The IACUC administrator should have provided an explanation of how the USDA pain and distress categories are assigned. The focus in this scenario is whether the animal's experience of more than momentary, pain or distress was relieved (category D) or not relieved (category E)1. As the IACUC chair expressed, category E is appropriate because the animal experienced pain prior to relief: “Animals must be listed in Column E if they are subjected to painful procedures and the anesthetics, analgesics, tranquilizing drugs or other palliative treatment did not adequately preclude more than slight or momentary pain or distress”1.

The IACUC Guidebook states, “It is the responsibility of the IACUC to critically evaluate all research protocols for the potential to cause pain or distress and assess the steps that are to be taken to enhance animal well-being”2. In this scenario, the lab technicians took the following steps: administer daily analgesia; realize that a dose was missed; reinitiate analgesia schedule; contact the IACUC. If there were no further steps in the approved protocol for the lab technicians to follow, then the IACUC should re-evaluate the protocol and ask the investigator responsible for the research to discuss with the attending veterinarian further steps to be taken, such as recording details of analgesic administration (technician, time, dose, etc.); monitoring animals more than once per day and documenting this monitoring; and having the investigator or other designated individual confirm that duties are completed. If the designated individuals are unable to monitor an animal or provide a scheduled treatment, then arrangements can be made with the veterinary staff to ensure this task is done. The protocol should also include guidance on managing a missed dose and list criteria that warrant intervention by the attending veterinarian, who should have been immediately contacted along with the IACUC.

The IACUC should have also considered re-training the staff members to confirm that the lab technicians and the investigator understand the privilege of working with research animals. The IACUC may require that the investigator submit a follow-up report and that the lab documentation be checked by the IACUC during semi-annual laboratory inspections. Staff members should be reminded that the veterinary staff and IACUC office are available and should feel comfortable contacting either group for assistance at any time. With everyone working together to ensure that research animals receive the proper care, compliance can be maintained while research is carried out responsibly.

Finally, the IACUC, upon being notified of the incident, should have phoned OLAW and USDA to alert them of the incident prior to sending the formal report to OLAW. The USDA inspector will evaluate the report during the annual inspection of the institution.

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