The veterinarian is right to be concerned. When entering the animal facility to collect tissues, Bryant will be exposed to possible health risks, including rodent allergens and toxic or uncharacterized chemicals. Any institution using animals in research is obligated to inform and protect animal users from research-related risks in compliance with federal, state and local regulations1. Although the IACUC oversees all aspects of research animal care and use, protection of researcher health and safety is typically the responsibility of an occupational health and safety (OHS) department. This department usually requires all personnel working in the facilities or vivaria to complete, at minimum, a health questionnaire for clearance prior to beginning work.

Although we can relate to the veterinarian's concern about a person who is not listed on the IACUC protocol entering the animal facility, the Public Health Service Policy on Humane Care and Use of Laboratory Animals overseen by the NIH Office for Laboratory Animal Welfare applies only to activities involving live vertebrate animals. Therefore, collection of tissues from dead animals in the research setting might not require formal IACUC approval. But it is within the purview of the Great Eastern University IACUC to require Chambers to add Bryant to the protocol with a description of his role, limiting it to the collection of animal tissues post mortem. In addition to OHS clearance, the Great Eastern University IACUC might require Bryant to receive training on vivarium entry requirements, biosecurity and use of specific areas such as necropsy rooms. Bryant should complete any required training before being allowed to enter the facility. We also recommend Bryant's access be limited to the designated areas in which he will be working and that he be escorted at all times.

Although there is no legal mandate for the IACUC to review the use of tissues from dead animals, review of this kind of research at the institutional level is considered best practice1 in order to provide assurance that the institution has applied the appropriate standards to the acquisition, use and disposal of the animal tissues. Standardized review of this kind of research also serves the best interests of the institution for a variety of other regulatory and non-regulatory reasons (e.g., biosafety, liability and occupational health and safety).

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