Assurance of Compliance With Public Health Service Policy On Human Care and Use of Laboratory Animals By Awardee Institutions

Bryn Mawr College, hereinafter referred to as institution, hereby gives assurance that it will comply with the Public Health Service Policy on Humane Care and Use of Laboratory Animals by Awardee Institutions, hereinafter referred to as PHS policy.

  1. Applicability

    This assurance is applicable to all research, research training, experimentation, biological testing, and related activities, hereinafter referred to as activities, involving live, vertebrate animals supported by the Public Health Service (PHS) and conducted at this institution, or at another institution as a consequence of the subgranting or subcontracting of a PHS-conducted or supported activity by this institution.

    "Institution" includes the following branches and major components of Bryn Mawr College; the Graduate School of Arts and Sciences, and the Graduate School of Social Work and Social Research.
  2. Institutional Policy
    1. This institution will comply with all applicable provisions of the Animal Welfare Act and other Federal statutes and regulations relating to animals.
    2. This institution is guided by the U.S. Government. Principles for the Utilization and Care of Vertebrate Animals Used in Testing, Research and Training.
    3. This institution acknowledges and accepts responsibility for the care and use of animals involved in activities covered by this Assurance. As partial fulfillment of this responsibility this institution will make a reasonable effort to ensure that all individuals involved in the care and use of laboratory animals understand their individual and collective responsibilities for compliance with this Assurance as well as all other applicable laws and regulations pertaining to animal care and use.
    4. This institution has established and will maintain a program for activities involving animals in accordance with the Guide for the Care and Use of Laboratory Animals (Guide).
  3. Institutional Program for Animal Care and Use
    1. The lines of authority and responsibility for administering the program and ensuring compliance with this policy are:

      The members of the IACUC are appointed by the President of Bryn Mawr College. The Chair of the IACUC submits appropriate reports to the Director of Faculty Grants and the Provost. The Provost is ultimately responsible for taking any actions necessary to sanction an investigator who fails to comply with PHS Policy and institutional requirements. The veterinarian may communicate with the Chair who then contacts the Provost.
    2. The qualifications, authority and percent of time contributed by veterinarian(s) who will participate in the program include:
        Dr. Carl M. Cousins, D.V.M. is the Veterinarian who participates in the IACUC. His qualifications are as follows:

        B. S. in Biology, Virginia State University, 1952; D.V.M., Tuskegee University, 1959; Internship in Veterinary Medicine, University of Pennsylvania, 1961; Enrolled in special seminars on laboratory animal medicine at both Tuskegee University and the University of Pennsylvania; Member of the Pennsylvania State Board of Examiners in Veterinary Medicine.

        Dr. Cousins serves on a consulting basis on problems of health of the animals and, together with the other members of the Committee, on inspection of the animal housing, research, and teaching facilities at Bryn Mawr College. Dr. Cousins is present at all meetings of the IACUC and is active in setting policy. Approximately one percent (1%) of his time is given to the functions of the IACUC.

        We have excellent, long-standing working relations with Dr. Cousins which permit us to avail ourselves of his serves on an "as needed" basis rather than in terms of some fixed percentage of his time. In the event Dr. Cousins is not available, the veterinarian on duty at Dr. Cousins' practice will act in his stead.
    3. This institution has established an Institutional Animal Care and Use Committee (IACUC), which is qualified through the experience and expertise of its members to oversee the institution's animal program, facilities, and procedures. Approval of animal use by all members of the IACUC is required prior to initiation of the animal research project. The IACUC consists of at least five members, and its membership meets the compositional requirements set forth in the PHS Policy at IV.A.3.b. Attached is a list of the names, position titles and earned degrees or other credentials of the IACUC chairperson and members.
    4. The IACUC will:
      1. Review at least once every six months the institution's program for humane care and use of animals, using the Guide as a basis for evaluation. The committee convenes every six months and reviews procedures. The committee convenes every six months and reviews procedures.
      2. Inspect at least once every six months all of the institution's animal facilities, including satellite facilities, using the Guide as a basis for evaluation. Facilities are inspected in conjunction with the above meetings. All facilities are subjected to walk through and examined for compliance with guidelines. Any animals housed are check for general health.
      3. Prepare reports of the IACUC evaluations as set forth in the PHS Policy at IV.B.3. and submit the reports to the Provost. Written reports are prepared by the Chairman of the IACUC, circulated to the committee for approval and then forwarded to the Provost.
      4. Review concerns involving the care and use of animals at the institution. Concerns may be raised by faculty members, staff, or students. Any concerns are studied promptly. Responses to the individual voicing the concern are prepared in writing. In the event that a genuine problem is uncovered, the Chairman of the IACUC convenes the committee which then makes recommendations to the Provost. Serious concerns will be reported by the IACUC Chair to OLAW. Individuals raising concerns are protected against reprisal as required by the AWA.
      5. Make written recommendations to the Provost regarding any aspect of the institution's animal program, facilities, or personnel training. The Chairman of the IACUC, after consulting with the committee makes written recommendations to the Provost and is responsible for appropriate follow-up.
      6. Review and approve, require modifications in (to secure approval) or withhold approval of those activities related to the care and use of animals as set forth in the PHS Policy at IV.C. The IACUC procedures for protocol review are the submission of the protocol in standard format to the Chair. The protocol is circulated to all members of the committee who then comment on it. Protocols are reviewed at regular meetings.
      7. Review and approve, require modifications in (to secure approval) or withhold approval of proposed significant changes regarding the use of animals in ongoing activities as set forth in the PHS Policy at IV.C. In the event of major revisions, required changes are communicated to the PI who then must respond in writing. The protocol is then re-reviewed.
      8. Notify investigators and the institution in writing of its decision to approve or withhold approval of those activities related to the care and use of animals, or of modifications required to secure IACUC approval as set forth in the PHS Policy at IV.C.4. If concerns are found, these are communicated to the P.I. who must respond prior to approval.
      9. Conduct continuing review of each previously approved, ongoing activity covered by this Policy at appropriate intervals as determined by the IACUC, including a complete review in accordance with the PHS Policy at IV.C. 1.-4. at least once every three years. All continuations of grants are subject to rereview at least every three years. Review of ongoing activities occurs as part of the semi-annual inspection, when all P.I.'s are spoken to. Expedited review is carried out in exceptional cases by electronic circulation of protocols. Concerns are sent to the Chair who then communicates with the P.I.
      10. Be authorized to suspend an activity involving animals as set forth in the PHS Policy at IV.C.6. Should suspension of activity be deemed necessary, the Chair of the IACUC will communicate with both the P.I. and the Provost.
    5. The individual authorized by this institution to verify IACUC approval of those sections of applications and proposals related to the care and use of animals is the current Provost.
    6. The Health program for personnel who work in laboratory animal facilities or have frequent contact with animals is as follows:
        All individuals working with animals must submit a brief medical history listing allergies and other sensitivities. Tetanus vaccination is required - current within 10 years Animal care personnel are instructed to wear latex or nitrile gloves whenever practical and to use of laboratory coats for all procedures other than routine cage cleaning. The P.I. also is responsible for direct training of all personnel working with animals, including specific techniques and safe and humane handling of animals. All employees are covered by Worker's Compensation and have access to the College's infirmary. The College also provides health insurance for full-time employees. Supervisors are required to keep medical records containing information on vaccinations and allergies on file.
    7. The total gross number of square feet in each animal facility (including each satellite facility), the species of animals housed therein and the average daily inventory, by species, of animals in each is : (See attached chart.)
    8. The training or instruction available to scientists, animal technicians, and other personnel involved in animal care, treatment, or use are:

        Bryn Mawr College subscribes to LATA (Laboratory Animal Training Association), which provides video modules for instruction and information about humane care and use of laboratory animals. LATA's program (which includes examination questions) provides an excellent general overview of the history of use of animals in experimentation and of societal views, philosophies, and laws concerning the humane use of such subjects. Included is a clear statement of the 1985 Improved Standards for Laboratory Animals Act and of USPHS's subsequent revisions and extensions of the Act. In addition, there are training modules dealing specifically with laboratory requirements and procedures for a variety of animal species. The training includes information on the humane practice of animal maintenance and experimentation and the concept, availability, and use of research and testing methods that limit the use of animals or limit animal distress.

        We use two modules: "Human Care and Use of Laboratory Animals" and "Humane Care and Use of the Mouse, Rat and Hamster." Every person having anything to do with laboratory animals (technicians, graduate and undergraduate students, faculty) is required to participate in the program before being permitted to use animals in research. Any project involving animals (including those in undergraduate instructional laboratories) must be approved by IACUC (Institutional Animal Care and Use Committee), whose responsibility it is to insure that the personnel involved receive prior training with the LATA Program. For example, students in the introductory courses in Biology and Psychology are required to go through the program in the initial laboratory meetings, if the courses require any involvement with laboratory animals. The training becomes more intensive the greater the involvement of personnel in laboratory research. Annual training of all personnel working with animals is required and P.I.'s must maintain records indicating the dates of each individual's training.
  4. Institutional Status: As specified in the PHS Policy at IV.A.2 as Category 2, all of this institution's programs and facilities for activities involving animals have been evaluated by the IACUC and will be reevaluated by the IACUC at least once every six months in accord with IV.B.1. and 2. of the PHS Policy, and reports prepared in accord with IV.B.3.of the PHS Policy. The most recent semiannual IACUC evaluation report has been submitted to the Provost and a copy of the report is attached.

    All IACUC semiannual reports will include a description of the nature and extent of this institution's adherence to the Guide. Any departures from the Guide are identified specifically and reasons for each departure are stated. Where program or facility deficiencies are noted, the report contains a reasonable and specific plan and schedule for correcting each deficiency. The report distinguishes significant deficiencies from minor deficiencies. Semiannual reports of the IACUC evaluation submitted to the Provost, will also contain a reasonable and specific plan and schedule for correcting each deficiency and distinguish significant deficiency from minor deficiencies. Semiannual reports of the IACUC evaluation will be maintained by this institution and made available to OLAW upon request.
  5. Record-keeping
    1. This institution will maintain for at least three years:
      1. A copy of this assurance and any modifications as approved by PHS.
      2. Minutes of IACUC meetings, including records of attendance, activities of the Committee and committee deliberations.
      3. Records of applications, proposals and proposed significant changes in the care and use of animals and whether IACUC approval was given or withheld.
      4. Records of semiannual IACUC reports and recommendations as forwarded to the Provost.
    2. This institution will maintain records that relate directly to applications, proposals, and proposed changes in ongoing activities reviewed and approved by the IACUC for the duration of the activity and for an additional three years after completion of the activity.
    3. All records shall be accessible for inspection and copying by authorized OLAW or other PHS representatives at reasonable times and in a reasonable manner.
  6. Reporting Requirements
    1. At least once every twelve months, the IACUC through the institutional official will report in writing to the OLAW:
      1. Any change in the status of the institution (e.g., if the institution becomes accredited by AAALAC or AAALAC accreditation is revoked), any change in the description of the institution's program for animal care and use described in this Assurance, or any changes in IACUC membership. If there are no changes to report, this institution will submit a letter to OLAW stating that there are no changes.
      2. Notification of the date that the IACUC conducted its semiannual evaluations of the institution's program and facilities and submitted the evaluation to the Provost.
    2. The IACUC through the institutional official will provide the OLAW promptly with a full explanation of the circumstances and actions taken with respect to:
      1. Any serious or continuing noncompliance with the PHS Policy.
      2. Any serious deviations from the provisions of the Guide.
      3. Any suspension of an activity by the IACUC.
    3. Reports filed under VI.A.2. and VI.B. above shall include any minority views filed by members of the IACUC.
  7. Institutional Endorsement and PHS Approval

Signed by the Provost and submitted to the DHHS on February 26, 2002