For many years, Happy Trails, a not-for-profit wildlife rehabilitation organization (WRO), occupied an otherwise unused building on the campus of Great Eastern University. There was no rent involved, and as far as anybody could remember, there was no formal relationship of any kind with the school. Students in Great Eastern's biology and other departments often volunteered at the WRO, and because the local newspapers always gave positive press to the WRO, Great Eastern saw no need to change the status quo. The Great Eastern IACUC also took a hands-off approach, rationalizing that because no research or teaching activities took place at Happy Trails, the WRO was not under its jurisdiction. Joanne Gusset, the attending veterinarian at Great Eastern, occasionally provided pro bono veterinary assistance to the WRO, and on occasion, the animal facility provided the WRO with dead, culled mice to feed to its raptors. More often, to feed the raptors, the WRO purchased live rats and mice from a local source unrelated to Great Eastern.

The WRO eventually began looking for larger quarters, but before it moved, an incident occurred wherein a live rat being fed to a raptor was injured but not killed by the bird. The community volunteer feeding the animal should have, but did not, observe what happened, and it was not until later that afternoon that a student volunteer found the severely injured animal. She called Gusset, who immediately came, euthanized the rat and reported the incident to the Great Eastern IACUC. At first, the IACUC chairman was not sure if he should do anything, given the IACUC's perceived non-existent relationship with the WRO, but he decided to have an IACUC subcommittee investigate the incident. The subcommittee eventually recommended to the full committee that the WRO's activities on campus should be suspended. This was a moot point because by that time, Happy Trails had already moved to its new location. When the IACUC chairman, the Institutional Official and Gusset met to discuss the incident, they decided to drop the issue because the WRO was no longer on the Great Eastern Campus.

Six months later, during a routine USDA/Animal Care inspection at Great Eastern, the inspecting veterinarian read the IACUC minutes of the incident and cited Great Eastern for inadequate veterinary care, conducting an animal activity without IACUC approval and failure to promptly report the incident.

Should Great Eastern have handled the entire situation any differently than it did? Do you think the inspecting veterinary officer should have cited Great Eastern? Should Great Eastern appeal the citation?

Response to Protocol Review Scenario: Get engaged

Response to Protocol Review Scenario: Hands off

Response to Protocol Review Scenario: A word from USDA

Response to Protocol Review Scenario: Lessons learned