This is not the best answer
Too late. The damage is done, the non-compliance has been discovered. This action could become part of some remedial plan at a later date. The IACUC has a more serious issue at this point, the conduct of unapproved survival surgery procedures in a covered species.
Perhaps the IACUC should contact the sponsor and ask the project manager at Northeast Medical Equipment Inc. to suspend the project until an amendment is submitted.