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Response to Protocol Review Scenario: Possible, but prudent?

Lab Animal volume 43, pages 266–267 (2014)Cite this article

The Institutional Official (IO) is the person charged with the responsibility of ensuring that the institution is satisfying regulations set for its animal use and care programs. The Public Health Service Policy on Humane Care and Use of Laboratory Animals (PHS Policy) defines the IO as “an individual who signs, and has the authority to sign the institution's Assurance, making a commitment on behalf of the institution that the requirements of this Policy will be met”1. This is further supported and clarified in the Guide for the Care and Use of Laboratory Animals2. There, the IO is defined as the person “responsible for resource planning and ensuring the alignment of Program goals and quality animal care and use with the institute mission”2. The Animal Welfare Act (AWA) defines the IO as the person who legally commits to ensuring that the terms of the animal welfare regulations are met by the institution3. The PHS Policy and the AWA define the term 'IO' and his or her responsibilities. The AWA and the PHS Policy do not stipulate explicitly whether this role is to be performed by one individual or by many. The US National Institutes of Health's Office of Laboratory Animal Welfare (NIH/OLAW) in the past has offered guidance on this issue:“...organizations having simple, clear, direct lines of responsibility and corresponding authority function well and are better able to respond quickly and effectively to the requirements of the PHS Policy”4. In NIH/OLAW's experience, programs that do not support clear communication have failed to be effective4.

The advantages of having multiple IOs include knowledge of each individual campus, speed in identifying and addressing campus needs and fair representation of each campus in negotiations. The foreseeable major disadvantages of having multiple IOs are possible miscommunication to regulatory officials, higher costs in paying several individuals instead of one and the potential for budgetary disputes among IOs. The use of one IO for all campuses also has multiple benefits, such as clear communication with regulatory agencies and uniformity in decision-making, and eliminates most of the disadvantages listed above. If the current Vice Provosts at Great Eastern were willing to continue to assist the IO, then the program would get the best of both worlds.

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References

  1. Public Health Service. Policy on Humane Care and Use of Laboratory Animals (US Department of Health and Human Services, Washington, DC, 1986; amended 2002).

  2. Institute for Laboratory Animal Research. Guide for the Care and Use of Laboratory Animals (National Academies Press, Washington, DC, 2011).

  3. Animal Welfare Regulations. Code of Federal Regulations. 9 CFR, Chapter 1, Subchapter A–Animal Welfare, Parts 1–4.

  4. Division of Animal Welfare, Office for Protection from Research Risks, National Institutes of Health. Frequently asked questions about the Public Health Service Policy on Humane Care and Use of Laboratory Animals. ILAR News 35, 47–49 (1993). <http://grants.nih.gov/grants/olaw/references/ilar93.htm>

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  1. Churchill is Lab Animal Post-Doctoral Fellow at the National Institute of Environmental Health Sciences (NIEHS), Research Triangle Park, NC.,

    Sheba Churchill

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Churchill, S. Response to Protocol Review Scenario: Possible, but prudent?. Lab Anim 43, 266–267 (2014). https://doi.org/10.1038/laban.586

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