UC Comment Letters

This comment letter responds to the National Institute of Health (NIH) Office of Laboratory Animal Welfare (OLAW)'s request for information on Flexibilities for Streamlining IACUC Review of Protocols and Significant Changes (NOT-OD-23-152) issued on July 11, 2023. UC supports efforts to streamline IACUC review but says OLAW’s proposed flexibilities mostly restate existing guidance or offer only minor clarifications, and UC recommends clearer wording on designated member review, accelerated three-year reviews, alternate member availability, and reporting expectations. UC urges OLAW to pursue more meaningful burden-reduction measures, such as longer or eliminated Assurance renewal cycles, less burdensome Assurance templates, five-year IACUC protocol approvals, and a more flexible NIH Just-in-Time process that allows certification of pending IACUC approval before animal work begins.