People for the Ethical Treatment of Animals published an open letter July 6 to President Christina Paxson P’19 condemning University laboratories for “chronic and egregious animal welfare violations,” citing 23 violations of federal animal welfare guidelines between March 2019 and April 2021.
The letter, which was penned by Alka Chandna, PETA vice president of laboratory investigations cases, urged Paxson to “take personal responsibility” in confronting the violations and called for the implementation of a zero-tolerance policy for researchers who fail to adhere to federal and University animal welfare guidelines.
In the letter, Chandna cited violations of federal regulations including the death of mice from starvation and dehydration, failure to provide animals with safe housing, failure to euthanize a mouse according to veterinary directives and failure to euthanize a mouse whose tumor exceeded University size limits. Chandna also cited that 300 mice were euthanized in a method “inconsistent” with the American Veterinary Medical Association’s Guidelines for the Euthanasia of Animals.
Given their previous concerns surrounding the treatment of animals in University laboratories, “Brown University has long been on (PETA’s) radar,” Chandna told The Herald.
According to Chandna, the University’s recent animal welfare violations came to PETA’s attention after the organization submitted a Freedom of Information Act request related to the University with the National Institutes of Health.
Since the NIH is an agency of the federal government, its records are accessible to the public through FOIA. And, because the University receives federal funding from NIH to conduct research — totaling $127,562,714 in Fiscal Year 2020 — the University is required to self-report any laboratory practices that violate animal welfare guidelines for federally-funded research institutions in publicly accessible NIH records, which PETA requested.
In addition to federal regulation violations, Chandna detailed violations of the Institutional Animal Care and Use Committee’s protocols in University laboratories, including improper euthanasia and tissue collection practices, the failure to provide support to animals after surgery and the injection of a substance into mice’s feet without IACUC approval, which resulted in injuries necessitating euthenasia.
The IACUC is responsible for reviewing and approving animal research practices in University laboratories and handling instances of noncompliance with animal welfare regulations, Jill Pipher, vice president for research and professor of mathematics, wrote in an email to The Herald.
The IACUC receives education and training on animal welfare regulations from the University and works “in accordance with (the University’s) Policy on Reporting Animal Welfare Concerns, Adverse Events, Unanticipated Problems and Noncompliance.” Its responses to infractions can range from retraining researchers to increasing unannounced laboratory inspections to suspending or terminating individuals from animal work, Pipher wrote.
“At Brown, we strive to maintain the highest standards of care in our research facilities and approach the health and safety of animals with the utmost seriousness,” she explained. “Our animal care and use program is a shared responsibility” spread between the IACUC as well as other offices and individuals, including Pipher herself, to ensure laboratories uphold University standards.
In incidents like those highlighted by PETA, “Brown abides by a detailed set of policies, procedures and protocols and takes immediate steps to ensure the well-being of the animal, investigate the situation and fulfill any regulatory reporting requirements,” Pipher wrote — including documenting violations through NIH.
It is because of the University’s self-reporting policy that outside organizations “can obtain information from Brown’s disclosures … and as such the factual information about these incidents is derived from Brown’s own reports,” Pipher added.
Still, Chandna said that the University’s animal welfare protocols are insufficient, as they fail to prevent “ongoing violations” from occurring in University laboratories.
“Year after year after year animals in the laboratories continue to suffer in the same ways,” Chandna said.
“We write (open letters) because we need the universities to know that they are being monitored, that what is going on in their laboratories is being observed by watchdog groups like PETA,” Chandna said. “They need to realize that the paper trail they create with NIH is not enough. There has to be real accountability.”
According to Chandna, these animal welfare violations extend beyond merely an animal rights issue. Oversights in animal treatment during research can jeopardize or discredit findings and waste University funding, she said. Moreover, the University receives federal funding stemming from taxpayer dollars. When it fails to adhere to federal regulations, she added, it becomes an “issue of public trust,” as the University’s conduct does not meet the expectations of the people who fund its practices.
In the open letter, Chandna proposed the University adopt a zero-tolerance policy for animal welfare violations, like the failure to provide food and water to animals or the failure to follow veterinary directives. Repercussions could include the revocation of privileges for lead experimenters and principal investigators who fail to comply with federal regulations and IACUC directives, she said.
For Chandna, the issue of advocating for animal rights becomes more urgent when the species under discussion is one that does not immediately evoke public support, like a dog or a monkey might. When discussing rats and mice, the public is less likely to respond critically, Chandna explained. Legislation also makes it harder to hold organizations accountable in these cases, as mice and rats are excluded from many federal regulations — including the Animal Welfare Act, which is the only federal law concerning animal welfare capable of imposing legal repercussions on those who violate it, she said.
Rocket Drew ’22, Brown Animal Rights Coalition executive board member, explained that issues surrounding “speciesism” in the public’s perception of animal welfare come up frequently in animal rights spaces, especially in conversations surrounding animal rights in research and experimentation.
“It’s an empathy problem,” Drew said. “Even if you don’t think mice are that important … There should come a point for you where some amount of suffering and death imposed upon these creatures is not worth it anymore, is just not morally justified.”
Drew also questioned the efficacy of self-reporting of animal welfare violations, speculating that the University might be disincentivized from reporting its own shortcomings, he said. “The analogy that’s often used for these kinds of self-reporting requirements is the fox watching the henhouse.”
“The incentive structure for a lot of animal welfare-related regulations is really corrupt and it just doesn’t work,” Ruthie Cohen ’23.5, BARC executive board member, said. “I think enforcement is pretty limited for a lot of these regulations, and I also think the lack of public pressure is a huge part of why the University, for example, doesn’t take these things seriously.”
According to Cohen, the failure of the University to correct practices which result in repeated mistreatment of animals indicates a lack of public demand for institutional change.
“Obviously the onus is on the people running the labs to make sure this doesn’t happen, but also on us to make people more aware of it,” she said.
Pipher emphasized that the University is continuing to work toward strengthening its animal welfare programming, noting that the University recently “voluntarily attained” an accreditation with the Association for Assessment and Accreditation of Laboratory Animal Care.
“Only institutions that have achieved the highest standards for their animal care and use programs receive AAALAC accreditation,” she wrote. “A comprehensive program description is submitted for review and facilities undergo an extensive site inspection. Program and facility reports are submitted annually. Re-accreditation, consisting of a complete program review and site inspection, occurs every three years with the most recent visit having just occurred in February 2020.”
In addition, Pipher explained that the University undergoes routine unannounced inspections from the United States Department of Agriculture — most recently occurring in June and resulting in no citations.
Chandna said that she holds out hope that the University will adopt more stringent animal welfare regulations, with PETA continuing to nudge institutions like Brown and NIH to reform their practices by highlighting shortcomings.
It has taken a lot of work on the part of animal rights groups, “but I feel it will happen,” Chandna said. “PETA’s been around for a little bit more than 40 years and through that time we’ve seen that public trust in animal laboratories has been eroding and public support for animal experimentation has been eroding to the point where the majority of Americans … don’t support the use of animals in (medical) experimentation.”
“I sincerely believe that it will happen, maybe in the next decade, maybe in the next two decades, but it will happen in my lifetime. We’re going to see real accountability” and a critical re-examination of the use of animals in research and experimentation, Chandna said.
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