The watchdog group Stop Animal Exploitation NOW! filed an official complaint with the U.S. Department of Agriculture Aug. 27 calling for a more complete investigation of the University’s past self-reported Animal Welfare Act violations, said Julia Orr, communications director of SAEN. If the USDA’s investigation finds the University guilty of negligence, it could exact a fine of up to $10,000 per offense, she added.

The Office of Lab Animal Welfare rarely exacts fines or punishes universities for self-reported offenses, Orr said.

The SAEN complaint highlights three instances over the past three years of University noncompliance with federal regulations requiring researchers to take proper care of the animals in their labs, according to a copy of the complaint letter sent to The Herald by SAEN. They reference letters self-reporting noncompliance or official USDA reports at the time of each of the events. The complaint also cites an earlier 2010 inspection report, in which the inspector discovered 11 violations in University labs, a finding that the report stated suggests a pattern of negligence.

This past July, a researcher moved several bats to separate living quarters for training without informing other workers in the lab of the venue change. The bats did not receive food over a weekend, and three bats subsequently died, according to a 2014 report by the USDA.

Another cited violation occurred when “one non-human primate did not have access to its usual daily water regimen for a period of approximately 48 hours” in September 2012, Vice President for Research Clyde Briant wrote on behalf of the University in a letter to the National Institute of Health’s Office of Lab Animal Welfare at the time of the violation.

The Animal Welfare Act states that non-human primates must be allowed unlimited access to water when experiments are not underway, according to a USDA inspection report.

Once the mistake was discovered and the animal was given water, his thirst and appetite were normal, Briant wrote, adding that a veterinarian examined the animal and determined he was “not harmed by the event.”

A similar incident occurred in 2010, when another non-human primate did not have access to water for 72 hours while a researcher was on vacation, according to the 2010 USDA inspection report.

The third violation that SAEN listed as “egregious” in their complaint occurred when University researchers commenced surgery on a different sheep than the surgery was intended for. After the researchers made an “initial incision” on the incorrect sheep, who was pregnant, they discovered their mistake and quickly provided post-operative care, Briant wrote in a separate self-reporting letter.

“The sheep was able to stand and eat within 20 minutes after surgery and was monitored closely thereafter,” Briant wrote.

Though the University self-reported each of the three instances, “there is a pattern of negligence, and we just don’t feel like it’s good enough to just give them a slap on the wrist,” Orr said, adding that “It’s happening again and again.”

Briant’s letters self-reporting the violations each included a set of actions the University would implement to ensure that similar violations would not occur in the future. The proposed corrective actions included increasing training for laboratory personnel and changing protocol to include procedures such as extra checks of surgical tags on animals.

“Brown University is committed to the highest standards of animal health and safety in research and works closely with internal committees and federal regulators to ensure that researchers follow strict policies, procedures and protocols,” wrote Marisa Quinn, vice president for public affairs and University relations, in an email to The Herald, adding that the University worked with the proper authorities promptly after each of the incidents.

“Obviously I don’t agree with animal experiments … but there are definitely huge steps we can take to mitigate these disasters,” Orr said, adding that she believes many animal experiments could be replaced with computer simulations. The USDA should also increase random inspections in labs, and lab workers should be encouraged to report negligence themselves, she added.

Additionally, the poor quality of animal care in some laboratories decreases the credibility of the results published based on animals’ behaviors, as stress can induce unusual psychological and physiological responses in the test subjects, said Michael Budkie, founder and executive director of SAEN.

The USDA usually launches inspections when SAEN files complaints, Orr said. They begin with a follow-up inspection of the laboratories, which usually occurs within 60 to 90 days of filing the complaint, Budkie said. Further investigations may occur depending on the findings, and the whole litigation process could take as long as three years, he added.

“I would expect that Brown would receive either a fine or at the very least an official warning from the USDA,” Budkie said.