The IACUC Chairperson was correct, in that the drawing of blood for clinical cases does not require an IACUC-approved protocol. If the veterinarian had drawn the blood before Burbank asked for a 1-ml sample, and there was extra blood already drawn, that would have been acceptable. Madela is also correct. One could consider the request for extra blood to be drawn as two separate collections: the usual amount for the clinical studies and the additional 1 ml requested for the research project. Because the additional 1 ml was drawn specifically to obtain data for a research proposal, an IACUC-approved protocol was necessary.
A situation similar to the drawing of blood involves the use of archived tissues that are collected at necropsy from animals on an approved project. Years later, another investigator may examine these archived materials to provide preliminary data for a proposed project. Although the tissues were not collected for the preliminary data study, they are available for that study. If the investigator had requested access to these tissues before they were collected, then that would require an approved IACUC amendment to the project involving the animals at the time of necropsy. If tissues and blood are routinely collected at necropsy and are later available for preliminary data, then an IACUC-approved protocol should not be necessary.
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