Office of Laboratory Animal Welfare
May 21, 1990
This letter is to clarify a provision of the Public Health Service
Policy on Humane Care and Use of Laboratory Animals (PHS Policy)
regarding protocol review by Institutional Animal Care and Use
Committees (IACUCs). The Office for Protection from Research Risks
(OPRR), as a result of increased site visit activity, has identified
a number of situations in which the requirements for IACUC review
of proposed activities have been misinterpreted.
The problem involves the misuse of so-called "expedited"
review procedures by IACUCs using the designated reviewer provision
set forth in Paragraph IV. C. 2. of the PHS Policy. Some institutions
have inappropriately allowed designated reviewers to grant approval
and for animal research activities to begin before all
members of the IACUC have had an opportunity to request review
by the entire Committee. This procedure is frequently referred
to as "provisional approval."
The process of approving research prior to providing opportunity for each Committee member to request review by the full Committee is contrary to the PHS Policy. OPRR considers the opportunity for any member to call for full Committee review before approval is given and before animal work begins to be an important safeguard of the well-being of animals. This PHS Policy requirement is also explicitly stated by the U.S. Department of Agriculture in Part 2, Section 2.31(d)(2) of their Animal Welfare Regulations.
All institutions are advised to evaluate IACUC procedures for
review of animal-related activities for compliance with the PHS
Policy and USDA Regulations. Additionally, the institution's Animal
Welfare Assurance should be reviewed and, if appropriate, clarified
in order to bring institutional practices into full compliance
with the PHS Policy and USDA Regulations. If needed, amendments
to Institutional Animal Welfare Assurances should be forwarded
to OPRR without delay.
Charles R. McCarthy, Ph.D.
John G. Miller, D.V.M.