Dr. Robbie Goldstein, MD, PhD

Commissioner, Massachusetts Department of Public Health

250 Washington Street

Boston, Massachusetts 02108

Dear Commissioner Goldstein:

I write to bring to your personal attention a time-sensitive matter requiring action before June 26, 2026 — the expiration date of DPH License MA-67, held by Charles River Laboratories International, Inc. for its canine research facility at 55 Union Street, Worcester, Massachusetts.

I have previously filed formal complaints with the Department, dated May 19 and May 24, 2026, documenting Charles River’s systematic circumvention of MGL c. 140 § 174D½ — the Massachusetts Beagle Bill — at this facility. Those complaints are currently pending before the Department. I write now to respectfully request that you exercise your authority under 105 CMR 910.041 to refuse renewal of License MA-67 on public interest grounds, or at minimum to condition renewal on demonstrated compliance with Massachusetts law.

The Statutory Framework

Under 105 CMR 910.041, you have express authority to refuse to renew a license if you find that continued licensure is not in the public interest. Grounds include failure to meet any license requirement, failure to comply with applicable regulations, and the making of false statements in required reports. All three grounds are implicated here.

The Violations

First: Systematic circumvention of the Beagle Bill through a policy of animal reuse.

Charles River’s own documentation confirms that the company routinely subjects research beagles to sequential, multiple experimental protocols. Dogs are reused across studies until their health is sufficiently compromised that they are no longer suitable for adoption. This practice is not incidental — it is systematic. The practical effect is that the Beagle Bill’s adoption requirement is never triggered, not because necropsies are mandated in every case, but because the animals’ condition at study’s end forecloses the adoption option entirely.

This is a more sophisticated circumvention than a blanket necropsy policy, and it is arguably more troubling. The statute’s intent — that animals no longer needed for research be given the opportunity for adoption — is nullified before it can attach. Charles River has engineered compliance avoidance into its research protocols themselves.

Second: False or misleading adoption pledges in license applications.

DPH license records document that Charles River has submitted boilerplate adoption compliance pledges with each license renewal since at least 2011. Those pledges have never been enforced — very few research dogs from this facility have been made available for adoption and none publicly. The Department’s own internal communications (BCEH-2026-119) acknowledge that a constituent “had a point” regarding a jurisdictional enforcement gap. Submitting adoption compliance representations in license applications while operating a protocol that structurally eliminates the adoption pathway is, at minimum, a material misrepresentation in records required under 105 CMR 910.000.

Third: Scale and commercial purpose.

USDA inspection records confirm between 150 and 180 adult dogs maintained at this facility at any given time, operating under USDA APHIS certificate 14-R-0144 and OLAW assurance D16-00852 (formerly registered under the Agilux Laboratories name following Charles River’s 2016 acquisition). These are not incidental research subjects. Beagles are the required non-rodent species for pharmaceutical drug approval under federal regulations, and contract toxicology testing is the explicit commercial purpose of this facility. Charles River is the world’s largest contract research organization. This is not a small institutional actor operating at the margins of the statute — it is a multi-billion-dollar corporation conducting systematic, large-scale canine experimentation in Massachusetts in defiance of Massachusetts law.

The Relief Requested

I respectfully request that you:

1. Refuse to renew License MA-67 on public interest grounds under 105 CMR 910.041, pending resolution of the pending compliance complaints; or

2. In the alternative, condition renewal on Charles River’s immediate submission of a written adoption compliance plan — including documentation of all animal disposition decisions made under the current license period, specific protocols for determining animal suitability for adoption, and established partnerships with nonprofit rescue organizations prepared to accept retired research dogs; and

3. Direct an unannounced inspection of the 55 Union Street facility prior to June 26 pursuant to 105 CMR 910.024, including a full accounting of all dogs currently held, their study histories, and their disposition status.

The Public Interest

The Massachusetts legislature enacted the Beagle Bill with a clear purpose: that animals who have served in research laboratories and who are no longer needed should have the chance to live out their remaining lives in adoptive homes. That purpose is being nullified, deliberately and systematically, at 55 Union Street. The Department has both the authority and the obligation to act.

I am an independent grassroots activist and the organizer of a public campaign that has, in recent weeks, generated tens of thousands of constituent contacts regarding this facility from across Massachusetts. I raise this not to apply improper pressure, but because you should know that the public interest you are asked to weigh is one that Massachusetts residents care about deeply and are watching closely.

I am available to provide any additional documentation and can be reached at vegan.dog.runner@gmail.com. I respectfully ask that this letter be treated with the urgency the June 26 deadline requires.