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Elizabeth Goldentyer, D.V.M.
USDA/APHIS/AC Eastern Region
920 Main Campus Dr., Suite 200
Raleigh, NC 27606
Submitted by e-mail (email@example.com)
Re: Use of Live Pigs for Emergency Medicine Residency Training at SUNY Upstate Medical
Dear Dr. Goldentyer:
The Physicians Committee for Responsible Medicine requests that the Animal and Plant Health
Inspection Service (APHIS) investigate the use of live animals for training at SUNY Upstate Medical
University in Syracuse, N.Y. The university uses pigs in its emergency medicine residency program to
teach procedural skills despite the widespread availability and implementation of educationally superior
nonanimal training methods. Based on documents obtained by the Physicians Committee under New
York’s Freedom of Information Law, the SUNY Upstate faculty member in charge of this animal use
appears not to be aware of available human-relevant methods for this training.
SUNY Upstate uses animals to teach emergency medicine residents the following procedures:
• Chest tube insertion (an incision between the ribs and the insertion of a tube into the chest cavity)
• Thoracotomy (an incision, spreading of the ribs, and splitting of the breastbone in order to access
the heart and control bleeding using sutures and staples)
• Peripheral venous cutdown (the surgical opening of a vein and the insertion of a tube)
• Peritoneal lavage (the insertion of a needle into the abdominal cavity)
• Intraosseous needle insertion (insertion of a needle into the bone)
• Cricothyroidotomy (an incision in the throat and the insertion of a breathing tube)
• Retrograde intubation – if requested by residents (the insertion of a wire into the throat and out
This animal use is at odds with current standards of practice in emergency medicine training in the United
States. According to an ongoing Physicians Committee survey, 110 of 128 emergency medicine programs
(86 percent)—including Weill Cornell Medical College, Mount Sinai School of Medicine, SUNY at
Stony Brook, and SUNY Downstate Medical Center—exclusively use nonanimal methods to teach
Under the Animal Welfare Act, SUNY Upstate meets the statutory definition of a "research facility" and is
therefore required to comply with the Animal Welfare Act. As part of this required compliance, any use of
live animals for research, testing, or training must be approved by the SUNY Upstate Institutional Animal
Care and Use Committee (IACUC).
We believe that inadequate oversight by the IACUC is responsible for the approval and scheduled use of
live pigs in the SUNY Upstate emergency medicine residency program. The specific regulatory violations
1. Justification of Animal Use is Not Possible Because Alternatives Exist
Section 2143 of the Animal Welfare Act and CFR Title 9, Section 2.31(d)(1)(i, ii) of the Animal Welfare
Act's implementing regulations require that the principal investigator—including course instructors—
consider alternatives to procedures that may cause more than momentary or slight pain or distress to any
animal used for research or educational purposes.
In addition, the principal investigator must provide a written narrative description of the methods and
sources used to determine that alternatives were not available. The content of this narrative is detailed in
the APHIS Animal Care Policy Manual (2011), which states in Policy 12: “If a database search or other
source identifies a bona fide alternative method (one that could be used to accomplish the goals of the
animal use proposal), the IACUC may and should ask the PI to explain why an alternative that had been
found was not used.”
We believe that this requirement was not met by the principal investigator because justification of
animal use for emergency medicine residency training is not possible in view of the validation and
widespread implementation of purpose-designed nonanimal training methods.
A proper alternatives search would have revealed excellent validated and widely implemented nonanimal
methods for the training of all procedures currently taught at SUNY Upstate using live pigs.
Simulab’s TraumaMan System is a realistic anatomical human body simulator with lifelike human skin,
subcutaneous fat and muscle that can be used to teach cricothyroidotomy, chest tube insertion, venous
cutdown, and peritoneal lavage among other procedures. In fact, the TraumaMan System is used by
nearly all Advanced Trauma Life Support programs to teach many of the same skills for which SUNY
Upstate is using animals.
While the TraumaMan System is widely used, there are many simulators that can be used in emergency
medicine residency training. SynDaver’s Deluxe Cric Trainer contains layered artificial skin to provide
residents with lifelike surgical experience. CAE Healthcare’s Human Patient Simulator can be used to
teach chest tube insertion on a breathing patient. Laerdal’s SimMan 3G and Gaumard’s Hal S3201 can be
used to teach residents retrograde intubation as well as cricothyroidotomy.
In addition, simulators exist to teach open thoracotomy. The Human Worn Partial Task Surgical
Simulator (known as the "Cut Suit") from Strategic Operations is a training device worn by a person that
includes breakable bones, interchangeable organs, and variable blood flow. In addition, Operative
Experience International has developed a simulation-based training system for emergency thoracotomy.
We emphasize that SUNY Upstate has not done a proper search for alternatives as demonstrated by the
principal investigator’s comments on page 9 of the IACUC animal use protocol. N. Heramba Prasad,
M.D., writes: “No other model exists currently for the training of these procedures.” In addition, Dr.
Prasad’s summary of his search for alternatives (page 14 of the protocol) does not mention the use of the
words “simulator” or “simulation.” If Dr. Prasad had conducted a proper search for alternatives, he
would have found many widely available nonanimal methods.
2. The Use of Pigs for Emergency Medicine Training is Not "Unavoidable"
The Animal Welfare Act also requires that activities involving animals are designed to “assure that
discomfort and pain to animals will be limited to that which is unavoidable for the conduct of
scientifically valuable research.” 9 C.F.R. § 2.31(e)(4).
We believe that this requirement was not met by the principal investigator because of the
widespread availability of validated simulators and the fact that 86 percent of surveyed emergency
medicine programs in the U.S. do not use animals. This clearly documents that such use of pigs is
3. SUNY Upstate’s IACUC is Failing to Properly Oversee Animal Use
Section 2143 of the Animal Welfare Act and Title 9, Section 2.31(d)(1)(i, ii) of the Animal Welfare Act's
implementing regulations require that the IACUC enforce the requirements described in items 1 and 2
above and thereby determine that the proposed activities are in accordance with the Animal Welfare Act
and CFR Title 9, Section 2.31(d).
Further, Policy 12 places the burden of alternatives justification on the IACUC as well as the principal
investigator by stating: “The IACUC, in fact, can withhold approval of the study proposal if the
Committee is not satisfied with the procedures the principal investigator plans to use in his study.”
We believe that these requirements were not met by the SUNY Upstate IACUC because the animal
use protocol was approved despite the violations described in items 1 and 2 above. Thus, the
Physicians Committee alleges inadequate institutional oversight by the IACUC.
Accordingly, the Physicians Committee requests that APHIS investigate this matter to find SUNY
Upstate Medical University in violation of the Animal Welfare Act and its implementing regulations as
detailed above. Thank you for your attention.
John J. Pippin, M.D., F.A.C.C. Richard W. Weiskopf, M.D., F.A.C.P.
Director of Academic Affairs Clinical Assistant Professor,
Chair, Physician Steering Committee Upstate Medical University
Phone and facsimile: (972) 407-9396 Syracuse, N.Y.
Vythl Alagappan, M.D.
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