In response to the questions posed in this scenario, the United States Department of Agriculture, Animal and Plant Health Inspection Service, Animal Care (USDA, APHIS, AC) offers the following guidance:

This scenario raises questions about the regulatory requirements for personnel training and ensuring the humane death of an animal as it applies to activity using wildlife. For activity regulated by the Animal Welfare Act (AWA), the IACUC is required to assess whether the method chosen for humane destruction produces rapid unconsciousness and subsequent death without pain or distress, as defines euthanasia (§2.31, §1.1; ref. 1). In the case of wildlife research, acceptable resources for this information include but are not limited to the American Veterinary Medical Association's Guidelines for the Euthanasia of Animals2, expert consultants (§2.31(c)(3); ref. 1) and recommendations from taxon-specific organizations such as the American Society of Mammalogists.

Under the AWA regulations, the IACUC is qualified to assess the research facility's animal program, facilities and procedures; hence methods to assess proficiency and training are at the discretion of the IACUC (§2.31(a); ref. 1). It is the IACUC's responsibility to confirm that death is achieved appropriately when necessary, and it is the institution's responsibility to make training available and ensure that all personnel working with animals are qualified to perform their tasks (§2.32; ref. 1).

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