The Great Eastern IACUC acted promptly and appropriately when notified of the noncompliant activity involving wound dehiscence and infection in post-surgical animals. Given the scale of the animal welfare concern created by this incident, it is likely the IACUC will vote to report the incident to the Office of Laboratory Animal Welfare (OLAW) at the National Institutes of Health. The lack of aseptic technique and shoddy surgical practices jeopardized the health and well-being of the animals and led to the subsequent euthanasia of the animals involved (Guidance on Prompt Reporting to OLAW under the PHS Policy on Humane Care and Use of Laboratory Animals, NOT-OD-05-034; ref. 1). The Great Eastern IACUC's decision to report this incident to OLAW would require a majority vote of the IACUC members in attendance.

Suspension of an animal activity initiated by the IACUC is a severe action reserved for the most serious situations. The IACUC is more likely to temporarily suspend the activity until the infractions are corrected. The most favorable situation is for the Principal Investigator (PI) to voluntarily suspend any animal-related activities until IACUC-directed retraining and corrective actions are completed.

Given the assurances of Girard and the PI that future surgical manipulations would be done as expected and the IACUC's mandate for further oversight, the committee would likely accept voluntary suspension of the activities approved under the PI's animal protocol. Possible corrective actions would be for Girard and the PI to meet with the Chair of the IACUC to receive counseling. During this meeting, the Great Eastern IACUC chair could stress the seriousness of the deviations, remind the PI and Girard that using animals is a privilege and not a right and also notify them of their required attendance at another survival surgical training session.

Even though Girard attended surgical training sessions and was well aware of the expected techniques and practices involved in survival surgery in animals, the Great Eastern IACUC does not seem to have policies in place outlining survival surgery and aseptic technique to which they can refer in this situation. The Guide for the Care and Use of Laboratory Animals2 addresses the subject of survival surgery and aseptic technique. Great Eastern can refer to this document as the basis for the proposed IACUC policy on aseptic technique and survival surgery. The Great Eastern IACUC protocol form should be reworked either to outline required practices in survival surgery or to refer to accepted aseptic technique and required survival surgery practices in the survival surgical portion of the form. The resulting IACUC-approved policies and guidelines would serve as a resource to all animal users regarding the IACUC's expectations.

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