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A Word from OLAW and USDA

Lab Animal volume 51, page 150 (2022)Cite this article

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In this scenario, two incidents of personnel safety findings involving research with animals were handled by the IACUC with varying outcomes. In the first incident, because the IACUC-approved protocol required containment housing and the required housing was not used, it would be a reportable noncompliance to OLAW1. Such a housing change potentially impacts personnel safety and is a significant change that requires IACUC approval via designated member or full committee review2. For this specific example, the findings involving lack of protective eyewear and eyewash flushing are outside the scope of the IACUC’s animal welfare focus and require corrective action but are not reportable to OLAW.

While the IACUC may, during its semiannual facility inspections or post-approval monitoring, identify safety and other regulatory concerns, further investigation, and corrective actions, including training, are the concern of oversight components responsible for enforcement of the specific safety or regulatory issues (hazardous agents, radiation, controlled drugs, chemicals, recombinant DNA, etc.). The IACUC has the discretion to recommend a corrective action in such cases but would reduce its workload by leaving the oversight to others. As mentioned by other reviewers, the PHS Policy section IV.A.1.f. and the Guide consider occupational health and safety critical in the oversight of research animal care and use3,4. The Guide expects safety equipment to be maintained properly and personnel to be trained and to use the safety equipment provided4. An effective safety program requires evaluation of the institution’s research program components and the associated risks combined with coordination by the researchers, animal facility, IACUC and the safety unit(s)4,5. In this case, the IACUC should reconsider its own role in oversight and work more effectively to ensure training for new employees and enhanced cooperation with its oversight counterparts.

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References

  1. National Institutes of Health, Office of Extramural Research 2005. Notice NOT-OD-05-034, Guidance on Prompt Reporting to OLAW under the PHS Policy on Human Care and Use of Laboratory Animals. http://grants.nih.gov/grants/guide/notice-files/not-od-05-034.html

  2. Office of Laboratory Animal Welfare, National Institutes of Health. Notice Number: NOT-OD-14-126: Guidance on Significant Changes to Animal Activities, Available at: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-126.html

  3. Public Health Service. PHS Policy on Humane Care and Use of Laboratory Animals. (U.S. Department of Health and Human Services, National Institutes of Health, Bethesda, MD, 2015). Available at: https://olaw.nih.gov/policies-laws/phs-policy.htm

  4. Institute for Laboratory Animal Research. Guide for the Care and Use of Laboratory Animals. 8th edn., 17–23. National Academies Press, Washington DC, 2011).

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  5. Public Health Service. Policy on Humane Care and Use of Laboratory Animals –FAQ. Institutional Responsibilities, Question No. G.2. What is required for an occupational health and safety program? (US Department of Health and Human Services, Bethesda, MD, USA). online at: https://olaw.nih.gov/faqs#/guidance/faqs?anchor=question50377

  6. Animal Welfare Regulations 9 CFR § 2.31(c)(3).

  7. Animal Welfare Regulations 9 CFR § 2.31(d)(8).

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Author information

Authors and Affiliations

  1. Director, Office of Laboratory Animal Welfare, OER, OD, NIH, HHS, Bethesda, MD, USA

    Patricia Brown

  2. Deputy Administrator, Animal Care, APHIS, USDA, Riverdale, MD, USA

    Betty Goldentyer

Authors
  1. Patricia Brown
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  2. Betty Goldentyer
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Corresponding authors

Correspondence to Patricia Brown or Betty Goldentyer.

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Brown, P., Goldentyer, B. A Word from OLAW and USDA. Lab Anim 51, 150 (2022). https://doi.org/10.1038/s41684-022-00983-4

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