Hope for luck with IACUC

Douglas Fitts dfitts at carson.u.washington.edu
Sun Jul 18 03:35:34 EST 1993

Institutional Animal Care and Use Committees (IACUCs) are essential
bodies if for no other reason than that we can say we have them.  Critics
of animal research, other than the radical end, are reassured by the 
fact that all researchers at an institution must pass judgement by
impartial observers.

There are deeply ingrained problems with these committees, however,
that often engender conflict between their members and individual 
researchers and that create inconsistencies across institutional

The American Association for Laboratory Animal Care (AALAC) has prescribed
guidelines which all IACUCs must follow.  These guidelines are well
reasoned and straightforward as far as they go.  The leadership of AALAC 
is pro-research and in no way supports the use of IACUCs to inhibit 
the progress of research.

On the other hand, AALAC cannot micromanage every IACUC.  The decisions
of IACUCs are ultimately based on the judgements of the individual 
personalities who comprise them, and in most cases there is no recourse
for researchers who believe their decisions are unfair.  If an individual
researcher becomes irate at a decision by the IACUC and out of frustration 
becomes a thorn in the committee's side, the natural human response 
of the committee's members is to uphold their decision at all costs 
rather than reconsider it as they might for a more eloquent and reserved 
defendant.  Thus, after receiving a heavily documented rebuttal including 
the testimony of top researchers in the area and several leading journals'
editors, the IACUC may take a simple way out rather than submit to 
overwhelming evidence against them:  They refuse to reassess the proposal 
on the grounds that the IACUC may decide in individual cases whether or 
not to reconsider any proposal.

This is a thickly veiled example of an actual incident.  The 
investigator charged that certain committee members were adamantly 
opposed to the use of a certain research technique even though it had
30 years of history in the literature.  It came down to a conflict of
beliefs -- by the investigator that the procedure was benign, and by 
some committee members that the procedure couldn't help but be painful 
for the animals because it involved electric shock, and shocking animals
is bad ^a priori^ (in their opinion).

The fact that the decisions of IACUCs are based upon the belief systems 
of the members that comprise them means that the decisions of different 
IACUCs at different institutions vary widely in their decisions 
about the worthiness of similar projects.  Thus, a project that is ruled 
perfectly acceptable at Institution A is ruled completely unacceptable 
by the IACUC at Institution B.  The researcher at Institution A gets the 
grant because the IACUC signed off on the proposal, and s/he then manages 
to publish in a prestigious journal because the manuscript meets the 
journal's rule that all published research be approved by the local 
IACUC.  The poor researcher at Institution B feels justifiably
angry at missing both the grant and the priority of publication.

The confusing part is that approval by one IACUC doesn't necessarily
assure the approval of a protocol by any other IACUC.  One can't claim
that one's pal at the U of X gets to do it so I should get to do it too.
The trend seems to be in the opposite direction, that is, that the IACUCs
focus on protocols that have been held in disfavor by some other IACUCs
rather than on protocols that have been widely used for decades.  The 
attitude seems to be that the researchers, especially the older and 
more recalcitrant ones, are the least capable of making informed, modern
decisions about the humaneness of a particular protocol.

Unfortunately, this is where the IACUC and AALAC part company.  AALAC is
adamant that the people who know best about the procedures they employ
are the experts within the areas.  Many IACUCs are staffed by clinical
veterinarians and even untrained lay persons who know very little about
the demands of research, and much less about the utility, potency, 
and importance of given research methods within the wide array of 
disciplines that use animals.  The demand by the institution that these 
persons perform their duties despite their ignorance eventually engenders 
a defensive arrogance on the part of the IACUC members.  When pitted 
against the massive egos of scientific academia they need only say, 
"No", and "Because we said so".  There is no higher law.

Power such as this is heady stuff, and it doesn't like to sit idle.
One of the most common complaints of researchers after site visits by 
IACUC staff concerns the lack of consistency from visit to visit.
Laboratory conditions that passed muster six months ago are now getting
cited.  The trend is to tighter and tighter controls and demands by 
the IACUCs, which lead to higher and higher direct costs for grants 
(no, not indirect costs), which contributes to fewer and fewer grants.  
Moreover, a Laboratory Animal Medicine branch, or whatever 
unit commands most of the authority within an IACUC, begins imposing 
or increasing tarriffs on animal users in order to cover the 
increased costs to their aleady restricted budgets.  Eventually the
grant that one got from NIH that already suffered a 10% across the board
cut and a 4% COLA markdown and the elimination of an RA's salary gets
hit for tripled costs for animals and a huge hike in the fee (called
extortion by the enraged) for animal use oversight.

To come back to my initial point, IACUCs are essential in today's 
political climate.  They are far from perfect, however, and a system
of guidelines and restrictions needs to be expanded to make IACUCs less
dependent on the belief systems of their individual members at different
times and different institutions.  Protocols that are approved anywhere
ought to be approved everywhere so long as the investigators are trained
or receiving training in the procedures.  Individual investigators need
the freedom to be able to experiment with new or unfamiliar protocols
in order to achieve the most impact in support of their hypotheses without
having to wait six months until a committee even more unfamiliar with the 
protocols decides whether or not they may be used.  Rapid provisional 
approval should be granted in most cases so that a post hoc appraisal 
can be made on a small number of animals rather than on the current system 
of deciding in the complete lack of any empirical evidence.

One personal experience I mention only because it came to nothing 
involved a completely unexpected challenge of my proposal by a young 
veterinarian regarding a procedure that I and others had been using 
often and was central to a certain project, to wit, a small wire knife 
cut of the lamina terminalis immediately below the subfornical organ in
the rat brain.  She expressed the concern that the "microlaceration"
technique I was doing would paralyze my rats.  I tried to reassure her
that this small amount of damage on the ventricle wall would have no
effect whatsoever on motor control, but it wasn't until our attending
veterinarian returned from a meeting that the challenge was overruled
and my project was signed.  Still I wonder:  What if she had been his 
permanent replacement rather than a temporary one?

Doug Fitts
Department of Psychology
University of Washington
dfitts at u.washintgon.edu

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