Awhpc Osu Iacuc Complaint 3

8/15/2019 Awhpc Osu Iacuc Complaint 3

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---------- Forwarded message ----------From: Suzanne Roy Date: Fri, Apr 8, 20! at 0:! "#$%&'e(t: Animal )el*are +on(erns: $/# )ild 1orse $teriliation 3esear(h4o: ia(%(.([email protected]%, 3e&e(([email protected]%, [email protected]%,3i([email protected]%+(: [email protected]%, #ar5."[email protected]%

Oregon State University Institutional Animal Care and Use CommitteeOregon State University Vice President for ResearchOregon State University Oce of Research Integrity

To Whom It ay Concern!

The American Wild "orse Preservation Cam#aign $AW"PC% and the Salt RiverWild "orse anagement &rou# call on you to intervene to halt the 'ureau of(and anagement)s $'()s% #ro#osed sterili*ation research on +ild maresheld at the agency)s Wild "orse Corrals in "ines, Oregon- This research is

conducted in con.unction +ith Oregon State University $OSU% and is currentlyunder revie+ /y the OSU Institutional Animal Care and Use Committee$IACUC%- The #ro#osed research is descri/ed in the 0nvironmentalAssessment $0A% availa/le at this lin1! htt#s!22e#lanning-/lm-gov2e#l3front3oce2#ro.ects2ne#a24567625869628:;;4-#df

The '( intends to su/.ect ;>> +ild mares held at its Wild "orse Corrals in"ines, Oregon to a surgical #rocedure 1no+n as ?ovariectomy via col#otomy,@in +hich the ovaries are accessed and removed manually through a mare)svaginal canal- This invasive #rocedure #resents an unacce#ta/le ris1 of deathto +ild mares from hemorrhage, evisceration $#rotrusion of /o+el throughsurgical incision% and infection, /ecause they cannot /e #rovided +ith the#ost3o#erative care that is reuired +hen domestic mares undergo the#rocedure- 84 #ercent of the mares used in the eB#eriment and the#rocedure +ill cause many to suer a/ortions- Dearly 6;,>>> American citi*ens have su/mitted comments to the '( ino##osition to this #ro#osed research- In addition, video evidence and aneye+itness account raise serious animal +elfare and scientiEc integrityconcerns a/out the conduct of this #rocedure /y its most outs#o1enadvocate, Fr- (eon Pielstic1, an Oregon livestoc1 veterinarian +ho may /eassociated +ith the #ro#osed research, since he is self #roclaimed as the only#erson +ith enough eB#erience #erforming this #rocedure on +ild horses- We /elieve that your IACUC must +ithhold its a##roval of this research andthat OSU should disassociate itself from the conduct of these eB#eriments forthe follo+ing reasons!

1. The well-being of wild horses used in these experimentscannot be ensured.

mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://eplanning.blm.gov/epl-front-office/projects/nepa/56292/67242/73184/MareSterilizationResearchEA_12172015.pdfhttps://eplanning.blm.gov/epl-front-office/projects/nepa/56292/67242/73184/MareSterilizationResearchEA_12172015.pdfhttps://eplanning.blm.gov/epl-front-office/projects/nepa/56292/67242/73184/MareSterilizationResearchEA_12172015.pdfmailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://eplanning.blm.gov/epl-front-office/projects/nepa/56292/67242/73184/MareSterilizationResearchEA_12172015.pdfhttps://eplanning.blm.gov/epl-front-office/projects/nepa/56292/67242/73184/MareSterilizationResearchEA_12172015.pdfhttps://eplanning.blm.gov/epl-front-office/projects/nepa/56292/67242/73184/MareSterilizationResearchEA_12172015.pdfmailto:[email protected]


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a. Post-operative care cannot be provided to wild horses.

“The possibility that ovariectomy may be followed by prolongedbleeding or peritoneal infection makes it inadvisable for eldapplication.” G Dational Research Council, 6>;:-

“My opinion is that the predominating concern with the proposed study is the signicant risk of Colpotomy to the health/life of the maresduring the surgery and postoperatively! because they are wild animalsand cannot be handled or treated in the same manner as domesticmares. To reduce the risk of evisceration of the bowel through theColpotomy incision! it is recommended that mares should bemaintained in a tie stall for up to " days and then restricted to a small

paddock turn out for # weeks following the surgical procedure. Theseguidelines were developed because the risks of post-operativehemorrhage or evisceration are real .” ary A- Scott, FV, PhF,FACT, euine re#roductive s#ecialist- H0m#hasis added-

Fr- Pielstic1 himself armed the im#ortance of #ost3o#erative conEnement atan Ari*ona +or1sho# he conducted last year- While #erforming anovariectomy via col#otomy on a horse, Dr. Pielstick told attendees thatthe horse had to be restrained from lying down to prevent herintestines from coming through the incision. She +as tied tightlyagainst the stall +all after the surgery- $Adavit of Simone Detherlands,attendee at +or1sho#, attached%-

Do such restriction is #ossi/le in +ild horses- Dor +ill +ild horses /e #rovided+ith #ost3o#erative anti/iotics or #ain relief des#ite real ris1 of infection anddiscomfort #ost3#rocedure- These facts elevate the ris1s of com#lications andresulting mortality to unacce#ta/le levels and #rovide clear cause for your

IACUC to re.ect the eB#eriments-

6- Outcome of Dr. Pielsticks training workshop in !ri"ona providesfurther cause for withholding approval of this research.

The South+est Wildlife Conservation Center near PhoeniB s#onsored Fr-Pielstic1)s training +or1sho# last year- The #enters director$ %inda&earle$ informed !'(P# that she does not support spaying mares asa method for population control due to the complications su)ered byburros and the horse used in the workshop and the extensiveaftercare the surviving animals re*uired- Fr- Pielstic1 re#orted to '(that he conducted the #rocedure on Eve /urros- Of these, one /urro /led to

death, one /urro a/orted her 4>38> day old fetus, and other /urros sueredfrom #ost3o#erative infections, meaning most if not all of the animals used inthe +or1sho# suered from com#lications- $See 0B#ert Panel attachment%-

The /urros and horse used in this #rocedure +ere tame- The #ost3o#erativecare they reuired could not have /een given to +ild, untamed /urros orhorses-

Video ta1en of the +or1sho# sho+s Fr- Pielstic1 o#erating on /urros +ho areclearly inadeuately sedated and anestheti*ed- In her adavit, s-


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Detherlands recounts +itnessing /urros visi/ly reacting to #ain and strugglingto get out of the chute- She also recounts Fr- Pielstic1s comments on thediculty of sedating +ild horses and /urros-

At the +or1sho#, Fr- Pielstic1 #erformed ovariectomies via t+o methods!col#otomy and Jan1 incision- "e informed #artici#ants that he had a higher

death rate associated +ith col#otomy than +ith Jan1 incisions, /ecause theinternal incisions +ith col#otomy cannot /e sutured- This fact +as notconsidered /y the '( in its 0A analysis of the ovariectomy via col#otomyeB#eriment-

:- +%,s analysis of the research was based on inaccurate andincomplete information.

The '( 0A relies on information from the eB#ert #anel it convene toevaluate dierent s#ay methods- In fact, the 0A uses the #anel notes in anattem#t to directly re/ut the 6>;: DAS study that too1 t+o years to com#leteKa re/uttal that sim#ly colla#ses under the +eight of the fundamental Ja+s,

omissions and scientiEc integrity uestions cited /elo+- Fr- Pielstic1 +as #artof that #anel- According to the '()s notes, Fr- Pielstic1 did not #rovideadeuate or accurate information to that #anel-

• "e failed to disclose that the Ari*ona +or1sho# included a horseas +ell as the /urros and that the horse had to /e tied to #reventher from lying do+n, +hich could cause evisceration of the /o+elthrough the internal incision $see attached FeclarationL alsoeye+itness under oath states that this horse +as not doing +ell t+ohours after surgery, +ith ears do+n, eyes half closed, nec1 hangingdo+nM a##earing very lethargic- M%- What +as the outcome for thehorseN

• "e failed to discuss the #ost3surgical infections in the /urros +hosurvived the #rocedure and +hat the ultimate outcome +as des#itethe #anel)s directly uestioning these infections-

• Regarding his eB#erience s#aying mares at the Sheldon DationalWildlife Refuge, he noted that com#lications only arose +ithin theErst t+o days, /ut did not disclose +hat those com#lications +ereand ho+ many horses suered from them-

• "e did not ac1no+ledge +hat he said at the Ari*ona +or1sho#$see Feclaration% that there +as no follo+ u# on the s#ayed maresat Sheldon, and other than the horses +ho died during surgery, hehad no idea ho+ many had #erished-

• "e stated that the #ain levels for s#ayed mares at Sheldon +ere?+ithin acce#ta/le limits@ /ut then noted that /ecause of lo+daylight, it +as dicult to actually o/serve the animals #ost3surgery-


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• "e did not inform the #anel that he had a higher death rateassociated +ith ovariectomy via col#otomy than +ith Jan1incisions-

These deEciencies render '()s reliance on the 0B#ert Panel re#ort to .ustify#roceeding +ith ovariectomy via col#otomy eB#eriments IDVA(IF and raise

serious uestions a/out scientiEc integrity as +ell as the outcome of all ;;4 DRC #anel that recommended funding the ovariectomy viacol#otomy research #ro#osal as1ed to evaluate the #ro#osals from a scientiEcuality #ers#ective- It did not consider animal +ell3/eing or the 6>;: DRCrecommendations- It +as not #rivy to information from Fr- Pielstic1)s+or1sho# or #rior eB#erience indicating! ;% horses undergoing the #rocedure

should /e tied to #revent eviscerationL 6% Jan1 incision +as associated +ith alo+er death rate than col#otomyL :% the #revalence of #ost3o#erativeinfections and eBtent of reuired after care- 0ven still, its revie+ of this research #ro#osal concluded as follo+s, ?TheCommittee believes that this procedure could be operationali$ed immediately to sterili$e mares! with the caveat that fatalities may be higher than the %&reported in the literature. The sterili$ation techni'ues put forward (in the lessinvasive research proposals) would be safer * with less risk of hemorrhageand evisceration+and probably less painful. Therefore! if the techni'ues in,roposals -! or %# prove to be successful after the research is conducted!the committee thinks that these techni'ues should replace ,roposal %s

method of ovariectomy via colpotomy as surgical approaches for permanentsterili$ation-@ 5- The /!#0# must withhold approval of the research.

• Dangerous and impractical for eld setting 2 goes to need touse animals in the rst place.

• #annot ensure the well being of the animals due to inability toprovide with re*uired post-operative care.

• Pain and su)ering cannot be minimi"ed due to 13 documenteddi4culty in ade*uately sedating wild horses and burros5 63inability to provide post-operative pain relief5

• Ovariectomy will profoundly change natural behaviors andalter herd dynamics and social organi"ation on the range.

• +ased on data that lacks scientic integrity and is replete withglaring omissions and unanswered *uestions that we believemerit an independent in*uiry by O&0s O4ce of esearch/ntegrity

8- /ncluded for your consideration7


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• 8ideo of the !ri"ona spay workshop by Dr. Pielstick o9dited7 http7::youtu.be:;?s>ci@o0ncut7 https7::www.youtube.com:watchAvB?C;h>o*;Ec

• Declaration of &imone etherlands$ attendee to the spayworkshop.

• Public comments of !'(P# on +%, ,are &terili"ation

esearch 9!• &tatement of obin ?elly$ D8, and ,ary !. &cott D8, on +%,

,are &terili"ation esearch.• +%, 9xpert 8eterinary &pay Panel.

Than1 you for your consideration- I reuest conErmation of your recei#t ofthis letter and urge you to decline to a##rove this research #ro#osal- Sincerely, Su*anne Roy, 0Becutive Firector7;7357837:

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Awhpc Osu Iacuc Complaint 3