Finding ‘qualified’ nonaffiliated members…the struggle is real

The regulatory requirements that should be reviewed are available and reliable to utilize when considering recruitment of qualified nonaffiliated IACUC members. Yet finding the perfect person who aligns to the cookie cutter version of what it means to be a nonaffiliated IACUC member is not an easy task in spite of the resources. Starling College, like many of us, reached out to those we know or have connections with for assistance.

There are a couple of things for both Starling College and Great Eastern University to consider before Rubin gets an appointment to Starling’s IACUC. First, as far as I know, there are no regulations that would prohibit someone from serving on more than one IACUC as long as the IACUC organizations are at two different institutions.¹ The issue of leakage of scientific ideas or procedures (proprietary information) may be a concern; however, both institutions should address this armed with proper training in the concerns of confidentiality. In most cases where this is an issue, institutions should follow the protocol of having the individual(s) sign a formal nondisclosure agreement, which would then properly address the issues related to disclosures. Second, both institutions need to discern the spirit in which the regulations define the term “nonaffiliated.”

There are three distinct criterion used by regulatory bodies to define a ‘nonaffiliated member:’ first, the member is not a laboratory animal user or former user; second, they are not affiliated with the institution; and third, they are not an immediate family member of an individual affiliated with the institution^2,3. In this scenario, the Starling IACUC would need to deliberate on the perceived conflict of interest by utilizing a former employee to fulfill the nonaffiliated role. In this situation, Rubin is not receiving any financial or other benefits from Starling even though she is a former employee. In addition, she is not serving on any other committee at Starling—her affiliation is strictly with its IACUC. This is an important consideration; because her income comes from Great Eastern University, any opinions or remarks that she may make during a Starling IACUC meeting would not put her at odds with her employer. Opinions also indicate that having someone familiar with the institution could lead to greater participation and a better quality of discussion during meetings.⁴

Rightfully so, utilizing a former employee can certainly be a gray area for some regulatory agencies. Where possible, it would be in the best interest of Starling College to find someone who is unmistakably nonaffiliated. If that is not the case, then I would recommend that both the IACUC and Institutional Official meet with Rubin on the record so that she can assure Starling College that she can fulfill the requirements of the nonaffiliated member as noted by the regulations.