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REGULATORY COMPLIANCE

PI finds number of IACUC inspections excessive

Reader Question: Our IACUC has a new chair, and it seems they are inspecting me every month. This seems really excessive, especially since I haven't been cited on anything yet. Is this a new regulation? Is there anything I can do to reduce the frequency?

Expert Comments:

Specific policies [PHS Policy (IV, B, 1; IV, B, 2) and AWAR (§2:31,c,1; §2.31,c,2)] require that institutional animal care and use committees (IACUCs) inspect animal facilities at least once every six months. An animal facility is either an animal housing area (animals housed more than 12 hours) or an animal procedure room. To my knowledge, most IACUCs do not go beyond this required number of facility inspections — especially because most members have duties outside their IACUC roles.

An inspection every month does seem excessive. However, without knowing the specifics of your situation, I can think of a number of reasons why there could be an apparent increase in inspections by a new IACUC chair (IC). For example:

• The IC might be establishing a new inspection schedule, which could initially result in some inspections closer than six months apart.

• The coordinator for inspections may not have all of your housing and procedure areas grouped in one inspection. (If this is the case, please notify the appropriate personnel and see if this can be corrected, not only for your benefit but for the IACUC’s as well.)

• How close is your institution to reaccreditation by the Association for Assessment and Accreditation of Laboratory Animal Care International (AAALAC)? Reaccreditation happens every three years and requires site visits. AAALAC has its own inspectors, but they usually are accompanied by IACUC inspectors. If it is close to accreditation time, there may be more visits to ensure that facilities are meeting recommendations of the Guide for the Care and Use of Laboratory Animals.

• Are you certain that all the inspections are in fact from IACUC members? Your institution’s attending veterinarian (AV) or his or her animal-care staff may make monthly rounds of facilities. While this is part of an institution’s animal-care program, it is not directly affiliated with IACUC.

• Other institutional programs (Occupational Health and Safety, Laboratory Safety, etc.) may involve inspections on a regular basis. The U.S. Department of Agriculture (USDA) also is required to make site visits to institutions receiving funding for USDA covered species.

• Recently, many IACUCs have developed strong written Post Approval Monitoring programs (PAMs). These are intended to ensure that PIs' research programs continue to be in compliance with their accepted protocols. Because many PAM programs are relatively new, they will initially involve more time for inspectors.

The IACUC is meant to represent the interests, not only of covered animal species but also those of the community, institution, and the PIs. I would suggest that you call your new IC and bring to his or her attention the number of inspections you've been getting. IACUC inspections were never meant to be burdensome to PIs or to IACUC members (many of whom are themselves PIs).

Perhaps there is a way to combine some of the inspections (e.g., semi-annual and PAM). I know of some IACUCs that have worked with other institutional programs so that inspections could be scheduled at the same time to reduce redundancies and decrease burdens on the PI.

I'm sure your new IC would welcome your feedback and useful suggestions to streamline the inspection process.

Comments by Debbie Cherney, PhD, MA, associate professor in the Department of Animal Science and seven-year IACUC member, Cornell University.