Response to Protocol Review Scenario: Performance standards for housing

We believe that the IACUC and the Attending Veterinarian (AV) have the authority to establish minimum space standards for Roth's animals. Both the Guide for the Care and Use of Laboratory Animals (the Guide)¹ and the PHS Policy on Humane Care and Use of Laboratory Animals (PHS Policy)² hold the AV responsible for animal health and wellbeing and give him or her the authority to oversee aspects of animal care and use, including husbandry and housing¹. Furthermore, the PHS Policy states that animal housing should be comfortable and should contribute to the overall wellbeing of the animals². Increased mortality or health problems in a particular species or program should be addressed by the IACUC. The PHS Policy mandates that the IACUC review any animal health or wellbeing concerns as raised². The Guide¹ states that institutions, investigators and IACUC members should evaluate the needs of each species during program evaluations and facility inspections and should continue to review ongoing research in these areas.

The role of the IACUC is to ensure humane use and care of animals at the institution. The IACUC, on the advice of the veterinarians, can vote to require that the animals be given more space. Roth's concern about the IACUC imposing European standards at a US institution may seem genuine, but the IACUC can make recommendations based on internal defined performance standards, European standards or other scientifically based space and housing recommendations as may develop over time, such as future updates from the American Society of Herpetologists.

We recommend a collaborative approach to solving this problem. Roth does bring considerable knowledge with his years of experience. The AV and the IACUC have the dual obligation of ensuring animal wellbeing and furthering research; hence, a collaborative effort with Roth to find an amicable resolution should be made.

According to the Guidelines for Use of Live Amphibians and Reptiles in Field and Laboratory Research³, reptiles and amphibians are ecotherms with relatively low energy systems and can therefore be housed at higher densities. These guidelines also emphasize that the physical, social and physiological needs of the animals must be met³. The duration of housing must also be considered: if animals are housed for only a short time, then housing at higher densities may be acceptable. But if animals are kept for longer periods of time, care and attention must be paid to the animal's health and wellbeing throughout the study. The program at Great Eastern needs to establish performance standards related to housing and cage density for this species based on parameters such as tank microenvironmental conditions, access to food, waste removal, ease of visualization and health assessment.

Although the literature is not clear on space requirements for reptiles, the views and recommendations of other investigators at the institution using similar species or of ad hoc experts or consultants, along with the data regarding the performance standards, can be communicated to Roth and the committee. The AV, the IACUC and Roth should try to work together to further research and establish an acceptable housing density standard. The IACUC is also responsible for making sure that the animals do not undergo unnecessary distress. The committee should make an informed decision in this regard, enforced by both committee deliberation and vote.

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