Tuesday, June 28, 2011

Federal regulations (a.k.a why your IACUC seems totally unreasonable)

It is a generally accepted belief that IACUCs as a whole and as individuals thrive on making animal use as annoying and difficult as possible, and derive great pleasure from rejecting, revising, rehousing and otherwise annoying animal users. I can assure you that, with rare exceptions, this is not the case.

Now, don’t get me wrong, there are a few animal users I’d like to have a little chat with. Like the pompous nitwit last month who sent me a one page “rebuttal” to my request for modification. I totted up his animal numbers, came up with 517, looked at his total of 617 and requested that he review his numbers. I got this >500 word rebuttal full of tables and equations and needlessly snotty language, I added them up again, still got 517.  I re-requested modification stating that his total was 517, the total on the rebuttal was 517 and the total on the protocol still said 617. Total waste of my time, total waste of his time, and totally his fault.

*Sidenote rant concluded*

The real reason our procedures are so darn convoluted is that we have to enforce federal regulations from multiple agencies, and they don’t always match. A priceless example of this emerged today.

1)   Animal users use gamma irradiators on some protocols. We are required to know where all animals go when they leave the animal facility, and to inspect all these places twice a year.
2)   Gamma irradiators are subject to increased controls, such that no one except for those certified as “Trustworthy and Reliable” (T&R) are allowed to know where the irradiators are, or who is certified to use them.

Long and the short of it, to uphold their laws, radiation safety wants us to permit irradiation users to avoid stating room locations and transit paths and to avoid inspection of these areas. We said no.

They said, OK, you can just let them not list the rooms. But then we still know who they are. And we have to inspect the rooms – without knowing where they are? They also said, fine, how ‘bout you have designated reviewers for irradiation protocols and we’ll just T&R a few people. We said sorry, we all have to have protocol access and the ability to conduct full committee review. Final answer: T&R the whole committee. And check up on the T&Rs every year. Honestly.

Also in our future – isoflurane badges? Does anyone else have halogenated-ether anesthetic monitoring for animal use? These drugs have hepatoxicity, the concern is that frequent use of anesthetics may expose humans to high levels of the drug. But honestly – we use these drugs on PEOPLE! To the point of unconsciousness! Is knocking out mice a few days a week really going to stack up to actual anesthesia?

The “Age of Enforcement” is going to be the death of me – the worst part is that it seems the majority of this enforcement is not directly about animal welfare.

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