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UC Comments on NIH/OLAW's RFI on Update to NOT-OD-05-034 Guidance on Prompt Reporting of Noncompliances to OLAW (NOT-OD-23-063)

Abstract

This comment letter responds to NIH Office of Laboratory Animal Welfare (OLAW)'s RFI (NOT-OD-23-063) on updating NOT-OD-05-034, Guidance on Prompt Reporting of Noncompliances to OLAW. UC supports OLAW’s effort to clarify reporting expectations and reduce administrative burden while maintaining animal welfare protections, but raised concerns that the proposed reporting exception for injuries among socially housed animals is overly broad and ambiguous. UC recommends removing the exception or narrowing and defining the covered species, situations, injury severity, separation period, reporting detail, and rationale to avoid unnecessary reporting and misinterpretation.