As most of us are aware in the animal research community, PHS-assured institutions must start using the 2013 AVMA Guidelines for Euthanasia of Animals for protocol review as of September 1st, 2013 (NOT-OD-13-048). Departures from the Guidelines could be acceptable upon written justification, as determined by the IACUC.
“OLAW encourages PHS-Assured institutions to begin using the 2013 Guidelines when reviewing research projects as soon as possible, and expects full implementation after September 1, 2013. Previously approved projects undergoing continuing review according to PHS Policy, IV.C.5., which requires a complete de novo review at least once every 3 years, must be reviewed using the 2013 Guidelines after September 1, 2013.”
Now back to the story…
Speaking of regulations, I was recently sent an article from the “Legal Humor” website www.loweringthebar.net (thanks to Jeffrey Waldin, our resident COI and TT Product Manager). The title was “USDA Requires Magician to Create “Disaster Plan” for His Rabbit”. For those of us who are not surprised by this (USDA/APHIS Handling of Animals; Contingency Plans), the Final Rule in this matter stated:
“We are amending the Animal Welfare Act regulations to add requirements for contingency planning and training of personnel by research facilities and by dealers, exhibitors, intermediate handlers, and carriers. We are taking this action because we believe all licensees and registrants should develop a contingency plan for all animals regulated under the Animal Welfare Act in an effort to better prepare for potential disasters.”
The Magician in this case is Marty Hahne (AKA Marty the Magician), and he is required to file a disaster plan with the USDA, as he now met the above AWA Rule. The Rabbit is named “Casey”. Regulations now require such exhibitors to (paraphrased from the article):
- identify likely potential emergencies, including blackouts, fires, and natural disasters;
- outline specific tasks to be carried out in response to the identified emergencies;
- identify a chain of command for the fulfillment of these tasks;
- address the materials, resources, and training required to fulfill them;
- maintain written copies of the plan for federal review upon request; and
- if a “traveling entity,” carry a copy of the plan at all times.
An unnamed magician has added his answers to above points “I’ll take a piece of paper and put down, ‘Note: Take rabbit with you when you leave”. However, Marty now has a Contingency plan, that runs 28 pages, see it here.
(Footnote, APHIS has issued “Handling of Animals; Contingency Plans; Stay of Regulations” in the Federal Register on July 31st, 2013, effectively staying 9 CFR 2.38(l) and 2.134 indefinitely, which dealt with Contingency Plans.)