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Grievance procedures

Animal Research Review Panel Policy 8
Revised: 16 December 2014
INT14/118891

The purpose of this policy is to assist Accredited Animal Research Establishments in developing and documenting grievance procedures related to the care and use of animals in research and teaching. Grievance procedures are mechanisms for handling concerns or complaints.

The Australian Code for the Care and Use of Animals for Scientific Purposes sets out the responsibilities of establishments in addressing complaints related to the care and use of animals for research and teaching.

Clause 2.1.7 (ii) states:
Institutions must identify clear lines of responsibility, communication and accountability by:
ensuring that procedures are developed for addressing complaints and non-compliance relating to the care and use of animals for scientific purposes (see Section 5).

Clause 2.2.29 states:
Institutions must have procedures for dealing with complaints and non-compliance with the Code, complaints related to the AEC process, and irreconcilable differences between the AEC and an investigator (see Section 5).

Section 5 of the Code provides guidance on dealing with complaints and non-compliance.

Procedures should be developed to handle the following:

Complaints from independent people who are not associated with the establishment.
Complaints by staff or students within the establishment without jeopardising the person's employment or entitlements.
Disputes between researchers or teachers and the Animal Ethics Committee (AEC).
Serious disagreements between members of the AEC.
Disagreements between the AEC and the establishment's management.

Procedures developed should be approved by the AEC.

Procedures developed should ensure that complaints about animal care and use are referred to the AEC for investigation.

Procedures developed to address disputes between researchers or teachers and the AEC should ensure that the ultimate decision of the AEC is not overridden. The Animal Research Act 1985 does not allow for the approval of animal research (the issuing of Animal Research Authorities), except with the approval of and in accordance with the directions of the establishment's AEC. Clause 5.6 of the Code states:

Where complaints concerning the AEC process of review of an application or report cannot be resolved by communication between the complainant and the AEC that is the subject of the complaint, the institution should ensure that the complainant has access to a person or agency external to the AEC for review of the process followed by the AEC. This person or agency may be within the institution. Following this review, the AEC may need to review its process in reaching its decision regarding the application or report, and re-evaluate its decision in light of the reviewed process. The ultimate decision regarding the ethical acceptability of an activity lies with the AEC and must not be overridden.

Procedures developed should be readily accessible within the establishment.