http://www.rssboard.org/rss-specification 720 https://escholarship.org/uc/rpac_ucletters_comments/rss Recent eScholarship items from Other Thu, 3 Sep 2026 03:31:32 +0000 https://escholarship.org/uc/item/7d17013p This comment letter responds to AAALAC International's proposed draft of their new position statement on "The 3Rs". UC recommends that AAALAC revise the 3Rs position statement to use more precise and flexible language, including referring to “scientifically validated” non-animal models and saying reduction techniques should be “considered” rather than automatically “applied” in all animal activities. UC also asks AAALAC to better account for wildlife research by adding examples such as camera trapping and non-invasive sampling, and to clarify that 3Rs training should apply as appropriate to institutionally affiliated personnel involved in animal care and use. The content of this letter was submitted through a comment portal and did not require a signature. https://escholarship.org/uc/item/7d17013p Wed, 2 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/5qq5413q This comment letter responds to the Department of State Directorate of Defense Trade Controls (DDTC)'s proposed amendments to the International Traffic in Arms Regulations (ITAR) originally issued on July 29, 2024. UC supports DDTC’s proposed ITAR revisions as a helpful effort to clarify defense-services controls, distinguish controlled from non-controlled activities, and protect national security while preserving professional and academic exchanges. UC endorses AUECO and COGR requests for further clarification on exclusions for repair or maintenance of EAR-controlled commodities/software, routine academic activities, medical and translation services, and definitions related to intelligence activities, so low-risk academic and research activities are not unnecessarily affected. https://escholarship.org/uc/item/5qq5413q Wed, 2 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/59z9m16x This comment letter responds to AAALAC International's proposed draft of their new position statement on "The Culture of Care". UC supports AAALAC’s effort to articulate Culture of Care as an institutional mindset and notes that UC has already adopted the concept, but asks AAALAC to clarify the intent of the position statement and how its key components should be implemented. UC recommends several wording changes, including removing the unnecessary qualifier “good,” consistently capitalizing Culture of Care, emphasizing communication with all institutionally affiliated people involved in animal care and use, clarifying the role of veterinary and animal care practices within the broader program, and promoting 3R approaches during protocol review as well as animal care activities. The content of this letter was submitted through a comment portal and did not require a signature. https://escholarship.org/uc/item/59z9m16x Wed, 2 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/3qf4328f This comment letter responds to the General Services Administration (GSA)'s Information Collection on the Federal Funding Accountability and Transparency Act Sub-Award Reporting System Registration Requirements for Prime Grant Awardees (FFATA reporting requirements) published in the Federal Register on February 29, 2024. UC acknowledges that FFATA subaward reporting is statutorily required, but says GSA’s estimated annual burden of 30 minutes per respondent is a major underestimate because UC submits reports monthly and campuses spend roughly 18 to 30 hours per report, or about 200 to 360 hours per year. UC recommends improving FSRS guidance and technical support, resolving recurring system errors, reducing duplicative data entry, carrying forward unchanged information for existing subawards, and limiting required FSRS fields to those actually required by FFATA. https://escholarship.org/uc/item/3qf4328f Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/3mj4m7rm This comment letter responds to SMART IRB's proposed revisions to their Reliance Agreement 3.0. UC asks SMART IRB to preserve continuity for existing studies under prior reliance-agreement versions, clarify confusing withdrawal/reporting language, and allow flexibility for non-federally regulated research through agreed-upon commensurate protections rather than defaulting rigidly to SMART IRB SOPs or the Common Rule. UC also raises several deal-breaker legal and operational concerns, including overly broad liability and indemnification language, burdensome or unclear QA/QI and reporting obligations, lack of flexibility for DOE-managed labs, and governing-law/venue provisions that could complicate participation. https://escholarship.org/uc/item/3mj4m7rm Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/31h4n0qg This comment letter responds to AAALAC International's proposed revisions to their position statement on "The Attending Veterinarian and Veterinary Care". UC generally supports AAALAC’s proposed revisions to the position statement, but recommends retaining language that makes surgical training/qualification and classification of major versus minor surgeries a shared responsibility of the IACUC and veterinary staff. UC also objects to using the undefined phrase “standards of veterinary practice,” urges AAALAC to reference regulatory expectations instead, and recommends adding clearer language on AV communication mechanisms, part-time AV oversight limits, and the AV’s role in animal husbandry. The content of this letter was submitted through a comment portal and did not require a signature. https://escholarship.org/uc/item/31h4n0qg Tue, 1 Sep 2026 00:00:00 +0000 UC Office of the President https://escholarship.org/uc/item/8k93x8wq This comment letter responds to the U.S. Geological Survey (USGS) request for comments on Helium Supply Risk. UC emphasizes that helium is essential for patient care and federally funded research because MRI, NMR, MEG, and other ultra-cold scientific instruments depend on reliable liquid helium supplies and can be damaged or taken offline by shortages. UC warns that repeated shortages and rising costs threaten healthcare, research, and U.S. strategic capacity, and recommends federal policies to protect, expand, and maintain affordable domestic helium production for the research community. https://escholarship.org/uc/item/8k93x8wq Mon, 31 Aug 2026 00:00:00 +0000 UC Office of the President