Kathy Mariucci, BS, CPIA, RBP
IACUC Vice Chair, Senior IACUC Manager
UM Biosafety Officer
Complaints and Violations
Date Adopted: July 11, 2006
Last Review Date: September 27, 2017
A. Reporting a Complaint or a Violation
phone numbers, email addresses and office locations for reporting of complaints
and violations in all University of Montana animal facilities. Such information must
also be included on the UM Institutional Animal Care and Use Committee
(IACUC) web site for easy public access. Contact information will be provided for
mistreatment, or that there is a potential violation of IACUC policy (even if
mistreatment or policy violations to any of the following: the Institutional Official
(IO), the IACUC Chair, the IACUC Coordinator, the AV, a member of the IACUC,
or LAR staff member. A complainant may remain anonymous
description of the violation, the time and date of violation, the location, the type
of animal involved, and any other items which are relevant to the complaint.
be forwarded to the IACUC Chair.
IACUC Chair at the initiation of the investigation. At that time, the Chair
may choose to conduct or reassign the investigation.
IO and the IO will appoint an appropriate person to investigate the
will contact the IO.
in writing and maintained in the office of the IACUC Coordinator.
and protocols shall be subjected to any retaliation.
undertake reprisals. Retaliations or reprisals in the context of IACUC procedures for
handling complaints represent violations of IACUC standards that could result in
loss of privileges and/or access to the facilities for animal care and use under the
oversight of the UM IACUC.
respected by all parties involved.
B. Initial Investigation by the Attending Veterinarian (AV) or designee
sufficient information to investigate further.
necessary action which may include temporary suspension of use of
animals by any and all individuals involved in the reported complaint.
to the IACUC Chair.
and recommendations for further action.
the IO will appoint someone to investigate the allegation.
C. Action Following Initial Investigation
person who is the subject of the complaint in writing of the findings and
recommendations and that no further action will be proposed, subject to
IACUC review at the next regularly scheduled meeting.
an existing IACUC approved protocol without proper amendments
subject of the complaint (and his/her direct supervisor or PI) in writing of all
findings, recommendations, and any remediation (except for confidential
personnel actions) required to be completed within a specified time
frame. Such findings, recommendations, and remediation (except for
confidential personnel actions) are subject to IACUC review at its next
regularly scheduled meeting.
are completed within the established time frame.
timely manner, and self-report to USDA if a protocol suspension occurs for
an USDA-covered species.
wait until the next scheduled monthly IACUC meeting to discuss the
violation. A quorum of the IACUC must be present for the meeting.
shall immediately notify the committee and remove themselves from
further participation in the matter.
recommendations of the AV or designee and obtain additional
information as needed.
complainant is unwilling or unable to make a personal appearance,
the complainant may submit a written statement to the IACUC Chair
prior to the meeting.
written description of the substance of the complaint and will be
given an opportunity to meet with the IACUC to respond to the
complaint. If the person who is the subject of the complaint is not the
PI, the complaint will be forwarded to the PI responsible for the
animal or protocol described in the complaint or the direct supervisor
if a LAR employee is the subject of the complaint.
may have an advisor at the meeting with the IACUC. Advisors are
present in an advisory capacity only and are not permitted to speak
or present information directly to the IACUC.
complaint elect not to meet with the IACUC, the complaint will be
reviewed on the basis of information available, and a
recommendation will be made by the IACUC. No inference may be
drawn against the complainant and/or person who is/are the subject
of the complaint for failure to appear before the IACUC.
received, the IACUC (after excluding all nonmembers) shall discuss,
deliberate and prepare its findings and recommendations. By majority
vote of those present, the IACUC will determine whether or not
mistreatment of animals or policy noncompliance has occurred and
make recommendations. If the findings and recommendations are
not unanimous, minority opinions may be written and attached by
those who differ with the majority's findings and recommendations.
the IO. The IACUC recommendation shall be immediately binding until
such time as the IO has reviewed the recommendation. IACUC action(s)
may include, but is/are not limited to:
may include notice to the supervisor that if the same or similar
circumstances which were the basis of the complaint are found to
continue, this could result in suspension or complete revocation of the
protocol approval under which animal(s) were obtained and/or may
include suspension or complete revocation of the violator's privileges
to access LAR and animals.
revocation of the protocol approval.
subject of the complaint; and
taken by the IACUC to external organizations and/or government
agencies as required.
D. Record Keeping
investigations, action plans and outcomes on file for a minimum of 3 years.