protocol.
3. Expired drugs or other substances past expiration dates must be discarded.
4. As always, laboratory animal veterinarians must be informed about sick animals, unexpected mortality, and any other adverse outcomes.
We’ll contact you with more detail about implementing these changes in the next couple of weeks, but I wanted to give you this update now since the inspection has been covered in the news. I also welcome any suggestions from you regarding how to improve our animal program. [Close it down, how 'bout?]
Eric Sandgren, VMD, PhD