In this scenario, a dean of one of the schools of an institution, who is not a member of the IACUC, believes he has the authority as an official of the institution to revoke an IACUC approved protocol that uses pigs for cardiopulmonary resuscitation, because a new human cardiothoracic simulation lab will replace live animal use.

The Animal Welfare Act regulations (AWAR) specify two possible outcomes for an IACUC approved protocol: namely to undergo further appropriate review and approval by officials of the research facility1; or suspension by the IACUC during a convened meeting with a quorum present2.

An approved protocol may require further review and approval by other officials outside of the IACUC as a result of institutional policies and other regulatory requirements. The regulations only specify that these officials do not have the authority to approve an activity using animals that the IACUC has not approved1; as a result, it is left to the institution to determine the appropriate levels of review and approval necessary for the activity to proceed.

Under the AWAR, an Institutional Official (IO) is defined as the individual at a research facility who is authorized to legally commit on behalf of the research facility that the requirements of the regulations will be met3. The institution designates a person to serve as the IO. The dean in this scenario should learn who is serving in that role. The regulations do not give the IO the authority to suspend a protocol. Only the IACUC can suspend a protocol it has approved and the suspension can only occur during a convened meeting with a quorum present2. But while an IO cannot “suspend” a research activity in accordance with the regulations, the IO may, depending on the institution’s policies, have the authority outside of the Animal Welfare Act regulations to stop an IACUC approved activity.