**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

Revised

June 1, 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 8^th^ 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]{.underline}.

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.]{.underline}

**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. An eighth
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]{.underline}**

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]{.underline}**

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]{.underline}**

This elephant is just 9-years-old. She has been suffering from
intermittent lameness in her hind legs since August 2001, shortly after
her 5^th^ 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]{.underline}**

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]{.underline}**

### 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 in both eyes**. 

**[Pearl]{.underline}**

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]{.underline}**

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]{.underline}

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 **11 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.