In response to the questions posed in this scenario, the United States Department of Agriculture, Animal and Plant Health Inspection Service, Animal Care (USDA, APHIS, AC) and the Office of Laboratory Animal Welfare (OLAW) offer the following guidance:

In this scenario, the dogs are under the care of a private practice veterinarian. State veterinary practice acts require a valid Veterinarian-Client-Patient Relationship (VCPR) under which the veterinarian is held responsible for the health and well-being of the client's animal1. A pet that receives care pursuant to a valid VCPR is not considered an animal2 used or intended to be used for research, testing and experimentation. Such care includes but is not limited to routine vaccinations, surgery and medical treatment. The collection of samples and data under these circumstances does not make the activity subject to oversight under the Animal Welfare Act.

The PHS Policy on Humane Care and Use of Laboratory Animals covers live vertebrate animals used or intended for use in research, research training and biological testing activities conducted or supported by the PHS3. Veterinary clinical care of a privately owned animal is not a research activity and does not require IACUC approval4. In the scenario, the investigator's research involves the ticks collected during routine veterinary clinical care, and the dogs are not being handled in response to the requirements of the NIH grant. The investigator has mistakenly indicated on the application that the activities involve research with live vertebrate animals and has completed the Vertebrate Animals Section. To rectify the situation, the investigator should contact the NIH extramural program official and grants management specialist managing the grant and inform them of the error. The program official and grants specialist will consult with OLAW and change the coding of the application to reflect no use of vertebrate animals. Verification of IACUC approval is not required.

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