Euthanasia is certainly a programmatic area that should be covered as part of the semiannual inspection. Manes' approach of speaking with investigators and their staff members about euthanasia appears to be in line with the expectations of a thorough program review. And Manes is correct that although the regulations and other guidelines do address the requirement to provide a description of the euthanasia method in the IACUC protocol, outside of keeping accurate records on controlled drugs, there is no direction regarding record-keeping for this activity. As a new member, Manes is providing a new (and hopefully welcome) perspective to the Great Eastern University IACUC by bringing up this topic for discussion as part of the program review. At Great Eastern, the investigators are keeping records of euthanasia but these do not include details about the euthanasia method.

It would benefit the Great Eastern University IACUC to establish expectations regarding euthanasia record-keeping and to communicate these expectations to the animal users. Documentation requirements could include specific details such as species, individual animal versus group euthanasia and method of euthanasia (e.g., injectable controlled drug versus carbon dioxide inhalation).

As a best practice, records should include the euthanasia date and method, in sufficient detail to confirm its consistency with the approved IACUC protocol. In the case of animals for which individual medical records are already being maintained (e.g., nonhuman primates, dogs, pigs), the euthanasia details should be included in the individual animal record. As part of colony or census management, the euthanasia of rodents should be recorded. Individual animal records may not add value in many situations. In these cases, group documentation (e.g., by experiment, by date of birth or by shipment) should suffice. When controlled drugs are used, the total volume dispensed on any given date should be accounted for and recorded. In order to calculate the total amount used, the individual amounts used would need to be tallied. Good Laboratory Practices require that records contain sufficient detail to enable reconstruction of the study.

Although there is no specific requirement to keep records of euthanasia, good records, including amount and route of administration, are the best way to identify and troubleshoot potential welfare, noncompliance or training issues that arise during the procedure. The Great Eastern University IACUC should take this into account as it develops and shares expectations regarding euthanasia documentation requirements with the investigators.

Return to Protocol Review