Action Following Initial Investigation

No violation – no findings of mistreatment of animals or policy noncompliance.
The IACUC chair will inform the complainant, the Veterinarian 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.

Minor violation – one instance of policy noncompliance, but no inhumane treatment of animals.
Examples of minor violations (this list is not intended to be exhaustive)

• Significant expansion or use of animal numbers or experiments under an existing IACUC approved protocol without proper amendments
• Improper entry into animal quarters
• Violation of SPF (Specific Pathogen Free) protocol or standard operating procedures

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.  The IACUC Coordinator will be responsible for verifying that the remedies are completed within the established time frame.
Major violation – repeated instances of policy noncompliance or one or more instances of inhumane treatment or neglect of animals.
Examples of major violations:  Use of animals without an IACUC approved protocol, Disregard for animal pain and suffering, Improper euthanasia, Improper surgical techniques or experimental treatments, Exposing humans or animals to substantial and unnecessary risks, Knowingly providing false or inaccurate information to IACUC, Any other unethical treatment of animals. 

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.

IACUC members or institutional employees with a conflict of interest shall immediately notify the committee and remove themselves from further participation in the matter.
Examples of conflicts:  Personal profit, Collaboration with the investigator, Supervisor for personnel directly implicated, Other situations where judgment may be affected by affiliation.

The IACUC will review the complaint and the initial findings and recommendations of the Veterinarian and obtain additional information as needed.

• 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.
• 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 laboratory employee is the subject of the complaint.
• 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.
• 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.
• At the meeting, the IACUC may call the Veterinarian or others as it deems necessary.
• 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.

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. The actions of the IACUC apply to PIs, animal users, and laboratory staff.

IACUC action(s) may include, but is/are not limited to:

• A finding of no violation and/or the complaint was not substantiated.
• 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 laboratory and animals.
• A suspension of the protocol for a stated period of time, or immediate revocation of the protocol approval.
• Permanently revoke all laboratory access of the person who is the subject of the complaint.

The IACUC Chair will report in writing, as appropriate, to the following individuals: the complainant; the person who is the subject of the complaint; the Department Chair or direct supervisor of the person who is the subject of the complaint; and the IO.  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.