It is unfortunate that White had to endure what many researchers face when dealing with their IACUCs: unnecessary delays. The amendment submitted was for a non-invasive behavioral observation procedure. For many IACUCs, a minor amendment like this could be reviewed through the designated member review (DMR) process. In most cases, the DMR process is faster than waiting for a full committee review. In this scenario, it appears that White's amendment was being reviewed by the DMR process.

Regardless of which process is used, the reviewers have the right to assess the amendment and how it fits with the procedures in the rest of the protocol. This may lead to concerns with parts of the protocol that were already approved, and the IACUC should require the investigator to address those concerns. However, the IACUC should not require the investigator to wait “seemingly forever” or to contact the committee for a status report.

IACUCs should have deadlines for their reviewers to respond, just as they have deadlines for researchers to submit materials. The IACUC could inform the investigator of the review deadline, so that he or she would know when to expect a response. This would make the review process more objective and ensure a timely response to the investigator. If problems had been found in already-approved procedures and the reviewer had provided that information quickly, then White likely would not have had the same response for Covelli.

The designated member reviewer should also be questioned as to why he or she was not already comfortable with the recently approved protocol. Perhaps the reviewer did not attend the meeting where the protocol was initially discussed and was unable to review it and provide feedback before that meeting, meaning that he or she is seeing the full protocol for the first time. In this situation, the reviewer can certainly raise concerns and ask for clarification regarding the approved procedures. Assuming there were no problems with this amendment, the IACUC, through the DMR process, could approve this amendment, allowing the researcher to collect data using the new procedure while addressing any concerns about the previously approved procedures.

IACUCs should adhere to the same standards that they expect from researchers. As the group responsible for the animal care program, the IACUC may become frustrated when researchers are delayed in responding to concerns. Likewise, IACUCs should be frustrated when their own processes cause delays in getting responses back to researchers.

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