Reporting, Receiving, and Handling Allegations of Misreatment or Other Noncompliance Issues

Reporting Noncompliance

DEFINITIONS

Mistreatment: Any action, physical or psychological, which results in wrongful or abusive treatment of an animal (e.g., inadequate or improper care or housing of animals).

Noncompliance: Violation of University procedures or policies, which encompass those of the Public Health Service and the Animal Welfare Act.  Examples include unauthorized use of animals for an activity or procedure; failure to have an active ARC approval for an activity involving animals; continuing an activity past its authorized expiration date.

Reporting allegations: It is not always obvious at what level of alleged mistreatment or noncompliance the Institutional Animal Care and Use Committee should become involved.  Frequently, the attending veterinarian, animal care personnel, and investigators can work together to prevent or resolve a problem.  However, serious or repeated problems always require the involvement of the IACUC.  If in doubt, it is better to submit a report, as this may well protect the institution, the complainant, the alleged violator(s) and, of course, the animals.

Below are examples of OLAW (Office of Laboratory Animal Welfare) reportable situations (to print a lab friendly posting, click here):

 1. Conditions that jeopardize the health or well-being of animals, including natural disasters, accidents, and mechanical failures, resulting in actual harm or death to animals;

 2. Conduct of animal-related activities without appropriate IACUC review and approval;

 3. Failure to adhere to IACUC-approved protocols;

 4. Implementation of any significant change to IACUC-approved protocols without prior IACUC approval;

 5. Conduct of animal-related activities beyond the expiration date established by the IACUC (note that a complete review is required at least once every three years);

 6. Participation in animal-related activities by individuals who have not been determined by the IACUC to be appropriately qualified and trained;

 7. Failure to monitor animals post-procedurally as necessary to ensure well-being (e.g., during recovery from anesthesia or during recuperation from invasive or debilitating procedures); 

 8.  Failure to maintain appropriate animal-related records (e.g., identification, medical, husbandry);

 9. Failure to ensure death of animals after euthanasia procedures (e.g., failed euthanasia with CO2);

 10. IACUC suspension or other institutional intervention that results in the temporary or permanent interruption of an activity due to noncompliance with the Policy, Animal Welfare Act, the Guide or the institutions's Animal Welfare Assurance. 

REPORTING PROCEDURES

Allegations may be reported in conversation with, or correspondence (letter, fax, email) with the IACUC Administrator, members or staff of the DLAM, the veterinary staff, the Chair of the IACUC or the Institutional Official (Vice President- Research).  There shall be no restrictions on who can report an alleged incident and there can be no threat of reprisal against anyone reporting the perceived mistreatment or noncompliance.  Any information should quickly be relayed to the Chairperson of the IACUC for action.  All complaints brought to the attention of the IACUC will be fully documented under signature.  There must be sufficient substance to the complaint for the Chair to proceed further.  An allegation has no substance until proven, and should remain confidential to the extent possible to protect all concerned.  If the complainant has freely identified him/herself, it is appropriate that receipt of the allegation be acknowledged.

CONTACT INFORMATION


IACUC office

DLAM vet staff

Phone

817-735-2533

817-735-2017

Email

Kim.Cavanaugh@unthsc.edu

Egeenee.Daniels@unthsc.edu

Fax

817-735-2406

817-735-2406

Mailing Address

IACUC Office

Office of Research Compliance

UNT Health Science Center

3500 Camp Bowie Blvd.

Fort Worth, Tx 76107

Attn: Attending Veterinarian

Dept. of Lab Animal Medicine

UNT Health Science Center

3500 Camp Bowie Blvd.

Fort Worth, Tx 76107

ADDITIONAL CONTACT INFORMATION CAN BE FOUND HERE: Contact List

IACUC PROCEDURES FOR THE INVESTIGATION OF A COMPLAINT

The Chairman may elect to bring the matter as a whole before the Committee or he may appoint a subcommittee to investigate the complaint.  In either case, the results of the investigation must be considered IACUC actions and all members must have the opportunity to present their views.  The person(s) against whom the complaint has been raised should have an opportunity to explain their position.  As much documentation as is reasonably needed will be collected.  This may include animal receiving records, housing and health records, billings, memos and other written materials.  It may also be necessary to interview persons or to carry out an inspection of the facilities.  The results should be made available to all parties involved, including the Institutional Official who is ultimately responsible for instituting corrective action.

INSTITUTIONAL RESPONSES

This is influenced by legal requirements, institutional policy and the nature of the investigative findings.  If the violation is verified by the IACUC, the IACUC is empowered under USDA Regulations and PHS Policy to suspend a previously approved project.  If the activity is supported by PHS funds, the IACUC, through the Institutional Official, must file a full report to the National Institutes of Health, Office of Laboratory Animal Welfare (OLAW).  In cases where there is sufficient evidence of serious noncompliance, it may be prudent for the IACUC to suspend an activity pending the outcome of a full investigation.  In these cases, a preliminary report will be sent to OLAW and the USDA, through the Institutional Official, on the understanding that a full report will be submitted upon completion.

The Institutional Official, in consultation with the IACUC, has the power to impose further sanctions on an investigator found to be responsible for mistreatment or noncompliance.  Each case must be considered individually and all cases will result in precedents being set, and the implications of these should be considered.  The institution must also consider whether to announce its findings publicly.

This page last updated 24th Sep 2014