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Investigating Animal Welfare Concerns
A final mandate given to the IACUC is to review, and if warranted, investigate allegations of improper animal use or concerns about such use. This includes allegations from both inside and outside of the institution. Allegations sometimes concern animal activities being performed without IACUC approval, or being conducted in ways not consistent with the information provided to the IACUC during the review process.
When raised, allegations should be taken seriously and thoroughly investigated in a timely manner. By doing so, the IACUC can move quickly to stop inappropriate activities, or to prevent unfounded allegations from negatively impacting legitimate research. Because communication with institutional officials is so important, it is a best practice for the IACUC Chair to notify the IO as soon as allegations arise to discuss an appropriate institutional or IACUC response.
The AWRs and PHS Policy make no specific requirement for how the IACUC should review allegations. Because it can be unwieldy to involve the entire IACUC in an investigation, many IACUCs form a subcommittee to collect facts and report them back to the full committee. The IACUC may then discuss the collected facts of the investigation during a convened meeting, decide if the allegations have merit, formally approve a course of action by a majority of a quorum, and prepare a report for the IO which includes appropriate recommendations.
If the IACUC decides to suspend an activity as a result of its investigation, it must meet in a convened meeting, and a majority of a quorum of voting members must vote to do so.
It is important to note that it is against federal law for an institution to take any reprisal against any employee who reports a violation of the USDA Animal Welfare Act Regulations. Institutions should maintain an open and receptive atmosphere that encourages employees to contact the IACUC with concerns about any aspect of the Animal Care and Use Program.