October 26, 2023

Deborah Kearse
Director
Division of Program Integrity
Office of Management Assessment
National Institutes of Health

Re: DPI Case Number 2021-017

Via e-mail: [email protected]

Dear Director Kearse:

Thank you in advance for your time. I’m writing on behalf of People
for the Ethical Treatment of Animals—PETA entities have more than 9
million members and supporters globally—to share additional
disturbing information to supplement our complaint dated February 17,
2021,1 which the Division of Program Integrity (DPI) assigned case
number 2021-017, and our related complaints dated November 18,
2021,2 and March 14, 2022.3

Based on the latest evidence presented below and the evidence

described in our former complaints, cumulatively over $9 million
in taxpayer money and at least 25,000 animals’ lives were
apparently wasted by institutions funded by the National Institutes
of Health (NIH) during their COVID-19 pandemic operations. We
urge your office to investigate and, if noncompliance is
corroborated, ensure that experimenters funded by NIH adhere to
federal mandates to reduce or replace the use of animals in
experiments and stop wasting public resources to support activities
related to the acquisition, breeding, confinement, maintenance,
repopulation, and use in experiments of animals deemed by
experimenters to be “extraneous,” “nonessential,” or “noncritical”
or described using similar terminology.

1
PETA. Letter to NIH OMA. February 17, 2021. Accessed January 4, 2023.
https://www.peta.org/wp-content/uploads/2021/02/2021-02-
17_Follow_up_letter_to_OMA_HHS.pdf
2
PETA. Letter to NIH OMA/DPI. November 18, 2021. Accessed January 4, 2023.
https://www.peta.org/wp-content/uploads/2022/03/2021-11-18_Complaint-
update_NIH-OMA_DPI.pdf
3
PETA. Letter to NIH OMA. March 14, 2022. Accessed January 4, 2023.
https://www.peta.org/wp-content/uploads/2023/01/2022-03-14-nih-oma-dpi-
complaint-update.pdf
History of PETA’s Complaints Regarding Euthanasia of Animals Deemed
Extraneous
On June 15, 2020, we submitted a detailed complaint to the U.S. Department of Health
and Human Services Office of Inspector General (HHS-OIG) regarding the troubling
problem of universities across the country that deemed many of their NIH-funded
experiments and the animals used in them “extraneous” or described them using similar
terminology in response to the COVID-19 pandemic, resulting in the euthanasia of such
animals confined to laboratories and a massive waste of taxpayer funds.4

On June 23, 2020, we were notified by HHS-OIG Public Affairs that our complaint had
been forwarded to the then-director of NIH’s Office of Management Assessment (OMA),
Michael D. Shannon,5 to which we received no reply. On February 17, 2021, we
submitted a new complaint6 addressed to Acting Director of OMA Meredith Stein, CPA,
which was assigned case number 2021-017 by NIH’s DPI on February 17, 2021. We then
acquired additional evidence that animals were being deemed “extraneous” and
euthanized in NIH-funded experiments, which we detailed in letters to you on November
18, 2021,7 and on March 14, 2022,8 to supplement the aforementioned complaints.

New Information That Supplements Our Complaints

Experimenters affiliated with the NIH-funded institutions mentioned below have
acknowledged that euthanasia of animals deemed extraneous to the experiments occurred
in response to the COVID-19 pandemic, similar to the numerous institutions we had
detailed in our original and supplementary complaints:

• University of Georgia
Experimenter Wendy Watford of the University of Georgia (UGA) conducted
protocols funded by the National Institute of Allergy and Infectious Diseases titled
“Regulation of Mucosal Immunity to Respiratory Viruses by Tpl2” (NIH project
number 5R21AI147003-02),9 and “Defining the Mechanisms by Which Placenta-
Specific 8 (Plac8) Facilitates CD8 Memory Formation” (NIH project number

4
PETA. Request to HHS OIG regarding COVID-19 contingency plans at U.S. universities. June 15, 2020.
Accessed March 10, 2022. https://www.peta.org/wp-content/uploads/2020/06/20-06-15-Request-to-HHS-
OIG-regarding-COVID-19-contingency-plans-at-US-universities.pdf
5
HHS-OIG Public Affairs RE: RE: For HHS OIG, from PETA—re request for investigation into apparent
waste at NIH and failure to reduce/replace animal use. June 23, 2020. Accessed March 10, 2022.
https://www.peta.org/wp-content/uploads/2021/02/2020-06-23_For-HHS-OIG-from-PETA-re-request-for-
investigation.pdf
6
PETA. Letter to NIH OMA. February 17, 2021. Accessed March 10, 2022. https://www.peta.org/wp-
content/uploads/2021/02/2021-02-17_Follow_up_letter_to_OMA_HHS.pdf
7
PETA. Complaint update. November 18, 2021. Accessed January 27, 2023. https://www.peta.org/wp-
content/uploads/2022/02/2021-11-18_Complaint-update_NIH-OMA_DPI.pdf
8
PETA. Complaint update. March 14, 2022. Accessed January 27, 2023. https://www.peta.org/wp-
content/uploads/2023/01/2022-03-14-nih-oma-dpi-complaint-update.pdf
9
NIH. RePORTER. Regulation of mucosal immunity to respiratory viruses by Tpl2. Accessed July 5, 2022.
https://reporter.nih.gov/search/x60VgnBNK0K0u8ALbRr0BQ/project-details/9926820
 5R21AI138027-02),10 both of which have received $188,750 each in taxpayer
funding. Per its COVID-19 response plan, UGA directed research staff to plan to
“[c]ull animals not needed.”11 As a result, mice assigned to Watford’s protocols were
euthanized. This was verified in a set of records from UGA12,13 in response to PETA’s
public records request.14 The euthanasia of these animals seemingly contradicts the
statement provided by UGA’s vice president for research, David Lee, who claimed
that no animals who were to be experimented on were killed at that point during the
pandemic.15

• West Virginia University

On March 18, 2020, the Research Office of West Virginia University (WVU) issued a
notification addressing the “Cessation of On-Site Research,” asking that
experimenters “stop performing on-site research” and “tend to animals/cell lines.” An
additional directive instructed biomedical experimenters that “in the event that
depopulation procedures need to be put in place in the future, researchers should
identify … specific animals [who] are critical to their research.”16 In alignment with
this directive, it’s apparent that animals deemed extraneous or unnecessary were
killed to reduce animal populations during the pandemic operations. In records
obtained in response to PETA’s records request,17 a draft of a document titled
“Stabilization of Mouse and Rat Breeding Colonies During a Prolonged Disaster or
Furlough” states, “[B]reeding may be allowed to continue and the young weaned as
usual until available space or personnel become a limited resource. Once that point is
reached, un-weaned animals, determined not to be critical, shall be humanely
euthanized …. Subsequently, new neonates < 5 days of age will continue to be
euthanized until the end of the disaster or furlough period”18 [emphasis added].

10
NIH. RePORTER. Defining the mechanisms by which Placenta-specific 8 (Plac8) facilitates CD8
memory formation. Accessed July 5, 2022.
https://reporter.nih.gov/search/x60VgnBNK0K0u8ALbRr0BQ/project-details/9833488
11
UGA. UGA University Research Animal Resources (URAR) and Researcher Pandemic Service
Reduction Plan. March 13, 2020. Accessed July 5, 2022.
https://research.uga.edu/docs/units/urar/UGA_URAR_service_reduction_plan_COVID-19_20200323.pdf
12
UGA. Responsive records. PETA.org. Accessed July 5, 2022. https://www.peta.org/wp-
content/uploads/2022/07/Watford-1_Redacted.pdf
13
UGA. Responsive records. PETA.org. Accessed July 5, 2022. https://www.peta.org/wp-
content/uploads/2022/07/Watford-2_Redacted.pdf
14
Flaugher K. Records Request. PETA.org. April 26, 2022. Accessed July 5, 2022.
https://www.peta.org/wp-content/uploads/2022/07/2022-04-26-university-of-georgia-request.pdf
15
Payne S. OPINION: UGA researchers need humane COVID-19 plan for animals. RedAndBlack.com.
May 27, 2020. Accessed July 5, 2022. https://www.redandblack.com/opinion/opinion-uga-researchers-
need-humane-covid-19-plan-for-animals/article_3099a688-9ffd-11ea-9490-7b72af6f715c.html
16
WVU. Research Office. Info letter. March 18, 2020. Accessed January 27, 2023.
https://www.peta.org/wp-content/uploads/2023/01/wvu-research-office-letter.pdf
17
Flaugher K. Records request. PETA.org. Accessed January 27, 2023. https://www.peta.org/wp-
content/uploads/2023/01/peta-records-request-wvu.pdf
18
WVU. Stabilization of mouse and rat breeding colonies during a prolonged disaster or furlough.
PETA.org. Accessed September 1, 2023. https://www.peta.org/wp-content/uploads/2023/01/Stabilization-
of-Mouse-and-Rat-Breeding-Colonies.pdf
 A March 17, 2020, e-mail with the subject line “Clarification—FROM DIRECTOR
OF OLAR/ATTENDING VETERINARIAN” stated, “Please assess your animal
colonies and remove any extra animals … . [Office of Lab Animal Resources] OLAR
has already had requests to maintain researchers’ colonies because labs are shutting
down”19 [emphasis added].

An e-mail on March 19, 2020, with the subject line “Lindsey lab mice” stated, “Dr.
Lindsey (Orthopaedics) [sic] has 13 mice in room V-308 [3 mice] & V-309 [10
mice]. He has advised that we can euthanize all of them”20 [emphasis added]. A
representative from experimenter Brock Lindsey’s laboratory also submitted an
“Elective Euthanasia Form” for two cages of mice.21

WVU’s “Health Sciences Center Animal Facility Training” document states, “All
cages with animals to be euthanized must be labeled by laboratory personnel with
blue cage cards, available from the OLAR staff …. OLAR Staff will euthanize only
the animals indicated.”22 Furthermore, experimenter Heath Damon signed an
“Elective Euthanasia Form” on March 17, 2020, to eliminate “6 to 8 cages” of mice.23
These animals were likely deemed extraneous due to circumstances imposed by the
COVID-19 pandemic.

• Pennsylvania State University

In an American Association for Laboratory Animal Science (AALAS) thread on
April 10, 2020, titled “What is it like working in high COVID-19 areas,”
Pennsylvania State University staffer Michelle Irish stated, “I am gutted by the mass
euthanasia I’ve both witnessed and been directed to do.”24 This statement seemingly
confirms that animals deemed extraneous were euthanized at the institution as a result
of the COVID-19 pandemic.

• Tulane University
In an AALAS thread on April 10, 2020, titled “What is it like working in high
COVID-19 areas,” Tulane University staff member Amy Pierce stated, “We have not
required any researchers to euthanize their animals but some have to keep their
colonies manageable while they are working remotely.”25 This quote suggests that

19
WVU. E-mail: FROM DIRECTOR OF OLAR/ATTENDING VETERINARIAN. PETA.org. Accessed
January 27, 2023. https://www.peta.org/wp-content/uploads/2023/01/FROM-DIRECTOR-OF-
OLAR_ATTENDING-VETERINARIAN.pdf
20
WVU. E-mail: Lindsey lab mice. PETA.org. Accessed January 27, 2023. https://www.peta.org/wp-
content/uploads/2023/01/lindsey-lab-mice-email.pdf
21
WVU. Elective euthanasia form. PETA.org. Accessed January 27, 2023. https://www.peta.org/wp-
content/uploads/2023/01/lindsey-elective-euthanasia-form.pdf
22
WVU. OLAR. Health Sciences Center Animal Facility Training. PETA.org. Accessed January 27, 2023.
https://www.peta.org/wp-content/uploads/2023/01/Health-Sciences-Center-Animal-Facility-Training.pdf
23
WVU. Elective euthanasia form. PETA.org. Accessed January 27, 2023. https://www.peta.org/wp-
content/uploads/2023/01/damron-elective-euthanasia-form.pdf
24
AALAS thread. “What is it like working in high COVID-19 areas.” PETA.org. Accessed January 27,
2023. https://www.peta.org/wp-content/uploads/2023/01/aalas-psu.pdf
25
AALAS thread. “What is it like working in high COVID-19 areas.” PETA.org. Accessed January 27,
2023. https://www.peta.org/wp-content/uploads/2023/01/aalas-tulane.pdf
 animals may have been euthanized at the institution at the discretion of individual
experimenters as a result of the COVID-19 pandemic.

• Montana State University

An article published by Sentient Media on May 29, 2020,26 makes reference to
Montana State University (MSU) records that include directives to euthanize mouse
colonies and “Animal Resources Center (ARC) Daily Animal Health Information”
documents related to guinea pigs, stating, “[A]ll animals euthanized. Room empty.”27
Furthermore, a set of responsive public records that we received from another
institution includes a March 31, 2020, e-mail that mentions that only 15% to 20% of
MSU’s laboratories were approved as “essential” that are continuing in a “much
reduced” manner28—indicating that the remaining laboratories at MSU were not
approved as “essential” and may have reduced animal populations in response to
circumstances resulting from the COVID-19 pandemic. When this information was
presented to MSU, it responded by stating, “All labs conducting animal research were
covered in the ‘15–20%’ that were deemed to be essential.” The university proceeded
to claim that it “cannot speak for the Sentient Media author’s interpretation of events,
but MSU Animal Resource Center records reflect that the euthanizing of animals
during that time period were for reasons other than COVID-19 impacts, such as the
conclusion of an experiment.”29 However, it is statistically unlikely that all ongoing
experiments on animals were considered essential and comprised the 15% to 20% of
essential research on campus, given the university directive on March 26, 2020, to
transition to Level 2 operations, which entailed “pausing research when possible, or
developing a plan for modified operations when research is deemed essential per
guidelines.”30

• University of Wisconsin–Milwaukee
According to the University of Wisconsin–Milwaukee’s “Emergency Operations
Center COVID-19 Operations Planning Report,” dated June 14, 2020, campus
operations were transitioned to more restrictive remote work. As such, plans were in
place for restarting campus operations, including research.31 In an AALAS thread on
March 18, 2020, with the subject line “Animal care during shelter in place
restrictions,” UW-Milwaukee’s Jennifer Nemke asked, “Are staff still being allowed
to access the facility to care for the animals? Are others of you planning for this

26
Oliver L. The sac rack: Death’s waiting room for animals in labs. Sentient Media. May 29, 2020.
Accessed January 27, 2023. https://sentientmedia.org/the-sac-rack-deaths-waiting-room-for-animals-in-
labs/
27
ARLO. MSU. Accessed January 27, 2023. https://arlo.riseforanimals.org/entity/montana-state-university-
2034/records/4971
28
Carter J. E-mail re essential labs at MSU. PETA.org. Accessed January 27, 2022.
https://www.peta.org/wp-content/uploads/2023/07/MSU-essential-labs-email.pdf
29
Peterson K. Public records request. May 13, 2022. PETA.org. Accessed January 27, 2023.
https://www.peta.org/wp-content/uploads/2023/01/msu-email-no-animals-euthanized.pdf
30
MSU. Archived messages and updates. Accessed July 31, 2023.
https://www.montana.edu/health/coronavirus/archived-comms.html#email29
31
UWM Emergency Operations Center. COVID-19 Operations Planning Report. June 14, 2020. Accessed
January 27, 2023. https://uwm.edu/coronavirus/wp-content/uploads/sites/515/2020/06/UWM-Emergency-
Operations-Center-Report_Final.pdf
 scenario? Aside from sleeping on a cot in my office or euthanizing all of the animals,
are there other options”32 [emphasis added].

Furthermore, in response to PETA’s public records request for records related to

animals who were euthanized due to the restrictions imposed during pandemic
operations,33 university staff confirmed that “[t]he [Institutional Review Board] IRB
office indicated that 65 of the animals on the attached census sheets were euthanized
due to COVID restrictions on personnel in the labs.”34,35

• Ferris State University

On March 11, 2020, Ferris State University President David L. Eisler issued an
“Important Update for Faculty Staff” regarding the initiation of modified campus
operations in light of the COVID-19 pandemic.36 According to responsive records that
PETA received from the university pursuant to public records requests related to
animals who had been euthanized due to these modified pandemic operations,37,38
animals assigned to different experimental protocols were euthanized.39 In an e-mail
on March 25, 2020, the university’s animal care facility director, Richard Marble,
stated, “I am currently drawing down the last of the colonies and preparing the
facility for restart once all of you restart. After today there will be no animals left in
the facility.”40 Furthermore, in an e-mail thread on March 19, 2020, with the subject
line “Animal Care Going Forward in Light of Yesterdays [sic] Message,” a university
member, whose name is redacted, wrote, “I am fine with euthanizing all animals at
this point. All of the male rats will be too large and there is no reason to continue to
maintain them. Nor the frog or turtle.” This staff member added, “In terms of my
animals, I can always purchase new rats later.”41 In another e-mail thread on March
23, 2020, titled “Animal care facility essential staff,” a university member, whose

32
Nemke J. AALAS thread “Animal care during shelter in place restrictions.” PETA.org. Accessed January
27, 2023. https://www.peta.org/wp-content/uploads/2023/01/uw-milwaukee-aalas-thread.pdf
33
Flaugher K. Records request. PETA.org. April 15, 2022. Accessed January 27, 2023.
https://www.peta.org/wp-content/uploads/2023/01/2022-04-15-uw-milwaukee-request.pdf
34
UW-Milwaukee. Responsive records. Census sheets. PETA.org. Accessed January 27, 2023.
https://www.peta.org/wp-content/uploads/2023/01/2022-05-13-census.pdf
35
UW-Milwaukee. Re: public records request. PETA.org. Accessed January 27, 2023.
https://www.peta.org/wp-content/uploads/2023/01/uw-milwaukee-response-email.pdf
36
Eisler D. Important Update for faculty staff. March 11, 2020. Ferris.edu. Accessed January 27, 2023.
https://www.ferris.edu/HTMLS/news/coronavirus/message-to-faculty-staff-mar11-2020.htm
37
Flaugher K. Records request. PETA.org. April 26, 2022. Accessed January 27, 2023.
https://www.peta.org/wp-content/uploads/2023/01/2022-04-26-ferris-state-university-request.pdf
38
Flaugher K. Records request. PETA.org. June 22, 2022. Accessed January 27, 2023.
https://www.peta.org/wp-content/uploads/2023/01/2022-06-22-ferris-state-university-request.pdf
39
Ferris State University. Responsive records. PETA.org. Accessed January 27, 2023.
https://www.peta.org/wp-content/uploads/2023/01/2022-07-15-documents-obtained.pdf
40
Ferris State University. E-mail. PETA.org. Accessed January 27, 2023. https://www.peta.org/wp-
content/uploads/2023/02/richard-marble-email.pdf
41
Ferris State University. Email: Animal Care Going Forward in Light of Yesterdays [sic] Message.
PETA.org. Accessed January 27, 2023. https://www.peta.org/wp-content/uploads/2023/01/Animal-Care-
Going-Forward-in-Light-of-Yesterdays-Message-email.pdf
 name is redacted, wrote, “It is our plan to have all animals euthanized and the facility
shutdown by the end of the week.”42

• Texas Tech University Health Sciences Center El Paso

In an AALAS discussion thread on March 22, 2020, titled “Who Is Suspending All or
Most Animal Research,” Texas Tech University Health Sciences Center El Paso
experimenter Chris Boehm discussed a sticker system to help make decisions about
euthanizing animals and stated, “We also euthanized about 80% of my training
colony.”43

That these laboratories had animals deemed by experimenters to be “unnecessary,”

“nonessential,” “noncritical,” or “extraneous” or described with similar terminology in
the first place should raise significant red flags. Given the widespread euthanasia of these
animals because of COVID-19 at universities across the country and the large amount of
NIH funding that these individual institutions receive in research grants, taxpayers should
not have to foot the bill for such waste.

Apparent Failure of NIH-Funded Protocols to Reduce and Replace Animal Use

The presence of such animals in these institutions’ laboratories flies in the face of
existing regulations to minimize animal use in experiments.

NIH-supported language to minimize animal use in experiments is present in the Health

Research Extension Act of 1985, the NIH Revitalization Act of 1993, the eighth edition
of the Guide for the Care and Use of Laboratory Animals, and the U.S. Government
Principles for the Utilization and Care of Vertebrate Animals Used in Testing, Research,
and Training.

• The Health Research Extension Act of 1985 states, “The Director of NIH shall
require each applicant for a grant, contract, or cooperative agreement involving
research on animals … to include in its application or contract proposal … (1)
assurances satisfactory to the Director of NIH that … (B) scientists, animal
technicians, and other personnel involved with animal care, treatment, and use by the
applicant have available to them instruction or training in the … use of research or
testing methods that limit the use of animals or limit animal distress” [emphasis
added].44
• The National Institutes of Health Revitalization Act of 1993 states, “The Director of
NIH … shall prepare a plan … for the National Institutes of Health to conduct or
support research into … methods of such research and experimentation that reduce
the number of animals used in such research” [emphasis added].45

42
Id.
43
Boehm C. AALAS thread “Who is suspending all or most animal research?” Accessed January 27, 2023.
https://www.peta.org/wp-content/uploads/2023/01/ttuhsc-aalas-thread.pdf
44
Office of Laboratory Animal Welfare. NIH. Health Research Extension Act of 1985, Publ. L. No. 99-158.
Accessed January 27, 2023. https://olaw.nih.gov/policies-laws/hrea-1985.htm
45
NIH. NIH Revitalization Act of 1993, Publ. L. No. 103-43. Accessed March 10, 2022.
https://grants.nih.gov/grants/olaw/pl103-43.pdf
• The eighth edition of the Guide for the Care and Use of Laboratory Animals states,
“The Guide … endorses the following principles: consideration of alternatives (in
vitro systems, computer simulations, and/or mathematical models) to reduce or
replace the use of animals” [emphasis added].46
• The U.S. Government Principles for the Utilization and Care of Vertebrate Animals
Used in Testing, Research, and Training (1985) states, “The animals selected for a
procedure should be of an appropriate species and quality and the minimum number
required to obtain valid results” [emphasis added].47

When these institutions’ experimenters buy, breed, trap, and/or use animals who at any
time—not just during the COVID-19 pandemic—can be deemed “extraneous” or
described using similar terminology, they squander limited research funds, much of
which come from taxpayers, and flout the foundational “3Rs” principle of reducing,
replacing, and refining the use of animals in experimentation that is enshrined in
government regulations and policies.

Under this standard, the number of “nonessential” animals used in the aforementioned
experiments should have been zero from the start, since they weren’t relevant to the
protocols led by these institutions’ employees. Also, because taxpayer funds were used to
acquire, breed, confine, and/or maintain these animals who were deemed “extraneous”
(or described using similar terminology) and then so readily euthanized and disposed of
in response to the COVID-19 pandemic, these institutions should reimburse the funding
agencies for this fiscal waste instead of seeking compensation for losses incurred.

Furthermore, the Congressional Research Service has found that during the COVID-19
pandemic, “[s]uspending research may result in additional costs for activities such as
animal care” and that “[r]estarting research, when conditions permit, may also incur costs
for staff time and supplies to … reestablish laboratory animal populations.”48 Taxpayers
should not be responsible for the additional costs associated with “reestablishing
laboratory animal populations,” since these institutions deemed many of them extraneous
to the experiments and because repopulating animals in laboratories at taxpayers’
expense would appear to violate the aforementioned federal regulations and policies that
mandate minimizing the use of animals in experiments.

Given this new supplementary information, we urge your office to investigate and
take appropriate actions. Furthermore, we urge you to respond to our full request

46
NIH. National Center for Biotechnology Information. National Research Council Committee for the
Update of the Guide for the Care and Use of Laboratory Animals. Appendix B: U.S. government principles
for the utilization and care of vertebrate animals used in testing, research, and training. Accessed March 10,
2022. https://www.ncbi.nlm.nih.gov/books/NBK54048/
47
NIH. National Center for Biotechnology Information. National Research Council Committee for the
Update of the Guide for the Care and Use of Laboratory Animals. Appendix B: U.S. government principles
for the utilization and care of vertebrate animals used in testing, research, and training. Accessed March 10,
2022. https://www.ncbi.nlm.nih.gov/books/NBK54048/
48
Congressional Research Service. Effects of COVID-19 on the federal research and development
enterprise. April 10, 2020. Accessed March 10, 2022.
https://crsreports.congress.gov/product/pdf/R/R46309
detailed in our HHS-OIG complaint dated June 15, 2020, and to our subsequent
NIH OMA complaints dated February 17, 2021, November 18, 2021, and March 14,
2022, respectively.

As we have reiterated in our past complaints, if noncompliance is corroborated, we ask

that you ensure that the experimenters adhere to federal mandates to reduce and/or
replace the use of animals in experiments. There is no justification for continuing to
waste public resources to support activities related to the acquisition, breeding,
confinement, maintenance, repopulation, and/or experimentation of animals in
laboratories who are deemed “extraneous,” “nonessential,” or “noncritical” or described
using similar terminology and subsequently killed.

Thank you for your consideration of this important matter. You can contact me at
[email protected]. We look forward to your reply.

Sincerely yours,

Shriya Swaminathan
Science Policy Advisor
International Laboratory Methods
Laboratory Investigations Department