The intent in submitting a proposal to the IACUC is to provide accountability for the animals being used for research. Accountability includes providing documentation and proof of what each animal is expected to endure during a particular study.

Concurrently running protocols on the same animals violates the requirement to declare all PIs and personnel working on the IACUC proposal because it undermines the accountability requirement. Everyone must be listed so that the IACUC can determine if the personnel are qualified1,2,3. Maintaining separate protocols for experiments on the same animals appears suspicious, as though the researchers are trying to hide something and somehow subvert full disclosure to the NIH or granting agency. Two protocols violates the spirit and wording of grant rules.

Creating a second protocol applying to the same animals undermines the ability to care for and singly account for the animals. If one of the rabbits became ill, there would be no clear recourse as to which PI can authorize treatment or euthanasia options. To carry Bergman's own argument through further, what if Wycroft's protocol is suspended for review? It would be easy to deny knowledge of the other studies taking place on his animals and difficult to localize the true source of the problem inciting the review.

While the researchers should be commended for their willingness to reduce the number of animals used, this particular proposition will not work. There remain several viable options. The first is to modify the existing Wycroft IACUC proposal to include Bergman's blood work as initially discussed. Routine blood work is often included in studies to confirm the health status of the participants. It would be unlikely the NIH would consider it a deviation from the original protocol. Depending on the time required to finish Bergman's study, Wycroft could wait and transfer the rabbits to her own protocol when available. The final option is to purchase new rabbits. Even though the final option requires new animals, it still provides the accountability to prove they receive appropriate care.

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