Per the inter-institutional agreements, the requested change in anesthetic delivery and drug should have received approval by both colleges before a change in ACUP (Animal Care and Use Protocol) procedure was made. Despite the fact that the veterinary verification and consultation (VVC) process was used for approval, the memorandum of understanding (MOU) between the two colleges clearly states that both colleges must review and approve changes to the protocol.

Per the NIH NOT-OD-126, Significant Changes to Animal Activities Previously Approved by the IACUC, point 2.aA. “The specific significant changes described in 2.a-c, may be handled administratively according to IACUC-reviewed and approved policies with a veterinarian authorized by the IACUC…. This includes changes in: a. anesthesia, analgesia, sedation or experimental studies.” The change in anesthetic delivery constitutes a significant change that is out of the scope of a VVC and not within the MOU between institutions.

As this is an NIH-funded study, appropriate external reporting of the incident should be determined by the institutions’ IACUCs.

Additional considerations for the change from injectable anesthetic drug to inhalant gas anesthesia may include the need for updates and changes to an administrative appendices for the ACUP, occupational health and safety concerns and possible need for staff training. As the use of inhalant anesthetic gases by mask administration carries increased risk to those involved, additional consultation and/or enrollment of those in contact should include their enrollment in the institutions occupational health and safety program.

As there is ongoing collaboration of research studies being conducted by the two institutions, a method for flagging collaborative studies where an MOU exists should be developed or (if exists) reviewed to help prevent future recurrences. This oversight falls on the shoulders of the IACUC chair and/or administrator.