SANTA CRUZ -- The U.S. Department of Agriculture has filed a 10-page complaint against Santa Cruz Biotechnology alleging numerous violations of the federal animal welfare act.

The complaint, dated July 19, lists incidents stemming from inspections in 2007 through May of this year, including problems with the handling of animals, inadequate veterinary care, improper food and unqualified personnel.

The USDA's complaint details a lengthy history of problems found by inspectors at the Delaware Avenue laboratory, which the agency's Animal and Plant Health Inspection Service launched an investigation into in 2010 after two inspections that year turned up a dozen sick or injured goats.

A representative from the company could not be reached to comment Monday.

Santa Cruz Biotechnology also was cited in February 2011 for noncompliance involving blood collection rules, three repeated citations and one goat that was unable to walk. Medical records for sick animals were found to be incomplete.

More recently, federal inspectors in March found that the facility had one staff veterinarian tasked with caring for 10,000 goats, about 6,000 rabbits and an undetermined number of cattle and horses.

During that inspection, as well as follow-ups in April and May, inspectors found goats with ailments ranging from an untreated broken leg, serious skin conditions and low body weight. One goat died of untreated pneumonia during an inspection on May

The company is required to file a response to the USDA's complaint within a specified time frame, or the agency will consider failure to response to constitute an admission of all allegations contained in the complaint. An oral hearing likely will be conducted if and after the company responds.

David Sacks, a spokesman for the USDA, said the company could face a penalty of up to $10,000 per violation. Determination of fines is based on multiple factors, including how egregious the violation is, the size of the facility, the facility's prior penalty history and whether the company made a good faith effort to correct the problem.

Animal rights activist Michael Budkie, executive director of Ohio-based Stop Animal Exploitation Now, said he was happy to see the USDA taking action.

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USDA files complaint against Santa Cruz Biotechnology, alleging history of violations