Eligibility to Serve as Principal Investigator (PI) on Rice IACUC Protocols

Purpose and Scope

This Standard Operating Procedure (SOP) outlines the eligibility requirements for serving as a Principal Investigator (PI) on animal care and use protocols at Rice University. It also defines the process for requesting special approval for non-faculty status to serve as PIs and oversee activities involving live vertebrate animals in research, teaching, testing, or training.

PI Eligibility Requirements:

Per Rice policies and federal guidelines, only faculty members with tenure-track or equivalent research appointments are automatically eligible to serve as PI on IACUC protocols. Per Rice Policy 301, “PI/PD status is a privilege granted to faculty members who hold an academic appointment in the tenure-track or research ranks under Policy 201”. This means that the following faculty ranks at Rice generally qualify for PI status:

  1. Assistant Professor (tenure-track)
  2. Associate Professor (tenure-track)
  3. Professor (tenure-track)
  4. Research Assistant Professor (non-tenure-track, promotable)
  5. Research Associate Professor (non-tenure-track, promotable)
  6. Research Professor (non-tenure-track, promotable)

These ranks are defined by Policy 201 and related procedures. In contrast, instructional or special-rank faculty appointments (e.g., instructors, visiting professors without formal faculty status, adjuncts, or other non-tenure-track teaching positions) are not eligible for PI status.

Ineligible PI Designation

The following categories are explicitly not eligible for PI designation on IACUC protocols under Rice policy:

  1. Temporary faculty or staff without a formal faculty appointment.
  2. Visiting scholars or adjuncts without tenure-track or research rank.
  3. Most non-tenure-track teaching or instructional positions (unless holding a research rank).
  4. Graduate students or postdoctoral fellows (unless an exception is granted, see below).

These restrictions align with Policy 301’s statement that “Instructional or special rank appointments do not have PI/PD eligibility status.”

Exception Procedures:

Circumstances Requiring Special Approval

Under rare circumstances, the Executive Vice President for Research may grant approval for PI status to individuals who do not meet the eligibility requirements. Such requests must demonstrate that the individual is qualified for the specific type of research and meets a programmatic need of Rice University's mission.

Student and Postdoctoral Fellow Considerations

When external sponsors require a student, graduate student, or postdoctoral fellow to be listed as PI on a grant application, the student's faculty mentor or advisor shall serve as the PI of record on all Rice internal systems and forms. The faculty mentor/advisor remains responsible for the conduct and oversight of the project, including all IACUC protocol obligations.

Exception Approval Process

Requests for PI eligibility exceptions must be submitted using the PI Eligibility Request Form, which requires completion and signatures from:

  1. The requesting individual
  2. Department Chair
  3. School Dean
  4. Executive Vice President for Research

The Executive Vice President for Research has the authority to grant approval for a specified period (typically up to 5 years) for individuals meeting exceptional criteria. These requests are subject to approval by the cognizant department chair and school dean prior to final review.

Responsibilities and Obligations:

Any individual granted PI status under this SOP must accept full responsibility for the animal research project. Key PI duties include:

  1. Scientific Oversight: Lead the scientific conduct of the study, ensuring that experimental design and procedures meet ethical and scientific standards.
  2. Compliance: Ensure all research activities comply with federal laws (AWA, USDA/APHIS regulations, PHS Policy) and Rice University policies (Policies 201, 301, 314, etc). The PI is accountable for submitting animal care and use protocols and timely reporting of any unanticipated problems or noncompliance to the IACUC.
  3. Animal Welfare: The PI must oversee adherence to humane endpoints, pain and distress minimization, and proper euthanasia practices per the Guide, PHS policy, and AWA regulations.
  4. Financial Management: Make budgetary decisions and be financially accountable for expenditures of the grant or project, in coordination with departmental and research administration staff.
  5. Training: Ensure that all personnel (staff, students, postdocs, technicians) working on the animal protocol have completed the required training before performing animal work. This includes:
    1. AALAS Laboratory Animal Research training: Complete the required training on the AALAS training site. Required modules can be found on the IACUC Training page.
    2. Laboratory Safety Training (following Rice EHSLO guidelines).
    3. Occupational Health Program Clearance: completion of the Occupational Health enrollment if working with animals.
    4. The PI must maintain records of hands-on animal training of all personnel and ensure compliance with IACUC training requirements.
  6. Protocol Administration: Submit completed animal use protocols through Rice’s Cayuse Research Suite (Cayuse Animal Oversight). Update protocols to reflect changes in personnel, procedures, or funding as needed.
  7. Reporting: Report any adverse events, protocol deviations, or noncompliance to the IACUC promptly. Collaborate with any information requests or site visits from the IACUC.

Regulatory Framework and References for the following federal regulations and institutional policies:

For the following federal regulations and institutional policies:

  1. Animal Welfare Act (Public Law 89-544 as amended)
  2. Public Health Service Policy on Humane Care and Use of Laboratory Animals
  3. Guide for the Care and Use of Laboratory Animals
  4. Rice University Policy 301 (Submission and Administration of Sponsored Projects)
  5. Rice University Policy 314 (Care and Humane Treatment of Animals)

Contact Information:

  1. IACUC Administration: Email iacuc@rice.edu for protocol submission procedures and training documentation.
  2. Assistant Vice President for Office of Research Integrity: For PI eligibility requests, please contact: Dr. Mickey Stevenson, Contact: 713-348-6200 | ms270@rice.edu

If in doubt, faculty and staff should consult/contact the Rice IACUC office for guidance on PI eligibility.

Definitions

  1. Principal Investigator (PI): The individual (usually a faculty member) with primary responsibility for the design, conduct, and oversight of an animal research project. The PI ensures that all aspects of the research comply with applicable regulations and that IACUC-approved procedures are followed. Under the Animal Welfare Regulations (9 C.F.R. §1.1), the PI retains authority over the research even when certain tasks are delegated.
  2. Tenure-Track Faculty Ranks: Positions governed by Rice Policy 201 (“Faculty Appointments, Promotions and Tenure”) that include Assistant Professor, Associate Professor, and (Full) Professor. These ranks carry research, teaching, and service responsibilities. Rice Policy 201 defines and regulates all tenure-track and non-tenure-track faculty ranks at the University.
  3. Research Faculty Ranks: Non-tenure-track but promotable positions (the “research professor” series), including Research Assistant Professor, Research Associate Professor, and Research Professor. These ranks also involve research responsibilities but are not tenure-eligible. Rice Policy 201 (and related policies) describes the terms for these ranks, which are eligible for PI status.
  4. Animal Welfare Act (AWA): The federal law (7 U.S.C. §§2131 et seq.) that regulates the humane treatment of animals in research, exhibition, and commerce. The U.S. Department of Agriculture (USDA) issues implementing regulations at 9 C.F.R. Parts 1–3. The AWA mandates that institutions maintain an IACUC and comply with USDA/APHIS standards.
  5. Animal Welfare Regulations (AWR): The USDA regulations (9 C.F.R. Chapter 1, Subchapter A, Parts 1–3) that implement the AWA, defining terms and requiring IACUC oversight.
  6. Public Health Service (PHS) Policy: The federal policy (NIH) on the Humane Care and Use of Laboratory Animals applies to all PHS-funded activities involving vertebrate animals. It requires institutions to maintain an OLAW-approved Assurance and to operate an IACUC that follows the Guide for the Care and Use of Laboratory Animals.
  7. Office of Laboratory Animal Welfare (OLAW): The NIH office administers the PHS Policy, provides guidance on compliance, and approves Institutional Animal Care and Use Assurance documents.
  8. Assurance: The written commitment filed with OLAW that an institution (Rice) will comply with the PHS Policy. Rice’s Assurance (A3010-01) documents these commitments.
  9. IACUC (Institutional Animal Care and Use Committee): Rice’s committee, mandated by the AWA and PHS Policy, reviews and approves all animal use protocols, oversees animal care programs, and ensures compliance with federal and institutional requirements.
  10. Rice Policy 201: “Faculty Appointments, Promotions, and Tenure,” which defines faculty ranks (tenure-track and non-tenure-track) and terms of appointment at Rice.
  11. Rice Policy 301: “Submission and Administration of Sponsored Projects,” which specifies that PI status (or PI/Program Director status) is a privilege of eligible faculty and outlines approval processes for exceptions.
  12. Rice Policy 314: “Care and Humane Treatment of Animals Used in Research, Testing, Education and Training,” which commits Rice to animal welfare and requires all animal activities to comply with federal regulations (AWA, PHS Policy, etc.)