Date Adopted: July 11, 2006
Last Review Date: December 11, 2020
I. Policy
Federal animal welfare regulations (under the Animal Welfare Act) state that all employees or concerned parties must have the means to report deficiencies in animal care and treatment. Federal animal welfare regulations state that no facility employee, committee member or laboratory personnel shall be discriminated against or be subjected to any reprisal for reporting violations of any regulation or standards under the Animal Welfare Act.
The Institutional Animal Care and Use Committee (IACUC) will investigate concerns involving the care and use of animals used in teaching or research at the 猎奇重口 (UM). This includes claims by the public or anonymous complaints concerning any aspect of the animal care and use program or by employees or students who report alleged instances of animal abuse, violation of approved protocols or standard operating procedures, use of animals not covered by approved protocols, violation of any animal-related regulation or standard (such as the Animal Welfare Act, Public Health Service Policy, or UM IACUC policy), or complaints regarding the care received by animals housed in UM laboratory animal facilities.
II. Procedure
A. Reporting a Complaint or a Violation
1. The Department of Laboratory Animal Resources (LAR) shall conspicuously post
phone numbers, email addresses and office locations for reporting of complaints
and violations in all 猎奇重口 animal facilities. Such information must
also be included on the UM Institutional Animal Care and Use Committee
(IACUC) web site for easy public access. Contact information will be provided for
the following:
a. IACUC Manager
b. IACUC Chair
c. Attending Veterinarian (AV)
d. LAR general information and phone numbers
2. Any person who believes a laboratory animal or animals is/are subject to
mistreatment, or that there is a potential violation of IACUC policy (even if
immediate harm to animals is not present), is encouraged to report allegations of
mistreatment or policy violations to any of the following: the Institutional Official
(IO), the IACUC Chair, the IACUC Manager, the AV, a member of the IACUC,
or LAR staff member. A complainant may remain anonymous
3. A complaint may be reported either orally or in writing and should include a
description of the violation, the time and date of violation, the location, the type
of animal involved, and any other items which are relevant to the complaint.
4. The AV or designee will reduce the complaint to writing as soon as possible.
a. The AV or designee will conduct the initial investigation and the results will
be forwarded to the IACUC Chair.
b. Complaints directed at LAR staff members will be forwarded to the
IACUC Chair at the initiation of the investigation. At that time, the Chair
may choose to conduct or reassign the investigation.
c. If the AV is the subject of the complaint, the IACUC Chair will contact the
IO and the IO will appoint an appropriate person to investigate the
allegations.
d. If the complaint is against the Chair, the person receiving the complaint
will contact the IO.
5. Investigation of and communications about the complaint shall be documented
in writing and maintained in the office of the IACUC Manager.
6. No person reporting a violation of LAR and/or IACUC standards, procedures, rules
and protocols shall be subjected to any retaliation.
7. Likewise, no person who is the subject of, or related to a complaint shall
undertake reprisals. Retaliations or reprisals in the context of IACUC procedures for
handling complaints represent violations of IACUC standards that could result in
loss of privileges and/or access to the facilities for animal care and use under the
oversight of the UM IACUC.
8. The confidential nature of the complaint and violation procedures must be
respected by all parties involved.
B. Initial Investigation by the Attending Veterinarian (AV) or designee
1. The AV or designee will evaluate the complaint to determine whether there is
sufficient information to investigate further.
a. If mistreatment of animals is found, the AV or designee will take all
necessary action which may include temporary suspension of use of
animals by any and all individuals involved in the reported complaint.
b. During an investigation, the AV or designee shall have the authority to
question the PI and the PI’s laboratory staff members or students, and to
request laboratory notebooks, datasheets, and spreadsheets.
b. The AV or designee will submit the initial findings and recommendations
to the IACUC Chair.
c. The IACUC Chair and the AV or designee will consider the initial findings
and recommendations for further action.
2. If the AV is the subject of the complaint, the IACUC chair will contact the IO, and
the IO will appoint someone to investigate the allegation.
C. Action Following Initial Investigation
1. No violation - no findings of mistreatment of animals or policy noncompliance.
a. The IACUC chair will inform the complainant, the AV or designee and the
person who is the subject of the complaint in writing of the findings and
recommendations and that no further action will be proposed, subject to
IACUC review at the next regularly scheduled meeting.
2. Minor violation - policy noncompliance but no inhumane treatment of animals.
a. Examples of minor violations (this list is not intended to be exhaustive)
1) Significant expansion or use of animal numbers or experiments under
an existing IACUC approved protocol without proper amendments
2) Violation of SPF protocol or standard operating procedures
b. The IACUC chair will inform the complainant and the person who is the
subject of the complaint (and his/her direct supervisor or PI) in writing of all
findings, recommendations, and any remediation (except for confidential
personnel actions) required to be completed within a specified time
frame. Such findings, recommendations, and remediation (except for
confidential personnel actions) are subject to IACUC review at its next
regularly scheduled meeting.
c. The IACUC Manager will be responsible for verifying that the remedies
are completed within the established time frame.
3. Major violation - inhumane treatment or neglect of animals.
a. Examples of major violations (this list is not intended to be exhaustive)
1) Use of animals without an IACUC approved protocol
2) Disregard for animal pain and suffering
3) Improper euthanasia
4) Improper surgical techniques or experimental treatments
5) Exposing humans or animals to substantial and unnecessary risks
6) Knowingly providing false or inaccurate information to LAR or IACUC
b. The AV or IACUC Manager should self-report the incident to OLAW in a
timely manner, and self-report to USDA if a protocol suspension occurs for
an USDA-covered species.
c. The IACUC Chair will determine if the IACUC should meet immediately or
wait until the next scheduled monthly IACUC meeting to discuss the
violation. A quorum of the IACUC must be present for the meeting.
1) IACUC members or institutional employees with a conflict of interest
shall immediately notify the committee and remove themselves from
further participation in the matter.
d. The IACUC will review the complaint and the initial findings and
recommendations of the AV or designee and obtain additional
information as needed.
1) The complainant may be requested to meet with the IACUC. If the
complainant is unwilling or unable to make a personal appearance,
the complainant may submit a written statement to the IACUC Chair
prior to the meeting.
2) The person who is the subject of the complaint will be provided a
written description of the substance of the complaint and will be
given an opportunity to meet with the IACUC to respond to the
complaint. If the person who is the subject of the complaint is not the
PI, the complaint will be forwarded to the PI responsible for the
animal or protocol described in the complaint or the direct supervisor
if a LAR employee is the subject of the complaint.
3) The complainant and the person who is the subject of the complaint
may have an advisor at the meeting with the IACUC. Advisors are
present in an advisory capacity only and are not permitted to speak
or present information directly to the IACUC.
4) If the complainant and/or the person who is the subject of the
complaint elect not to meet with the IACUC, the complaint will be
reviewed on the basis of information available, and a
recommendation will be made by the IACUC. No inference may be
drawn against the complainant and/or person who is/are the subject
of the complaint for failure to appear before the IACUC.
5) When the IACUC concludes that all pertinent information has been
received, the IACUC (after excluding all nonmembers) shall discuss,
deliberate and prepare its findings and recommendations. By majority
vote of those present, the IACUC will determine whether or not
mistreatment of animals or policy noncompliance has occurred and
make recommendations. If the findings and recommendations are
not unanimous, minority opinions may be written and attached by
those who differ with the majority's findings and recommendations.
e. The IACUC will then determine the final action to be recommended to
the IO. The IACUC recommendation shall be immediately binding until
such time as the IO has reviewed the recommendation. IACUC action(s)
may include, but is/are not limited to:
1) A finding of no violation and/or the complaint was not substantiated.
2) A reprimand to the person who is the subject of the complaint, which
may include notice to the supervisor that if the same or similar
circumstances which were the basis of the complaint are found to
continue, this could result in suspension or complete revocation of the
protocol approval under which animal(s) were obtained and/or may
include suspension or complete revocation of the violator's privileges
to access LAR and animals.
3) A suspension of the protocol for a stated period of time, or immediate
revocation of the protocol approval.
4) Permanently revoke all LAR access of the person who is the subject of
the complaint.
f. The IACUC Chair will report in writing, as appropriate, to the following
individuals:
1) The complainant;
2) The person who is the subject of the complaint;
3) The Departmental Chair or direct supervisor of the person who is the
subject of the complaint; and
4) The IO.
g. The IO, after review and approval, will report the findings and actions
taken by the IACUC to external organizations and/or government
agencies as required.
D. Record Keeping
1. The IACUC Manager will keep all records of complaints, violation,
investigations, action plans and outcomes on file for a minimum of 3 years.