and the Home Office Exposed
scathing exposé of a cruel vet and cosmetic testing under the vivisectors
Laboratories: An Animals Scientific Procedures Inspectorate Report –
A damning official
report on the inner workings of the Wickham Laboratories, has laid the
final nail in the coffin of botox testing on animals in the UK. Self appointed,
supervising lab vet, William Bamber Cartmell who is also the Managing
Director of this unpleasant place is accused by his peers of a dereliction
of duty, an absence of leadership and of a routine failure to protect
hundreds of thousands of animals from unnecessary suffering. The report
also more significantly exposes as an utterly worthless piece of legislation
the Animals (Scientific Procedures) Act, 1986 (ASPA).
That animals are badly
cared for is a given for most observers of this dark cruel world - after
all their demise is usually the goal - but this scathing report has been
reached by the very body which serves to gives credibility to process
of inflicting bad things on caged animals. The self appointed, self serving
Inspectorate consisting of former vivisectors and pharmaceutical industry
men was born of those with an interest in the continuance of vivisection.
It serves best to confuse public perception.
This shocking report
was instigated following the latest in a stream of covert incursions into
the Wickham labs in Hampshire over many years, each of which have revealed
the wasteful, cruel and unnecessary suffering of animals used to test
products. During 2003 I was working to expose the inner workings of the
wacky Wickham labs and the cruel botox experiments they specialise in
and was eventually forced to break in to reveal their nasty secret. I
was therefore especially eager to digest the unparalleled findings of
the ASPA Inspectorate released this week. This is not an independent organisation
by any stretch of the imagination and it has shamefully struggled to control
the Wickham vivisectors over many years with it's halfhearted approach.
For this reason there has never been an ASPA led prosecution for breach
of the pathetic rules 'protecting' lab animals. Not one since 1986. Not
a single prosecution for the 70 million plus animals tortured in that
time by thousands of vivisectors in hundreds of UK labs. None! How can
this be an accident?
Wickham is a government
licenced contract testing laboratory. Its major animal contract is with
Ipsen Biopharm who manufacture Dysport, an injectable botox product. For
the past 10 or 15 years Wickham has poisoned upwards of 90,000 animals
each year to test this toxin. Botulinum Toxin is otherwise known as botox
which is of course used for cosmetic purposes in the vast majority of
consumers. Since we are told that cosmetic testing has been banned in
the UK we might wonder how is this possible? Well here's the crux.
The agreed medical
claim in the UK for the botulinum toxin product Dysport is:
improvement in moderate to severe glabellar lines seen at frown, in adult
patients under 65 years of age, when the severity of these lines has an
important psychological impact on the patient”.
Glabellar lines are
the vertical creases between the eyebrows, created in some of us by too
The Medicines &
Healthcare Regulatory Agency (MHRA) oversees the use of botulinum toxin
in the UK. They agree that injecting botox causes a cosmetic change in
the users appearance, but propose that it is the psychological condition
of the consumer which is massaged by the injections as opposed to the
quest for perfection.
It's impossible to get statistics for the number of sufferers of glabellar
lines who are in clinical need of botox injections to improve their psychological
state, any more than it is to get numbers for those who have botox injected
by beauticians for exactly the same reason. 90,000 tortured animals is
unacceptable however which way.
If the logical gymnastics
of the 'medical' assessment haven't done enough to secure the slow and
painful death of tens of thousands of animals then we have the new and
improved EU definition of a cosmetic which the Home Office relies upon
to exclude botox from the principle of a cosmetic test ban. Additionally
the HO absolves itself of responsibility for the liberal use of this stuff
for cosmetic purposes, once it has been through their testing programmes
and passed as safe in dead mice, because it then suddenly 'falls' “outside
the jurisdiction of the Home Office.” Smashin.
According to the new
EU doctrine a cosmetic is now:
substance or preparation intended for placing in contact with the various
external parts of the human body (epidermis, hair system, nails, lips
and external genital organs) or with the teeth and mucous membranes of
the oral cavity with a view exclusively or principally to cleaning them,
perfuming them or protecting them in order to keep them in good condition,
change their appearance or correct body odours." (From Article
1(1) of Directive 76/768). http://eurlex.europa.eu/LexUriServ/LexUriServ.douri=CONSLEG:1976L0768:20080424:en:PDF
All of the definitions
I can find agree with my general perception of a cosmetic as: “a
powder, lotion, lipstick, rouge, or other preparation for beautifying
the face, skin, hair, nails, etc.” Botox is a preparation used
Such is the absurdity
of this situation that, not only can people inject a crudely tested killer
toxin containing human blood albumin, which documents recovered from Wickham
in 2003 show carries the risk of transmitting viral infection, http://www.fromdusktildawn.org.uk/Keith%27s%20view/botox_and_dead_bodies.html
into unsuspecting customers, but we seem to have redefined the widespread
use of botox as a cosmetic and replaced it with whatever it is one applies
to ones external genital organs in order to keep them in good condition!
This is a rather moot
point anyway as botox is being injected into large numbers of people and
the animals being used to test it tell us that it is not safe.
The report makes recommendations
that the self appointed vet in charge of poisoning so many animals (WBCartmell)
and his staff be prosecuted for inflicting “adverse animal welfare
burdens” on test animals and for “routinely”
causing unnecessary suffering to them. Cartmell and his wife own the laboratories
and are renowned for their chilling lack of empathy.
Internal lab notes
record the number of animals left to die “in extremis”,
in other words to the torturous end of the crude LD50 test and when compared
with the animals recorded' as humanely sacrificed' before succumbing to
the botox we find that between 80% and 100% are left to die slowly.
Wickham's animal technicians are happy to report that they failed to suffocate
by gas or break the neck of a single one of the dying animals in their
tests, instead opting to observe each one be consumed by the toxin. By
allowing this wholesale suffocation by toxin Wickham workers broke the
rules and it is anticipated that Cartmelll and his appointed Named Animal
Care and Welfare Officer (NACWO) with 17 years experience as an animal
technician with this sick business be prosecuted for their crimes.
Also highlighted in
this report is a “conflict of interest” in the messy dealings
of the company MD & chief vet. This peer acknowledged “cause
for concern” regarding this cancerous operation was first highlighted
in the 1992 Home Office report but has been allowed to grow for a further
capacity at Wickham includes provision of veterinary care to the animals,
giving advice and training to scientists, licensees and others using the
animals under him; he is a majority shareholder and co-owner (with his
wife) and Managing Director and owner - in his sick - mind of the animals
used in experiments.
were made that the position, performance and independence of the Named
Veterinary Surgeon (NVS) at Wickham (Cartmell), a major shareholder in
the company and, as managing director of the company, the employer of
the certificate of designation holder was untenable; these allegations
have in part been substantiated with respect to the incomplete performance
of the duties expected of a NVS. Allegations as to a perceived conflict
of interest among these roles are recommended for further examination.”
The absolute failings
of the 1986 ASPA, which was meant to prevent unnecessary suffering and
identify breaches with these mostly unannounced inspections, has always
failed to do so and must be abandoned in light of this report. Alerted
once again by an animal rights investigation in 1991 the Inspectorate
repeatedly failed to do their duty. It is of course expected they will
miss so much given their history of failure but such expectations are
just not acceptable.
In the five years
between 2005 and 2009, 25 unannounced inspections took place at Wickham.
That's five per year, each inspection lasting an average of one hour 50
minutes. The Wickham vivisection operation “comprises 12 animal
holding rooms and three procedure rooms (including the pyrogen suite where
the rabbits are held as a procedure room)”. While not all animal
holding rooms are occupied on all occasions there are still hundreds of
live and dying animals to inspect on any given day, 11 workers licenced
to vivisect and a great many files and records of numbers, dates and times
and so on to inspect. I know very well how long this can take because
I did my own detailed inspection of their animals and records one night
in December 2003. You can read the full story here http://www.fromdusktildawn.org.uk/Keith%27s%20view/botox_and_dead_bodies.html
The 2009 inspectorate
of oversight is considered appropriate for an Establishment of this size”
but goes on to admit that it isn't appropriate at all because even with
this oversight, “not
all issues raised by Inspectors were followed through to completion by
the duty holders at Wickham.”
And then the confessions
pour out with the remarkable admission that: “it
is not possible for Inspectors to observe all procedures and systems of
work (such as killing by Schedule I methods) at each Establishment...
at a single Inspection”.
Oh well, it probably
wouldn't make much difference anyway, as we see that... “over the
course of time, all significant stages of work conducted at Wickham Laboratories
were inspected during ASPI Inspections.”
So it took from 1986
to 2009 – a full 23 years - to file an incomplete inspection of
one small vivisection facility and still do nothing about the widespread
cruelty, abuse and neglect taking place there daily. There is something
very wrong here.
The report gives us
great incite into how this lab had been failing to follow even the most
rudimentary principles of animal care and scientific study for many years.
Back in 1992/93 the lab was the subject of 'formal actions' for non compliance
over the very same issues and involving the same individuals. Back then
“Several members of staff, including the holder of the Certificate
of Designation were warned as to future conduct and one employee was removed
as NACWO and had his Personal Licence revoked.”
In the intervening
Inspectors have maintained a regular programme of inspections and raised
issues of compliance and best practice with staff at the Establishment
in the areas of study design, application of humane end points, environmental
issues and development of a valid alternative to the mouse bioassay. However,
when this Establishment transferred between Inspectors, the handover process
varied and follow up was not always documented as being completed on issues
raised by the outgoing Inspector.”
failure to comply with most of the recommendations of previous inspectors
the latest report must at least hint that “consideration...
be given to the appropriate level of any sanctions now imposed under the
Animals (Scientific Procedures) Act, 1986”. This translates
to 'think seriously about properly punishing these repeat offenders or
we will look more ridiculous than we already do.'
As we can see under
the current Act it can take many years to find even significant faults
in experiments which have inevitably led to skewed results and unnecessary
suffering, because not enough time is spent looking. One of the more recent
inspections of Wickham lasted a whole one hour 15 minutes with the average
taking less than two hours from start to finish. If the will is not there
to monitor this grisly process with any conviction, especially at a lab
that is known to be flouting the rules of engagement with these gentle
creatures, then how is the paying public to believe that animals are being
protected anywhere that they are used in this way or trust the methods
being used to test these products?
Alerted by an outside
agency – the BUAV – Home Office Inspectors identified a significant
number of areas for improvement at Wickham, including some very basic
ones which should have been in place from the beginning, like not using
the corridor floors to kill used mice using ball point pens and “ensuring
the establishment is adequately equipped to euthanase animals efficiently
and humanely using carbon dioxide.” An animal killing lab that
can't even kill animals properly! As the findings record “Training
of new staff may be too hurried and appears directed to achieving a ‘sign
off’ for Good Laboratory Practice (GLP) requirements.”
In other words even Wickham had figured it out: all that is necessary
to avoid conflict with the law which the public is led to believe protects
lab animals, is to tick some boxes.
Somehow they still
messed it up!
has been substantiated with respect to poor practices for both killing
by cervical dislocation and by use of exposure to rising concentrations
of carbon dioxide”. Wickham blame their failure to resolve
these problems in 17 years on a “lack of time”.
It goes on to accuse
Wickham of being “inconsistent” and “at
times incompetent” in the way it deals with the animals they
have crippled and concludes that “the end point continue to be subjective,
and since the scientific end point is survival to 72 or 96 hours there
is reluctance to kill animals too early to avoid skewing the data.”
I would use far stronger language than incompetent but this painfully
polite critique is a devastating indictment of the Wickham operation,
William Cartmell and the especially the utterly useless Animal Scientific
Procedures Act which Wickham use to give credibility to their behaviour.
This pack of lies can be found on Wickham's website in 2010 alongside
a cosy image of some mice . Compare this direct quote with what anyone
who has inspected Wickham has to say:
The ASPA report falls
short of accepting the BUAV claim “In respect of the allegation
that the licensing of the mouse bioassay median lethal dose (LD50) test
for routine botulinum toxin batch testing should not have been allowed
– for which the BUAV believes there are existing more humane alternatives
available”, but goes on to immediately qualify that, “The
authorised end point to alleviate suffering in these assays is observation
and appropriate intervention by humane killing.”
The report then goes
on to acknowledge that appropriate intervention is not taking place and
at best is subject to the motivation of the badly trained duty technician.
The animals feature
greatly in all this and that is crucial, but the point of it all we are
assured are the results they generate. Yet the way the animals are treated
reflects the results and this is very important too.
From the report:
made by Wickham staff repeatedly indicate that the prevailing advice from
the PPL holder and senior technicians was to positively encourage staff
to err on the side of ‘not choosing euthanasia’ for mice on
study so that ‘results are not biased’ by such mortality data”.
Blimey! The test results
are invalidated by this shoddy approach!
A big blot on this
report in the fixation with piling emphasis on the HO to redefine the
term cosmetic, in order to prevent “confusion”. This
is flippant particularly in light of the devastating failings of the Act
Also raised in the
report is the lack of accessible water for the dying, increasingly paralysed
mice who can no longer reach the regular water drip in their cages. Then
there's the basic idea of training new staff to inject mice using dead
animals prior to letting them loose on live ones. And a need for improvements
in 'environmental enrichment', which translates into adding more than
a cheap scattering of sawdust at the bottom of the tiny cages.
With respect to the
main purpose of Wickham's purpose for being – the botox testing
programmes - there are issues with the “timing and conduct of clinical
observations”, the need to stop using animals in favour of something
else and a “study management to minimise possible operator bias”.
That says spend more time looking at all of the struggling mice during
hourly checks rather than just glancing at those injected with the greatest
amount of poison and so potentially closer to death.
The point the inspector
makes here is accidentally commendable: each animal is an individual and
therefore the written rules on when one is expected to suffer and die
are meaningless. If this were a conscious statement as opposed to paying
attention to the rule of the law then this gentleman wouldn't climb high
up this career ladder. Nevertheless the problem he highlights will always
be a distraction as long as this corrupted system is in place. The animals
are destined to die horribly whoever decides – as long as we interfere
- and human health will be poorer because of it.
The Inspectorate should
also be commended for referring to the need to replace the animal tests
at Wickham. Disappointingly there is no direct recommendation to do that,
which is shameful.
made to take formal action against the abusers, to fiddle with the word
“cosmetic”, and to break more necks and create more
mice gassing than allow 'end point' demise. This is unpalatable advice
for the conscious mind and clearly meaningful change will not come as
long as the same mentality that created these problems is left in place
to fix them.
Then there are the
rabbits. The Animals (Scientific Procedures) Act, 1986 was meant to protect
lab animals from unnecessary suffering but, as predicted by conspiracy
theorists and extremists at the time, the Vivisector's Charter did precisely
the opposite. One of the backwards steps taken upon its implementation
into law was that test animals could be used in repeat experiments. Of
course they always had been but by 1986 it became legit. This backward
step of course pleased the psychopaths with rabbits in cages as it cut
their costs and increased the trauma they could inflicted on their animal
Wickham record “approximately
1,800 regulated procedures on rabbits annually” in 2009. Approximately?
Surely this information is exact in the scientific study? Of which “a
majority are classified as authorised re-use”. So grateful we all
are that Wickham don't torture 1,800 rabbits each year for essential medical
research eh? Well the rabbits they do use are restrained is stocks so
they cannot move and are injected in the ear with test products.
They have a probe
inserted in their anus for the duration of the experiment.
Each rabbit can be
reused up to 45 times each year. Lab records show that the oldest remaining
rabbit at Wickham was put through this 28 times in 2008 and a further
29 times to October 2009. Then shoved back into their barren metal cage.
rabbit pyrogen test authorises withdrawal of food overnight – current
and recorded practice at Wickham Laboratories is for this to be undertaken
by staff on night shift work. The rabbits will be without food for a variable
period of typically 10 hours prior to commencement of the test. After
acclimatisation animals are restrained in purpose made stocks so that
continual recordings of rectal temperatures can be made via electronic
thermometers. Tests may run
for 6 – 8 hours on any single occasion.”
are not re-used if the results of the test indicate a pyrogenic response,
or if certain classes of compound have been tested; e.g. cytotoxic agents,
some biological materials (which may produce sensitisation). The PPL authorises
reuse on up to approximately 45 occasions each year, provided that the
animals are healthy, the ear veins have healed and that veterinary certification
has been undertaken. A mandatory six day interval between any re-use is
also set in the Licence for all animals being re-used.”
As the man in charge
of this debacle wasn't bothering to inspect the health and condition of
the rabbits, the results of tests on them therefore become invalidated!
This is serious.
no examination by the NVS of individual rabbits prior to them being signed-on
as suitable for re-use in the rabbit pyrogen tests. This system of work
is a further example of the NVS appearing to incompletely discharge his
expected responsibilities in full.”
in stocks at Wickham. (BUAV)
cutting edge of modern science? Just how advanced is it to restrain an
animal in this way for eight hours, shove a temperature probe up its arse
and inject a some test material into its blodd stream via one of the marginal
veins in its ear?
injection (via ear vein) of the test material is not intended to produce
any adverse or toxic effects, and the discomfort of restraint with a rectal
thermometer inserted is regarded by ASPI as a mild procedure. A normal
response to ongoing or moderate stress in rabbits would be to raise metabolic
rate and hence rectal temperature. This does not occur in animals which
are appropriately trained to periods of restraint in purpose-built stocks.
Subject to veterinary certification (by the NVS), animals which have completed
pyrogen tests may be re-used in subsequent pyrogen tests.”
Following this logic
the results of ALL the tests at Wickham are corrupted because the NVS
was not doing his job.
The ASPA Inspectorate
focuses on semantics like “the need for a regime for increased
exercise provisions and the need for a sustained programme of improvement
in the fabric of the facilities.”
I wonder how these
people can sleep at night. This is what the undercover investigator wrote
in her diary
April 1st 2009:
heart-wrenching scream sent me flying down the corridor to the pyrogen
room. I couldn’t believe a rabbit could make such a sound. I saw
a member of staff struggling to re-insert a temperature probe into the
rabbit’s anus. The probe had fallen out and the poor rabbit was
clearly in pain.”
June 11 2009
of staff had problems with pyrogen injecting today. Some rabbits suffered
repeated attempts as she became more and more exasperated. One rabbit
called Hamish kicked and struggled - this was his first test. The person
cursed at them, calling one a 'disgrace' and another 'stupid.' To one
rabbit who ended up with punctured ears she said, 'It’s your own
stupid fault. I told you you were going to end up with earrings.' The
whole time music was blaring in the background.”
Those poor animals.
This is chaotic!
would often sniff and groom each other (BUAV)
In these intervening
years between investigations few of the issues raised by Inspectors were
addressed by staff and management at Wickham as they continued to arrogantly
flout the rules. All these rules are window dressing anyway in my view
and there should be no animals used period, but there are rules and as
these people are so willing to flout them with indifference so they should
be punished to the full force of the law as any criminal using violence
is. Their licence to vivisect should be withdrawn immediately. No more
chances. These people don't get it! And besides, there are alternatives,
as referenced in this very report:
the mouse LD50 assay is recommended for use by national and international
regulatory authorities as the primary assay method for use prior to marketing,
a number of alternative methods and approaches which minimise the distress
caused to test animals, use more humane endpoints, or which could replace
their use, have been developed and adopted.” http://www.nc3rs.org.uk/downloaddoc.asp?id=853&page=1023&skin=0
Ipsen is the weak
link in this chain and the mainstay of the Wickham vivisection operation.
They have a thing about ethics:
committed to applying the highest ethical standard... is also committed
to apply the highest ethical standard in all its business operations.
Behaving in an ethical manner includes implementing principles of integrity,
honesty and fairness and complying with applicable laws and regulations.
Consequently, Ipsen expects its employees to behave ethically in the conduct
of Ipsen's activities and more generally in their daily professional activities”
Wickham is employed to torture to death 89,000 animals each year and in
doing so breaks the laws of the land and higher moral laws. This is the
opposite of ethical.
01753 627700 190 Bath Road, Slough SL1 3XE
01978 661181 Unit 9 Ash Road, Wrexham LL13 9UF
We must be minded
of the reaction we offer to this official confirmation of what we already
knew. We are good at reacting. Protesting en masse at the trial of a couple
of the Wickham vivisectors may give some small satisfaction, but as with
calling for more lab inspectors or some new legislation promising what
the 1986 Act didn't deliver it will take us no further forward. Immediately
we want what we have always wanted and that's a fully independent public
inquiry into every aspect of animal research. We want Wickham's licence
revoked and we want the ASPA to be scrapped. We wont get what we want
because we are dealing with a system that thrives on precisely this kind
of repugnant moral contradiction. We should also be conscious of the fact
that 'independent public inquiries' are also the opposite of what they
are meant to be and are neither public nor independent. That said we should
never stop raising the issues and challenging the practice.
It is all to play
for and the ball is in our court. We are smart enough to know that it's
the people who change things for the better not governments. Governments
do the opposite.
Ultimately we have
to be bold and consider that it is the system at fault and that no amount
of tweaking or regulating it with stricter rules or reacting to the next
horror story with further calls for more tweaking will change anything.
It was Albert Einstein
who noted that a problem cannot be solved by the same level of consciousness
that created it.
Keith Mann December