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|Animal Use Policy and Planning for Animal Use|
RECOMMENDATIONS FOR EDUCATIONAL INSTITUTIONS EMPLOYING ANIMALS IN TEACHING OR RESEARCH
Revised December 2013
Adopted January 2009
Statement of purpose: Public interest has focused attention on animal use in teaching and research in institutions of higher education. Questions are commonly raised regarding the need and purpose of animal use, and institutions are increasingly called upon to justify animal use to students and to members of the general public. It is not possible to foresee and plan for every possible situation relating to the use of animals in educational settings, but a number of events, including natural disasters, long-term power outages, disease outbreaks and contamination of live animals or their environment may occur. In addition, institutions may be subjected to incidents of protest or vandalism relating to animal use. When a college or university finds itself in the middle of such an event, it is possible for the situation to deteriorate rapidly as individuals, trying to figure out how to respond, miss important details, duplicate one another’s efforts, or act inappropriately. If the press is involved, reporters will try to speak to anyone that seems to have any information. This can lead to conflicting and inaccurate information being provided, making the institution’s response appear chaotic. It is therefore important that the institution have in place clear policies regarding animal use and care, and that the institution have a well-considered policy for dealing with requests for information and with any questions or incidents that may arise. Having a plan in place before a situation occurs is a classic example of an ounce of prevention being worth a pound of cure.
The Human Anatomy and Physiology Society (HAPS) recommends that any institution using animals in teaching or research develop such a plan, using the following as a model:
1. Institutions using animals in teaching or research shall establish and formally adopt an Animal Use Policy.
a. The HAPS Position Statement on Animal Use is attached. It may be used as a model for institutions wishing to formulate a policy. In addition, other organizations, such as the American Physiological Society, have developed detailed position statements and rationales for the use of animals in teaching that can be used in the development of institutional policies. This policy is available at: http://www.theaps.org/pa/action/news/animalsinteaching.htm)
Note: we have received formal approval from the APS to cite this policy.
b. The policy shall be developed by representatives of all institutional departments and units involved with animal use.
Note: in institutions employing live animals, this committee should be the Institutional Animal Care and Use Committee (IACUC), formally established per USDA guidelines established under the Animal Welfare Act. In institutions that employ preserved animals, or that do not meet the criteria established by the Animal Welfare Act requiring establishment of an IACUC, the intent is to allow a less "formal” committee, but to ensure that it includes input from all departments or units employing animals as specimens. Inclusion of non-departmental faculty and community members on the committee should also be encouraged. The role of the Animal Use Committee, as explained below, supports the institution’s use of animals by confirming that the use was reviewed and approved.
c. The policy shall be reviewed and formally approved by the appropriate institutional governing body (administration, college senate, board of trustees, etc.)
Note: this is to ensure that the policy is carefully considered before adoption, and to ensure that any policy is viewed as institutional, not departmental.
d. The institution’s policy on animal use shall be included in the institution’s catalog and other official documents.
Note: this documents the institution’s commitment to the policy. Since these documents are regularly reviewed and revised, it will also serve to ensure periodic review and revisions to the policy.
e. Courses or programs requiring use of animals shall include a clear description of such use in the catalog, with a specific reference to the institution’s animal use policy.
Note: the intent is to provide clear notification to students intending to enroll in a course employing animals. This also ties the use within a program or course directly to institutional policy.
f. Departments or units employing animals in teaching or research shall formulate and establish a clear rationale for such use.
Note: this will require some work initially, but ensures that each use is justified and tied to institutional policy. It will also provide necessary documentation in the event of a challenge to animal use.
g. Prior to the use of live or preserved animals, a proposal for such use shall be presented to and reviewed by the institution’s Animal Use Committee. The proposal shall include a justification of how animal use achieves the learning objectives of the course, the ratio of students to animals, a justification for the number of animals to be used, the source of animals, a description of how the animals will be housed or stored, a description of the specific use (including experimental protocols and euthanasia methods) and how animals or their remains will be disposed of.
h. A statement that animal use is required in a course or program shall be included in the syllabus for that course or program and discussed with students at the start of the semester. A summary of the importance of animal use in teaching and research should also be included in the syllabus.
Note: Again, the intent is to provide clear notification to students intending to enroll in a course employing animals.
i. Alternatives to such use, if available, should be discussed in the syllabus.
Note: Faculty involved in a program or course involving animal use should agree on the availability and scope of any alternatives. Similarly, if no alternative to animal use is provided, this should be agreed upon by faculty involved in the course and clearly communicated to students. This should be a well-considered decision, made before circumstances require it
ii. Penalties for non-participation in the animal use portions of the course should also be included in the course syllabus.
Note: Penalties should be agreed upon beforehand, not invented on the fly. Penalties for non-participation should be commensurate with the amount of material missed and applied uniformly and consistently. Again, this should be well considered and be made before circumstances require it.
i. Animals used in teaching and research must be obtained, maintained and used in accordance with applicable federal, state, and local regulations including the Animal Welfare Act (for regulated species), the Health Research Extension Act of 1985 and the Public Health Service Policy on Humane Care and Use of Laboratory Animals and/or the Guide for the Care and Use of Laboratory Animals (if required by the funding agency). These documents may also be used in the training of personnel.
Note: HAPS Safety Guidelines can serve as a reference.
2. Institutions using animals in teaching or research should establish an Animal Use Committee
Note: the intent of this section is to recommend that institutions assemble a committee similar to the Institutional Animal Care and Use Committee (IACUC) defined in the Animal Welfare Act. The Animal Welfare Act sets specific requirements for the membership on the IACUC; these requirements (veterinarian as member, for example) may not be appropriate for institutions using preserved rather than live animals. See the note to 1(b) above.
a. Institutions using live animals in teaching or research and whose program meets the requirements established by the Animal Welfare Act shall establish an Institutional Animal Care and Use Committee as defined in the act. Membership in the Animal Use Committee shall be determined using USDA guidelines.
b. Institutions employing preserved animals in teaching or research or whose program does not meet the requirements if the Animal Welfare Act shall establish an Animal Use Committee whose membership, at a minimum, includes representatives of the following:
i. The institution’s administration;
ii. Content experts from each department or program using animals;
iii. An individual from the general public or from a group not directly connected with animal use at the institution
c. The animal use committee shall have the responsibility of ensuring that all animal use at the institution is in compliance with applicable policies and regulations.
d. The animal use committee shall also be responsible for ensuring that faculty and institutional personnel dealing with live or preserved animals have received training on the acquisition, treatment and disposal of those animals.
Note: Institutions may want to establish a mechanism to ensure periodic review of animal use.
e. The committee shall also be responsible for the review and consideration of questions or appeals regarding animal use, including requests for exemptions from such use by individuals and, in cooperation with the institution’s academic appeals procedures, for the development of recommendations on adjustments to grades, academic penalties, or the recommendation of acceptable academic alternatives, if appropriate.
Note: the intent here is to provide a mechanism that will result in appeals being considered by a body fully informed about the institution’s policies and procedures dealing with animal use.
3. Institutions using animals should establish an Animal Use Incident Response Team.
Note: the intent of this portion of the model is to provide a formal institutional mechanism for dealing with major incidents, such as disasters, disease, formal protests, threats, or vandalism. It also provides a mechanism for dealing with news media by individuals best prepared for such contacts. The Animal Use Incident Response Team facilitates communication within the institution and with the public, coordinates the institution’s actions and provides necessary support to faculty, staff and students. The makeup of the Response Team will vary, depending on the size and structure of the institution and on the extent and type of animal use in teaching and research. In a large university with extensive use of live animals, the Response Team will include faculty and staff from relevant departments, representatives of campus security, individuals responsible for biosafety, individuals responsible for animal acquisition, care, and use, public information, health services, laboratory and field coordinators and legal services. At a smaller institution, or at an institution where animal use is limited to preserved specimens or small numbers of live animals (frogs for physiology demonstration, for example), the Response Team may be as small as the minimal list below.
a. The team should include representatives from each of the following groups, at a minimum:
1. Media liaison or Public Information Office;
4. Individual representing the department or office responsible for the acquisition or care of animals;
5. Representatives from departments or programs using animals.
b. The Incident Response Team shall be responsible for responding to significant incidents such as accidents, natural disasters, outbreaks of disease, acts of protest, questions, or concerns raised by groups or organizations, and incidents involving damage or vandalism.
Note: The Incident Response Team may not necessarily be directly involved in all phases of the response. Instead, the Incident Response Team will ensure that responsible individuals have been notified and that resources necessary to deal with the incident are provided.
4. The institution should have an Incident Response Plan. The plan should set out an Emergency Operations Plan that clearly indicates areas of responsibility and the individuals responsible for specific activities, provides necessary contact information and resources, and identifies emergency procedures to be followed. An outline of an Incident Response Plan is provided below:
a. All individuals dealing with animals should be aware of the institution’s incident response plan and emergency operations plan.
Note: institutions should consider providing incident response training to all faculty and staff dealing with animals.
b. The first responsibility of an individual observing an incident is the safety of faculty, staff, and students.
1. Security should be notified immediately;
2. Security will notify the Incident Response Team.
3. If the situation is safe, individuals at the site of an incident should remain where they can observe the situation and where security can find them;
4. Individuals responding to an incident should determine if others around them are safe. If injuries are identified, security should be notified and emergency services requested.
5. If the situation at the site of the incident is unsafe, individuals should go to a safe site where security can find them;
6. If it is necessary to dismiss students, security should be notified of this action.
c. After the safety of personnel has been addressed, the Emergency Operations Plan portion of the Incident Response Plan should be engaged. The Emergency Operations Plan should consider the following:
i. Reliable communication is necessary for any plan to work successfully. All personnel should have access to telephones. Consideration should be given to the use of two-way radios in the event that telephone lines are inoperable.
ii. Personnel dealing with animals and the facilities where animal use occurs should be provided with a list of contact information for institutional security.
iii. Contacts for ambulance, fire and other emergency services should be available onsite.
iv. Animal Care: Each facility using animals should have an individual plan, containing:
1. A description of the facility and the animals housed there (if live animals are in use) or of the preserved animals used there;
2. Contact information for the personnel responsible for the care of live animals and the acquisition, storage and disposal of preserved animals;
3. For live animals, resources available for their care. This would include items such as vehicles available to transfer animals, equipment necessary to wash or disinfect cages, backup plans for providing electrical power, heating or cooling, and food and bedding supplies;
4. For live animals, animal care procedures such as feeding or exercise schedules and veterinarian contact information.
5. For preserved specimens, resources available for alternate storage or disposal of specimens and backup plans for electrical power, ventilation, heating and cooling.
d. Communication regarding the incident: All communications with the press, other news media or the general public should be routed through the media liaison representative;
i. Incidents involving vandalism or disruption of institutional activities should be referred immediately to security;
ii. Institutions should have clear policies about how to deal with acts of provocation, requests for information, and media requests for comment, for example by directing all such requests to the appropriate institutional official or committee. The institution should provide personnel with training in these policies
iii. All responses to requests for information should include explicit reference to or discussion of the institution’s Animal Use Policy
Note: In many cases, a group organizing a protest or responsible for an incident will have notified news media to ensure their presence at the event. In these cases, college personnel may be "ambushed” by the media. It is important that college personnel be aware of this situation and that all media contacts be made through the media liaison.
iv. The Incident Response Team should prepare a fact sheet as soon as possible (within the first hour). This can be used as a press statement, even if only a few facts are known. This will demonstrate that the institution is on top of the situation.
v. The Incident Response Team should meet with everyone involved in the incident as soon as possible (ideally within the first hour) to prepare a more detailed report. This report should be distributed to all offices that need to be informed (deans, department heads, public information office, etc.).
vi. The Incident Response Team should consider the worst-case public scenario for the institution. Was anyone hurt in the incident? Were animals hurt or released? Is it possible that the incident was recorded? If that happened, it is likely that the recording will be distributed widely within hours. The institution must quickly work to issue a response.
vii. Within the first few hours after the incident, the Incident Response Team should visit the site of the incident and interview personnel affected. The Public Information Officer should prepare a summary description of the incident from the institution’s point of view, which should include a statement of how animal use enhances student learning, provides a research model, and how this may yield benefits for society at large.
viii. Over the next few days, the Incident Response Team should:
1. Keep affected personnel informed of developments;
2. Arrange for a site visit by administrative personnel (ideally the president and vice-presidents of the institution);
3. Arrange a meeting between involved faculty and staff and security personnel to discuss what happened, the response to the incident, and needed changes in the Emergency Operations Plan;
4. Ensure that concerns and fears of affected personnel are addressed.
5. Elicit administrative support for affected personnel.
6. Notify funders of research or education about the incident, Information on the incident should come directly from the institution, not from the press.
Note: the specific recommendations above regarding communication are adapted from "After the Attack: A Step-by-Step Plan” by Sharon Kha, Associate Vice President-Communications-News Service, the University of Arizona. The document has benefited from extensive review and comment from Alice Raanan of the American Physiological Society, Dan Lemons of the City University of New York and Torsten Hopp of Baylor College of Medicine. The Animal Use Committee is grateful for their assistance and criticism.