Dr. Elizabeth Goldentyer USDA/APHIS/AC 920 Main Campus Drive, Suite 2000 Raleigh, NC 27606 Dr.

Goldentyer,

3/31/14

I am writing to you today to file an Official Complaint against the Yale University (16-R-0001), for what I believe are clear violations of the Animal Welfare Act which occurred in the last two years. The incidents that I am referencing were reported by Yale University to the National Institutes of Health as being non-compliances with PHS policy on animal care/use. Most of these incidents are also clearly violations of the Animal Welfare Act, upon which the NIH policies are based. On January 25, 2013, Yale University reported an incident from November of 2012, in which a hamster was found to have escaped from a cage. I believe that this violates: 9 C.F.R. 3.28(a)(4) Primary enclosures. All primary enclosures for guinea pigs and hamsters shall conform to the following requirements: (a) General. (1) Primary enclosures shall be structurally sound and maintained in good repair to protect the guinea pigs and hamsters from injury. On August 31, 2012, Yale University reported the deaths of 17 hamsters which had occurred on June 28, 2012. This reporting discussed the suspension of the protocol. If this protocol suspension was not reported to USDA/APHIS/AC, that is a violation of the requirements for reporting all protocol suspensions Section 2.31 (d)(7) This may also be a violation of 2.33 Adequate Veterinary Care and Attending Veterinarian. On August 31, 2012, Yale University reported the deaths of 15 mastomys which had occurred on June 28, 2012. These animals had received an oral vaccine. It is possible that this oral vaccine was not administered to these animals properly, thereby causing physical problems and death. This could potentially be a violation of: 9 C.F.R. 2.32(b) Personnel qualifications. (b) Training and instruction shall be made available, and the qualifications of personnel reviewed, with sufficient frequency to fulfill the research facility's responsibilities On February 8, 2012, Yale University reported the death of a dog which had occurred on August 1, 2011. This death was due to malfunctioning equipment, and failure of staff to react properly. This incident violates: 9 C.F.R. 2.33(b) Attending veterinarian and adequate veterinary care. (b) Each research facility shall establish and maintain programs of adequate veterinary care that include: (1) The availability of appropriate facilities, personnel, equipment, and services to comply with the provisions of this subchapter and (2) The use of appropriate methods to prevent, control, diagnose, and treat diseases and injuries, and the availability of emergency, weekend, and holiday care. 9 C.F.R. 2.32(b) Personnel qualifications. (b) Training and instruction shall be made available, and the qualifications of personnel reviewed, with sufficient frequency to fulfill the research facility's responsibilities. I hereby file an Official Complaint against Yale University for multiple violations of the Animal Welfare Act. I must insist that your office institute an immediate investigation.

1081-B State Route 28 #280

Milford, OH 45150

513-575-5517

www.SAENonline.org

I know that your office considers major violations of the Animal Welfare Act to be very serious in nature, especially when these violations kill or seriously injure animals. Since negligence at Yale University has led to multiple animal deaths, I must insist that you take the most severe action allowable under the Animal Welfare Act and immediately begin the process of issuing the maximum fine allowable against Yale University at the completion of your investigation -- $10,000 per infraction. I look forward to hearing from you in the near future about the fate of this facility. Sincerely, Michael A. Budkie, A.H.T., Executive Director, SAEN Attachments: 3 NIH Non-Compliance Reports