Joshua Richmond knew that the procedure he performed on a rat was not approved by Great Eastern University’s IACUC. He had reminded Dr. Paul Levine, his graduate studies mentor, that they needed IACUC approval before initiating the procedure, but Levine became irate, as he often did, and told him to do what he was told to do or find another lab to work in. That was not a desired option for Richmond, so he performed the procedure.

Still bothered by the incident after a few months had passed, Richmond wrote an anonymous letter to the IACUC, relating the noncompliance. When the IACUC began its investigation, the rat was long gone. When confronted with the accusation, Levine denied the claim and demanded to know who his accuser was because the university’s bylaws specified that a faculty member accused of wrongdoing had a right to know his or her accuser. Richmond denied writing the letter but eventually admitted that he performed the procedure. Levine did not think Richmond was the whistleblower, assuming that would be too obvious; however, because Richmond was the only person working for him, he told Richmond to find another mentor, as he was no longer welcome in his laboratory.

Distressed by the impending loss of his job and possibly revealing himself as the letter writer, Richmond began reading. The school’s IACUC policy manual stated that the identity of a whistleblower would remain confidential if that was the preference of the whistleblower, but the policy said nothing about protection from reprisals. Nevertheless, he was somewhat heartened to find that the Guide for the Care and Use of Laboratory Animals stated that “The process [of reporting concerns] should include a mechanism for anonymity, compliance with applicable whistleblower policies, nondiscrimination against the concerned/reporting party, and protection from reprisals.”1 Richmond told the IACUC that Levine obviously imposed a reprisal against him, but the IACUC chair opined that the Guide was only referring to reprisals against a known whistleblower. The IACUC chair was also concerned with the comment in the Guide about protection from reprisals because a document from the federal Office of Laboratory Animal Welfare (OLAW), stated that “OLAW may withhold identifying information to protect whistleblowers, but protection from reprisal for whistleblowers must be addressed at the institutional and/or state level.”2

Is Richmond both a whistleblower and the target of a reprisal even though he denied writing the letter? Is there a conflict between the OLAW statement which assigns responsibility against reprisals to the institution or state, and the Guide, which is incorporated into the PHS Policy3,4 and appears to expect an institution to provide protection from reprisals? Should Richmond tell the whole truth and look for another lab? How should the IACUC deal with these issues?