Firstly, the decision to develop an enhanced PAM program should be commended. While there are no regulations for a formal PAM program outside of the IACUC's federally mandated continuing review requirements, the Guide, alongside my own experiences, suggest that this both enhances the wellbeing of animals, and provides opportunities to refine research procedures. With the PAM staff reporting to the IACUC, I feel that Covelli, as the Chair of the IACUC, is their supervisor. However, this is fraught with issues. The Chair likely does not have sufficient understanding of regulations governing IACUC operations, or PAM programs, to be able to appropriately supervise them. In addition, there is a significant potential for a conflict of interest to arise. To avoid this, it would be preferable for the PAM personnel to report to a single person in the Office of IACUC, or equivalent department.
Having found and reported the noncompliance, PAM specialist Hall should feel that she has fulfilled her job responsibilities. This is because it is the responsibility of the IACUC, and not the PAM officers, to assess whether an activity is in accordance with all federal regulations and the institution's Animal Welfare NIH/OLAW Assurance, and if not, to determine whether there is sufficient reason to investigate. While there is no mandate for the IACUC to investigate every allegation, I agree with Hall that not providing analgesia and compromising animal welfare is a noncompliance that should warrant investigation. I also strongly believe that IACUC Chair Covelli should not be unilaterally deciding the outcome of that review, but rather the convened quorum of the IACUC as a whole should decide on how to proceed. In addition, the IACUC is required to use due diligence to determine if the noncompliant activity is being done on a PHS/NSF-supported project, and if prompt reporting to OLAW is necessary (PHS IV,F,3; NIH guidance document NOT-OD-05-034.). If this project was PHS/NSF-sponsored, or if it was written into the institution's assurance that all investigations need to be reported, then the IACUC is noncompliant with federal policy in not investigating and reporting this noncompliance.
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