3 * h :i r .. 3 NATIONAL SCIENCE FOUNDATION OFFICE OF INSPECTOR GENERAL OFFICE OF INVESTIGATIONS CLOSEOUT MEMORANDUM Case Number: A05040016 Page 1 of 2 We received an allegation1that a scientist on an NSF-funded subaward2had improperly used three guinea pigs. The scientist allegedly used the animals without the proper review and approval by the supporting university's Institutional Animal Care and Use Committee (IACUC). If true, such use would constitute a violation of NSF policy and applicable federal regulations. During our review, we determined that the proposal University 1 sent to NSF did not indicate that vertebrate animals were to be used.4 When questioned by University 1 officials, the PI stated that he never intended to use animals during this award. Although both universities have policy and training on the use and care of animals, we determined that the scientist working on the subaward unilaterally decided to use the animals. The scientist went to a local pet store, purchased three guinea pigs, and, subsequentlyharvested them. He did not seek or obtain permission from University 2's IACUC or inform the PI of his intentions. University 2 officials did not find out about the use of the animals until the scientist sought reimbursement for their cost. University 2 quickly informed both NSF and University 1 of the matter. In addition, University 2 referred the matter to their IACUC committee. Because the scientist had no prior history of wrongdoing and cooperated fully in the investigation, University 2 took no action against him, However, he was not reimbursed for the animals, consequently no NSF Any grantee performing research on vertebrate animals shall comply with the Animal Welfare Act [7 U.S.C. 2 131 et seq.] and the regulations promulgated there under by the Secretary of Agriculture [9 CFR 1.1-4:111 pertaining to the humane care, handling, and treatment of vertebrate animals held or used for research, teaching or other activities supported by Federal awards. The awardee is expected to ensure that the guidelines described in the National Academy of Science (NAS) Publication, "Guidefor the Care and Use ofLaboratory Animals" (1996) are followed and to comply with the Public Health Service Policy and Government Principles Regarding the Care and Use of Animals (included as Appendix D to the NAS Guide). NSF Grant Policy Manual $713 (07102). NSF requires that when vertebrate animals are to be used in an NSF funded project, the proposal include sufficient information to enable reviewers to evaluate the choice of species, number of animals to be used, and any necessary exposure to animals to discomfort, pain, or injury. Furthermore, NSF requires that the proposal receive the approval of the submitting organization's Institutional Animal Care and Use Committee (IACUC). Finally, NSF requires that the "Vertebrate Animal" box on the NSF cover sheet be checked. See NSF Grant Proposal Guide §C (1 l)(d) (12101) II UI NSF OIG Form 2 (1 1/02) NATIONAL SCIENCE FOUNDATION OFFICE OF INSPECTOR GENERAL OFFICE OF INVESTIGATIONS CLOSEOUT MEMORANDUM funds were ultimately involved. We were informed that University 1 also consulted its IACUC and that University 1 decided to terminate the subaward. There are no remaining issues. Accordingly, this case is closed. II I i I
Animal Subject Reg. Violation
Published by the National Science Foundation, Office of Inspector General on 2006-04-04.
Below is a raw (and likely hideous) rendition of the original report. (PDF)