The question of who has the body parts at UCSD and where they came from has drawn the attention of university auditors, who say that the increased use of anatomical materials from commercial sources has challenged the ability of administrators to adequately deal with a potentially risky situation.
The lack of accountability is cited in an August 2014 audit, entitled "Body Donation Program Operations," obtained this week from the university in response to a California public records act request made last December.
UCSD’s Body Donation Program dates back to 1967, the audit relates.
"The mission of this Program is to provide quality cadaveric material to the School of Medicine, the Skaggs School of Pharmacy and Pharmaceutical Sciences, and other qualifying educational programs to support medical education and research, and the development of diagnostic and therapeutic products."
According to the program's website: "In addition to being used for teaching medical and other health profession students, bodies that are donated to medical schools are also used by research physicians in the development of new surgical procedures, such as for developing new arthroscopic surgeries, knee, ankle and shoulder joint research, plastic surgery procedures including flap reconstruction for burn victims, surgical approaches to various internal organs, and many other surgical and medical procedures."
Five staffers operate the unit, the audit report says. "Technical personnel process donations, provide materials to approved courses or other requestors, and ensure that materials are cremated in accordance with state regulations."
According to the audit, "the Director maintains a funeral director license, an embalmer license, and a crematory operator certificate. Three other technical staff members maintain embalmer’s licenses, two maintain crematory operator certificates, and one maintains a funeral director license."
The assistant director "provides administrative support including interface with donors and their families, donor contract maintenance, assistance with source material preparation, and other administrative and technical services."
In addition, the body-donation program conducts "community outreach efforts by hosting an annual memorial service and reception for donor family and friends, and plans to create a permanent donor memorial on campus," according to the report.
"As of March 2014, 8,450 donors were registered" in the program, the document says.
To keep track of the donated bodies and parts, the university "utilizes the UC Digital Donor Library, also known as the Anatomical Materials Registry, as its primary donor registry database," run by UC Irvine.
"This electronic application tracks all stages of donation from registration to final disposition. It contains records of registered donors, and materials received, re-allocated and disposed from July 2005 to present."
So far, so good, but the auditors reported that a new trend has emerged to disrupt the school's accounting process.
"Management advised us that the number of UC San Diego conferences and/or physician training sessions that utilize anatomical materials purchased from outside companies has been consistently increasing," says the document.
"In addition, there are UC San Diego Health Sciences research units including, but not limited to the Alzheimer’s Disease Research Center and the UC San Diego Brain Observatory that receive donations directly."
Says the audit, "When materials not managed by the [body donation program] are used in UC San Diego facilities, there is greater risk that methods of transporting, testing, storing and disposing of materials may not fully comply with University requirements."
UCSD officials have take some steps to deal with the problem, according to the report. "Campus Environmental Health and Safety notifies the [donation program] staff when human anatomical materials are found in laboratories and other training venues."
In addition, staff "periodically evaluates training sites, and assists with the preparation of materials procured from outside vendors," says the document.
"However, even these additional controls do not completely mitigate the inherent risks associated with procurement practices. In addition, the distribution of certain responsibilities to multiple personnel does not help to guarantee that [donation program] personnel have been notified of all outside material purchases."
To deal with the problem, the audit says that body-donation program management agreed to "form a campus-wide committee to assist in enforcing UC policy."
Adds the report, "This committee will also serve as a formal commission for preventing the use of specimens from outside companies unless they are monitored by the [body-donation program], and will assist in identifying and minimizing the risks associated with donated or vendor provided anatomical materials."