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Just because you can, should you?

Lab Animal volume 51, page 207 (2022)Cite this article

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Requirements for DMR outlined by the NIH Office of Laboratory Animal Welfare (OLAW) and the USDA APHIS 9 CFR AWR does not prohibit reassigning a protocol review to another reviewer by the Chair if all the members of the IACUC were given a reasonable opportunity to call for Full Committee Review (FCR) when the renewal was first submitted for review1,2. However, whether this is a viable option for an institution is dependent upon what is stated in the Assurance that is on file with OLAW and any IACUC-approved institutional policies.

While reassigning the protocol to a different DMR may avoid expiration of a time-sensitive protocol, the waste of animals and possible reports to regulatory agencies, it may not be a best practice. It is not necessarily bad to have a new reviewer who may catch issues the prior reviewer missed, but the new reviewer may not follow up on Principal Investigator (PI) responses to the prior reviewer’s comments as extensively. This means some concerns may not be fully addressed to the satisfaction of all reviewers involved. Also, one must ask how the Chair becoming the reviewer would be perceived by a USDA inspector or AAALAC International site visitor if they ask for this protocol’s records. There could be a negative perception of the institution’s commitment to a robust protocol review process and, ergo, animal welfare.

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References

  1. Public Health Service Policy on Humane Care and Use of Laboratory Animals – Frequently Asked Questions. https://olaw.nih.gov/faqs/#/guidance/faqs?anchor=question50314

  2. USDA, Animal Welfare Act and Animal Welfare Regulations. https://www.aphis.usda.gov/animal_welfare/downloads/bluebook-ac-awa.pdf

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Authors and Affiliations

  1. Memorial Sloan Kettering Cancer Center, New York, NY, USA

    Judith L. Farber

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  1. Judith L. Farber
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Correspondence to Judith L. Farber.

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Farber, J.L. Just because you can, should you?. Lab Anim 51, 207 (2022). https://doi.org/10.1038/s41684-022-01023-x

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