One animal, two protocols—an appropriate application of the 3Rs?

One of the IACUC’s responsibilities is to help ensure that researchers use the least possible number of animals compatible with research requirements. Therefore, it seemed like a good idea to Patty Bergman to use the same animals for her own research that her colleague Yancy Wycroft was using for his research. His work involved behavioral testing of rabbits after exposure to different chemical scents, and hers required a weekly blood sample of 0.5 ml per rabbit. On the surface, this sounded like a fine idea to Craig Miller, the IACUC Chairman. Then Bergman clarified things. She wanted to have her own IACUC protocol, but do her experiments concurrently with those of her colleague, using the same animals he was using. This was a new twist for Miller. He had thought that Bergman planned on using the animals after Yancy was done with them. “You know, Patty,” Miller said, “since all you’re planning on doing is taking a little blood once a week from each of the rab­ bits, wouldn’t it just be easier to amend Yancy’s protocol by adding you as one of the research personnel and indicating you will just be taking the blood?” “I thought of that,” said Bergman, “but Yancy said he wasn’t comfortable with that arrangement. He’s very confident that my taking a little blood won’t affect his own research in any way, but his NIH [National Institutes of Health] grant doesn’t say any­ thing about the kind of work I’m doing or about taking any blood. He’s afraid that if I add my work onto his protocol, there might be questions at NIH about a change in the direction of the work.” “I understand what you mean,” Miller said, “but he’s not changing the direction or scope of the work under his grant; he’s just letting you use his rabbits for an unre­ lated purpose that doesn’t affect his own research.” “Thanks,” said Bergman, “but I already tried that argument and it didn’t get me anywhere. As a practical matter, I’d rather have my own protocol anyway and not have to worry if Yancy put in his protocol renew­ al on time or did anything else that might affect my research. My work is NIH-funded so if it’s a real problem for the IACUC, I’ll just purchase rabbits for bleeding rather than use Yancy’s animals. I’m only making this request because I’m trying to save ani­ mals and save money. It seems like a winwin deal all around.” “It is a good idea,” said Miller,“but I really have to think about the consequences and legality of doing this. Let me get back to you.” Can Patty Bergman have her own IACUC protocol but use Yancy Wycroft’s rabbits for blood draws at the same time he is using them for an unrelated research purpose? What IACUC problems, if any, can you foresee?