Though not stated in the scenario, we are to assume that the protocol going to the DRs has been previously sent to all members of the IACUC, any of whom have the right to call for a Full-Committee review. Given that no member calls for a Full-Committee review, it seems that the process that Great Eastern University's IACUC has been using to review protocols, by use of the DR method, complies with the Animal Welfare Act Regulation and is consistent with guidance provided by the Office of Laboratory Animal Welfare and the United States Department of Agriculture1. The Chair of the IACUC may appoint an individual to be the PR and grant him or her the authority to convey the final approval decision. DRs do not have the authority to disapprove a protocol. They can only “...approve, require modifications in (to secure approval), or request full Committee review...2.” Therefore, in effect, they do not vote. If, in the end, all DRs are not in agreement, then the protocol must go before the convened IACUC for a Full-Committee review. The suggested use of the voting feature on the email program would seem to give the erroneous impression that the DRs were voting.
If the Chair has appointed a PR and granted him or her the authority to convey the final approval decision, then there is no need for the IACUC Administrator to have on record documentation from all DRs indicating so. It is incumbent upon the PR to ensure that the process is complete before notifying the IACUC Administrator of a decision. All DRs must see the final product as changes are made and give agreement for approval before the PR conveys such approval. If the other reviewers are receiving email of all correspondence and interactions as indicated, then there should be sufficient communication to make an informed and appropriate decision.
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