The Great Eastern University IACUC cannot approve Benoit's protocol amendment. Because rabbits are covered by the USDA, Great Eastern University must abide by the Animal Welfare Act. The Animal Welfare Regulations (AWRs; § 2.31,d,1,x)1 and APHIS Policy #14 (ref. 2) state that “no animal will be used in more than one major operative procedure from which it is allowed to recover, unless justified for scientific reasons by the principal investigator, required as a routine veterinary procedure or to protect the health or well-being of the animal, or in other special circumstances as determined by the Administrator of APHIS.” The Guide for the Care and Use of Laboratory Animals (the Guide) suggests that reasons for major multiple survival surgeries may include procedures that are related components of a single research project or protocol, procedures that will conserve scarce animal resources or procedures conducted for clinical reasons3. The Guide further states that “the application of such a practice on a single animal used in separate protocols is discouraged”3, and APHIS Policy #14 states that “a 2nd major survival operative procedure must not be performed on an animal in a separate animal study activity”2. The first surgical procedure, ovariectomy, penetrates a body cavity, and the second surgical procedure, induction of long bone fracture, results in physical impairment. Both surgeries qualify as major operative procedures as defined by the AWRs1. It is relevant that ovariectomy is being performed for the purpose of experimentation and not for routine veterinary care.
It is laudable that Benoit and Harding are considering the principles of the 3Rs and, more specifically, an approach that would ultimately reduce the animal numbers used by both projects. It appears, however, that Benoit's initial intent may be to reduce the overall cost of her research. The Guide explicitly precludes cost savings as a justification for multiple major survival surgeries and, in concert with the AWRs, requires that the surgical procedures be “essential components of a single research project or protocol”3. The key issue in the current scenario is that Benoit's and Harding's protocols are separate and unrelated.
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