This scenario asks whether there can be more than one Institutional Official (IO) at Great Eastern University. As the IACUC attending veterinarian (AV) pointed out, the US Department of Agriculture (USDA) and the US National Institutes of Health's Office of Laboratory Welfare (NIH/OLAW) have previously stated that the structure of an organization can vary to accommodate its specific needs1. The Public Health Service Policy on Humane Care and Use of Laboratory Animals (PHS Policy)2 and the Animal Welfare Act and regulations (AWARs)3 do not specifically prohibit Great Eastern University from having multiple IOs. But we believe the IACUC Chair was correct in assuming that each IO should have full authority over a designated campus and not just partial authority over the entire university.

In this solution, each of the four campuses of Great Eastern University would have a designated IO along with its previously designated campus AV while retaining their single university IACUC. The logistics of this structure would need to be documented so that all parties understand the expectations, responsibilities and lines of authority. Some of the complicating factors of having a single IACUC and potentially a single PHS Assurance and USDA Registration are indicated below. Most importantly, Great Eastern would need to have a mechanism in place to resolve conflict and maintain programmatic consistency among the four IOs with regard to committing the institution to meet the requirements of the PHS Policy and the AWARs, reporting to regulatory and funding agencies, appointing IACUC members, subjecting protocols to additional review and ensuring personnel training and the availability of training programs.

The IACUC would also need to communicate with all IOs equally regarding semi-annual facility inspection reports, semi-annual program reviews, IACUC suspensions, non-compliance activities and other issues surrounding the animal care and use program. Finally, the IOs would need to reach consensus before communicating decisions with the IACUC to guarantee consistency.

The document described above, detailing the responsibilities and lines of authority for the multiple IOs, should also dictate and outline who has signatory authority for the various regulatory reports (i.e., PHS Assurance, USDA Annual Report). Furthermore, that document should be submitted to NIH/OLAW with the institution's PHS Assurance, USDA Registration and Program Description for the Association for Assessment and Accreditation of Laboratory Animal Care International (as applicable) so that the organizational structure, lines of authority and responsibilities are transparent and codified.

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