This scenario was based around having an off-site attending veterinarian (AV) to service the veterinary care of Reddington State University (RSU), but could also be applicable to situations where the AV is a full-time staff member. We believe RSU should appeal the citation for several reasons. It is stated that RSU has a written program of veterinary care and is approved by the USDA, therefore, the citation appears to have been issued based on the choice of clinical care and a principal investigator (PI) decision to euthanize the pig.

The Animal Welfare Act Regulations1, the Guide2, and ACLAM3 all state that a facility shall provide adequate veterinary care and state further that there should be timely and accurate methods for communication of any abnormalities in or concerns about animal health, behavior, and well-being to the veterinarian. According to the USDA Animal Welfare Inspection Guide4, the facility should be considered in compliance if: the veterinary care issue was identified by the facility prior to inspection; and the facility followed the authorized treatment plan or contacted the AV; and the treatment plan was followed but does not appear to be effective and the licensee re-contacted the AV.

The inspector’s opinion that the AV was negligent in not prescribing or discussing antibiotic therapy is an inappropriate position to take if the citation was not based on medical record review and/or discussion with Dr. Meyers. Further, accusations of negligence on the part of a practitioner, if valid, should be addressed with the state veterinary medical board and only used as a basis for facility citation if true negligence were established by that board.

One of the interpretations with this scenario is that the PI did not report the animal’s change in condition to the facility. If he did not, then the facility would not know to contact the AV for follow-up. This is a difficult position for the facility since the PI has control of his study animals and may elect euthanasia if an animal is at risk for a decline in health or well-being and can no longer be used in the study. This is a common scenario in many facilities, including both industry and academia, wherein PIs can, and do, remove animals for a variety of reasons without having to contact veterinary resources. It is also unclear if the USDA Veterinary Medical Officer is aware that the PI has this authority, independent of veterinary opinion.

The PI’s lack of communication does not mean that an inadequate program of veterinary care existed at the facility and therefore should not be the basis for a citation of non-compliance. Whether RSU will appeal the citation will be more of an administrative/political decision, but an IACUC reevaluation of the procedure for reporting adverse events is definitely a good idea. If the IACUC already has a policy it thinks is sufficiently clear, the PI is in need of training on the responsibilities of reporting adverse events and documenting activities for both facility and regulatory review.