In responding to this scenario I will begin with some assumptions about Great Eastern University: as a research facility, it is registered with the United States Department of Agriculture (USDA), assured by the Public Health Service (PHS), and accredited by the Association for Assessment and Accreditation of Laboratory Animal Care International (AAALAC). My assumptions about the State Rabies Diagnostic Laboratory (RDL) are that it is not registered with the USDA, assured by the PHS or accredited by AAALAC and does not house animals in its facility. The RDL has no direct affiliation with Great Eastern University, other than as a tenant, and is therefore functionally and administratively separate.
If the RDL does not conduct any research activities with covered species (i.e., does only diagnostic work), then there is no need for USDA registration as a research facility. In this context, the RDL is considered to be doing disease surveillance for health or population management and thus is not covered by the Animal Welfare Act regulations. If it does not receive any PHS funding, then it does not need a PHS assurance. If both situations are true, then the RDL would not need an IACUC to oversee its activities. On the other hand, if the RDL conducts research activities involving covered species in addition to its routine diagnostic activities, then it needs to be registered with USDA as a research facility. If RDL also receives money from PHS, then it needs to file an assurance with the Office of Laboratory Animal Welfare (OLAW). In either case, it would require an IACUC to oversee its research activities involving animals.
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