This scenario provides several areas for process improvement for the IACUC, researcher and Safety Officer. The use of containment (assumed, biocontainment) may be excessive burden for a commonly used hazardous chemical agent such as tamoxifen. The Principal Investigator (PI) is correct to question the IACUC on the inconsistent and perhaps overburdensome regulation set forth by this animal care and use program.
The IACUC and Safety Officer should first meet and review the use of tamoxifen, as well as other hazardous agents, at the institution. The group should review the type of housing options and determine what is most suitable for the various class of agents, as well as the equipment in use, cleaning/sanitization standard operating procedures (SOPs), and personal protective equipment (PPE) used. Containment housing, used for biological hazards, often includes autoclaving of bedding and equipment used to inactivate any viruses present, as well as increased PPE use. However, as tamoxifen is a chemical hazard, it might be a waste of money, time, and space in the containment housing facility to require investigators keep their animals under all of those conditions. In the case of this and other chemical hazards, an alternative cage labeling and/or designated rack, and appropriate bedding dumping process may be sufficient to protect staff from the hazard. As tamoxifen is a very common agent used in rodent research, it is likely that the institution can achieve both time and money savings with such a review, as well as improve investigator buy-in to appropriate practices.
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