Does the PHS Policy place any proscriptions on filling the positions of IO, attending veterinarian, and IACUC Chairperson with the same individual?
While there are no specific prohibitions, OPRR strongly recommends against having more than one of these positions filled by the same individual. OPRR considers that the responsibilities and authorities vested in each of the aforementioned positions are distinct, often requiring different skills. Also, the assignment of more than one of these roles to the same individual circumvents the intended checks and balances designed by the framers of the PHS Policy. Circumstances arising from having the same person serving as the IACUC Chair, the institutional veterinarian, and the IO have, in the past, been an underlying factor in some of our most serious cases of noncompliance with the PHS Policy. In addition, the mere perception of conflict of interest may lead to allegations of improprieties from various sources. However, the intent of the PHS Policy is to provide levels of responsibility and authority within institutions which would provide an optimal environment for its implementation. He
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