Assuming that Great Eastern University has a Public Health Service (PHS) Assurance and is accredited by the Association for Assessment and Accreditation of Laboratory Animal Care International, the university needs to abide by the PHS Policy on Humane Care and Use of Laboratory Animals1 (PHS Policy) and the Guide for the Care and Use of Laboratory Animals2 (the Guide); the former requires “animal care committees at each entity which conducts biomedical and behavioral research”1. Because the animals destined for MDL are ordered by and temporarily housed at Great Eastern University, Great Eastern is responsible for the oversight of these animals. Moreover, approval of the Great Eastern University IACUC is necessary for the current arrangement.

Great Eastern seems to treat MDL as a 'satellite' facility. Therefore, it was appropriate to have an IACUC-approved protocol for the procedures done at MDL and to include the facility in the semiannual IACUC inspections. However, Covelli's comments regarding the IACUC's oversight of the current situation suggest that Great Eastern may not be completing all required IACUC duties, including proper post-approval monitoring and adequate training. A formal written agreement between the collaborating institutions is necessary to define their respective responsibilities and ensure that MDL is following all federal laws and regulations.

Covelli's suggestion that Great Eastern order the animals and have them delivered directly to MDL is not a satisfactory solution. If the Great Eastern IACUC is trying to minimize its involvement with MDL, it should avoid all aspects of the arrangement. Because MDL does not receive federal funding or house any species covered by the USDA, the facility is not subject to the guidelines of the PHS Policy1, the Animal Welfare Act and Regulations3 or the Guide2. Consequently, if the current situation is altered so that all animals are ordered by and sent directly to MDL, without any connection to Great Eastern University, an IACUC protocol would not be necessary.

MDL should be able to obtain its own animals without substantially affecting its operations. Instead of having access to animals on an 'as needed' basis, as it does under the current arrangement with Great Eastern, MDL would need to plan about one week in advance to order its animals directly from a vendor. As there is currently no acclimation period to the new facility, having animals delivered directly to MDL should not present a problem.

The Great Eastern IACUC should thoroughly evaluate the situation when deciding whether to renew the protocol. The current arrangement may be a source of revenue for Great Eastern, and continuing it may preserve the neighborly relationship between the institutions. However, the Great Eastern IACUC must be certain that the relationship is clearly defined and that its post-approval monitoring is adequate.

Return to Protocol Review