There has been some confusion regarding minority views, i.e., what they are, who can submit one, when one should be submitted, and whether we report them. Part of the confusion stems from the fact that the Guide, OLAW Policy and AWAR provide limited guidance and do not define “minority view.”
PHS Policy and AWA Regulations
PHS Policy (IV,E,1d) requires institutions to maintain copies of minority views of semiannual reports (not protocol reviews), but does not specify how the IACUC should handle them. There is also a PHS Policy (IV,F,4) requirement that minority views filed by IACUC members be forwarded (via the IO) to NIH/OLAW along with the annual report to NIH/OLAW (but again, this does not refer to protocol reviews). If the minority views relate to an IACUC action that is required to be reported promptly (PHS Policy IV,G,3), they should be provided to NIH/OLAW at that time.
The AWAR (§2.31.c.3; §2.35,a,3) also require maintaining records of semiannual reports, including minority views.
What is a minority view?
A minority view is the dissenting opinion of one or a minority of the membership regarding a specific issue that is up for approval.
Who can submit a minority view?
Any member of the IACUC can submit a written minority view and submit it to the IACUC Coordinator.
When is a minority view submitted?
A minority view can be submitted any time a member determines that they are not in agreement with the majority of the membership about a specific issue and want this noted in the IACUC meeting minutes.
Normally, minority reports are very few. Most IACUCs devise reasonable compromises to difficult problems. Dissenting members generally do so by voting “no” on an issue with regard to the semiannual report to the IO and requesting that a notation be made in the regular committee minutes. However, a member may write a full minority opinion if so desired. This opinion then becomes part of the official report to the IO and OLAW.
Do we have to report minority views?
Yes. Both PHS Policy (IV,F,4) and AWAR (§2.31,c3) mandate that minority reports be attached to the Semiannual Report to the Institutional Official. Minority reports are also included in the OLAW Annual Report.
Note: This information is provided solely as an educational tool for IACUC members and should not deter them from submitting a minority view should they feel strongly about a committee decision with which they are not in agreement.
Reference:
- Silverman, J., Suckow, M.A., & Murthy, S. (Eds.). (2000). The IACUC Handbook. Chapter 9, p. 127; Chapter 23, p. 398. Florida: CRC Press.
- PHS Policy IV,E,1d; IV,F,4; IV,G,3
- AWAR §2.31.c.3; §2.35,a,3