September 8, 2010

Dr. Elizabeth Goldentyer

Eastern Regional Director
USDA/APHIS/AC
920 Main Campus Dr., Ste. 200, Unit 3040
Raleigh, NC 27606

Via e-mail: Betty.J.Goldentyer@usda.gov

Dear Dr. Goldentyer,

On behalf of People for the Ethical Treatment of Animals (PETA) and our more
than 2 million members and supporters, I am submitting this complaint regarding
the treatment of animals at Professional Laboratory and Research Services, Inc.
(PLRS), Certificate #55-R-0027, at 1251 NC Hwy. 32 N. in Corapeake, N.C.

A PETA investigator was hired as an animal caretaker at PLRS and worked from
December 2009 to September 2010. During this time, the investigator documented
egregious and repeated violations of the Animal Welfare Act inside the filthy,
deafeningly loud kennels of the laboratory. PLRS is hired by pharmaceutical
companies to test insecticides and other chemicals used in companion animal
products. Bayer, Eli Lilly, Novartis, Schering-Plough (now Merck), Sergeant's,
Wellmark, and Merial, the makers of Frontline flea and tick products, are some of
the corporations that have paid PLRS to force-feed chemicals to or smear them
onto dogs and cats.

Laboratory workers appeared to despise the animals in their care—they yelled and
cursed at cowering frightened dogs and cats, calling them "asshole,"
"motherfucker," and "bitch," sprayed them with water, bleach, and other harsh
chemicals using pressure hoses, and dragged dogs too frightened to walk through
the facility. PETA's investigator saw employees kick, throw, drop, and drag dogs;
lift rabbits by their ears; lift puppies by their throats, and violently throw cats into
cages. Through apparent carelessness, one employee accidentally poured bleach
on a dog's face.

Dogs, cats, and rabbits at PLRS were forced to live in their own feces and urine,
with the result that they suffered from burns and sores. PETA's investigator was
instructed by a PLRS supervisor to remove fecal matter from rabbits' cage floors
by vigorously shaking the floor of the cage up and down with the rabbits still in
the cage. PETA's investigator learned of two incidents in which rabbits' feet had
been severed through this process. Dogs and cats trapped in their enclosures
during cleaning were exposed to a caustic bleach solution—often for as long as 15
minutes—that burned the animals' skin and respiratory tissue and irritated their
eyes. The animals received no veterinary care for their wounds.
Indeed, PLRS had no veterinarian employed on site but instead used a contract veterinarian, who
visited the facility for only about 45 minutes each week. Most diagnoses and treatments were
performed by an untrained, unqualified employee who often insisted that illness and injury were
"just part of life" for the animals at PLRS.

PLRS used living rabbits to grow ticks, in a procedure that subjected the rabbits to significant
pain, discomfort, and suffering even though non-animal methods of rearing ticks have been in
use for at least 14 years. PLRS workers applied more than 1,000 ticks to the shaved backs of
rabbits, and in some cases, a plastic capsule filled with ticks was attached to the shaved skin of
rabbits to allow the ticks to become engorged with blood.

PETA's evidence shows that PLRS failed to do the following:

1. Maintain a program of adequate veterinary care [9 C.F.R. §2.33 (b)]

2. Ensure that personnel conducting procedures were qualified to perform their duties [9 C.F.R.
§2.32(a)]
3. Provide training and instruction to personnel on humane methods of animal care, treatment,
and use [9 C.F.R. §2.32(b)]
4. Handle animals in a way that did not cause trauma, behavioral stress, physical harm, or
unnecessary discomfort [9 C.F.R. §§2.32(c)(1)(ii), 2.33(b)(4), 2.38(f)]
5. Remove dogs and cats from cages before using hoses to clean the enclosures [9 C.F.R. §3.11]
and avoid getting rabbits wet during cleaning [9 C.F.R. §3.56(a)(1)]
6. Ensure that the primary enclosures in which dogs, cats, and rabbits were housed were
adequately cleaned [9 C.F.R. §§3.11, 3.53(a)(2), 3.56(a)(1)]
7. Ensure safe and adequate housing for dogs and cats [9 C.F.R. §§3.1 (c)(1)(i)-(ii),
3.6(a)(2)(ii)-(iii), 3.6(c)(1)(i), 3.6(c)(2), 3.7]
8. Ensure safe transportation for cats and dogs [9 C.F.R. §§3.14(a)(1), 3.14(a)(3), 3.14(d)(1)]
9. Ensure that the feeding of dogs complied with the standards outlined in regulations [9 C.F.R.
§§3.9(a), 3.1(e)]
10. Provide exercise to dogs housed individually in cages [9 C.F.R. §3.8]
11. Ensure that rabbits had sufficient access to clean water [9 C.F.R. §§3.53(a)(3), 3.55]
12. Ensure that the transport of rabbits comported with regulations [9 C.F.R. §3.61(c)]
13. Use aseptic techniques when performing procedures on animals [9 C.F.R. §2.31(d)(1)(ix) and
§§2.32(c)(iii)-(iv)]

In addition, evidence seems to indicate that the PLRS Institutional Animal Care and Use
Committee failed to do the following:

1. Ensure that procedures involving animals would "avoid or minimize

discomfort, distress, and pain to the animals" [9 C.F.R. §2.31 (d)(1)(i)]
2. Ensure that principal investigators (PI) "considered alternatives to procedures
that may cause more than momentary or slight pain or distress to the animals"
[9 C.F.R. §2.31 (d)(1)(ii)]
3. Ensure that the "animals' living conditions [would] be appropriate for their
species … and contribute to their health and comfort" [9 C.F.R. §2.31
(d)(1)(vi)].

Based on the documentation compiled by PETA's investigator, there is reason to believe that the
problems identified in this complaint are far from comprehensive and represent a larger issue of
failed oversight and institutional noncompliance at PLRS. Indeed, PLRS employees knew the
general time period when the U.S. Department of Agriculture inspector would be making her
annual visit and they prepared for the visit, camouflaging facility deficiencies. Employees filled
out forms to report ailing animals to the attending veterinarian—who reportedly said that she
would not treat the animals—so that PLRS staff would be “covered” should the USDA inspector
inquire about the veterinary care given to the animals. When the inspector arrived for her once-a-
year visit of PLRS, which then housed more than 400 animals, she was in and out in two hours
and fifteen minutes.

The very serious nature of these allegations warrants immediate investigation by the USDA. The
actions of PLRS staff show a flagrant disregard for the law and for the animals for whom they
are responsible. Noncompliance at PLRS appears to have become business as usual—a state of
affairs that must not be allowed to continue.

We urge your office to treat this matter with gravity and respond swiftly to investigate and take
appropriate disciplinary action.

I look forward to hearing from you and am available to assist you in your investigation. I can be
reached at 410-889-1035 or AlkaC@peta.org.

Sincerely,

Alka Chandna, Ph.D.

Laboratory Oversight Specialist
Laboratory Investigations Department