Report Deficiencies in Animal Care and Use

General Policy

Institutional policy requires that animal care and use conform to all applicable federal, state, and local laws, regulations and policies including, but not limited to:

Principal Investigators (PIs) are responsible for ensuring that the members of their research team who are listed in approved protocols use proper procedures and techniques when performing animal experimentation. Certification of compliance with institutional policy is provided when the PI signs the front page of the IACUC Protocol and submitted to the IACUC for review and approval. The veterinarian is responsible for ensuring that animal care and veterinary staff use proper procedures and techniques in animal husbandry and veterinary care.

Any employee observing a deficiency in animal care or use is encouraged to report it as outlined below. A deficiency may include acts of perceived negligence, omission or non-compliance with approved protocols and IACUC policies, and intentional acts of cruelty towards laboratory animals. Hospital policy, as well as federal law, prohibits any discriminatory or reprisal measures being taken against any employee for reporting deficiencies in animal care or use. The institution intends to protect, to the extent possible, the privacy of an individual who in good faith reports an apparent deficiency.

Reporting Procedures

Any employee who observes a deficiency in animal care or use should take the following steps:

  • Note the date, time, building location, room number, and species of animal involved
  • Provide a complete description of the act, personnel involved, and observed circumstances. This description must  contain sufficient details to allow proper assessment by the staff person receiving the report
  • Report the information by telephone, by mail, e-mail or in person to one of the following individuals: Institutional Official, Attending Veterinarian, or IACUC Chair

Review Procedures

All reports of deficiencies in the care and use of animals will be reviewed and, if warranted, investigated by representatives of the IACUC. Reported deficiencies will be documented at the time by the person receiving the report, either using the written report of the person reporting the incident or writing a report of the conversation.

An initial evaluation of all reports involving deficiencies in animal care or use will be made under the direction of the veterinarian. Such evaluation may involve reviewing any relevant protocols on file and interviews with the PI and/or involved research personnel. Incidents that involve potential variations from approved protocols may be reviewed by an audit by the IACUC protocol compliance specialist. If the veterinarian finds that the reported incident was within the limits of an approved protocol for the research involved, then that determination will be reported to the IACUC. No further action will be taken.

If the veterinarian determines that further action is indicated, then a written report of the incident and the subsequent findings will be made to the IACUC and the Institutional Official.

The IACUC, in consultation with the veterinarian and the Institutional Official, if necessary, will review the report, investigate as appropriate, and take any further steps it deems necessary, which may include:

  • Convening a meeting between IACUC members and the PI and others on the protocol to review the incident and to discuss necessary changes
  • Reiteration of approved protocol practices and applicable IACUC policies
  • Training/re-training of personnel
  • Letter of notification/reprimand to personnel involved
  • Temporary restriction on the use of animals in research by personnel involved
  • Permanent prohibition of the use of animals in research by personnel involved
  • Appropriate disciplinary action against personnel involved
  • Remand to the appropriate institutional process if determined to be a case of misconduct in research or a serious violation of any other policy

[NB: should allegations of a deficiency involve a veterinarian or animal care technician under the veterinarian, the matter will be referred to the IACUC Chair or his or her designee, and processed as described above, during which time the veterinarian and his or her staff will cooperate fully with the investigation.]

The IACUC intends to provide the individual(s) alleged to have engaged in deficiencies in animal care or use with:

  • Confidential treatment, to the extent possible
  • A prompt, thorough, and impartial review and, where the Committee deems appropriate, investigation
  • An opportunity to comment and refute allegations and findings of the review and/or the investigation