Dear Investigators,
I am writing to inform you of my impressions of the results of the recent AAALAC
accreditation site visit. At
the exit briefing, the evaluation team indicated that many aspects of our animal
care and use program
are excellent but there are several programmatic deficiencies relative to oversight
of the program. The site
visitors identified sufficient programmatic problems that they will recommend
that the full AAALAC
council impose a probationary status on us. During a probationary
status, we maintain accreditation for a
limited period of time.
During that time, we will be required to show that we have resolved the identified
problems. Because many
of the problems that were identified were also identified three years ago when
AAALAC visited, it is likely
that we will have a re-inspection at the end of the specified probationary time.
The site visit team suggested
that we start resolving certain kinds of problems now rather than waiting until
we get the official AAALAC
report sometime in the late winter or early spring.
The site visitors commended several aspects of our program. Commendable Aspects
include institutional
support of the program as related to financial support of new facilities and
renovations of existing
physical plant; emergency preparedness and the disaster plan; the animal health
monitoring plan and overall
veterinary care program; and maintenance, sanitation, and enrichment programs
in dedicated animal facilities.
The site visitors identified several problems and concerns. They indicated
that they expect to find some
things that are not up to standards in a large institution like ours; however,
they found sufficient items along
a recurring nature that they feel we have some systematic problems. They were
very concerned that a
number of the major issues identified as problems by the site visit team three
years ago have not been
corrected. They were concerned that several of the non-ULAR housing,
surgery, and study areas are not up
to standards.
They indicated that they felt that the ILACUC does not exert sufficient rigor
in information gathering during
review of protocols and amendments and that ILACUC doesn't have adequate oversight
of all of the
program areas for which it is responsible relative to the animal care and use
program. The site team felt that
semiannual review was not adequate. They indicated that we allow activities
that are not up to standard to
continue and that we do not identify a timetable for corrections and then follow
up on the timetable. The site
review team was concerned about occupational health. They're concerned about
our inability to identify
whether any particular animal handler is up to date with participation in occupational
health. They were also
concerned that people can actually get into laboratories and start work before
being trained in animal
handling and/or in safety procedures for working with chemical or infectious
disease hazards.
From my perspective, I think that we will have to implement a number of changes
that will affect policies
regarding use of animals in research. I am providing a few examples of changes
I anticipate. We will require
that new personnel attend training and enroll in Occupational Health before
being granted access to animal
facilities. We will require that animals housed in laboratory areas receive
the same quality of care as those in
ULAR areas. Basically, we need to make all animal housing areas ULAR areas.
We will have more inspections of laboratory areas where procedures using animals
are done. We will likely
have some modifications to our protocols, but full compliance with training,
occupational health, etc. will need to be achieved before a protocol can be
designated as approved.
The ILACUC, ULAR, and Office of Responsible Research Practices will be working
diligently over the next few
months on a comprehensive plan to correct all problems identified by the AAALAC
site visit team. We welcome your ideas as to program improvement. We will do
our best to developprocedures that are efficient in the time and effort required
from each of us. I am confident that we can meetall regulatory standards and
continue to do excellent research. Your support
and cooperation will be essential to successful re-initiation of AAALAC accreditation.
Lane Wallace
Chair, ILACUC