Little Downside for Multiple Federal Law Violations

On April 15, 2020, the USDA fined the University of Wisconsin $74,000 for series of twenty-two violations of the Animal Welfare Act that occurred from March 4, 2015 to April 25, 2019.

The USDA reports that the university has not been inspected since December 10, 2019. [To see the data, you need to enter 35-R-0001 into the "Certificate Number" field.

Since December 10, 2019, the university has self-reported thirty-seven violations (most involving monkeys) to the NIH Office of Laboratory Animal Welfare (OLAW). [See UW-Madison's Self-Reported Animal Welfare Violations] OLAW rarely, if ever, issues citations or levies fines.

You might imagine that an institution fined for multiple violations would warrant extra attention, but in the world of tax-payer-funded vivisection, that does not appear to be the case. There is no downside for repeat violations of the so-called Animal Welfare Act.

USDA Animal and Plant Health Inspection Service (APHIS) Isn't Doing Its Job and They Know It.

USDA Inspector General's Audit Report: 33601-0002-31 "Animal Care Program Oversight of Dog Breeders."

APHIS is responsible for enforcement of the Animal Welfare Act. The agency not doing its job is like all the cops being on vacation at the same time.

There's really no one policing APHIS. This is just the latest scathing report on APHIS from the USDA's Inspector General's Office.

Excerpts from the summary:

"We identified data reliability issues with reports generated from APHIS’ Animal Care Information System (ACIS) database. This occurred because the agency no longer has a data manager for ACIS, and several large patches to the system have made it unreliable. As a result, APHIS is impeded in its ability to make informed management decisions, identify trends in noncompliant items, and identify how many inspections have been completed."

We also found that APHIS did not consistently address complaints it received or adequately document the results of its follow-up. This occurred because APHIS does not have a documented process for responding to complaints or for recording the results of the agency’s actions. As a result, some dog breeder facilities may be conducting regulated activity without a USDA license or oversight. Therefore, APHIS is not able to ensure the overall health and humane treatment of animals at these facilities."

"APHIS agreed with our findings."

The vaccination problem.

The risk of acquiring or transmitting covid (severe acute respiratory syndrome coronavirus 2, or SARS-CoV-2,) is reduced in vaccinated humans. It isn't clear to me that that is sufficient reason to get vaccinated.

Try as I might, I haven't been able to find the details on all the vaccines' production methods. I don't get a flu shot because I don't want to be part of the reason that chickens are hurt and killed.

If I was stranded on a desert island with a dog, a chicken, or a human I could overcome, I wouldn't kill and eat them even if I would starve to death otherwise. The risk of getting and dying from Covid is lower than the risk of starving to death when stranded on a desert island.

I suspect that the mRNA vaccines use fewer animals in their producton, but, as I mentioned above, mRNA production details are hard to find.

At 68, I'm in a high-risk group. At my day job, I interact with the public. We are all masked, and when we are the closest and I'm speaking with them, there is generally a barrier between us. When I shop for groceries, I wear a mask and avoid being very close to other shoppers. I use self-checkout even though I'd prefer to help create a job by being checked out by a clerk. At the dog parks, no one is masked, but we are outdoors, and I keep my distance.

I wish I knew about the mRNA vaccine production methods.

For the record, the primate vivisection industry's claims about the need for monkeys in the development of the Covid vaccines rings hollow to me. Vivisectors have claimed that just about everything is the direct result of their experiments on animals. I've debunked many of these, and in the process of reading the history of medicine and the historical details behind many of the drugs and treatments ballyhooed by the vivisectors, I've learned that their claims can never be taken at face value. If their claims about the use of monkeys was the only mention of animals being used I might go ahead and get vaccinated because their claims are almost always bogus.

Cruelty pretending to be heroics at UW-Madison

Why are Chancellor Blank and vet school Dean Markell grinning? Does he imagine extra space for more hideous experiments on dogs and other animals like the ones he has conducted? [For example: rabbits, rats, and dogs]. Does she think her bosses, the Board of Regents, will extend her contract? Is she completely in the dark about the terrible things done to animals at the vet school? We need more sifting and winnowing.

There is something particularly distasteful, hideous in fact, about those who hurt and kill animals and at the same time portray themselves as “heroes” for animals. This would be like Joseph Mengele declaring himself a hero for children if something he discovered by experimenting on children turned out to be in some way beneficial to other children. A better example might be J. Marion Sims.

Sims, the “father of genecology” conducted experiments on enslaved Black women (and children) that led to improvements in gynecological care for women. His work is a textbook example of the ends not being justified by the means. He could and should have found unenslaved women willing to take part in his experiments.

The University of Wisconsin-Madison is expanding its vet school. See the hype here and here.

Not mentioned anywhere in the propaganda are the terrible things done to animals at the vet school. I’ve pointed to a tiny fraction of them here.

People get rich by hurting the most vulnerable among us and they declare themselves heroes. No one but a tiny few seem to notice the dark irony. Local media jumps on-board. On matters concerning the terrible things done to animals there is next to no investigative journalism.

We live in a very sick world.

On fonctionne tous de la même manière

UW-Madison College of Letters and Science "Macaque Enrichment" Doc.

Of the 4 documents I recieved form the university on May 10, 2021, after 142 days of waiting, the College of Letters and Science was, in a way, the oddest.

These redactions are odd and questionable. The use of macaques at the School of Letters and Science generally takes place at the Harlow lab, just across an alley form the Primate Center. Why redact that location? Maybe if crazy animal rights fanatics learned that monkeys are being experimented on in the building that used to house and is named after Harry Harlow, they would go crazy? Who doesn't know that the Harlow lab experiments on monkeys? And why is the title of something staff are required to read hidden? Strange indeed. Or just silly and/or dumb.

It's doubly weird and silly because anyone can google "Harlow lab" and immediately see a picture of it and the address and phone number. And if you go to their webpage, you see immediately that the Director is (still) Chris Coe.

Whatever, here's the document:
UNIVERSITY OF WISCONSIN-MADISON
COLLEGE OF LETTERS AND SCIENCE
STANDARD OPERATING PROCEDURES
SOP #325 DATE ISSUED: April 13, 2018
TITLE: Macaque Enrichment

There is no mention of what to do when a monkey starts exhibiting signs of mental illness. Maybe that's in yet another document. We'll see.

Primate Environmental Enrichment at UW-Madison - The Plan

The image above is from the University of Wisconsin, Madison's Primate Research Center's Animal Services webpage. (The splash images rotate periodically.) I think it more fair to point to this image rather than a generic image from another source.

The Animal Welfare Act (Public Law 89-544) was passed in 1966. For the most part, laboratories using animals continued their business as usual. Exercise requirements for dogs and psychological well-being for primates were not mandated until 1985. The law requires laboratories using primates to have a plan that provides an environment that promotes their psychological well-being. This plan musy be available to USDA inspectors on request. It took the University of Wisconsin, Madison 142 days provide me with this copy of their legally required plan. Oddly, the plan is dated 2020. Did they have to write it because I requested it? It woundn't surprise me.

The introduction captures the essence of the plan:

The Environmental Enhancement Program at the Wisconsin National Primate Research Center (WNPRC) is dedicated to promoting and enhancing psychological well-being for the entire non-human primate (NHP)colony while ensuring that our animals are free from unnecessary pain and distress. By utilizing a combination of environmental enrichment, behavior modification, and positive reinforcement, the program attempts to promote a diverse array of species typical behaviors and decrease the occurrence of stereotypical and self-injurious behavior (SIB) by increasing activity.

Tellingly, the plan merely attempts to decrease the incidence of profound psychological distress. There is nothing in the Animal Welfare Act that mandates success. Everyone who takes the time to learn about the issue knows that it is next to impossible to maintain the psychological well-being of macaques kept for years in small steel cages.

There is nothing in the law that says the plan must be successful.

The Animal Wefare Act does though stipulate who must have sufficient and appropriate authority to assure that adequate veterinary care is provided at all times and that he or she is able to oversee the adequacy of all aspects of animal care and use for all animals. That person must be the attending veterinarian. The attending veterinarian at the UW-Madison is Saverio “Buddy” Capuano.

I doubt his situation is unique, though I've not looked closely at the publishing histories of attending vets at the other large primate labs aroung the country. In Capuano's case, he is a coauthor of numerous papers detailing a host of terible things done to monkeys that he has had a hand in.

So it can't come as too much of a surprise that monkeys at the university are caged alone for years on end, that there are monkeys pulling their hair out, pacing endlessly, whose lives are pretty much a living hell.

Look at the picture at the top of this essay. It must be an example of what the university, Capuano, et al consider an example of good care. But these young monkeys are in a box and will be for their entire lives. Compare their likely life experiences with those of wild rhesus macaques.

In any case, here's one more document I received in response to my request: cage size exemptions.

Environmental Enrichment at UW Madison - pair housing macaques

Just about a month ago, I suggested that the University of Wisconsin might be in violation of the Animal Welfare Act because they had been dragging their feet for so long in providing me with copies of documents that they are required to have on hand and ready to be reviewed by a UDSA Animal Welfare inspector.

I wrote to the state Attorney General's Office about the length of time I had been waiting -- The AG's office says on its website that though there is no specified time requirement in the law, that two weeks is a reasonable amount of time. Within a few days I received the documents that I had been waiting 142 days for. The cover letter was undated; the records were made available to me on May 10, 2021 (see below). I asked for them on December 19, 2020.

Of the four documents I received, the pair housing exemption list provides the most insight into the living conditions of monkeys at the university. The NIH Office of Laboratory Animal Welfare booklet "Macaques," a part of it's series Enrichment for NonHuman Primates, says:

Because of the intrinsic social nature of macaques, pair or group housing of compatible animals is extremely important. It is well-known that raising a macaque alone, without the company of other macaques of the same species, will result in that animal expressing a pattern of abnormal behaviors that can become self-destructive. Even the behavior profiles of adult animals housed alone can degenerate into inciting these abnormal behaviors, which may include repeated pacing, circling, or somersaulting; hyper-aggression; depression; and self-injurious behavior, including hair plucking or self-biting.

Everyone even a tiny bit interested and even minimally informed seems to know that keeping macaques in cages by themselves is harmful to them. The effects seems to be significantly worse than keeping humans in solitary confinement. And yet, if I am reading the document correctly (there is no one to ask), on or about the day the document was printed, 67 macaques were in cages by themselves.

One female monkey, rh2347, was apparently moved to a cage with another monkey on February 25, 2021, afer 12 years of being alone.

Three monkeys have been cages alone since 2013. Six since 2014. Eleven since 2015.

The Wisconsin National Primate Research is a hideous place, all the monkey labs are. They all operate in pretty much the same way.

View Message

CC: lisa.hull@wisc.edu;
Subject: Rick Bogle Public Records Request :: P001468-121920
Body:
RE: PUBLIC RECORDS REQUEST of December 19, 2020.
Reference # P001468-121920.

Dear Requester:

I write in response to your request under the Wisconsin Public Records Law, Wisconsin Statutes §§19.31-19.39, dated December 19, 2020 for, “the university's primate psychological enhancement plan or (plans) and any exemptions that have been granted from January 1, 2020 to present. (For reference see 9 CFR § 3.81).”

Attached please find 33-pages of records in response to your request.

We have redacted or withheld the following categories of information for the reasons given below:

[blah, blah, blah...]

Sincerely,
Lynn Rusch
Senior Administrative Program Specialist
University of Wisconsin – Madison

UW-Madison May Be in Frank Violation the Animal Welfare Act

Using their public records request on-line portal, I submitted a public records request to the University of Wisconsin, Madison on December 19, 2020.

Please send me a copy (or copies) of the university's primate psychological enhancement plan (or plans) and any exemptions that have been granted from January 1, 2020 to present. (For reference see 9 CFR § 3.81).

Thanks in advance,

Rick Bogle

Almost 5 months later, I’m still waiting.

9 CFR § 3.81:

§ 3.81 Environment enhancement to promote psychological well-being.

Dealers, exhibitors, and research facilities must develop, document, and follow an appropriate plan for environment enhancement adequate to promote the psychological well-being of nonhuman primates. The plan must be in accordance with the currently accepted professional standards as cited in appropriate professional journals or reference guides, and as directed by the attending veterinarian. This plan must be made available to APHIS upon request, and, in the case of research facilities, to officials of any pertinent funding agency.

If the plan must be made available to APHIS upon request, it seems that the plan must be readily available. (APHIS, the Animal and Plant Health Inspection Service, is a small branch of the USDA. APHIS is charged with oversight of compliance with the Animal Welfare Act, of which § 3.81 is a part.)

Why hasn’t the university sent me a copy of their primate psychological enhancement plan or plans?

The University of Wisconsin is odd in a number of ways, but particularly so with regard to the use of monkeys. Numerous vivisectors across campus use these animals. Maybe the School of Medicine and Public Health, where the infamous Michele Basso experimented on monkeys, has its own plan. Maybe the infamous Harlow Center for Biological Psychology (aka, the Harlow Lab) has its own plan. And maybe the University of Wisconsin National Primate Research Center, just across the street from the Harlow lab, has its own plan. Who knows? Maybe they don’t have a plan? Maybe they are writing one right now?

In any case, a four month-long delay in sending me a document that they are legally required to have on-hand doesn’t instill a lot of confidence. It suggests to me that they are breaking the law by not having a plan, can’t find it (which means that no one ever looks at it), or are afraid I will read it and write about it, or.... Honestly, I can’t come up with another scenario to explain their delay.

"Good Animal Care and Good Science Go Hand in Hand"

If good animal care and good science go hand in hand, it follows that poor animal care results in poor science.

The most appropriate behavioral management program houses macaques in a sufficiently enriched and safe environment to prevent the development of abnormal behaviors.

Abnormal behaviors include repetitive movements, such as pacing, circling, rocking, spinning, somersaulting and bouncing. Cage-licking, self-clasping, self-sucking, masturbation, “saluting,” and eating feces are some other aberrant, repetitive behaviors. Abnormal behaviors in macaques also can hurt or injure the animals, as in the case of hair plucking, self-biting and head banging.

Abnormal behaviors are an undesirable consequence of captive housing, reflecting an inadequate environment for maintaining the animal.” Macaques Kathryn Bayne, M.S., Ph.D., D.V.M., DACLAM, CAAB AAALAC International. (NIH Publication No. 05-5744).

The only conclusion that can be drawn from the undercover investigations and whistle-blower reports documenting a variety of serious behavioral problems like self-wounding, pulling out their hair, repetitive movements, and chronic diarrhea afflicting monkeys at the Wisconsin National Primate Research Center is that the "science" being conducted there is not good science.

From Peta's 2020 undercover investigation at UW-Madison Keeping a monkey alone in such a bleak environment is obviously very cruel. It should be illegal.

This begs the questions of why does NIH continue to fund poor science? Why are the university's Animal Care and Use Committees consistently approving the resulting poor scientific projects? Why haven't USDA-APHIS inspectors cited the primate labs for their poor care? Why hasn't NIH OLAW required the reporting of behavioral problems and chronic diarrhea?

Unfortunately, the answer is the same for all of these questions. No one really cares. All the claims about good science being dependent on good animal care are just propaganda. Everyone on the inside must know this, which makes all of them liars.

And, of course, the reason no one cares is that there is no reason to. The money keeps pouring in.