Given that the IACUC is empowered to suspend a project if it finds non-compliance with the PHS Policy, the Guide, Institutional Assurance, or violations of the Animal Welfare Regulation, is this empowerment extended to the institutional-appointed Attending Veterinarian (AV)1,2? The AV will need to be empowered to have the appropriate authority to support a comprehensive animal care and use program that ensures the health and well-being of animals. If Great Eastern University (GEU) has a written policy that describes the AV’s authority that includes suspending an animal-related activity prior to IACUC review, if warranted because of serious and urgent animal welfare and safety concerns, then Dr. Thompson followed the duties expected of someone with AV authority. Although an immediate convened IACUC meeting couldn’t be secured, there was proper hierarchical notification to the IACUC Chair, IACUC Director, and the PI, Dr. Guaio, of Dr. Thompson’s concerns which are critical in ensuring institutional accountability and communication for the welfare of the rabbits.
Dr. Thompson may have identified this event as serious non-compliance based on: (1) a failure to adhere to IACUC-approved protocol by not following the single-housing experimental design, (2) creating a condition that jeopardizes the health or well-being of the rabbit with the two rabbits potentially fighting, and (3) the continuing non-compliance as demonstrated by what Dr. Guaio shared with the repeat error by the laboratory technician. The AV terminating access to the vivarium is a form of temporary suspension, and the IACUC at a convened meeting with quorum can vote to approve the suspension of access, modify, or lift it. There is no complete suspension of any or all protocol activities; thus Dr. Guaio can still perform the animal activities as approved, amend the protocol to add qualified personnel, or make arrangements with the animal care staff so the animals are properly monitored and/or initiated experiments can be saved, if allowed, according to the protocol.
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