The Public Health Service Policy on Humane Care and Use of Laboratory Animals (PHS Policy)1 states that the IACUC shall consist of not less than five members but does not specifically include a chairperson as one of those five members. Additionally, the PHS Policy1 requires the Assured institution to “comply with the applicable regulations (9 CFR, Subchapter A) issued by the U.S. Department of Agriculture (USDA) under the Animal Welfare Act.” The Animal Welfare Act and Regulations (AWARs)2, as stated in §2.31(b)(2), require an IACUC to have at least three members, one of which is a chairperson. In this scenario, however, the AWARs2 do not apply because the institution is using only laboratory mice. Furthermore, there is no definition of or guidance on the chairperson's responsibilities in the PHS Policy1, the AWARs2 or the Guide for the Care and Use of Laboratory Animals3. The PHS Policy1 also states (in section A.3.b.), “The Assurance must include the names, position titles, and credentials of the IACUC chairperson and the members,” implying that the Chair is not necessarily a member. Therefore, we believe that the veterinarian's advice was accurate. The dean can serve as the Chair of the IACUC without being a member.
There are several reasons why the president of the college might wish to reconsider the dean's appointment. The role of Chair typically includes many responsibilities beyond chairing meetings. It is difficult to envision how a person with no experience in animal care and use could make informed decisions when needed. There exists a potential conflict of interest in this scenario as the dean may not be in a position to objectively evaluate the research. The dean's role at the college includes promoting research funding; therefore, she has a vested interest in the proposed research. The AWARs2 (in §2.31(d)(2)) and the PHS Policy1 state that “no member may participate in the IACUC review or approval of a research project in which the member has a conflicting interest except to provide information as requested by the IACUC.” Perhaps the dean recognized this conflict of interest and that is why she elected not to be a member. However, even though she is not a member of the IACUC and therefore would not have a vote, she is an authority figure and her presence as IACUC Chair could influence the voting of junior faculty members on the IACUC.
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