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

In this scenario, IACUC inspectors report concerns to the committee about algae overgrowth in tanks in a satellite Xenopus frog room. Because there are no apparent health problems with the frogs housed in the more natural habitat, the principal investigator is not concerned and does not find it outside the standards of care.

The PHS Policy requires the IACUC, as an agent of the institution, to inspect at least once every six months all of the institution’s animal facilities including satellite facilities using the Guide for the Care and Use of Laboratory Animals as a basis for evaluation1. The expectations of both the PHS Policy and the Guide is for institutions to establish standards for IACUC and veterinary oversight of all animal species whether housed in central or satellite facilities2,3,4. The Guide states that “establishing standard operating procedures can assist an institution in complying with regulations, policies, and principles as well as with day-to-day operations and management2.” While it is the IACUC’s responsibility to review husbandry standards that directly impact animal welfare, it may engage the expertise of others to assure the standards are appropriate for the species. The IACUC may also allow standards that deviate from commonly acceptable practices if justified for scientific reasons5. Likewise, the veterinarian may allow deviations for veterinary care or husbandry reasons. Standard operating procedures or written performance standards are clearly needed for Great Eastern University’s frog room that address water turbidity and ensure daily observations, adequate oxygenation, and limited biofilm accumulation while providing a more natural habitat2.