FASEB Submits Comments on OLAW’s Updated Guidance Disclaimer

By: Naomi Charalambakis
Wednesday, October 11, 2023
On October 3, FASEB issued comments in response to the National Institutes of Health (NIH) Office of Laboratory Animal Welfare (OLAW) Request for Information (RFI) seeking input on its revised guidance disclaimer (NOT-OD-23-157). The disclaimer, a statement that is included on all guidance documents issued by the agency, serves to facilitate stakeholder implementation of current policies and statutes related to animal care and use. Acknowledging that this statement represents a significant source of confusion for institutions, the proposed update seeks to better emphasize that OLAW guidance should be viewed as recommendations rather than legally binding requirements.

In its comments, FASEB supports the revised disclaimer and thanks OLAW for emphasizing that institutions have the flexibility to use alternative strategies to comply with animal research regulations. Considering that many institutions view advisory language as mandatory, removing prescriptive language and phrases such as “recommendation,” “advice,” and “best practices” in the updated disclaimer is an important step in lessening institutional misinterpretation and excessive requirements. FASEB highlights that a flexible approach enhances research productivity and allows Institutional Animal Care and Use members to focus on essential animal care activities rather than superfluous institutional requirements.

To view OLAW’s continued efforts to implement the 21st Century Cures Act and reduce administrative burden for the animal research community, visit the agency’s dedicated webpage.