IACUC Guideline 1 - Documentation of Consideration of Alternatives

The following statement is a direct quote from the federal regulations regarding the need to document the consideration of alternatives to potentially painful procedures:

"...Further, the Institutional Animal Care and Use Committee (IACUC) shall determine that the proposed activities or significant changes in ongoing activities meet the following requirements:

• i. Procedures involving animals will avoid or minimize discomfort, distress, and pain to the animals;
• ii. The principal investigator has considered alternatives to procedures that may cause more than momentary or slight pain or distress to the animals, and has provided a written narrative description of the methods and sources, e.g., the Animal Welfare Information Center, used to determine that alternatives were not available..."

Recently, the United States Department of Agricultural (USDA) has increased enforcement of Policy #12 requiring a search for alternatives for procedures that may cause pain or distress to research animals. If your project involves procedures that may cause pain or distress, documentation of a search is needed. You are required to submit a summary of the key words used in the search, the databases and other sources utilized, the years covered, and the date of the search. Also, the Committee would like to inform you that while the IACUC does not need to review the actual results of the search, the Principal Investigator (PI) must maintain them in the event that an USDA inspector requests them.

However, the IACUC recognizes that, for certain situations, a computerized literature search may not be an appropriate means of identifying alternatives. In other cases, research designs and regulatory requirements from other agencies may make alternatives inappropriate or unacceptable. In such cases, the investigator should supply a narrative that includes a justification for not using alternatives or why no alternative exists.