Covelli is correct that there are only a few specified functions where a quorum is required by the Animal Welfare Act Regulations1 or the Public Health Service Policy on Humane Care and Use of Laboratory Animals (PHS Policy)2: full committee review of a research project (PHS Policy IV.C.2 and 9 CFR Part 2 subpart 2.31(d)(2)) and suspension of an activity (PHS Policy IV.C.6 and 9 CFR Part 2 subpart 2.31(d)(6)). However, it can be inferred from the regulations and communications by the regulatory bodies that approval of minutes by the IACUC requires a vote of a quorum at a convened meeting. This is because the IACUC is required to maintain “minutes of IACUC meetings, including records of attendance, activities of the Committee, and Committee deliberations” (PHS Policy IV.E and 9 CFR Part 2 subpart C 2.35 (a)(1)).
Ultimately, the question at hand goes back to what is considered acceptable electronic communication in order to meet the requirement for a deliberative process. Garnett and Potkay, both formerly of the Office of Laboratory Animal Welfare, co-wrote an article on this subject in which they stated that the preferred method for meetings is to have all members present in the same room so that a full discussion could be conducted3. With the advent of technology, however, methods such as telephone or audio-visual conferencing may be appropriate, provided that the institution's Assurance allowed for this and that all members participating in the meeting are able to hear and interact with one another at the same time. What Covelli is suggesting, e-mail polling, is appropriate only for activities such as distributing and reviewing drafts of meeting minutes or reports. In addition, Garnett and Potkay also state that “all official IACUC reports are considered to be the result of 'full committee' action” and “[t]hus, endorsement of final reports issued under the IACUC aegis should include the opportunity for full participation and the opportunity for minority views to be expressed and recorded. This function should normally occur at a meeting of a convened quorum of the IACUC”3. Therefore, although this is not specifically addressed in the PHS Policy, it is clear that the Office of Laboratory Animal Welfare has interpreted that it is important that all members have a chance to participate in the deliberative process for the final vote on committee reports, such as meeting minutes, so that accurate descriptions of the discussions and votes are reflected in the permanent record.
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