Dr. Lisa Blackmore's original IACUC protocol approval did not include the use of the school's cold room to house some of her mice, but during the course of experimentation it became necessary to use the room and Blackmore submitted a protocol amendment to the IACUC office for a change in the housing site. Because there was an existing IACUC-approved Standard Operating Procedure for housing mice in the cold room, the IACUC office forwarded the requested change to the attending veterinarian and using the veterinary verification and consultation (VVC) process1, the veterinarian concurred with the change.
Soon afterwards, during the semiannual inspection of animal housing areas, an IACUC inspector walked into the cold room that housed Blackmore's cages along with many cages from other mouse studies. All the animals were fine and the studies were being conducted as per the approved protocols, but the inspector noticed exposed electrical wires that could easily be contacted by anybody working in that part of the room. The wires were above the cages housing Blackmore's mice and due to the other ongoing studies there was no place to relocate the cages. The inspector notified Blackmore and the vivarium of the problem and the vivarium director said that she would call the facilities maintenance department to have the problem remedied. The inspector advised the IACUC office and vivarium that the problem should be considered a significant deficiency because, in the inspector's opinion, it threatened the safety of personnel working in the area.
The exposed wires were quickly put into a proper conduit by the maintenance department which explained that a repair to the cooling unit had not been completed when the inspection occurred. Nevertheless, the IACUC was not entirely sure about how to handle the inspection finding. There was no question about the safety issue for personnel but the static mouse cages were on a table that was well below the wires. The committee was not sure if a danger to personnel but not to animals constituted a significant deficiency. A second problem was that the Blackmore protocol change was implemented by VVC and NIH guidance on VVC states that changes impacting personnel safety must be approved by either full committee or designated member review1. The committee was unsure if the inspection finding was a reportable incident to OLAW or if it was just a wake-up call for the veterinarian to be more thorough before approving a change by VVC.
How do you think the IACUC should proceed?
References
National Institutes of Health. Guidance on Significant Changes to Animal Activities. Notice NOT-OD-14-126.
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Silverman, J. How should the IACUC handle a questionable VVC change to a protocol?. Lab Anim 47, 9 (2018). https://doi.org/10.1038/laban.1380
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DOI: https://doi.org/10.1038/laban.1380
