Principal investigators are responsible for insuring that members of their staffs who work with animals are familiar with relevant procedures and details specified in the protocols. In addition, supervision of work performed on animals must be adequate to insure that approved protocols are being followed and that significant changes are not implemented prior to IACUC approval.
The Central Washington University Use of Animals in Research and Teaching policy [2-2.37] states "It is the policy of Central Washington University to provide the best possible care for animals used in research or teaching, thereby meeting or exceeding accepted guidelines and all applicable federal, state, and local legislation." One of the roles of the IACUC is to review all concerns about the animal care and use program, regardless of origin, and to investigate them as warranted. Furthermore, as an institution that accepts federal funds for research, CWU is legally obligated to report to the appropriate federal agencies (a) any serious or continuing noncompliance with PHS policy or the requirements or determinations of the IACUC, (b) any serious deviation from the provisions of the Guide and (c) any suspension of any activity by the IACUC.
The procedures described below are guided by recommendations in the OLAW Institutional Animal Care and Use Committee Guidebook.
B. NONCOMPLIANCE COMPLAINTS
Several types of noncompliance problems may be brought to the attention of the IACUC, such as:
C. NONCOMPLIANCE PROCEDURES
Given the wide range of possible noncompliance events, the procedures and timelines to be followed will depend on the seriousness of the situation and the potential impact on animals involved.
Emergent Situations: The IACUC is authorized to suspend an activity involving animals as set forth in the PHS Policy at IV.C.6.
An investigation will be performed of the research or activity against which the complaint is lodged and may include any or all research at CWU conducted by the principal investigator (PI). The investigation procedures may include but are not limited to:
The person(s) conducting the investigation will prepare a written report of the investigation findings that will be presented to the full IACUC at its next convened meeting. The report may recommend actions, if appropriate, based on its findings.
4. Possible findings
a. No evidence to support concern or complaint: A finding of no evidence will be signed by the IACUC chairperson. Copies of the communication will be forwarded to appropriate parties.
b. Concern or complaint not supported, but related aspects of animal care and use program or other institutional programs may require further review: A finding of no evidence will be made as above, and the issue will be followed up by the IACUC and/or reported to appropriate institutional officials or committees for their consideration.
c. Nonserious and noncontinuing : If the incident appears to be isolated and, in essence, a miscommunication of a nonserious or noncontinuing nature, the incident will remain internal to the university. A letter from the IACUC Chair to the PI describing a summary of the investigation will be written. A response from the PI describing corrective action, if any, is required. This will be considered the final step if the incident is considered nonserious and continuing noncompliance was not determined. The finding of nonserious and noncontinuing noncompliance will be signed by the IACUC chairperson. Copies of the communication will be forwarded to the PI, the PI's department chair or director, and the IO.
d. Serious or continuing : If the investigation indicates noncompliance that is serious or continuing, the IO will contact OLAW. If applicable, the funding source will also be notified. This notification will consist of an immediate phone call to apprise the office of the incident of serious or continuing noncompliance and will be followed with a formal report including corrective actions for this specific incident as well as for the research program in general at Central Washington University to ensure incidents will not occur again.
A letter to the PI describing a summary of the investigation will be written. This finding of serious or continuing noncompliance will be signed by the IACUC chairperson and may include corrective actions to be taken and/or recommendations to the IO for sanctions. Copies of the communication will be forwarded to the PI, the PI's department chair or director, the appropriate college dean, and the IO. The IACUC and the IO will confer as necessary to resolve the issue. All communication regarding the finding and resolution will be documented.
CWU Noncompliance Procedures Flow Chart