FASEB Responds to OLAW RFI on Streamlining IACUC Protocol Review

By: Naomi Charalambakis
Wednesday, October 11, 2023
On October 3, FASEB submitted comments to the National Institutes of Health (NIH) Office of Laboratory Animal Welfare (OLAW) in response to its Request for Information (RFI) on flexibilities for streamlining Institutional Animal Care and Use Committee (IACUC) review of animal protocols (NOT-OD-23-152). According to the Public Health Service (PHS) Policy, IACUCs are required to review PHS-funded animal activities and decide whether to approve, require modifications, or withhold approval before research can move forward. To facilitate this process, PHS Policy affords IACUCs various strategies to improve review efficiency such as designated member review and veterinary verification and consultation. The current RFI seeks input on ways to encourage more IACUCs to use these flexibilities and reduce administrative burden.

FASEB supports the flexibilities and offers suggestions for promoting their adoption. For example, OLAW provides IACUC chairs the freedom to use whatever mechanism they find suitable for determining who serves as the designated reviewer during designated member review. Options include using a rotational list of reviewers based on expertise, setting a formal policy, or appointing a vice chair to assign reviewers in the chair’s absence. FASEB recommends OLAW update its Frequently Asked Questions to share these example strategies and emphasize the IACUC chair’s ability to decide what works best. For other flexibility clarifications, FASEB suggests OLAW collaborate with scientific societies to strengthen its public outreach efforts by organizing additional public webinars and issuing e-mail communications.

In addition to offering ways OLAW could encourage more institutions to use existing flexibilities, FASEB’s response highlights that these strategies are frequently used already. Recognizing that many areas of animal research remain cumbersome and inefficient, FASEB emphasizes the need to explore new opportunities for alleviating administrative burden for IACUCs. For example, the timing discrepancy between IACUC protocol reviews (e.g., every three years) and the average length of an NIH grant (e.g., four to five years) causes unnecessary research delays and interruptions in animal care. FASEB recommends aligning the timing of congruency reviews to maximize research productivity and ensure continuous animal care. Finally, FASEB advises increasing engagement with animal research stakeholders through listening sessions and/or publishing new RFIs to collect feedback on ways to improve research efficiency while enhancing animal care and welfare.