Reducing administrative burden seems to have been the flavor of the month for quite some time now, so maybe it would be better to say it is the flavor of the decade. One of the many ways institutions can work on reducing unnecessary administrative burden is by re-evaluating their current policies, procedures, and forms. This can seem like a very daunting task and some may not really know where to start. But the answer is simple, really: when in doubt, go to the regulations.
Every IACUC and IACUC office has access to regulations via the Public Health Service (PHS) Policy on Humane Care and Use of Laboratory Animals, the Animal Welfare Act, and the Guide for the Care and Use of Laboratory Animals (Guide). Depending on your type of institution, the VA regulations, DOD regulations and the Agricultural Guide may also be applicable. Additionally, if your institution is OLAW-assured, or accredited with AAALAC, you can reference these documents to see how your program is describing its functions. If your institution is up for renewal with your assurance, or the site visit for AAALAC is coming up, these serve as perfect opportunities to really evaluate where and how administrative burden can be reduced within the program.
The protocol forms, be they paper-based or an electronic system, can be a great source of administrative burden for institutions due to the vast amount of information that is collected. When evaluating the protocol forms, you should be asking yourself the following questions:
- Does this question truly need to be here?
- What do the regulations say in terms of asking for this information?
- What benefit is gained by having this question in the protocol form, rather than in some other place?
The information that is currently collected in the protocol forms may be useful to the animal care and use program, but there could be better avenues for gathering and storing that information. For example, if the protocol form asks how mice will be ear tagged, and this procedure is done frequently across multiple labs, perhaps it would be better if a standard operating procedure was developed that could be utilized by every research team. This way, all they would need to do is reference the name of that operating procedure document, and only describe ear tagging procedures that are not included in the standard operating procedure. This could be applied to a wide variety of commonly used procedures, or even commonly used and administered drugs.
Another thing to think about is how multiple types of regulations get applied. It is not uncommon for institutions to be OLAW-assured and be registered with USDA, and in those cases, in order to keep things "easy," institutions may have the regulations for both applied, no matter the species. Until recently, we had a similar approach at my institution. We had the USDA pain categories apply to every species, even though it did not need to apply to our rats and mice bred for research, birds, amphibians and reptiles, and fish. We have since moved towards only using the USDA pain categories for our USDA-covered species. This change was met with great enthusiasm from our researchers as this was one area that would cause a lot of back-and-forth with the vets in discussing if a procedure was Category C or D, and ensuring that the number of animals matched up for each category.
So when you're looking at reducing administrative burden, get back to basics and really look at what is required by the regulations, and see where your own program has maybe gone unnecessarily above and beyond what is required by the regulations. Making efforts to reduce administrative burden does not mean that the care and concern for the animals is being reduced, or that the science is being negatively impacted either; it just means we're all trying to work together towards the common goal of ethical and humane treatment of animals, while moving research forward.
Samantha Sullivan, BS, BA, is the IACUC Coordinator at Arizona State University (ASU). She received her BS in Psychology, and her BA in Business–Global Leadership, from ASU. She started her career in Research Compliance as a student worker in the Office of Research Integrity & Assurance at ASU as a student worker. That position opened up a whole new world to her, and upon graduating with her BS, she was hired on full-time as the IACUC/IBC Coordinator in 2015. With research needs expanding as ASU works towards $815M in research expenditures by 2025, the IACUC/IBC Coordinator position was split into two positions. Samantha then became the main IACUC Coordinator, and she still provides back-up support to the IBC Coordinators.
Members of PRIM&R’s Blog Squad and other guest contributors are valued members of our community willing to share their insights. The views expressed in their posts do not necessarily reflect those of PRIM&R or its employees.
Registration is now open for PRIM&R's 2021 IACUC Conference (IACUC21), which will be streamed virtually April 14-16, 2021. Interested in attending "IACUC Administration for New IACUC Administrators/Coordinators"? It's session B08 at IACUC21!
This online event will also include keynote and plenary sessions, breakout sessions, networking events, and in-depth workshops designed to help build and strengthen effective animal care and use programs, as well as provide ample opportunity to exchange ideas, discuss best practices, and work through the challenging issues that can arise when using animal models in research. Register today!