The USDA Animal Welfare Act and regulations (AWARs)1 and the Public Health Service Policy on Humane Care and Use of Laboratory Animals (PHS Policy)2 both require the IACUC to evaluate the institution's programs and facilities semiannually3. The IACUC may be represented by a subcommittee of at least two IACUC members appointed by the IACUC chair (provided any member who wishes to do so is allowed to participate), and the IACUC may elect to include ad hoc consultants in conducting the evaluation. The PHS Policy requires that the evaluations be based on the Guide for the Care and Use of Laboratory Animals (Guide)4, and compliance with the AWARs is also required.
Brown, the veterinarian, is correct when she states that it is the IACUC's responsibility to set a reasonable and specific plan and schedule for correction of deficiencies. The IACUC must first classify each deficiency as either minor or significant. Minor deficiencies are, by definition, generally associated with lower risk, so some flexibility in the timetable for correction is appropriate. In contrast, a significant deficiency is one that the IACUC and Institutional Official (IO) judge to present a threat or potential threat to the health or safety of the animals and, therefore, must be addressed as soon as possible, commensurate with the risks involved. It is essential for the IACUC to work with other professionals (occupational health and safety staff, engineering staff, veterinarians, etc.) as needed to a gain a full understanding of the problem, the specific actions required to fully resolve the problem, the estimated costs involved, any appropriate interim (stop gap) measures necessary and a specific work plan for implementing the comprehensive response. The responsibility of the IACUC is to evaluate the body of information collected and to decide on a feasible plan and schedule of correction that appropriately safeguards the well-being of the animals and personnel. The IO is then responsible for ensuring that funds and other resources are allocated as needed to correct the significant deficiency according to the IACUC approved plan and schedule. If the institution fails to do this, then the IO is required to inform the USDA Animal and Plant Health Inspection Service within 15 business days. Typically, a report would also be prepared for the Office for Laboratory Animal Welfare (if the institution holds a PHS Assurance), and other agencies might also have to be informed.
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