Regulations state that at least every six months, the IACUC performs a program and facility review. I’m not sure about your institutions, but at my institution the announcement that these are coming up is often met with grumbles and jokes about being unavailable. Our program is not even that bad! We always get them done, and it is typically a smooth process with good discussions, but the fact remains that this is not one of the IACUC’s favorite tasks, even though they understand the importance.
With this in mind, I had high hopes for the 2020 IACUC Conference (IACUC20) presentation “Innovative and Alternative Approaches to Program and Facility Review” from Shay Cook, BA, RVT, LATg, CPIA; and Susan B. Harper, DVM, MS, DACLAM, DACVPM, RBP (ABSA). And the session did not disappoint!
While OLAW has handy templates, which are easily available for institutions to use when it comes to the program and facility reviews, these are not necessarily the end-all-be-all. Checklists and templates can only go so far in terms of providing data and encouraging engagement among those involved. If your institution relies mostly on the OLAW-provided checklists and templates for the program review and facility reviews, it might be time to consider adding to the existing processes in place. The ultimate goal of doing so is not to create more work, but to help increase engagement and help create more and/or better ways to truly evaluate the program.
By adding another layer to the review process, such as the Red, Amber, Green (RAG) Rating System, institutions can better track issues that are discovered. At my institution, one of the most recurring findings (program-wide) is expired, or close-to-expired, materials. While this has not been deemed an animal welfare issue, it comes up often enough that I am able to think of it without going and looking at previous records. This begs the question, is there room for improvement among the program to help this occur less often? On the other hand, if there are no animal welfare issues, do we even need to change the processes we have in place?
Implementing a RAG Rating System could have benefits for better flagging labs that may not be a problem yet but have the potential for it. Thinking about a couple of labs at my institution where we do not have a RAG Rating System currently, they are larger labs that are active in their animal research activities. These labs always made sure that they were available for inspections; they always submitted the appropriate paperwork to get approvals before implementing work; and, in general, they had a good relationship with the IACUC. However, at each inspection, there were always “little” things found. In the moment, these things didn’t present any animal welfare concerns, but in the bigger picture these “little” things spoke to a larger problem of organization within the lab that ultimately contributed to bigger noncompliance issues. Luckily, the bigger noncompliance issues were addressed, and the labs are more organized and better off as result of working with the IACUC, but hindsight leads me to believe that if we had a better way to track the trend of the “little” things, we may have been able to work with the lab to prevent bigger noncompliance issues from happening.
After attending this session, I am inspired to help make our program even better and will be bringing up some of the ideas shared during this presentation with my supervisor, IACUC Chair, and Attending Vet. No program is perfect, and there will always be room for improvement. I hope others are just as inspired by this presentation to re-evaluate how they perform their regulatory duties of program and facility reviews.
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.
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