Assuming that the post-operative analgesic regimen was written within the approved IACUC protocol, the research technician was in violation of the protocol when he decided to withhold the final dose of analgesia from the rat. The decision to withhold analgesics is considered a significant deviation from the protocol and, assuming this study was funded through PHS awards, this event must be reported to OLAW.
The OLAW website has a section addressing Frequently Asked Questions, where it states in FAQ B13 that, “...conducting procedures that constitute a significant change in approved animal activities without prior IACUC approval is serious noncompliance that must be reported to OLAW”1. In FAQ D9, OLAW states that, “examples of changes considered to be significant include, but are not limited to, changes...in anesthetic agents or the use or withholding of analgesics”1. While skipping the last dose of the analgesic may not have significantly impacted the animal’s well-being, the point is that the technician was not at liberty to make that decision.
The Great Eastern University IACUC was correct to vote for sanctions; however Newland was also correct in her conviction that the event be reported to OLAW—though the manner in which she went about reporting the incident could have been handled better. As a member of the IACUC, Newland has a responsibility to speak up and make her opinion known, especially when there are potential animal welfare concerns; just because she is vice-chair does not mean she needs to remain neutral when there are disagreements. After the IACUC majority voted to not report the incident, Newland had alternate reporting options: specifically she could have spoken with the chairman about the issue upon his return or taken the matter directly to the IO. According to PHS policy, all reporting from the IACUC to OLAW takes place through the IO, so it appears Newland was in violation of said policy2. She certainly betrayed the IACUC’s trust and intent by not speaking up at the meeting and defending her position. Had she approached the issue with the IACUC chairman or the IO, the matter could have been revisited and immediately reported in the appropriate manner.
References
- 1.Office of Laboratory Animal Welfare. Frequently asked questions PHS policy on humane care and use of laboratory animals. National Institutes of Health Office of Extramural Research. http://grants.nih.gov/grants/olaw/faqs.htm#630 (2016).
- 2.Public Health Service. Policy on Humane Care and Use of Laboratory Animals (US Department of Health and Human Services, Washington, DC, 1986, revised 2015). [Google Scholar]