FASEB Submits Comments to OLAW Regarding IACUC Exemptions

By: Naomi Charalambakis
Wednesday, July 26, 2023
On July 17, FASEB submitted comments to the National Institutes of Health (NIH) Office of Laboratory Animal Welfare (OLAW) in response to their Request for Information (RFI) (NOT-OD-23-119) on Institutional Animal Care and Use Committee (IACUC) exemptions. As part of OLAW’s continuing efforts to reduce administrative burden on investigators, the RFI sought stakeholder feedback on ways to clarify guidance about animal activities exempt from IACUC review. These institutional committees are required by the Public Health Service (PHS) Policy to review PHS-funded animal research and decide whether to approve, suggest modifications, or disapprove proposed studies as it relates to the care and use of animals. 

OLAW’s proposed exemptions span various research scenarios, including animal studies with invertebrates, observational field studies, and dual review of protocols by more than one IACUC involving collaborating institutions. FASEB’s comments support the proposed exemptions and emphasize the importance of allowing IACUCs to exercise their discretion in making animal welfare decisions that best suit local needs. For example, while there is no universal federal policy or guidelines for invertebrate studies, AAALAC International—a private organization that promotes the humane treatment of animals in science through voluntary accreditation and independent guidelines—holds specific standards for this research and has influenced the way many institutions view and approve this work. To reconcile these differing approaches, FASEB’s comments encourage OLAW to specify that exemptions for invertebrate activities should depend on the degree of invasiveness as well as individual IACUC judgment. Such guidance provides enough latitude for local IACUCs to discern the best research approach while respecting the scientific community’s commitment to optimal animal care and welfare.

To close the response, FASEB expresses appreciation for clarifying existing guidance to reduce administrative burden and urges OLAW to provide ample time for final implementation to ensure institutions have adequate time to adjust to potential changes.