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A Word from OLAW and USDA

Lab Animal volume 51, page 245 (2022)Cite this article

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In this scenario, questions are asked about IACUC review and approval for data collected in the context of veterinary clinical care for an NSF-funded activity.

A researcher at Great Eastern University is using zoo animals for data collection for an NSF-funded project. The biological sampling and data collection is added to routine veterinary care and is performed by the zoo’s clinical veterinarians. The NSF has a memorandum of understanding with OLAW that stipulates Animal Welfare Assurances for NSF-affiliated institutions1. Therefore, the requirements of the PHS Policy apply to NSF-funded vertebrate animal use2. Because the animals are held in captivity, cared for regularly by veterinary staff and are not living under field conditions, the activity cannot be considered a field study. The Guide for the Care and Use of Laboratory Animals describes field studies as use of non-domesticated vertebrate species living under natural conditions3. When data are collected for the advancement of animal or human health, the activity is considered research rather than veterinary patient care4. Such animals are subject to IACUC oversight5, even if housed in zoological collections at domestic or foreign locations6, and Assurances are required to cover the performance sites5,7. The university should have written agreements with the participating zoos that address the responsibilities for animal care and IACUC oversight3,8. If the samples were routinely collected as part of the zoos’ standard operating procedures, providing the samples to the Principal Investigator would not require Assurances for the performance sites or IACUC approval. In such a case, the sample collections would be listed on the grant application as not involving vertebrate animals.

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References

  1. Office of Laboratory Animal Welfare - MOU Between NIH and NSF. https://olaw.nih.gov/NSF.html

  2. Public Health Service. PHS Policy on Humane Care and Use of Laboratory Animals. (U.S. Department of Health and Human Services, National Institutes of Health, Bethesda, MD, 2015).

  3. Institute for Laboratory Animal Research. Guide for the Care and Use of Laboratory Animals 8th edn. (National Academies Press, Washington DC, 2011). p. 15, p. 32.

  4. Public Health Service Policy on Humane Care and Use of Laboratory Animals – Frequently Asked Questions. Applicability of the PHS Policy, Question No. A.8. How can the IACUC determine if activities involving privately owned animals constitute veterinary clinical care or research activities? (US Department of Health and Human Services, Bethesda, MD, USA). https://olaw.nih.gov/faqs#/guidance/faqs?anchor=question50227

  5. Public Health Service Policy on Humane Care and Use of Laboratory Animals – Frequently Asked Questions. Applicability of the PHS Policy, Question No. A.7. Does the IACUC need to approve research studies that use privately owned animals, such as pets? (US Department of Health and Human Services, Bethesda, MD, USA). https://olaw.nih.gov/faqs#/guidance/faqs?anchor=question50226

  6. Frequently Asked Questions about the Public Health Service - Policy on Humane Care and Use of Laboratory Animals Question 2. Contemporary Topics 36:47-50. https://olaw.nih.gov/guidance/articles/faq-labanimals1997.htm (1997).

  7. Silverman, J. Lab Anim (NY) 38, 185–187 (2009).

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  8. Public Health Service Policy on Humane Care and Use of Laboratory Animals – Frequently Asked Questions. Protocol Review, Question No. D.8. When institutions collaborate, or when the performance site is not the awardee institution, which IACUC is responsible for review of the research activity? (US Department of Health and Human Services, Bethesda, MD, USA). https://olaw.nih.gov/faqs#/guidance/faqs?anchor=question50320

  9. 9 CFR, Chapter 1, Subchapter A, Part 1, § 1.1 – Definitions.

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Author information

Authors and Affiliations

  1. Director, Office of Laboratory Animal Welfare, OER, OD, NIH, HHS, Bethesda, MD, USA

    Patricia Brown

  2. Deputy Administrator, Animal Care, APHIS, USDA, Riverdale, MD, USA

    Betty Goldentyer

Authors
  1. Patricia Brown
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  2. Betty Goldentyer
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Correspondence to Patricia Brown or Betty Goldentyer.

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Brown, P., Goldentyer, B. A Word from OLAW and USDA. Lab Anim 51, 245 (2022). https://doi.org/10.1038/s41684-022-01057-1

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