And not most rabbits in laboratory use, either
WASHINGTON D.C.––Former Environmental Protection Agency chief Andrew Wheeler, in one of his last actions before leaving office with the Donald Trump presidential administration, “issued a January 20, 2021 directive instructing the agency to plan for the retirement of the last remaining rabbits in the EPA’s taxpayer-funded testing labs,” White Coat Waste Project campaign assistant Natalie Warhit emailed to ANIMALS 24-7.
“The rabbits have been used as ‘sperm donors’ for wasteful experiments,” Warhit charged, “confined in EPA labs for years. They are typically killed when they’re no longer useful, even though they are healthy and adaptable.”
Wheeler wanted to eliminate mammal studies by 2035
Wheeler, described by Washington Post staff writer Karin Brulliard as “a former coal lobbyist who championed the Trump administration’s rollback of environmental regulations,” may nonetheless be the only ranking member of the Trump administration to depart with a positive record on animal welfare.
The directive to retire the rabbit sperm donors was consistent with a June 2019 memo to EPA staff which, in Wheeler’s own words, “directs the agency to aggressively reduce animal testing, including reducing mammal study requests and funding 30% by 2025, and completely eliminating them by 2035.”
The June 2019 order was welcomed by the Humane Society of the U.S., People for the Ethical Treatment of Animals, and the Physicians Committee for Responsible Medicine, but was vehemently denounced by the Natural Resources Defense Council. Whether either the June 2019 order or the rabbit sperm donor retirement order will be implemented by the EPA under the Joseph Biden administration remains to be seen.
Why were rabbits used as sperm donors?
The Wheeler edict, even if fully and promptly implemented, would be a reprieve for only a very small number of all the rabbits used in federally funded research: 77,838 in 2015, according to USDA Animal & Plant Health Inspection Service data.
The rabbits were used by the EPA as sperm donors under “Guidelines for Reproductive Toxicity Risk Assessment” in effect since October 31, 1996––literally, since Halloween 1996.
Explained the 1996 guidelines, “The parameters that are important for sperm evaluations are sperm number, sperm morphology, and sperm motility [capability of movement].”
Will human onanites be substituted?
Added the guidelines, “Of the common test species, ejaculates can only be obtained readily from rabbits or dogs.”
Rabbits became the preferred sperm donors for reproductive toxicity risk assessment because they are more easily and less expensively kept in laboratories than dogs.
“Similar data can be obtained non-invasively from human ejaculates,” the 1996 guidelines noted.”
This appears to have been the direction in which Wheeler hoped the EPA would go, encouraged in particular by the White Coat Waste Project.
Vanderbilt suspends experiment & researcher
Stop Animal Exploitation Now [SAEN] also claimed a mid-January 2021 campaign success, when Vanderbilt University in Nashville, Tennessee “suspended an animal experiment following the deaths of multiple animals,” and indefinitely suspended an employee “from all hands-on live animal work at the institution,” SAEN executive director Michael Budkie said.
The federal Animal Welfare Act of 1970 delegates enforcement responsibility to the U.S. Department of Agriculture [USDA].
Under scrutiny due to rat & mouse deaths
Wrote Budkie to USDA Animal & Plant Health Inspection Service [APHIS] director of animal welfare operations Robert M. Gibbens, DVM, seeking federal penalties against Vanderbilt, “On August 18, 2020, the Office of Animal Welfare Assurance [OAWA] was notified by the Division of Animal Care Veterinary Faculty that five guinea pigs had died or were euthanized as a result of failed ventilator testing procedures conducted on August 17 and 18, 2020.
“Previous reports cited Vanderbilt for failing to provide adequate veterinary care to six rabbits who received painful injections into their eyes, and for the illegal deaths of 17 gerbils during multiple botched procedures over the course of 10 months,” Budkie mentioned.
Emailed Budkie to ANIMALS 24-7, “There have been several more protocol suspensions [at Vanderbilt] over the last several years, as well as the fact that Vanderbilt was put on enhanced reporting by Office of Laboratory Animal Welfare,” which Budkie said was “very rare,” due to “the number of rat/mouse deaths in recent years.”
Rats, mice, & birds
The USDA-APHIS reports that Stop Animal Exploitation Now cofounders Michael and Karen Budkie peruse to spot and spotlight egregious alleged Animal Welfare Act violations rarely mention rats, mice, and birds––though rats and mice are by far and away the species most often used in laboratories––because rats, mice, and birds are explicitly exempted from Animal Welfare Act protection and data-tracking requirements.
This came about when the USDA wrote rats, mice, and birds out of the legal definition of “animal” in the Animal Welfare Act enforcement regulations, circumventing the intent of Congress that all animal species should be covered.
Hiding the numbers
Nearly 30 years of litigation followed before the American Anti-Vivisection Society in September 2000 won an out-of-court settlement in which the USDA agreed that rats, mice, and birds would at last receive Animal Welfare Act protection and would be included in laboratory data reporting.
But the USDA then delayed implementing the settlement, until in May 2002 former
U.S. Senator Jesse Helms (R-North Carolina) attached a rider to a USDA budget bill that made the exclusion of rats, mice, and birds from the enforcement regulations an actual part of the law.
Because USDA-APHIS does not track the use of rats, mice, and birds in laboratories, animal advocacy organizations, journalists, and even animal researchers themselves have found various other means of constructing estimates of the numbers involved.
“Without transparent statistics, it is impossible to track efforts to reduce or replace these sentient animals’ use or to project government resources needed if Animal Welfare Act coverage were expanded to include them,” University of California at San Francisco researcher Larry Carbone, DVM, explained in the January 12, 2021 edition of Scientific Reports, a publication of Nature.com.
111.5 million rats & mice used per year
Carbone in his article “Estimating mouse and rat use in American laboratories by extrapolation from Animal Welfare Act-regulated species” compared “annual rat and mouse usage data from 16 large American institutions [which voluntarily tracked and disclosed their numbers] and compared rat and mouse numbers to institutions’ legally-required reports of their Animal Welfare Act-covered mammals.
“Rats and mice comprised approximately 99.3% of mammals at these representative institutions,” Carbone found. “Extrapolating from 780,070 Animal Welfare Act-covered mammals in 2017–2018,” Carbone deduced that about “111.5 million rats and mice were used per year in this period.
“If the same proportion of rats and mice undergo painful procedures as are publicly reported for Animal Welfare Act-covered animals, then some 44.5 million mice and rats underwent potentially painful experiments,” Carbone concluded.
“Far higher number than previously thought”
Commented Sue Leary, president of both the American Anti-Vivisection Society and subsidiary Alternatives Research & Development Foundation, “This is a far higher number than previously thought, including by our organizations, which have extrapolated numbers based on European patterns of use,” which “underscores the urgent need for the use of all animals in research and testing to be regulated under the Animal Welfare Act.”
The Carbone approach is not new. People for the Ethical Treatment of Animals investigators Justin Goodman, Alka Chandna, and Katherine Roe made a similar case in the February 25, 2015 online edition of the Journal of Medical Ethics, based on an analysis of “use of all vertebrate animals by the top institutional recipients of National Institutes of Health research funds over a 15-year period.”
Goodman is now vice president of advocacy and public policy for the White Coat Waste Project.
Accelerating use of mice & rats
Goodman, Chandna, and Roe found “a statistically significant 72.7% increase in the use of animals at these U.S. facilities during this time period—driven primarily by increases in the use of mice,” they wrote, in a peer-reviewed article entitled “Trends in animal use at U.S. research facilities.”
Goodman, Chandna, and Roe estimated animal use from the “approximate average daily inventory” of vertebrate animals reported by each NIH-funded institution “in the Animal Welfare Assurances filed at least once every four years by these institutions.”
At the “top 25 largest public and private recipients of NIH funds for 2011,” Goodman, Chandna, and Roe found, total animal use increased over fifteen years from an average of 74,619 animals per year to an average of 128,846.”
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