Great Eastern does not need to reappoint the IO or the IACUC. As it says in 9 CFR 2.31(a), the CEO appoints the IACUC. Once the IACUC is properly appointed by a CEO—either past or present—there is nothing in the regulations that says the IACUC members must be reappointed when the CEO leaves or a new CEO joins an institution.

Senior management changes happen at an institution for many reasons and sometimes there is an interim CEO that precedes the appointment of a new CEO. In that case, should the IACUC get reappointed? Then, when the new CEO takes over from the interim CEO, should the IACUC get reappointed once again? The answer is obviously 'no' in both cases. The need for frequent reappointments would affect the proper function of the IACUC. CEOs may come and go in an institution, but to maintain continuity and smooth operation, the organizational structure of an institution should not be altered. A CEO may not be familiar with the AWRs, PHS Policy, or structure and function of the IACUC. In such cases, it may be prudent to brief the new CEO about the IACUC's role in overseeing animal research.

Moreover, the CEO always retains the authority to change the IO or the composition of the IACUC. The AWRs state that the CEO (or IO) “shall appoint an [IACUC], qualified through experience and expertise of its members to asses the research facility's animal program, facilities, and procedures1.” PHS Policy defines the CEO as the “highest operating official of the organization (such as the President of a university)2” and allows the CEO to delegate the authority to appoint the IACUC. The AWRs define the IO as “the individual at a research facility who is authorized to legally commit on behalf of the research facility that the requirements of 9 CFR, Parts 1, 2, and 3 will be met1.” According to the Guide for the Care and Use of Laboratory Animals (Guide), “the responsible administrative official at each institution must appoint an IACUC3.” If this authority is delegated in writing to someone other than the CEO, then that individual should have the ability to appoint the IACUC. In some institutions the CEO delegates the authority for appointing the IACUC to a senior administrator, who also often signs the Animal Welfare Assurance4.