Establishment of protocols for grievance procedures
The following policy has been prepared to assist institutions in formulating and documenting grievance procedures related to the use of animals in research and teaching.
Requirements of the Australian Code of Practice for the Care and Use of Animals for Scientific Purposes:
Clauses 2.1.1 (xi) and (xii) of the Australian Code of Practice for the Care and Use of Animals for Scientific Purposes specifies that institutions must:
- establish mechanisms to respond to enquiries or complaints concerning the use of animals within the institution and ensure that personnel and students may voice concerns without jeopardising their employment, careers or coursework;
- establish and make known procedures for the fair resolution of disagreements between AEC members, between the AEC and investigators or teachers, or between the AEC and the institution.
Clause 2.2.10(i) states:
Proposals must be assessed: '...in a manner that is fair to applicants and acceptable to all members including the need to provide AEC members with information in a timely manner.'
Clause 2.2.14 states:
'Irreconcilable differences between the AEC and an investigator or teacher must be referred to the governing body of the institution for review of the due process. The ultimate decision of an AEC after such a review must not be over-ridden.'
Guidelines
1. A grievance procedure is a mechanism for handling concerns or complaints from staff and students within the organisation and also from people outside the organisation. It should also be used for resolving disputes between researchers or teachers and the Animal Ethics Committee (AEC). A formal record should be kept of all steps in the process.
2. Institutions must have an appeal mechanism in place for investigators or teachers who feel that an AEC is unfair or for AEC members who feel that decisions being made by the AEC are unacceptable. It should , however, be noted that the Animal Research Act 1985 does not allow for the approval of research (the issuing of Animal Research Authorities), except with the approval of and in accordance with the directions of the institution’s Animal Ethics Committee.
3. Procedures should be developed to handle the following:
- Complaints from independent people who are not associated with research.
- Complaints by staff or students within the accredited research establishment without jeopardising the person's employment or entitlements.
- Disputes between investigators or teachers and the AEC.
- Serious disagreements between members of the AEC.
- Disagreements between the AEC and the institution's management.
Types c, d and e may need referral to a higher authority than the AEC - possibly the Chief Executive Officer of the institution.
Guidance on policy matters may be sought from the Animal Research Review Panel in the case of an irreconcilable dispute.
4. All complaints must be treated confidentially.
5. Investigation of a complaint or dispute may include:
- interviews of the complainant, the subject of the complaint and witnesses
- unannounced inspection of the facility or animal(s) in question
- seeking expert advice on technical matters from outside the institution
6. Any member of an AEC receiving a welfare complaint is obliged to raise the matter with the AEC as soon as possible.
7. Staff and students of an institution must be made aware of what grievance procedures exist.
Animal Research Review Panel Policy 8