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Usda Complaint Re Wustl (Usda Cert. No. 43-R-0008) - 4-17-13

Usda Complaint Re Wustl (Usda Cert. No. 43-R-0008) - 4-17-13

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Published by: samtlevin on Apr 21, 2013
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 April 17, 2013Robert Gibbens, D.V.M.Regional Director USDA/APHIS/AC Western Region2150 Centre Ave.Building B, Mailstop 3W11Fort Collins, CO 80526-8117Via e-mail: Robert.M.Gibbens@aphis.usda.gov  Dear Dr. Gibbens,Thank you in advance for your time. I am writing on behalf of PETA and our more than 3 million members and supporters to request an investigation intoapparent serious violations of the Animal Welfare Act (AWA) by WashingtonUniversity in St. Louis (WUSTL) (Western Region USDA Customer No. 1444,USDA Certificate No. 43-R-0008). New video footage obtained by PETA,filmed on March 7, 2013, depicts live cats being used for intubation trainingexercises in WUSTL’s Pediatric Advanced Life Support (PALS) course, which isheld in conjunction with St. Louis Children’s Hospital. This video, which youmay view by visitinghttp://www.petapreview.com/4preview/footage_supporting_petas_april_18_2013 _complaint_to_usda.asp,supports the following alleged AWA non-compliances.
I. Failure to Minimize Pain, Distress, Harm and Discomfort to Animals
The AWA regulations require that WUSTL “minimize discomfort, distress, and pain to the animals” during experimental procedures [9 C.F.R.§2.31(c)(8d)(1)(i)], handle animals “in a manner that does not cause trauma, … physical harm, or unnecessary discomfort” [9 C.F.R. §2.38(f)(1)], and provide a“description of procedures designed to assure that discomfort and pain to animalswill be limited to that which is unavoidable for the conduct of scientificallyvaluable research.” [9 C.F.R. § 2.31(e)(4)].During video time mark 00:06 – 00:26, a PALS course participant asks WUSTLveterinarian Mike Talcott how often the cats are used for intubation training.Talcott replies, “About three years. And we use them for about four times a year.Four times a year we intubate them less than 15 times per lab.” During videotime mark 00:27 – 00:31, Talcott tells a PALS course participant, “Yes there’s atime where we have, you know, maybe some [vocal] cord edema” in the cats dueto as many as 15 intubations performed on each animal per training session.Research on repeated intubations in animals by faculty at Delaware’s
Alfred I.duPont Hospital for Children shows that, “Repeated intubation alone results in
significant tracheal trauma and systemic inflammation.”
One highly-cited study conducted at theUniformed Services University of the Health Sciences found that 29 percent of animals used for intubation training showed trauma to the larynx or trachea after 5 intubation attempts and 100 percent of animals who were intubated 10 times or more experienced trauma.
Another recent paper by faculty at Naval Medical Center-Portsmouth suggested that nomore than 10 intubations be performed on eachanimal before risking serious trauma to the airway.
 Talcott’s admission that cats in WUSTL’s PALS course suffer from “[vocal] cord edema” and that catsendure as many as 15 intubations per session confirms that WUSTL is grossly exceeding the establishedveterinary medical practice limits for safely performing intubations without injury, and these injuries are
“unavoidable for the conduct of scientifically valuable research.” Such a high number of intubationsand confirmed injury to the animals indicates that WUSTL is allegedly violating AWA regulations for minimizing pain, distress, harm and discomfort to animals.
II. Failure to Provide Adequate Anesthesia to Animals During Painful Procedures
 The AWA regulations state, “Procedures that may cause more than momentary or slight pain or distressto the animals will … [b]e performed with appropriate sedatives, analgesics or anesthetics …” [9 C.F.R.§ 2.31(d)(1)(iv)(A)].During video time mark 00:42 – 00:50, a PALS course participant who had completed the cat intubationsession states, “They had to give Jessie [a cat used in the WUSTL PALS course] more ketamine becauseI was messing with him so much.” During video time mark 00:51 – 01:00, one PALS course participantasks a trainee, “Was he [Jessie] waking up for you?” A PALS course participant replies “mmmhmm”(indicating yes) and another PALS course participant states, “they gave him [Jessie] more ketamine …”The acknowledgement that at least one cat was waking up during a potentially painful intubation procedure indicates that WUSTL provided inadequate anesthesia to the animal, in apparent violation of the AWA’s requirement that animals receive proper anesthesia during painful procedures.
III. Failure to Consider Alternatives and Justify Use of Cats
The AWA regulations require that WUSTL faculty must have “considered alternatives” to the use of animals in painful procedures and “provided a written narrative description of the methods and sources… used to determine that alternatives were not available." [9 C.F.R. §2.31(d)(1)(ii)]. USDA Policy 12goes onto explain, “
Regardless of the alternatives sources(s) used, the written narrative should includeadequate information for the IACUC to assess that a reasonable and good faith effort was made todetermine the availability of alternatives or alternative methods. If a database search or other sourceidentifies a bona fide alternative method (one that could be used to accomplish the goals of the animal
A. Oshodi
et al
., “Airway Injury Resulting From Repeated Endotracheal Intubation: Possible Prevention Strategies,”
Pediatric Critical Care Medicine
(2011) 12.1: e34-39.
D. Powell
et al
., “Use of the Ferret as a Model for Pediatric Endotracheal Intubation Training,”
Lab AnimSci
(1991) 41.1:86–89
S. Kircher 
et al
, “Minimizing Trauma to the Upper Airway: A Ferret Model of Neonatal Intubation,”
 J AmAssoc Lab AnimSci
(2009) 48.6: 780-4.
use proposal),the IACUC may and should ask the PI to explain why an alternative that had been foundwas not used.”
 It is literally impossible for WUSTL faculty to demonstrate that non-animal alternatives cannot meet therequirements of the PALS training course since the course’s developer and sponsor, the American HeartAssociation (AHA), has clearly stated that, “The AHA does not endorse the use of live animals for PALS training. The use of lifelike training manikins for PALS courses is the standard accepted norm. [T]he AHA recommends that any hands-on intubation training for the AHA PALS course be performedon lifelike human manikins.”
When asked recently to explain why it has taken position, the AHA’sDirector of Training Center Operations and Quality stated, “We do not endorse or require the use of animals during the AHA-PALS training because of advances and availability of simulationmannequins. These mannequins provide the oppotunity to practice all the necessary skills required for successful completion of an AHA PALS course.”
 Indeed, there is absolutely no evidence available to show that using animals improves intubation proficiency. WUSTL is the only one of the more than 1,000 PALS facilities that PETA knows of thatuses animals for intubation training. Clearly, alternatives to the use of animals for completing thistraining course are available and the preferred standard nationwide.The AWA regulations also require that WUSTL provide a reasonable “rationale for … theappropriateness of the species … to be used” during the PALS course; yet, the use of cats for intubationtraining in the PALS course has been criticized in the scientific literature.Cindy Tait—co-developer of the PALS course and a flight nurse, medical educator and president of theCenter for Healthcare Education, an AHA training center—has written extensively on the drawbacks of animal use and benefits of simulation for neonatal and pediatric intubation training. She describes theanatomical differences that make cats poor substitutes for human infants, stating: “Kittens and ferretshave proportionately longer tongues than human infants that are one and a half times the length of their mouth. Further differences include more profuse salivation, dome-shaped arytenoid cartilage, andcomparatively larger epiglottises and smaller anterior larynxes .... [T]here is no anatomical specificity between the maxillofacial or oropharyngeal features of animals and humans. … The bottom line is thatthere is no need to traumatize and harm animals to teach [intubation], especially when highly efectivenon-animal methods are the accepted standard of practice and readily available to instructors.”
 As such WUSTL is allegedly violating the AWA regulations since it cannot reasonably determine thatalternatives to animal use in PALS training are not available, nor can WUSTL provide a reasonablerationale for using cats despite their obvious anatomical differences from human infants.
Request for USDA Investigation
We urge you to undertake a full investigation into WUSTL’s use of live animals in the PALS course andany underlying issues that such an investigation might expose. If noncompliance is found, we urge you
USDA, “Policy #12: Consideration of Alternatives to Painful/Distressful Procedures,” 25 Mar. 2011<http://www.aphis.usda.gov/animal_welfare/policy.php?policy=12>.
American Heart Association, Letter to PETA, 3 Feb. 2009.
American Heart Association, E-mail to PETA, 18 Mar. 2013.
C. Tait.

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