The problems facing Great Eastern's IACUC are not unique to their institution or the use of electronic communications. Although the use of electronic communications in IACUC processes and procedures is relatively new, they do not fundamentally change regulatory requirements for these processes and procedures. Under PHS Policy and AWA/USDA Regulations, there are two acceptable methods of protocol review—Full-Committee review and DR review—both of which are specifically described. It is not clear whether the protocols are being handled properly by allowing for any member of the Committee to call for Full-Committee review before assignment of the protocol to the DR process. However, for the purposes of this discussion, we will assume that the Committee has properly assigned the protocols.
Although the primary concern of the Committee was about the details of expression of agreement among the DRs and the PR for protocol approval when communications were conducted electronically, this is a minor issue that is amplified by the awkward system currently in use. The authenticity of the electronic communications is not in question in this situation, as they are in most problems using electronic communication as part of the review process; instead, it is the lack of documentation being provided to the Committee, a concern about the absence of the usual full and open communication among all of the DRs, the PR, and the Administrator, and the use of an overly complex, quasi-legitimate process that is creating the problem.
This is a preview of subscription content, access via your institution