The veterinary medical officer (VMO) was correct in issuing a citation, as there was protocol noncompliance. Recordkeeping is essential to many fields including animal research. It serves as documentation of completed tasks and assignments and that the protocols were followed, allows researchers to brainstorm research ideas, maintains current veterinary practices1 and is a regulatory requirement2,3,4.
The protocol required the dogs to receive an analgesic twice daily and there was no record that each individual animal on this record actually received appropriate treatment. The species in question, dogs, are USDA-covered species and thus are required to have a medical record that includes everything from initial purchase to final disposition4. Routine preventive medical procedures such as vaccinations and dewormings performed on a group of animals are often documented on a 'herd-health' type of record. Individual animal treatments must be documented for each animal. In addition, all records regardless of format or whether they be research lab generated or animal facility generated, must be readily available for regulatory inspection. Numerous medical record formats exist but they must meet the letter of the law, be legible and provide the necessary information for all involved in an animal's care.
While the drug log was correct, there was no individual animal treatment record maintained. Compliance without documentation is noncompliance.
References
Field, K. et al. Medical records for animals used in research, teaching, and testing: public statement from the american college of laboratory animal medicine. ILAR J. 48, 37–41 (2007).
United States Department of Agriculture. Animal Care Policy Manual (2016).
Institute for Laboratory Animal Research. Guide for the Care and Use of Laboratory Animals 8th edn. (National Academies Press, Washington, DC, 2011).
United States Department of Agriculture. Animal Welfare Act and Animal Welfare Regulations (2013).
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Williams, C., Huet, Y. Response to Protocol Review Scenario: If it's not recorded, it didn't occur. Lab Anim 46, 338 (2017). https://doi.org/10.1038/laban.1334
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DOI: https://doi.org/10.1038/laban.1334