Anti-animal research activities during the past several years against insti-tutions using animals in research, testing and teaching programs have included demonstrations, break-ins, vandalism, life threats and harassment by mail or telephone, arson, and bomb threats. Since the IACUC has responsibility for the welfare of animals at its facility, it shares responsibility for the security of the animals and personnel who care for and use these animals with other units within the institution, such as the units responsible for security, public information, and governmental relations. Institutions receiving federal funds have an obligation to protect the federal investment in research by exercising due diligence in this area. The IACUC can serve a key role in advising the IO and the institution of potential risks and vulner-abilities, and in developing a plan for responding to potential or real threats.
In all cases the IACUC must consider allegations of noncompliance or animal welfare issues as concerns that must be addressed in accordance with relevant PHSPolicy provisions and Animal Welfare Regulations (AWRs) (see Section D).
There are four key elements to an institution’s preparedness:
an animal care and use program of impeccable integrity;
an integrated communication plan with descriptions of research projects in lay terminology, spokespersons, and a telephone tree; and
an internal and external community outreach program that includes legislators and funding agencies.
Crisis Management Team
The establishment of a crisis management team before a crisis occurs is important in order to respond in a timely manner. This team may be comprised of individuals representing the following areas: security, public information, laboratory animal resources, the IACUC, management/research administration (including the IO), legal affairs, and governmental relations.
It is helpful for this team to meet periodically to keep abreast of current issues at the national and local level, and to be apprised of current research activities.
Risk Assessment – Security
The first step in developing a security program is to conduct a risk assess-ment of the institution's facilities and evaluation of the existing security system. Organization of a security and communication plan then follow. Some key points include:
Determine facility vulnerability.
Look at the research facilities with a “public eye.”
Be aware that use of certain animal species can increase vulner-ability (e.g., nonhuman primates, cats and dogs).
Be aware that some kinds of research may be perceived to be controversial (e.g., surgical and neuroscience protocols, including drug-addiction studies).
Carefully review protocols that are more likely to generate requests for information under state or federal open records laws, such as items (b) and (c) above.
Evaluate the security system.
Review policies regarding access and electronic surveillance systems.
Check location of keys and access to animal rooms; entrances and exit sites such as stairwells and roof access.
Determine who has access to buildings during nights and weekends.
Ensure computer security, network access, etc. with computer administrators.
Check storage of research data.
Ensure security of IACUC records and research data, including copies maintained offsite.
Review research protocols for confidential information.
Review protocols for graphic and/or sensitive terminology.
Organize a security plan.
Consult with local police to establish procedures.
Establish clear lines of authority and roles in a crisis situation.
Maintain a list of research projects and scientists.
Identify ongoing investigations by regulatory agencies.
Limit access of delivery persons within animal care facilities.
Keep duplicate physical layout plans available off site.
Share information with security personnel about activism at other research organizations.
Develop a document that will provide pertinent information to the police in the event of an incident such as type of incident, loca-tion, animals or property destroyed or stolen, people involved, time, method of entry, and need to check for hazardous materials.
Organize a communication plan in the event of an incident during the day, after hours, weekends, and holidays.
Communications and Risk Reduction
Institutions using animals need to communicate effectively and on an on-going basis with the internal and external community and the media. It is important to build these relationships over time and to keep individuals in all of these areas informed about the significance of the work in which animals are used, and the institution's commitment to scientific standards through quality animal care and use. Being proactive by conveying signi-ficant advances in research using animals ethically and humanely can reduce the potential for negative public reactions in a crisis situation.
The IACUC Chair and members can interact with institutional public infor-mation officers, researchers, veterinarians, technicians and the research administration to identify spokespersons to address animal research issues. These spokespersons should be provided adequate training. Fact sheets should be readily available about the institution's policies and commitment to humane and appropriate animal care and use, the quality of its animal care and use program (including accreditation), and brief summaries of the value and importance of any specific animal use under scrutiny. Written materials need to be written in language understandable to nonscientists. Institutions must be prepared to respond to allegations honestly (i.e., if real noncompliance with relevant policies or regulations is substantiated then the institution must take appropriate action and should be forthcoming about the situation).
In the event of a crisis the facility that is prepared can respond quickly through its spokespersons with accurate and factual information. It is also important for the institution to notify OLAW in such an event so they can
confirm the status of the institution's PHS Assurance and any PHS sup-port, as well as AAALAC, which maintains a crisis communication plan to assist accredited institutions.
Maintaining a high quality animal care and use program, good relationships within the institution and the community, and an effective education program can help to prevent and alleviate many crisis situations and significantly reduce the need for long term damage control.
References CBRA Crisis and Communications Manual, California Biomedical Research Association. April 2000
Institutional Administrator's Manual for Laboratory Animal Care and Use. PHS. NIH Publication #88-2959.
B.6.b. Disaster Planning As a fundamental component of the operational plans for most animal facilities, the Disaster Plan is a detailed, site-specific compilation of critical resources that are helpful in a variety of crisis events. The Guide recom-mends that all animal facilities have a Disaster Plan as part of their overall program and that the veterinarian or animal facility manager be part of the official institutional response team. While the Guide does not outline the elements of a Disaster Plan, it does suggest that facilities maintain sufficient emergency power necessary to maintain critical services (e.g., heating, ventilation and air conditioning (HVAC) system) and support functions (e.g., freezers, ventilated racks and isolators). Unique components of the facility may require special considerations. The proper institutional authority should approve the final plan so that appropriate resources can be committed during an emergency event. Typically, the IACUC does not have primary responsibility for emergency preparedness, but because emergency events could have significant impact on animals and the animal facility, the committee may choose to assess their site's preparedness during regular semiannual program reviews.
Emergency Management In addition to the development of a Disaster Plan, an animal facility should consider approaching disaster preparedness from the more encompassing perspective of emergency management. One invaluable resource for emergency management information is the Federal Emergency
Management Agency (FEMA). FEMA is an independent federal agency founded in 1979 that reports directly to the President. FEMA’s mission is to reduce loss of life and property and protect our nation's critical infra-structure from all types of hazards through a comprehensive, risk-based, emergency management program. FEMA considers an effective emer-gency management program to consist of four parts:
Mitigation (activities related to preventing future emergencies or minimizing the effects of emergencies that occur);
Preparedness (incorporation of the planning and preparations required to handle an emergency, including the Disaster Plan);
Response (the Disaster Plan put into action when an emergency occurs); and
Recovery (the actions needed to return to normal after an emergency occurs.)