The Great Eastern University IACUC always informed the federal Office of Laboratory Animal Welfare (OLAW) about significant animal welfare concerns that the IACUC was investigating. After an investigation was complete, it would inform OLAW of its findings and any subsequent actions taken by the committee. On occasion, the IACUC deemed it appropriate to suspend all or part of a protocol. When this happened, the IACUC would also inform the USDA and appropriate federal funding agencies if the involved species was covered by the Animal Welfare Act (AWA) and its regulations.

Dr. Hillary Banks used hamsters as part of her photoperiodicity studies. She had a well-deserved reputation as an outstanding researcher and an equally well-deserved reputation as a difficult customer of the IACUC. The IACUC previously had issued a warning to Banks about her blatant disregard for following her protocol. The warning contained an ultimatum that all or part of her study would be suspended if any additional study-related problems were verified by the IACUC. True to form, another significant protocol violation occurred, and Banks was called in front of the full IACUC. She readily admitted to the infraction, blaming one of her technicians for the incident, and said that she had suspended the technician without pay for one week and had also voluntarily suspended any further animal work on the protocol. The IACUC thanked her for her cooperation and said that it would get back to her with the committee's decision.

After Banks left the room, Larry Covelli, the IACUC chairman, turned to the committee and announced that because another protocol violation had occurred, he would inform OLAW of the problem and of Banks' remedial actions, if the committee was in agreement with what she had done. However, he added that there was no need to inform the USDA or any federal funding agency, since neither the IACUC, the Institutional Official nor any other university official had suspended the protocol. This bothered some of the members who had had their fill of problems with Banks. They wanted some form of punitive sanctions against her, in addition to the voluntary suspension. Covelli calmly said that punitive sanctions could occur with IACUC approval, and he would inform OLAW of the same, but any such sanctions would be wholly based upon the authority given to the IACUC by the university. Nonetheless, he was adamant that under the AWA regulations, there was still no need to report anything to the USDA.

Do you agree with Covelli that a voluntary suspension of an animal activity by an investigator need not be reported to the USDA and the appropriate federal funding agency; or is any suspension of an animal activity, no matter how it occurred, a reportable action?

Response to Protocol Review Scenario: Reporting may vary

Response to Protocol Review Scenario: A word from OLAW and USDA

Response to Protocol Review Scenario: Report a suspension