The Great Eastern IACUC must send a message to Wright and all other researchers that no animal procedures will be allowed without an approved protocol. While his cooperation after the fact would be considered in his favor, it in no way excuses knowingly embarking on unapproved surgeries. Since IACUC members familiar with Wright's previous research might be hesitant about stopping his work, we would suggest that the following steps be taken:

  1. 1

    The IACUC immediately report a serious noncompliance to OLAW. The aspects of Wright's research program that require use of the affected animals will be temporarily suspended. The suspension would remain in effect until Wright prepares a relevant animal protocol proposal and that proposal is approved by the IACUC. Because of the critical nature of his research, the IACUC would expedite review of this protocol with the expectation that this suspension could be lifted within a few days. Wright would also be placed on probation for a specified amount of time (e.g., one year). During that time, his use of animals would be closely monitored by animal care personnel and the IACUC. If it is discovered during the course of that year that he was again performing unapproved surgeries, his animal-based research would be suspended. A supervised probation would allow Wright to continue his research while at the same time send a clear message that further noncompliance would result in serious consequences.

  2. 2

    The IACUC immediately begin an investigation to determine if students and post-docs working with Wright were aware that the surgeries were not approved. This would emphasize to all that, although Wright (as PI) bears the burden of responsibility for noncompliance, all persons using animals at Great Eastern are responsible for reporting violations of animal care policies. If this investigation determined that Wright instructed those under him to disregard animal use and care policies, the IACUC would have no choice but to suspend his animal-based research until the situation is resolved. If this investigation did not find evidence of intentional violations, then his cooperation with the IACUC and the probationary period would be considered sufficient to prevent recurrence.

If Wright's research was funded by a grant or contract from an extramural funding source, then the funding agency's policies governing animal use must also be considered. Those policies might require additional responses by the Great Eastern IACUC.

As far as the IACUC is concerned, the species of animal should make no difference. However, every researcher should be sensitive to how their work would be viewed by the general public. We cannot imagine that public revelation of unapproved surgeries on NHPs would be very favorable for Wright or for Great Eastern University.