Colleagues, I posted the following query on the AALAS IACUC listserv but only got one response. Perhaps some of you have dealt with the same issue and can provide some insight. Any help will be appreciated! Thanks. Barbara ************ Our IACUC has been struggling with an issue about graduate student research with animals at other governmental agencies that we haven't been able to solve to everyone's to everyone's satisfaction, so I'm looking for guidance. BACKGROUND: The College of Charleston has a marine research laboratory at a multi-agency research complex that also houses several federal and state agencies. Many of our graduate students work at these other agencies and are involved in ongoing vertebrate animal research there (fish and turtles primarily) during the early stages of their academic programs. None of the other governmental agencies has an IACUC or a formalized in-house protocol review program. However, scientists at those agencies do utilize certain standard research protocols and have obtained the required permits to collect animals for research purposes. As students progress through their academic programs, their routine work at these agencies often leads to the formulation of a thesis project which will be carried out at the agency as a subproject of the agency's larger research program. When we established our IACUC, we determined that all animal protocols, regardless of funding source, should be reviewed and approved in accordance with PHS guidelines and AWA. Our policy further states that all animal work done by our students must be approved by either our IACUC or another institution's IACUC. Since these other governmental agencies do not have IACUCs, our students working with animals there must submit their research protocols to our IACUC for approval before beginning their thesis research. However, we do not allow students to serve as PIs on animal protocols; the agency research scientist under whom the student works must be the PI of record. Most of these agency researchers have non-paid adjunct faculty appointments at the College. However, short of never again assigning a student to him/her (thus cutting off access to a qualified but inexpensive labor pool), the College has no real control over the agency researcher and cannot implement sanctions for noncompliance or animal mistreatment. In the event that the animals would be housed at those agencies, the College IACUC also has no jurisdiction over their facilities. Our IACUC will not approve a protocol retroactively since it is impossible to ensure appropriate care and use after the animal activity has already occurred. Many of the students working at other agencies have already collected some data that will be used in their theses before they formalize the thesis research proposal and prepare an application for IACUC approval. So the IACUC is asked to approve a protocol for an animal activity that has already begun but has not yet been completed. Some graduate faculty members suggest that, at the moment he/she determines the thesis topic, the student should stop all work with the animals until IACUC approval is obtained. In reality, this may not be very practical. For instance, if sampling is to occur at certain intervals and the student's assistance as a paid worker of the agency is required when it is time to sample, it would be impractical--and perhaps detrimental to the research--to tell the student that he/she cannot now assist in the collection because the thesis protocol has not yet received CofC IACUC approval. It seems we have created a real dilemma for ourselves. So we are now questioning whether indeed graduate students doing animal research under the jurisdiction of another entity (that does not have an IACUC) should be required to submit their protocols for thesis research to our IACUC for review and approval. Faculty members in the graduate programs are in favor of the students preparing protocol applications and going through the CofC IACUC process for the educational benefit. But some IACUC members question why they should be reviewing the studen's' research at all when it is being done in another agency as part of a larger research project over which they have no jurisdiction. Educational benefit for the student may be a positive thing, but is that the primary role of the College's IACUC and should the IACUC be trying to take responsibility when it has no authority to ensure compliance? We are toying with the idea of developing Memoranda of Understanding with the various government agencies that will address such issues as liability, health and safety of the students, humane animal issues, ability to publish non-IACUC approved studies, ability of our IACUC to enforce regulations at a site over which they have no authority (if any), procedures for handling problems that may arise, etc.—and so are looking for model MOUs, if any exist, that would be applicable to our situation. Any other thoughts about how we're dealing with our graduate students would be most appreciated! Thanks. Barbara -- ================================================================== Barbara H. Gray, Director Office of Research & Grants Administration College of Charleston 66 George Street Charleston, SC 29424 Campus Location: 407-G Bell Bldg. Office: 843.953.5673 Desk: 843.953.5885 Fax: 843.953.6577 e-mail: xxxxxx@cofc.edu URL: http://www.orga.cofc.edu/ ================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
