This is a common problem. What to do when the regulations are not explicitly stated, and the investigator says, “If it is not in the regulations, I don't have to do it”? Morrison is correct in stating that his work is not covered by the AWRs. However, if his work is funded by the Public Health Service (PHS), his studies are subject to the Health Research Extension Act of 1985. This law requires that “animal care committees... assure compliance with the guidelines established...” including “...appropriate pre-surgical and post-surgical veterinary medical and nursing care....1” The guidelines referred to in this Act are those set forth in the PHS Policy on Humane Care and Use of Laboratory Animals (PHS Policy) and the Guide. If the PHS does not fund his work but his institution has filed assurance with the Office of Laboratory Animal Welfare (OLAW), and/or the Association for Assessment and Accreditation of Laboratory Animal Care International (AAALAC International) accredits his institution, then the IACUC really does have the final say in this matter (not just the AV). The IACUC does have the authority to compel Morrison to keep medical records they believe to be appropriate.
The main point is that the IACUC must assure compliance. What is the best mechanism to assure compliance that can withstand external review? If outside reviewers can 'easily' follow the mechanisms for IACUC oversight and find that oversight to be appropriate, the IACUC is doing its job. Everyone close to the field of laboratory animal science would agree that a veterinarian can be trusted to provide appropriate postoperative medical care (blatant bias intended). However, the most appropriate manner to 'assure' that appropriate postoperative care is given would be to maintain records. The AV is correct in stating that “...it would be impossible for the IACUC to determine whether proper postoperative care was provided if there were no records for review.” Maintaining medical records for rodents is new, but times are changing. We can no longer use the excuse that the volume of paperwork would impede research and thus these species do not require the same level of oversight. Institutions can achieve this oversight by following a performance-based approach, which can be efficient for both the IACUC and the investigator.
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