Keith's View

Wickham and the Home Office Exposed

A scathing exposé of a cruel vet and cosmetic testing under the vivisectors charter

Wickham Laboratories: An Animals Scientific Procedures Inspectorate Report – 2009/10

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:

“The temporary 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 much frowning.

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:

"any 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 to beautify.

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 17 years.

Cartmell's official 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.

“Allegations 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 reports that:

“This level 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 years

“Home Office 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.”

Acknowledging Wickham's 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!

“The allegation 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 law directly referring to Wickham Laboratories is; Animals (Scientific Procedures) Act 1986.
The welfare of the animals at Wickham Laboratories is central to the ethics of the Toxicology department. Many systems are in place to ensure the daily routines of the animals are structured and regular, to meet their environmental, food & drink and enrichment needs. Many procedures are in place to ensure the system for the welfare of the animals is in continual working order. The animals have environmentally controlled conditions which are monitored regularly, including; humidity and temperature control to suit the particular species. The animals are provided with appropriate food and water and their environment is enriched with toys and hides, giving them the space they need to relax or play. The animals come into regular human contact for grooming and nurturing. They are encouraged to play by staff thereby aiding enrichment. The animals also have their own exercise room where they can stretch, run around and socialise with the other animals. A named Veterinary Surgeon is always available; 24hrs a day, seven days a week. The Vet will make a routine visit to the animals. This is to conduct health checks and to ensure correct running of the facility. In addition, the Veterinary Surgeon is available to provide advice on the animal’s health and welfare, this includes assistance in the assessment of the likely consequences for the animals welfare."

Meaningless waffle.

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:

“Statements 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 therein contained.

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.

Recommendations are 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 victims.

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.

“A typical 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.”

“Rabbits 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.

“There is 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.”

Rabbits in stocks at Wickham. (BUAV)

The 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?

“The single 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:

“A loud 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

“A member 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!

Rabbits 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:

“Although 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:

“Ipsen is 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.
http://www.ipsen.com/en/contact-us

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 2010

From Dusk 'til Dawn
An Insider's View of the Growth of the Animal Liberation Movement

© Keith Mann
puppypincher@yahoo.co.uk