In response to the issues posed in this scenario, the National Institutes of Health - Office of Laboratory Animal Welfare (NIH-OLAW) provide the following clarifications:

In this scenario, a university-supported club provides informal instruction on handling, grooming and training of pet dogs overseen by an experienced faculty advisor. The question raised is whether IACUC review and approval is required for these activities.

As noted by other reviewers, IACUC review of such informal activities is not a federal requirement because the animals are not undergoing manipulation for research or for training of medical or veterinary students1,2. However, some IACUC oversight is advisable to ensure animal and human safety and limit liability to the institution should a pet be injured accidentally or cause harm to the students or others. A consent agreement with animal owners developed with legal counsel may also be a consideration. A university policy or standard operating procedure for the club that addresses animal vaccinations, temperament, access to food and water, locations where animals are allowed, and how animals are to be restrained is a suggested approach. When the institution includes all animals regardless of the activities or funding source in the Assurance with OLAW, some form of IACUC oversight would be expected. However, there is flexibility in the use of policies or SOPs for non-research activities.