Great Eastern University received an NIH-funded grant to perform a study with deer mice (Peromyscus sp.). Although most of the work would be performed at Great Eastern, the school contracted out a small component of the study to Little Eastern College. The Memorandum of Understanding (MOU) between the two institutions stated that both schools were responsible for reviewing and approving the protocol for the work to be performed at Little Eastern College.

As the study progressed at Little Eastern it became obvious that the ketamine/xylazine anesthetic being used was unsatisfactory and that isoflurane would be a better choice. The principal investigator (PI) at Little Eastern submitted a request to his IACUC office to change the anesthetic. The office had an IACUC-reviewed and approved policy on anesthetic use for rodents; therefore, using the veterinary verification and consultation process (VVC), the PI’s request was forwarded to the attending veterinarian at Little Eastern. The veterinarian verified that isoflurane at the dosage requested by the PI was within the boundaries of the IACUC’s policy and would be an acceptable anesthetic for the study. The PI’s request and the veterinarian’s subsequent concurrence were documented in the IACUC’s meeting minutes.

Some time later, at a routine USDA site inspection at Little Eastern College, the inspector read the IACUC minutes and the MOU between the two schools and saw that the anesthetic change was made without the concurrence of Great Eastern University. She asked why this happened, as the MOU clearly stated that both schools had to review and approve the protocol. The explanation provided by Little Eastern was that the protocol was approved by both schools, but the anesthetic change was made by using VVC and there was nothing in the MOU stating that a VVC request had to be approved by both schools.

What is your opinion? Did the Little Eastern College’s IACUC overstep its authority in one or more ways or was it compliant with the MOU?