UW-Madison Notifications Regarding Serious Noncompliance for Activities Involving Animals

Page Updated: September 20th, 2019

PHS Policy requires that the University of Wisconsin-Madison notify the Office of Laboratory Animal Welfare (OLAW) and the NIH IC of instances of serious noncompliance, which may include:

  • The conduct of animal activities in the absence of a valid Animal Welfare Assurance on file with OLAW.
  • The conduct of animal activities in the absence of a valid IACUC approval of the activities. Absence of the IACUC approval include failure to obtain IACUC approval, expiration, or suspension of IACUC approval.

The RARC has established Policy Number 1999-007-io to ensure that any research, teaching, or outreach involving animal subjects is conducted only after an IACUC protocol has been approved for the activity. Further, Policy Number 1999-008-io describes guidelines in the event of instances of noncompliance by individuals engaged in the care or use of animals for research, teaching, or outreach. In addition to these policies, RARC IACUC Office internal standard operating procedures contain specific steps to be followed should noncompliance occur.

Potentially reportable events must be reported to the IACUC Chair and the Chief Campus Veterinarian. The Chief Campus Veterinarian is responsible for contacting the Office of Laboratory Animal Welfare (OLAW) or other regulatory body regarding noncompliant events as required by PHS or other agency policy. Instances of noncompliance may result in different actions being taken by the IACUC, up to and including suspension of activities using animals or animal use privileges. In some cases, an initial verbal report to OLAW or another organization may require a follow-up written report from the IACUC Chairperson and the Institutional Official (I.O.).

When OLAW requests additional information about a serious noncompliance in writing beyond the initial written report from the IACUC Chair and I.O., the IACUC Administrator will notify the Office of Research and Sponsored Programs (RSP). Notifications will be sent via email to the RSP Associate Director of Research Financial Services and the DHHS Post-Award Manager. The IACUC Administrator will provide information regarding the impacted protocol, the PI and funding source(s) associated with the protocol, and other useful information.

For impacted protocols involving projects funded by the National Institutes of Health (NIH), RSP will communicate with the NIH IC supporting the grant award and consult with them as needed regarding questions concerning allowable costs. RSP will also work with the campus department to ensure that no charges are made to federal grants for unauthorized animal activities.

Federal Policy References: