St. Louis Zoo

Addendum to IDA Citizen Petition
By Suzanne Roy
Program Director
03/16/2006

The Honorable Mike Johanns
Secretary of Agriculture
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Room 200A
Whitten Building
Washington, DC 20250

Dr. Chester Gipson
Deputy Administrator
Animal Care
U.S. Department of Agriculture
4700 River Rd, Unit 84
Riverdale, MD 20737-1234

RE: Addendum to In Defense of Animals Citizen Petition (Feb. 2, 2006) Before the USDA Seeking An Interpretive Rule and Enforcement Under the Animal Welfare Act to Eliminate Violations of the Space and Conditions Regulations for Elephants at Zoos

Dear Secretary Johanns and Dr. Gipson:

Thank you for your decision to publish in the federal register In Defense of Animals February 2, 2006 citizens petition to the USDA seeking an interpretive rule and enforcement under the Animal Welfare Act to eliminate violations of the space and conditions regulations for elephants in zoos.

This enclosed report (below) on the St. Louis Zoo is submitted as an addendum to that petition. We request that it be published along with the full text of the petition in the Federal Register.

A review of elephant medical records (obtained through the Missouri Sunshine Law) reveals that elephants at the St. Louis Zoo are suffering from foot and joint disease due to inadequate space and living conditions. As a result, believes that St. Louis Zoo is violating the Animal Welfare Act requirement that states:

Enclosures shall be constructed and maintained so as to provide sufficient space to allow each animal to make normal postural and social adjustments with adequate freedom of movement. Inadequate space may be indicated by evidence of malnutrition, poor condition, debility, stress, or abnormal behavior patterns. (9 C.F.R. § 3.128)

IDA requests that USDA immediately inspect the St. Louis Zoo and enforce the adequate space and conditions regulations, by citing the zoo for violations of the Animal Welfare Act and compelling the zoo either to drastically improve space and conditions for the elephants held there or move the elephants to a sanctuary with the space and environment suitable to the vast spatial and social needs of this species.

Thank you for your consideration.

Sincerely,
Suzanne Roy
Program Director

ADDENDUM TO

FEB. 2, 2006 CITIZEN PETITION BEFORE THE UNITED STATES DEPARTMENT OF AGRICULTURE

SEEKING AN INTERPRETIVE RULE AND ENFORCEMENT UNDER THE ANIMAL WELFARE ACT TO ELIMINATE VIOLATIONS OF THE SPACE AND CONDITIONS REGULATIONS FOR ELEPHANTS AT ZOOS

Submitted by:
IN DEFENSE OF ANIMALS ("IDA")
131 Camino Alto, Suite E,
Mill Valley, California 94941

To:

MIKE JOHANNS
Secretary of Agriculture
U.S. Department of Agriculture
Room 200A Whitten Building
1400 Independence Ave., S.W.
Washington, DC 20250

DR. CHESTER GIPSON
Deputy Administrator
Animal Care
U.S. Department of Agriculture
4700 River Rd
Unit 84
Riverdale, MD 20737-1234

On
March 14, 2006

General Overview
The St. Louis Zoo ("SLZ") houses six female Asian Elephants; Clara, Sri, Ellie, Rani, Donna, and Pearl, and one male Asian Elephant; Raja. In addition, a seventh female, Carolyn, died at the facility in April 2000. Foot and/or joint problems have been reported in the medical records for 6 of the 7 elephants. Joint and foot problems are also noted in the necropsy of the 8th elephant, Carolyn.

Exhibit and Holding Space
The zoo’s Elephant Management Facility is a 13,000 square-foot holding area with 6,720 square feet of indoor space divided into 8 stalls and corridors for shifting. The barn is kept at 55-60 degrees Fahrenheit year round through gas circulating heat. All floors are concrete and unheated.

The zoo’s outdoor exhibit area totals 53,860 square feet. One of the exhibits is smaller and is only used to house cows or calves and the other two are capable of housing bulls. The largest exhibit is just a .5 acre (23,250 square feet) yard.

Elephant Health Problems
All but one of the elephants currently alive at the St. Louis Zoo has experienced foot problems, lameness and/or joint disease. A seventh elephant who died at the zoo in 2000 also suffered from foot irregularities and arthritis.

The medical records demonstrate that SLZ personnel continue to treat the symptoms of these problems by administration of antibiotics and painkillers, foot soaks and cutting necrotic (dead/rotting) tissue from the feet, without ever addressing the cause of the problem – the lack of space, exercise, confinement indoors during the winters and the concrete-floored barn.

Records indicate that SLZ personnel are aware that confinement indoors (where the floors are concrete) is the cause of some of these problems. For example, the "deeply worn" and sensitive nails of the young elephant Rani are attributed to "increased wear due to animals only recently being allowed out after being indoors all winter. (This animal is very active.)"

Skin problems on the feet of Pearl and Donna are thought to need no treatment because “animal is now spending more time outside, where the feet are dry and in more sunshine.”

Below is a brief summary of the health problems of elephants. More detailed excerpts from medical records are included in Appendix 1. Finally, copies of relevant pages from the medical records are attached as Appendices 2-9. Full copies of the medical records are included on the enclosed CD, along with an electronic version of this addendum and its appendices.

Details of Elephants and their Health Problems

Carolyn
Carolyn was found dead in her stall on April 11, 2000. She was 32-years-old. The necropsy found “severe polynephritis” and the cause of death was kidney failure. This condition was likely caused initially by a chronic urinary tract infection.

The necropsy identified cracks and defects on 3 of 4 of Carolyn’s feet and osteo-skeletal erosions on 3 of 4 limbs (arthritis). The left stifle (knee) showed severe DJD, erosion of half of the kneecap, femur and tibia. The left coxofemoral joint (hip) had severe Degenerative Joint Disease. The erosive lesions on the stifle and coxofemoral joint of the left rear leg are particularly disturbing, in that they indicate a chronic painful degenerative condition.

This elephant also suffered from uterine cysts and had tuberculosis bacterium present in a lymph node. She had been exposed to TB from an exhibit mate who died in 1979. Veterinarian performing necropsy believed that TB was “walled off” in granulomas and that Carolyn did not have “patent tuberculosis.”

Clara

Clara, 52-years old, has experienced numerous foot and limb problems, including recurring abscesses of both back feet for at least five years (the records only begin in January 2000).

Clara’s left foot appears to have been abscessed for five years. Her right foot abscess appears to have lasted for three years, but then reoccurs a year later. Her left foot ends up with a serious defect – a 1.5 x 5 cm fissure near her middle toe.

Clara has also suffered from decubital sores (bedsores) on the left side of her face, her left elbow and left hip as a result of “prolonged recumbency” (laying down a lot) presumably due to foot pain.

Clara wears sandals on both back feet due to the chronic abscesses. Prior to the sandals, a boot was placed on Clara’s abscessed left foot. A note in the records from April 2000 indicates that when a boot was first placed on this foot, Clara removed it and “rubbed sole on chain until moderate hemorrhage.” Chaining of course would only worsen Clara’s problem and the fact that she rubbed her foot to the point of hemorrhage is an indication of the degree of discomfort she has experienced.

Notes indicate that Clara has arthritis as well. Her left leg has had a problem with swelling. Signs that Clara is in pain include direct mention of pain in the medical records: “arthritis pain” on 8/1/01, and “pain management” on 4/28/05. In addition, the records include entries noting “prolonged recumbancy” (lying down) leading to pressure sores, and prolonged use of non-steroidal anti-inflammatory drugs (NSAIDs).

Clara’s foot infections are treated with antibiotics, foot soaks and trimming the necrotic tissue from her foot. Her foot pain and arthritis have been treated with banamine and phenylbutazone, two Non-steroidal Anti-inflammatory Drugs (NSAIDs).

Rani
This elephant is just 9-years-old. She has been suffering from intermittent lameness in her hind legs since August 2001, shortly after her 5th birthday.

On July 4, 2004, her lameness was described in records: “She is very hesitant to bend at the knee and the left rear limb is worse than the right. She is still moving around the stall and eating well, but she shuffles along and even occasionally circumducts her rear limbs to not have to bend.” Her lameness is treated periodically with the NSAID phenylbutazone.

She has also suffered nail cracks and abnormal nail wear. Considered a “very active elephant,” this young animal has been locked indoors for the winter, a factor which the zoo acknowledged contributed to her nail problems.

Rani’s other problems include recurring belpharospasm (muscle contraction of her eyelids - indicative of eye pain and/or something lodged in the eye) of her right eye, which has forced her to hold her right eye closed; anemia; a bite wound on her tail; and tusk problems (missing right tusk, broken left tusk). In June 2005, a rectal ultrasound indicated that Rani was not pregnant, however news reports from November 2005 indicate that this young elephant is pregnant. (See Appendix 9) This is an early age for an Asian elephant pregnancy, as the average age of first pregnancy in the wild is 13 years old.

Ellie
Age 35, Ellie had a calf in approximately 1997. She is currently pregnant, after having been diagnosed in 2004 as a questionable breeder with a confirmed ovarian cyst.

Ellie has experienced foot problems. In 2002, three of four feet show superficial circular depressions or deficits. Her right front foot had a cracked nail with a deep separation from the nail bed. This was treated by cutting flesh away from margins of the separation. Her left foot had cracks in 2 nails.

News reports from November 2005 indicate that Ellie is pregnant. (See Appendix 9)

Donna
This 34-year-old elephant has suffered from a sole abscess and cracked nail in her left foot. The records indicate that the sole abscess on her left foot lasted for at least a year (2001-2002). By February 2004, the abscess was back, with keepers reporting that the “site heals and then breaks open again.” In 2005, the left foot was still infected and being treated with foot soaks and debriding (cutting away the dead tissue.)

Donna has also suffered from repeated nail cracks, with medical records noting in January 2005 that “This animal always had challenges with its nails.”

The records indicate that the SLZ has an indication of the source of Donna’s foot problems. In July 2000, veterinarians decided that no treatment was necessary for the dermocytosis of Donna’s front feet “as animal is now spending more time outside, where the feet are dry and in more sunshine.”

In January 2002, Donna was diagnosed as overweight. Her other health problems include infertility and endometrial cysts, chronic problems with both tusks (cracks, breaks and infections) and nuclear sclerosis (cataracts) in both eyes.

Pearl
Pearl is a 35-year-old elephant who has suffered from foot problems for years. She has a prolapsed uterus, presumably stemming from the birth of Raji. The condition has caused urinary incontinence and her back feet have been affected from constantly standing in urine. Both back feet have soft soles and superficial ulcers. This condition is recorded consistently in the records since March 2001. The backs of her legs have had urine burns from this condition as well.

Pearl’s front feet also have problems. There are nail cracks and superficial erosions over 60 percent of the surface of the soles, according to a 2002 note. A January 2003 entry notes a “cuticle abscess that erupted this month.”

Pearl was been given phenylbutazone for front left quarter lameness in August – September 2002. This lameness recurs, according to the records, in January 2004.

Pearl’s other health problems include repeated urinary tract infections, a perineal hernia, endometrial cysts, tusk and tooth fracture and infection.

Raja
This 13-year-old son of Pearl is suffering from the beginning stages of foot disease. Between 2001 and 2005, medical records note nail cracks on 3 of 4 feet. He has also been noted to have pitted soles in front feet and dry, cracked heals in rear feet. Raja also has had chronic fractured tusks with infected pulp cavity on one occasion.

Sri
Sri, 26, is the only elephant at the SLZ who has not experienced foot or joint problems. In November 2005, a pregnant Sri lost her baby during labor. To date, she still carries the dead fetus in her body. Failed pregnancies are another captivity-related problem, with 9 elephant pregnancies since 2001 ending in stillbirth, death of fetus in utero, or death of baby within 1 day of birth.

Conclusion
Elephants at the St. Louis Zoo are being held in inadequate conditions that are not consistent with their health and well-being. In addition to the foot and joint disease discussed in detail above and in the attached excerpts, the elephants suffer from other common “zoo-genic” conditions such as reproductive abnormalities and tusk injuries.

The St. Louis Zoo is aware at minimum that prolonged confinement of elephants during winter months causes problems with elephants’ feet, yet it has done nothing to address the cause of the elephants’ foot and joint problems: inadequate space and substrates.

Given this information, USDA should inspect the St, Louis Zoo elephants’ feet, medical records, and living conditions and require this zoo to either significantly improve the conditions under which it confines elephants, or relocate the elephants to a sanctuary where their needs can be met.