Policy on Requirements for Personnel Working with IACUC-Covered Animals
Approval Date: August 7, 2019
I. Purpose of Policy
Regulatory agencies, accrediting bodies, and funding entities have requirements for personnel who use or are exposed to animals in research, teaching, and/or training. Each institution is charged with devising programs that address these requirements through the Institutional Animal Care and Use Committee (IACUC). The purpose of this policy is as follows:
List the requirements that personnel must complete to work on IACUC protocols.
Provide authority to determine exceptions or modifications to these requirements, as necessary.
Summarize how compliance will be ensured.
II. IACUC Clearance for Personnel
At Tufts University/Tufts Medical Center, all training and health requirements must be complete before an individual may work with animals or be a Principal Investigator (PI) on an IACUC-covered activity. When the necessary requirements for each person are complete, the IACUC office will notify the individual and PI in writing.
There are many different types of animal use and levels of risk; therefore, it is necessary to ensure that these requirements are completed, standardized, and documented. This policy provides general parameters for each requirement, and acceptable alternative methods and criteria to allow exemptions. The IACUC office is charged with interpreting this policy for each person and will keep documentation regarding IACUC Clearance.
No work with animals may occur prior to IACUC Clearance.
III. Personnel Requirements
Below are the requirements to obtain IACUC Clearance (see above). Our institutions provide forms and presentations that can be used to complete the requirements. Access to the forms, trainings, and further guidance is provided on the IACUC Personnel Page.
Request to add Personnel to an Animal Protocol (Supplement P)
a. Mandatory Animal Care and Use Training
b. Rodent Survival Surgery Training, as applicable
Occupational Health and Safety (OHS) Authorization
1. Personnel Added onto an Animal Protocol
To work with live animals each person must be added to each active IACUC protocol on which he or she will work. All listed personnel must review and understand the approved IACUC protocol/amendments. The Principal Investigator is responsible for ensuring that all protocol personnel are familiar with the study and are adequately trained (see IACUC Policy on Definition and Responsibilities of an IACUC Principal Investigator). Personnel additions on a protocol are handled administratively via Supplement P and do not need to be reviewed by the IACUC.1
By way of this policy, the IACUC exempts the following groups from being listed as protocol personnel. However, training and occupational health and safety requirements must still be met.
Veterinary and husbandry staff of the Laboratory Animal Medicine Service (LAMS), the Farm, Foster Hospital for Small Animals (FHSA), Hospital for Large Animals (HLA), Tufts Comparative Medicine Services (Tufts CMS), and Comparative Biology Unit (CBU) performing routine clinical duties.
Students in a classroom or veterinary clinical setting involved in training activities with animals, who are monitored by the Principal Investigator or designee. Designated instructors may NOT be student instructors.
Clients on studies that are overseen by a Tufts CMS or LAMS veterinary staff member as the Principal Investigator, conducted only in the Tufts CMS/LAMS/CBU facilities, FHSA, or HLA and are always supervised by Tufts CMS/LAMS/CBU staff.
2. IACUC Trainings
Mandatory Animal Care and Use (MACU) Training – the Institution provides an online Mandatory Animal Care and Use presentation and quiz. This module provides training on how to comply with animal regulations, institutional policies, and the guidelines and procedures within Tufts CMS/LAMS/CBU. All personnel listed on an animal protocol, including Principal Investigators, must complete this basic training at least once every three years.
Rodent Survival Surgery (RSS) Training – all personnel who will participate in rodent survival surgery must complete this training prior to performance of surgery and renew at least once every three years. Principal Investigators of protocols that include rodent survival surgery must also complete and renew this training even if they do not perform the surgery(ies).
The IACUC understands that alternative training may be better suited to a project (or person’s) situation. In these cases, there may be other forms of training that are acceptable to the IACUC. These situations can be justified and determined as compliant with this policy by the IACUC office with IACUC Chair/Vice-Chair consultation, if necessary.
3. Occupational Health and Safety (OHS) Authorization
The OHS authorization is a required risk management assessment that is used to establish a high level of safety for all individuals who 1) work with animals in research, teaching/training, 2) are involved in the care and use of research/teaching animals, and/or 3) may have significant exposure to animal housing areas. The purpose of the form is to identify relevant individual health concerns which may affect a person’s ability to safely conduct the proposed activity.
To allow accurate assessment of individual risk, each person must submit a confidential form directly to the OHS service provider for their campus. Once the medical professional has completed the review of the form, the IACUC office will receive a date of medical authorization for that person to be exposed to animals. This authorization must be updated on an annual basis.
The IACUC understands that there may be alternative ways to achieve OHS training, risk assessment, and medical treatment that are better suited to a project or person’s situation. These situations can be justified and determined as compliant with this policy by the IACUC office with IACUC Chair/Vice-Chair consultation, if necessary.
IV. Failure to Complete or Renew Personnel Requirements
A database of all completion dates per individual is managed by the IACUC office. Personnel will be assisted with reminders, but it is the Principal Investigator’s responsibility to ensure that his/her personnel have completed and renew all IACUC personnel requirements.
1Office of Laboratory Animal Welfare (2017). “Significant Changes to Animal Activities” [Online]. Available: https://grants.nih.gov/grants/olaw/significant_changes.htm
United States Department of Agriculture. (2017). Animal Welfare Act and Animal Welfare Regulations. Retrieved from
Institute of Laboratory Animal Resources. (1987) Occupational Health and Safety in the Use and Care of Research Animals