In this scenario Dr. Roger Gooding, a new faculty member at Great Eastern University, now teaches the course in animal handling and minor procedures in pigs and sheep. The instructor, Gooding, does not want to continue the process of submitting an IACUC protocol for the animals used in procedure training for students.

The question is raised as to whether an IACUC protocol is required for these activities. The Principal Investigator believes that he is not required to have an IACUC protocol or submit new techniques that he wishes to add to the course because his previous institution did not require IACUC oversight. He also believes that the animals he is using are farm animals that do not fall within the Animal Welfare Act’s definition of animal because they are not used for biomedical research.

The Great Eastern University IACUC’s interpretation of the definition of animal is correct. The Animal Welfare Regulations (AWR) definition of animal includes any “warm-blooded animal, which is being used, or is intended for the use for research, teaching, testing, experimentation, or exhibition purposes, or as a pet, except farm animals such as livestock intended for use as food or fiber or intended for use of improving animal nutrition, breeding, management, or production efficiency1”. It is not evident that Gooding’s course is meant to improve nutrition, breeding, production (or any additional conditions that exclude it from oversight) but it is clear that the animals are used for teaching, and therefore should be subject to IACUC oversight. The IACUC is also correct in that an approved protocol is required in this scenario because the AWR Part 2 subsection C requires the registration of any institution which is part of a school or department of a university or college, except if they can demonstrate to the Secretary that it is a separate legal entity2. This means that their PHS Assurance and USDA registration list all facilities using animals in any capacity as a research institution, thus requiring IACUC oversight3. This holds true despite of Gooding’s claim that the training animals are not directly funded by a research grant.