There might be an unrecognized opportunity for collaboration between the two IACUCs as they consider advancing a mutually advantageous research endeavor. As dual review is not required, only one IACUC is responsible for reviewing and approving the activity. It is customary that the IACUC at the institution where the work with live animals is taking place assumes the responsibility. Although this is not a required arrangement, and technically both institutions can use discretion as they arrange their review, in this particular case the proposed work at Great Eastern University does not fall under IACUC purview at all. Since the work under IACUC purview concerns euthanasia for the purpose of harvesting tissue, the burden of review should fall on the BeachFront IACUC. However, if members feel that they are insufficiently familiar with the topic, the BeachFront IACUC can always request external expertise to advise their consideration of the proposal. They could, in effect, request such a review from Great Eastern University and use that feedback in their review decision. While a Memorandum of Understanding might be needed to formalize this arrangement—since there seems to be some ambiguity among these institutions on the matter—one is not necessary from a regulatory perspective because Gold's work uses tissues in vitro and therefore does not require IACUC oversight. Great Eastern University may elect to decline to contribute expertise to the review of this protocol in order to manage the scope of their portfolio and workload. Alternatively, it would also be appropriate for the BeachFront IACUC to rely upon other external consultants with appropriate expertise to review the proposal.
It is not entirely surprising that Flatt's protocol now requests additional animals for this collaboration. The principles of the 3Rs (replacement, reduction and refinement) generally encourage the sharing of post-mortem tissue, as this maximizes the use of research animals in both life and death; it is therefore unusual that an IACUC would express concern at such an approach. Still, the committee might be wondering whether it is necessary for Flatt to add additional animals to his protocol. Ideally Flatt, in coordination with Gold, would decide to only use tissue from those animals for which he had already been approved, collecting tissues post mortem when he had completed his own work. Under these conditions no additional IACUC review would be necessary, because Gold does not require IACUC approval to conduct research with tissues in vitro. It is safe to assume that there are already natural death or euthanasia endpoints for the existing protocol and the animals described therein, so the IACUC should have already assessed Flatt's relevant expertise with euthanasia in the initial review. In fact, given that both IACUCs are hesitant to accept the scientific merit of the work, one approach might be to adopt this 'slow and steady' plan. This approach would allow Flatt and Gold to collect initial pilot data that might subsequently support the merits of a larger study in the future. The effectiveness of this approach would depend on how regularly or frequently Flatt expects to euthanize or encounter natural deaths due to attrition in his colony.
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