A Biref History of Human Experiments
A Biref History of Human Experiments (wordpress.com)
https://florencioviray.files.wordpress.com/2010/04/ti-brief-history-of-human-experimentations.pdf
1718
George I offers free pardon to any inmate of Newgate Prison who agrees to be inoculated with infectious
small pox in variolation experiment. You can read about this in one of our history articles, in the section:
The History of Innoculation.Â
1796
Edward Jenner injects healthy eight-year-old James Phillips first with cowpox then three months later
with smallpox and is hailed as discoverer of smallpox vaccine.
1845-1849
J. Marion Sims, the "Father of Gynecology" in the United States, conducts gynecological experiments on
slaves in South Carolina. You can read more on Dr Sims in our Biographies.Â
1865
French physiologist Claude Bernard publishes "Introduction to the Study of Human Experimentation,"
advising: "Never perform an experiment which might be harmful to the patient even though highly
advantageous to science or the health of others.
1874
Cincinnati physician Roberts Bartholow conducts brain surgery experiments on Mary Rafferty, a 30 yearold domestic servant dying of an infected ulcer.
1891
Prussian State legislates that a treatment for tuberculosis cannot be given to prisoners without their
consent.
1892
Albert Neisser injects women with serum from patients with Syphilis, infecting half of them.
1896
Dr. Arthur Wentworth performs spinal taps on 29 children at Children's Hospital in Boston to determine
if procedure is harmful.
1897
Italian bacteriologist Sanarelli injects five subjects with bacillus searching for a causative agent for
yellow fever.
1900
Walter Reed injects 22 Spanish immigrant workers in Cuba with the agent for yellow fever paying them
$100 if they survive and $200 if they contract the disease.
1906
Dr. Richard Strong, a professor of tropical medicine at Harvard, experiments with cholera on prisoners in
the Philippines killing thirteen.
1915
U.S. Public Health Office induces pellagra in twelve Mississippi prisoners. All the prisoners are,
however, volunteers and after the experiment they are cured (with proper diet) and released from prison.
You can read about it here, in our History of Vitamins.Â
1919-1922
Testicular transplant experiments on five hundred prisoners at San Quentin
1931
Germany issues "Regulation on New Therapy and Experimentation" while 75 children die in Lubeck,
Germany from pediatrician's experiment with tuberculosis vaccine.
In America, Dr. Cornelius Rhoads, under the auspices of the Rockefeller Institute for Medical
Investigations, infects human subjects with cancer cells. He later goes on to establish the U.S. Army
Biological Warfare facilities in Maryland, Utah, and Panama, and is named to the U.S. Atomic Energy
Commission. While there, he begins a series of radiation exposure experiments on American soldiers and
civilian hospital patients.
1932
The Tuskegee Syphilis Study begins. 200 black men diagnosed with syphilis are never told of their
illness, are denied treatment, and instead are used as human guinea pigs in order to follow the progression
and symptoms of the disease. They all subsequently die from syphilis, their families never told that they
could have been treated.
This is one subject we will cover in depth some day soon.
1935
The Pellagra Incident. After millions of individuals die from Pellagra over a span of two decades, the
U.S. Public Health Service finally acts to stem the disease. The director of the agency admits it had
known for at least 20 years that Pellagra is caused by a niacin deficiency but failed to act since most of
the deaths occurred within poverty-stricken black populations.
1938
Japanese immunologist Ishii Shiro ("Dr. Ishii") conducts experiments with anthrax and cholera on
Chinese prisoners in Harbin.
1939
Third Reich orders births of all twins be registered with Public Health Offices for purpose of genetic
research.
1939-1945
Unit 731. Dr Ishii begins "field tests" of germ warfare and vivisection experiments on thousands of
Chinese soldiers and civilians. Chinese people who rebelled against the Japanese occupation were
arrested and sent to Pingfan where they became human guinea pigs; there is evidence that some Russian
prisoners were also victims of medical atrocities. "I cut him open from the chest to the stomach and he
screamed terribly and his face was all twisted in agony. He made this unimaginable sound, he was
screaming so horribly. But then finally he stopped. This was all in a day's work for the surgeons, but it
really left an impression on me because it was my first time." These prisoners were called 'maruta'
(literally 'logs') by the Japanese. After succumbing to induced diseases â€â€ï¿½ including bubonic
plague, cholera, anthrax â€â€ï¿½ the prisoners were usually dissected while still alive, their bodies
then cremated within the compound. Tens of thousands died. The atrocities were committed by some of
Japan’s most distinguished doctors recruited by Dr. Ishii.
1940
Four hundred prisoners in Chicago are infected with Malaria in order to study the effects of new and
experimental drugs to combat the disease. Nazi doctors later on trial at Nuremberg will cite this American
study to defend their own actions during the Holocaust.
1941
Sterilization experiments at Auschwitz.
1941-1945
Typhus experiments at Buchenwald and Natzweiler concentration camps.
1942-1945
According to congressional hearings held in Washington, D. C., in September 1986, former American
POWs were among Ishii's experimental subjects. The hearings produced a litany of horror stories told by
former American POWs. http://www.researchprotection.org/history/chronology.htmlÂ
1942
Harvard biochemist Edward Cohn injects sixty-four Massachusetts prisoners with beef blood in U.S.
Navy-sponsored experiment.
High altitude or low pressure experiments at Dachau concentration camp.
Chemical Warfare Services begins mustard gas experiments on approximately 4,000 servicemen. The
experiments continue until 1945 and made use of Seventh Day Adventists who chose to become human
guinea pigs rather than serve on active duty.
1942-1943
Bone regeneration and transplantation experiments on female prisoners at Ravensbrueck concentration
camp.
Coagulation experiments on Catholic priests at Dachau concentration camp.
Freezing experiments at Dachau concentration camp.
1942-1944
U.S. Chemical Warfare Service conducts mustard gas experiments on thousands of servicemen.
1942-1945
Malaria experiments at Dachau concentration camp on more than twelve hundred prisoners.
1943
Epidemic jaundice experiments at Natzweiler concentration camp.
Refrigeration experiment conducted on sixteen mentally disabled patients who were placed in refrigerated
cabinets at 30 degree Fahrenheit, for 120 hours, at University of Cincinnati Hospital., "to study the effect
of frigid temperature on mental disorders."
1942-1943
Phosphorus burn experiments at Buchenwald concentration camp.
In response to Japan's full-scale germ warfare program, the U.S. begins research on biological weapons
at Fort Detrick, MD.
1944
Manhattan Project injection of 4.7 micrograms of plutonium into soldiers at Oak Ridge.
Seawater experiment on sixty Gypsies given only saltwater to drink at Dachau concentration camp.
U.S. Navy uses human subjects to test gas masks and clothing. Individuals were locked in a gas chamber
and exposed to mustard gas and lewisite.
1944-1946
University of Chicago Medical School professor Dr. Alf Alving conducts malaria experiments on more
than 400 Illinois prisoners.
1945
Manhattan Project injection of plutonium into three patients at Billings Hospital at University of Chicago.
Malaria experiment on 800 prisoners in Atlanta.
Project Paperclip is initiated. The U.S. State Department, Army intelligence, and the CIA recruit Nazi
scientists and offer them immunity and secret identities in exchange for work on top secret government
projects in the United States.
"Program F" is implemented by the U.S. Atomic Energy Commission (AEC). This is the most extensive
U.S. study of the health effects of fluoride, which was the key chemical component in atomic bomb
production. One of the most toxic chemicals known to man, fluoride, it is found, causes marked adverse
effects to the central nervous system but much of the information is squelched in the name of national
security because of fear that lawsuits would undermine full-scale production of atomic bombs.
1946
U.S. secret deal with Ishii and Unit 731 leaders cover up of germ warfare data based on human
experimentation in exchange for immunity from war-crimes prosecution. A top-secret U.S. Army Far
East Command report on Thompson's findings reads: "The value to the U.S. of Japanese biological
weapons data is of such importance to national security as to far outweigh the value accruing from warcrimes prosecution." A 1956 FBI memorandum reveals that by the mid-1950s the U.S. knew everything
about Ishii's human experiments but agreed not to prosecute in exchange for Japan's scientific data on
germ warfare. (In other words, when it comes to human torture and sacrifice, even of American
POW’S, the ends justify the means as far as the U.S. Government is concerned….and,
the U.S. Government placed a very high value on knowledge of efficient ways to kill large numbers of
people )
Opening of Nuremberg Doctors Trial.
1946-1953
Atomic Energy Commission and Quaker Oats-sponsored study of Fernald, Massachusetts residents fed
breakfast cereal containing radioactive tracers.
1946
Patients in VA hospitals are used as guinea pigs for medical experiments. In order to allay suspicions, the
order is given to change the word "experiments" to "investigations" or "observations" whenever reporting
a medical study performed in one of the nation's veteran's hospitals.
1946-1974
The Atomic Energy Commission authorized a series of experiments in which radioactive materials are
given to individuals in many cases without being informed they were the subject of an experiment, and in
some cases without any expectation of a positive benefit to the subjects, who were selected from
vulnerable populations such as the poor, elderly, and mentally retarded children (who were fed
radioactive oatmeal without the consent of their parents), and also from students at UC-San Francisco. In
1993, the experiments were uncovered and made public. In 1996, the United States settled with the
survivors for 4.9 million dollars.
1947
Judgment at Nuremberg Doctors Trial including ten point Nuremberg Code which begins: "The voluntary
consent of the human subject is absolutely essential."
Colonel E.E. Kirkpatrick of the U.S. Atomic Energy Commission issues a secret document (Document
07075001, January 8, 1947) stating that the agency will begin administering intravenous doses of
radioactive substances to human subjects.
The CIA begins its study of LSD as a potential weapon for use by American intelligence. Human subjects
(both civilian and military) are used with and without their knowledge.
1949
Intentional release of radiodine 131 and xenon 133 over Hanford Washington in Atomic Energy
Commission field study called "Green Run."
Soviet Union's war crimes trial of Dr. Ishii's associates.
1949-1953
Atomic Energy Commission studies of mentally disabled school children fed radioactive isotopes at
Fernald and Wrentham schools.
1950
Department of Defense begins plans to detonate nuclear weapons in desert areas and monitor downwind
residents for medical problems and mortality rates.
In an experiment to determine how susceptible an American city would be to biological attack, the U.S.
Navy sprays a cloud of bacteria from ships over San Francisco.
Monitoring devices are situated throughout the city in order to test the extent of infection. Many residents
become ill with pneumonia-like symptoms.
Dr. Joseph Stokes of the University of Pennsylvania infects 200 women prisoners with viral hepatitis.
1951-1960
University of Pennsylvania under contract with U.S. Army conducts psychopharmacological experiments
on hundreds of Pennsylvania prisoners.
1951
Department of Defense begins open air tests using disease-producing bacteria and viruses. Tests last
through 1969 and there is concern that people in the surrounding areas have been exposed.
1952-1974
University of Pennsylvania dermatologist Dr. Albert Kligman conducts skin product experiments by the
hundreds at Holmesburg Prison; "All I saw before me," he has said about his first visit to the prison,
"were acres of skin."
1952
Henry Blauer injected with a fatal dose of mescaline at Psychiatric Institute of Columbia University per
secret contract with Army Chemical Corps.
1953
Newborn Daniel Burton rendered blind at Brooklyn Doctor's Hospital during study on RLF and the use
of oxygen
1953-1957
Oak Ridge-sponsored injection of uranium into eleven patients at Massachusetts General Hospital in
Boston.
1953
U.S. military releases clouds of zinc cadmium sulfide gas over Winnipeg, St. Louis, Minneapolis, Fort
Wayne, the Monocacy River Valley in Maryland, and Leesburg, Virginia. Their intent is to determine
how efficiently they could disperse chemical agents.
Joint Army-Navy-CIA experiments are conducted in which tens of thousands of people in New York and
San Francisco are exposed to the airborne germs Serratia marcescens and Bacillus glogigii. The germs
and chemicals used by the Army and Navy posed known health risks before and during the time of
testing. This is documented in scientific studies cited in The Eleventh Plague by Leonard A. Cole and in
Cole's previous book, Clouds of Secrecy: The Army's Germ Warfare Tests Over Populated Areas.
CIA initiates Project MKULTRA at eighty institutions on hundreds of subjects. This is an eleven year
research program designed to produce and test drugs and biological agents that would be used for mind
control and behavior modification. Six of the subprojects involved testing the agents on unwitting human
beings.
A declassified CIA document dated 7 Jan 1953[1] describes the experimental creation of multiple
personality in two 19-year old girls. "These subjects have clearly demonstrated that they can pass from a
fully awake state to a deep H [hypnotic] controlled state by telephone, by receiving written matter, or by
the use of code, signal, or words, and that control of those hypnotized can be passed from one individual
to another without great difficulty. It has also been shown by experimentation with these girls that they
can act as unwilling couriers for information purposes."
1953-1970
U.S. Army experiments with LSD on soldiers at Fort Detrick, Md.
1954-1974
U.S. Army study of 2300 Seventh-Day Adventist soldiers in 150 experiments code named "Operation
Whitecoat."
1955
The CIA, in an experiment to test its ability to infect human populations with biological agents, releases a
bacteria withdrawn from the Army's biological warfare arsenal over Tampa Bay, Fl.
1955-1958
Army Chemical Corps continues LSD research, studying its potential use as a chemical incapacitating
agent. More than 1,000 Americans participate in the tests, which continue until 1958.
1956
U.S. military releases mosquitoes infected with Yellow Fever over Savannah, Ga and Avon Park, Fl.
Following each test, Army agents posing as public health officials test victims for effects.
Dr. Albert Sabin tests experimental polio vaccine on 133 prisoners in Ohio.
1958
LSD is tested on 95 volunteers at the Army's Chemical Warfare Laboratories for its effect on
intelligence.
1958-1960
Injection of hepatitis into mentally disabled children at Willowbrook School on Staten Island in an
attempt to find vaccine.
1958-1962
Spread of radioactive materials over Inupiat land in Point Hope, Alaska in Atomic Energy Commission
field study code named "Project Chariot."
1959-1962
Harvard Professor Henry A. Murray conducts psychological deconstruction experiment on 22
undergraduates including Theodore Kaczynski, the result of which, at least according to writer Alton
Chase, may have turned Kaczynski into the Unabomber.
1960
The Army Assistant Chief-of-Staff for Intelligence (ACSI) authorizes field testing of LSD in Europe and
the Far East. Testing of the European population is code named Project THIRD CHANCE; testing of the
Asian population is code named Project DERBY HAT.
1962-1980
Pharmaceutical companies conduct phase one safety testing of drugs almost exclusively on prisoners for
small cash payments.
1962
Thalidomide withdrawn from the market after thousands of birth deformities blamed in part on
misleading results of animal studies; the FDA thereafter requires three phases of human clinical trials
before companies can release a drug on the market.
Injection of live cancer cells into elderly patients at Jewish Chronic Disease Hospital in Brooklyn.
Stanley Milgram conducts obedience research at Yale University. We’ve talked of
Milgram’s experiment in a previous newsletter, and there is a link to a great online video on the
subject that is very good.Â
1963
NIH supported researcher transplants chimpanzee kidney into human in failed experiment.
Linda MacDonald was a victim of Dr. Ewen Cameron’s destructive mind control experiments
in 1963. Dr. Cameron was at various times president of the American, Canadian, and World Psychiatric
Associations. He used a "treatment" which involved intensive application of these brainwashing
techniques; drug disinhibition, prolonged sleep treatment, and prolonged isolation, combined with ECT
[Electro Convulsive Therapy] treatments. The amount of electricity introduced into Linda’s
brain exceeded by 76.5 times the maximum amount recommended. Dr. Cameron’s technique
resulted in permanent and complete amnesia. To this day, Linda is unable to remember anything from her
birth to 1963. As recorded by nurses in her chart, she didn’t know her name and
didn’t recognize her children. She couldn’t read, drive, or use a toilet. Not only did
she not know her husband, she didn’t even know what a husband was. A class action suit
against the CIA for Dr. Cameron’s MKULTRA experiments was settled out of court for
$750,000, divided among eight plaintiffs in 1988.
1962-1980
Pharmaceutical companies conduct phase one safety testing of drugs almost exclusively on prisoners for
small cash payments.
1963-1973
Dr. Carl Heller, a leading endocrinologist, conducts testicular irradiation experiments on prisoners in
Oregon and Washington giving them $5 a month and $100 when they receive a vasectomy at the end of
the trial.
1964
World Medical Association adopts Helsinki Declaration, asserting "The interests of science and society
should never take precedence over the well being of the subject."
1965-1966
CIA and Department of Defense begin Project MKSEARCH, a program to develop a capability to
manipulate human behavior through the use of mind-altering drugs.
University of Pennsylvania under contract with Dow Chemical conducts dioxin experiments: prisoners at
the Holmesburg State Prison in Philadelphia are subjected to dioxin, the highly toxic chemical component
of Agent Orange used in Viet Nam. The men are later studied for development of cancer, which indicates
that Agent Orange had been a suspected carcinogen all along.
1966
CIA initiates Project MKOFTEN, a program to test the toxicological effects of certain drugs on humans
and animals.
U.S. Army dispenses Bacillus subtilis variant niger throughout the New York City subway system. More
than a million civilians are exposed when army scientists drop light bulbs filled with the bacteria onto
ventilation grates.
Henry Beecher's article "Ethics and Clinical Research" in New England Journal of Medicine.
U.S. Army introduces bacillus globigii into New York subway tunnels in field study.
NIH Office for Protection of Research Subjects ("OPRR") created and issues Policies for the Protection
of Human Subjects calling for establishment of independent review bodies later known as Institutional
Review Boards.
1967
British physician M.H. Pappworth publishes "Human Guinea Pigs," advising "No doctor has the right to
choose martyrs for science or for the general good."
CIA and Department of Defense implement Project MKNAOMI, successor to MKULTRA and designed
to maintain, stockpile and test biological and chemical weapons.
1968
CIA experiments with the possibility of poisoning drinking water by injecting chemicals into the water
supply of the FDA in Washington, D.C.
1969
Dr. Robert MacMahan of the Department of Defense requests from congress $10 million to develop,
within 5 to 10 years, a synthetic biological agent to which no natural immunity exists.
1970
Funding for the synthetic biological agent is obtained under H.R. 15090. The project, under the
supervision of the CIA, is carried out by the Special Operations Division at Fort Detrick, the army's top
secret biological weapons facility. Speculation is raised that molecular biology techniques are used to
produce AIDS-like retroviruses.
United States intensifies its development of "ethnic weapons" (Military Review, Nov., 1970), designed to
selectively target and eliminate specific ethnic groups who are susceptible due to genetic differences and
variations in DNA.
1971
Dr. Zimbardo conducts Psychology of Prison Life experiment on students at Stanford University.
1973
Ad Hoc Advisory Panel issues Final Report of Tuskegee Syphilis Study, concluding "Society can no
longer afford to leave the balancing of individual rights against scientific progress to the scientific
community."
1974
National Research Act establishes National Commission for the Protection of Human Subjects and
upgrades OPRR Policies to Regulations to be known as "The Common Rule."
1975
The virus section of Fort Detrick's Center for Biological Warfare Research is renamed the Fredrick
Cancer Research Facilities and placed under the supervision of the National Cancer Institute (NCI) . It is
here that a special virus cancer program is initiated by the U.S. Navy, purportedly to develop cancercausing viruses. It is also here that retrovirologists isolate a virus to which no immunity exists. It is later
named HTLV (Human T-cell Leukemia Virus).
HHS promulgates Title 45 of Federal Regulations titled "Protection of Human Subjects," requiring
appointment and utilization of IRBs.
1976
National Urban league holds National Conference on Human Experimentation, announcing "We don't
want to kill science but we don't want science to kill, mangle and abuse us."
1977
Senate hearings on Health and Scientific Research confirm that 239 populated areas had been
contaminated with biological agents between 1949 and 1969. Some of the areas included San Francisco,
Washington, D.C., Key West, Panama City, Minneapolis, and St. Louis.
1978
Experimental Hepatitis B vaccine trials, conducted by the CDC, begin in New York, Los Angeles and
San Francisco. Ads for research subjects specifically ask for promiscuous homosexual men.
1979
National Commission issues Belmont Report setting forth three basic ethical principles: respect for
persons, beneficence, and justice.
1980
The FDA promulgates 21 CFR 50.44 prohibiting use of prisoners as subjects in clinical trials shifting
phase one testing by pharmaceutical companies to non-prison population.
1981
First cases of AIDS are confirmed in homosexual men in New York, Los Angeles and San Francisco,
triggering speculation that AIDS may have been introduced via the Hepatitis B vaccine.
1981
Leonard Whitlock suffers permanent brain damage after deep diving experiment at Duke University.
1985
According to the journal Science (227:173-177), HTLV and VISNA, a fatal sheep virus, are very similar,
indicating a close taxonomic and evolutionary relationship.
1986
According to the Proceedings of the National Academy of Sciences (83:4007-4011), HIV and VISNA are
highly similar and share all structural elements, except for a small segment which is nearly identical to
HTLV. This leads to speculation that HTLV and VISNA may have been linked to produce a new
retrovirus to which no natural immunity exists.
A report to Congress reveals that the U.S. Government's current generation of biological agents includes:
modified viruses, naturally occurring toxins, and agents that are altered through genetic engineering to
change immunological character and prevent treatment by all existing vaccines.
1987
Department of Defense admits that, despite a treaty banning research and development of biological
agents, it continues to operate research facilities at 127 facilities and universities around the nation.
Supreme Court decision in United States v. Stanley, 483 U.S. 669, holding soldier given LSD without his
consent could not sue U.S. Army for damages.
1990
More than 1500 six-month old black and Hispanic babies in Los Angeles are given an "experimental"
measles vaccine that had never been licensed for use in the United States. The Center for Disease Control
later admits that parents were never informed that the vaccine being injected to their children was
experimental.
The FDA grants Department of Defense waiver of Nuremberg Code for use of unapproved drugs and
vaccines in Desert Shield.
1991
World Health Organization announces CIOMS Guidelines which set forth four ethical principles: respect
for persons, beneficence, nonmalfeasance and justice.
Tony LaMadrid commits suicide after participating in study on relapse of schizophrenics withdrawn from
medication at UCLA.
1994
With a technique called "gene tracking," Dr. Garth Nicolson at the MD Anderson Cancer Center in
Houston, TX discovers that many returning Desert Storm veterans are infected with an altered strain of
Mycoplasma incognitus, a microbe commonly used in the production of biological weapons. Incorporated
into its molecular structure is 40 percent of the HIV protein coat, indicating that it had been man-made.
Senator John D. Rockefeller issues a report revealing that for at least 50 years the Department of Defense
has used hundreds of thousands of military personnel in human experiments and for intentional exposure
to dangerous substances. Materials included mustard and nerve gas, ionizing radiation, psychochemicals,
hallucinogens, and drugs used during the Gulf War.
1995
U.S. Government admits that it had offered Japanese war criminals and scientists who had performed
human medical experiments salaries and immunity from prosecution in exchange for data on biological
warfare research.
Dr. Garth Nicolson, uncovers evidence that the biological agents used during the Gulf War had been
manufactured in Houston, TX and Boca Raton, Fl and tested on prisoners in the Texas Department of
Corrections.
1996
Department of Defense admits that Desert Storm soldiers were exposed to chemical agents.
1997
Eighty-eight members of Congress sign a letter demanding an investigation into bioweapons use & Gulf
War Syndrome.
1998
Three children die at St. Jude Children's Hospital in Memphis during participation in clinical trial for
acute lymphoblastic leukemia.
1999
Veterans Administration shuts down all research at West Los Angeles Medical Center after allegations of
medical research performed on patients who did not consent.
OPRR shuts down research at Duke University because of inadequate supervision of human subject
experiments..
Year-old Gage Stevens dies at Children's Hospital in Pittsburgh during participation in Propulsid clinical
trial for infant acid reflux.
18-year-old Jesse Gelsinger dies after being injected with 37 trillion particles of adenovirus in gene
therapy experiment at University of Pennsylvania. His death triggers a still-ongoing reevaluation of the
conflicts of interest plaguing human subject research.
2000
University of Oklahoma melanoma trial halted for failure to follow government regulations and protocol.
OPRR becomes Office of Human Research Protection ("OHRP") and made part of the Department of
Health and Human Services.
2001
Biotech company in Pennsylvania asks the FDA for permission to conduct placebo trials on infants in
Latin America born with serious lung disease though such tests would be illegal in U.S.
Ellen Roche, a 24 year-old healthy volunteer, dies after inhaling hexamethonium in an asthma study at
Johns Hopkins Medical Center. OHRP shuts down all research at Hopkins for four days.
Elaine Holden-Able, a healthy retired nurse, dies in Case Western University Alzheimer's experiment
financed by the tobacco industry.
2003
FDA reports that, for the past four years, experiments on cancer patients were conducted at Stratton
Veterans Affairs Medical Center by Paul Kornak who had no valid medical license and who repeatedly
altered data and committed numerous violations of the protocols..