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 the NIH Notice Clarification of Animal Activities Exempt from the PHS Policy Requirements for IACUC Review (NOT-OD-23-119). UC supports OLAW’s effort to clarify which animal activities do not require IACUC review and approval, but recommends avoiding the term “exempt” because it may be confused with human-subjects research terminology. UC also asks OLAW to clarify several examples involving observational field studies, commercially available surgically modified animals, and reliance on another institution’s IACUC review, and urges OLAW and USDA-APHIS to harmonize field-study requirements and definitions to reduce administrative burden.