Ecology and Evolutionary Biology
University of Colorado
Boulder, Colorado 80309-0334 USA
January 26, 2004
Associate Executive Director
Division on Earth and Life Studies
National Research Council
Dear Dr. Symmes:
Below is my review of the report titled Review of the Smithsonian Institution's National Zoological Park. I will try to follow your guidelines and I hope that you find my comments useful. If you have any further questions please do not hesitate to contact me. Can you please acknowledge receipt of this document? Thank you.
P. S. For your information, I am a Fellow of the Animal Behavior Society and a recipient of their Exemplar Award for major lifetime contributions to the study of animal behavior. If you need it, more detailed information can be found on my homepage at http://www.literati.net/Bekoff and at http://www.ethologicalethics.org.
Review of the Smithsonian Institution's National Zoological Park
I received the Review of the Smithsonian Institution's National Zoological Park on January 23, 2004. As I understand it, I am to judge whether the arguments, findings, and conclusions of this report are supported by the text and determine whether the report is accurate, complete, and even-handed. I will also identify issues that are of major concern. The title is appropriate, and I have no editorial comments.
General and major comments and concerns
The Review of the Smithsonian Institution's National Zoological Park is a comprehensive, well-written, and well-organized report. The specific case studies are very helpful for assessing how poorly the zoo is run and for highlighting the pitiful and shameful lack of documentation of pertinent information and the utter failure across administrative levels to implement procedures that could have helped to improve the well-being of animals who were ill as well as the well-being of other individuals. I congratulate the stellar group of scholars who obviously worked very hard on the project at hand and who then wrote this report. Even objective or dispassionate readers will be able to see that there is a long history of many major problems at the National Zoo, and that the numerous infractions of various federal and other guidelines, statutes, and laws (and common sense) constitute serious and egregious violations. The review is balanced and fair. Sensitive issues are given proper care and in many ways the authors of this review "bent over backwards" to be nice and accommodating to the zoo. I agree with the committee's summary that "Many issues remain unresolved at the National Zoo." (p. 59) Indeed, this is gross understatement.
The charge to the committee is clearly described in this report and in my view, the conclusions that are reached are supported by evidence, analysis, and argument. The authors do not go beyond their charge or expertise. The recommendations that are offered are realistic and strict (as they should be) and unwavering compliance should be enforced at all levels. That the existence of zoos is "inevitable" at least in the foreseeable future does not mean that we should lower our standards or accept the deplorable situation at this institution. Blatant disregard for the lives of the animals should never trump our responsibility to provide the best possible lives for those non-consenting beings who are held captive. I fully realize that it is very difficult to run a zoo and to maintain the highest of ethical standards, but difficult does mean impossible and the National Zoo (and all zoos) should be expected to put the animals first and not run a shoddy operation. Surely, administrators must oversee the entire operation and "run a tight ship." And there must be coordination and communication among all levels. Everyone has to talk to one another because it is clear that the proper operation of a zoo (like all businesses) requires ongoing dialogue and frank but cordial exchanges in which everyone is given a chance to express their views and each individual's views are listened to.
There are many major concerns about the operation of the National Zoo, and the clear organization and structure of this review makes it easy to highlight them. Frankly, I do not see many "strengths" to the way in which the National Zoo is run -- the numerous and blatant "weaknesses" overshadow any positive aspects. There is a shameful and regrettable lack of concern for the animal's well-being by some but not all of the people who are responsible for overseeing the zoo's operation from day to day. It is difficult to see how the goals of providing support for conservation, education, and science are met when there is such rampant disregard for the health and nutrition of the zoo's inhabitants, the beings whose lives and well-being underpin the goals of the zoo and are the very reason that this and other zoos exist in the first place.
I agree with the committee's recognition (p. 3) that "the decline of the state of the National Zoo had accrued over many years." I also find it extremely disconcerting that there are so many violations despite a sharp decrease in the zoo's animal populations (p. 22). I would have expected much better care for fewer residents. And, it is also disquieting that these infractions/abuses are occurring given that the veterinarians who work at the National Zoo are board-certified by the AVMA.
Some major concerns include (but are not limited to): (1) the lack of documentation for the preventative medicine program and the lack of compliance in numerous instances in providing annual exams, vaccinations, tuberculosis tests, and infectious disease testing; (2) shortcomings in the animal nutrition program despite a "history of world-class nutrition research" (p. 51) that have "undoubtedly lead to animal deaths at the National Zoo" (p. 6); (3) the disregard for adherence to guidelines in research supported by the PHS (and also other research supported in other ways) stipulated by the PHS itself, the Federal Animal Welfare Act, the American Zoo and Aquarium Association (AZA), IACUCs, and the zoo's own policies and procedures for animal health and welfare (p. 8); (4) failure to comply with guidelines for euthanasia; (5) violation of quarantine procedures and protocols; (6) failure to keep adequate animal husbandry and management records; (7) poor pest control; (8) poor compliance with the zoo's own policies (p. 63); (9) poor record keeping; and (10) the lack of accessibility to records.
One of the most egregious violations is the alteration of veterinary records weeks and years after the event (p. 9). Another is the failure to keep "official records" of complaints (p. 60). Yet another is the inexcusable death of two red pandas after they were exposed to rodenticide. Where was the safety manager? I select this example from among many others merely to make the point that individual's lives are at stake and that because of a failure to comply with even the most elementary guidelines and common sense, numerous individuals needlessly suffer interminable psychological and physical pain and death.
A major concern is that the zoo's AZA accreditation will be approved once again in March 2004. I recommend against this. I favor withholding accreditation until the many wrongs are righted. There is a lack of a strategic plan, as highlighted in this review (pp. 89, 91). There has been enough time for the people running the zoo to get things in order and I fear that giving them accreditation will mean that things will change far too slowly if at all. It is time to play "hard ball" because the situation as described in the Review of the Smithsonian Institution's National Zoological Park is deplorable, inexcusable, and an embarrassment to humankind. It is an insult to the people who support the zoo and trust that those who work at the zoo (perhaps especially administrators) will work hard to maintain the highest of standards. Most importantly, it is an affront to the animals who depend on the goodwill of those who are responsible for their well-being and lives. The fact that there still is no strategic plan for the National Zoo "despite the recommendations of previous AZA accreditation reports" (p. 11, my emphasis) in and of itself justifies withholding further accreditation until the zoo gets things in order. Obviously, good intentions and promises to do so have not been sufficient to make suitable changes.
Other substantial issues or concerns
I found myself wondering how and why the high profile situation at the zoo got to be as bad as it is. How and why did conditions deteriorate despite (1) close scrutiny by organizations and individuals who are supposed to be responsible for overseeing zoos and (2) repeated and deep expressions of concern by the public that were carried in high profile media? Why wasn't there better communication and interaction among all levels of the zoo's administration and the people who are responsible for people who interact with the animals first hand,, each and every day, those who do the hand-on work? What has morale been like at the zoo? Has morale declined as the zoo declined? Did anyone at the zoo speak out about the conditions before they snowballed into such a horrific and inexcusable state? What happened to those who did speak out? Were they listened to or dismissed? Was there open communication even about difficult or contentious issues?
To sum up, it is worth emphasizing that the review committee recognized (p. 63, my emphasis) "a lack of evidence that the administration has embraced its role in providing for animal care and management, compounded by a lack of responsibility and accountability at all levels." This summary says it all. There are far too many unresolved questions and issues and a lack of accountability throughout all administrative levels. Pondering the questions that I and the review committee have raised, along with the review committee's summary, is extremely troubling. The future at the National Zoo must not mirror their decline, even in the slightest.
Once again, I congratulate the review committee for writing a fair and balanced report. While I knew that conditions at the National Zoo were bad and continuing to decline, I had no idea that things were as bad as they are. I was alarmed by the extent of the problems that have compromised the well-being of individual animals and have needlessly caused much pain, suffering, and death. There is culpability across all levels. Shame on the individuals responsible for knowingly compromising the lives of animals at this zoo. Shame on them also for mindfully forfeiting public trust.
The National Zoo defines its mission (p. 88) as "exhibiting and protecting biodiversity by joining public education and recreation with research in conservation biology and reproductive sciences." They surely are a long way from realizing that goal and strict and uncompromising measures must be taken to ensure that they "clean up their act" immediately. Stern enforcement of recommendations must commence at once regardless of the zoo's status with the AZA. The entire National Zoo must be kept under the closest scrutiny by organizations and individuals who will enforce recommendations without compromise (and without fear of retribution if necessary). There should be serious consequences for failure to comply with recommendations by oversight committees, and one way to begin is to withhold AZA accreditation. The well-being of all animals must come first.