Sunday, September 25, 2011


I don't know how many times I've read dismissals by vivisectors following USDA inspections that the citations were for trivial house keeping problems like a little rust on a door hinge or some peeling paint in a hallway. These PR snow jobs usually include patently fictitious claims that their staff care deeply for the animals (they experiment on and kill.)

An interesting document has come to light that sheds some light on USDA-, OLAW-, and AAALAC-identified ACUC/institution deficiencies in the oversight of experiments using animals.

[For those understandably confused by this alphabet soup, USDA is the United States Department of Agriculture; in this context USDA is shorthand for the Animal and Plant Health Inspection Service (APHIS), the branch of the USDA responsible for inspecting research facilities using animal species covered by the Animal Welfare Act (AWA), a federal law. OLAW is the euphemistically-named Office of Laboratory Animal Welfare, a unit of the National Institutes of Health (NIH) charged with assuring that institutions receiving grant monies from the NIH are in compliance with the Public Health Service (PHS) Policy on Humane Care and Use of Laboratory Animals and a recently watered-down small book-sized document published by the National Academies of Science (NAS) titled the Guide for the Care and Use of Laboratory Animals (the Guide). AAALAC is shorthand for AAALAC International, or the Association for Assessment and Accreditation of Laboratory Animal Care International, which describes itself as "a private, nonprofit organization that promotes the humane treatment of animals in science through voluntary accreditation and assessment programs," but is actually an industry support group working to shield institutions with a weak and complicit "accrediting" process from understandable public criticism.]

The document seems to be a handout but is labeled as "notes" from a session of the 2011 PRIM&R's IACUC (Institutional Animal Care and Use Committee) conference that was held in Chicago. I've transcribed it below; you can view a pdf of the original here. PRIM&R is just another of the many organizations that have sprung up over the years to protect the cash flow from the public coffers into the pockets of researchers and their respective institutions.

This document suggests that, nationwide, the oversight committees aren't doing a very good job, but without knowing how many citations were issued for each of the named problems, it is impossible to know how they are doing overall with any certainty.

Top 10 Deficiencies from the Perspective of USDA, OLAW, and AAALAC

Based on a review of 1,724 citations, USDA reported the following as most frequent violations:

1. Issues, with IACUC Reports on Semi-annual Program Reviews and inspections (reports and inspections not conducted in a timely manner, reports not signed by the majority of the committee, reports not submitted within 15 days)

2. Protocol Reviews (descriptions of procedures incomplete; work performed that is not covered by a protocol)

3. Outdated Pharmaceuticals (present in lab/facility and available for use)

4. Search for Alternatives (search described does not relate to pain/distress or minimizing those; search does not address specific procedures included in protocol)

5. House Keeping (facilities must be clean and in good repair; accumulations of trash have been major concern)

6. Semi-annual Inspections (not done on time - i.e. every 6 months; when a date slides, the schedule should not be reset - i.e. the committee should get back on schedule with following inspection)

7. Access and Inspection of Facilities (must have someone available to allow inspections of records, facilities, and animals; must allow inspectors to take photographs - this is now a requirement of USDA Inspectors in specific situations)

8. Veterinary Care (daily observations to assess health and well being are a must; communications with vets and vet techs must be-timely)

9. Occupational Health/Safety Issues (all staff must be made aware of OHS facilities, personnel, equipment, and services; documentation must be available)

10. Rationale for Involving Animals and Appropriateness of Species and Numbers (most citations are for failure to provide an adequate rationale for using animals)

Based on 4,694 reportable issues (73% in higher education- institutions), OLAW has identified three main groups of related issues:

1. Protocol Issues (failure to follow approved protocols, unapproved significant changes to protocols by PIs, work conducted prior to protocol approval, inadequate PI oversight of protocol implementation, doing work under expired protocols)

2. Husbandry (Inadequate records/inadequate identification of individual animals - i.e. inability to tie records back to specific animals, escaped animals, lack of enrichment)

3. Other (human errors/accidents; natural disasters; equipment failures; training failures; crime, neglect and abuse [this was noted as occurring rarely, but is categorized for reporting purposes within the “other” category])

The OLAW inspector noted that 55% of all concerns with physical facilities related to HVAC systems, and stressed that it is always better to err on the side of reporting as the consequences for reporting are almost always less if the incident results in a penalty (i.e. not reporting results in larger fines).

Based on certification reviews for 800+ institutions, AAALAC reports that the bulk of accreditation denials stem from:

1. Occupational Health and Safety Issues (OHS programs not fully implemented, coordination, inconsistent implementation, risk assessments based on contact time rather than actual risk [e.g. Ebola doesn't require significant contact time but is of high risk], lack of follow up after initial assessments [e.g., for vaccines], lack of safety training for personnel [particularly a concern for student employees])

2. Protocol Reviews (lack of intensity of protocol reviews, lack of clear procedurs or failure of ACUC to follow procedures when doing reviews, inappropriate use of committee alternates, lack of a defined schedule for administration of analgesia, inappropriate/inadequate committee composition)

3. HVAC Systems (significant cause of animal deaths; inadequate maintenance of temperature according to Guide, inappropriate relative air pressure differential, environmental data to complete/not being recorded, inadequate air changes, inability to maintain humidity)

Notes, from session from session D7, PRIMR 2011, Chicago IL attended by Dreux Watermolen, L&S ACUC

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