Useful Flexibilities for Animal Care and Use Programs to Comply with the PHS Policy During the COVID-19 Pandemic

As we continue to address the effects of COVID-19 and as some states and institutions are considering reopening, we would like to share some administrative flexibilities that NIH is providing to research institutions with laboratory animal programs. These flexibilities are meant to assure personnel safety and animal welfare while enabling research personnel to prioritize and preserve research efforts. Some of these can be useful in reducing administrative burden, too.

My colleagues with the NIH Office of Laboratory Animal Welfare (OLAW), Drs. Catharine Pritchard, Nicolette Petervary, and Neera Gopee, described these administrative flexibilities in their recent contribution to Laboratory Animal Science Professional (available on the OLAW website). If you’d like more information to help your animal program during this pandemic, please visit OLAW’s frequently updated COVID-19 webpage for additional resources. FAQs were also recently updated last week.

Here are some highlights:

OLAW wants to ensure Institutional Animal Care and Use Committees (IACUCs) can continue functioning during the pandemic, while also promoting a safe environment for all. To this end, OLAW is temporarily granting waivers to semiannual inspections, and the article describes the process for requesting these waivers. The remaining flexibilities presented here are always available to institutions but may be particularly useful during pandemics.

Virtual is doable. One flexibility is that IACUCs may conduct business virtually, including semiannual program review, recordkeeping, and reporting, according to OLAW’s guidance on telecommunications (NOT-OD-06-052). Other flexibilities include increasing the use of designated IACUC member review (DMR) of animal activities, using ad hoc consultants who are without conflicts of interest, and using appropriate remote methods to conduct semiannual facility inspections. IACUCs may also reduce the number of meetings, but OLAW recommends meeting at least twice a year to conduct business to comply with the Public Health Service (PHS) Policy on the Humane Care and Use of Laboratory Animals (Policy).

OLAW recognizes that COVID-19 has many institutions rethinking their business processes. You can modify the processes described in your institution’s Assurance during the pandemic, as long as the changes are compliant with PHS Policy requirements. The institution may choose to adopt some changes permanently, while others may be temporary. Temporary changes should be included as updates to institutional disaster plans, while any permanent changes should be included in your Annual Report to OLAW and in your next Assurance renewal. As always, apprise your IACUC members of any modifications to processes described in your Institution’s Assurance before implementing. You can always reach out to my OLAW colleagues if you have any questions about such changes or any other questions about flexibilities.

The COVID-19 pandemic is an opportunity for institutions to re-revaluate and improve their disaster plans in light of lessons learned. These plans are a required part of any animal program as a way to be prepared for emergencies, even pandemics (see Guide page 35). Disaster plans help institutions protect human and animal welfare and minimize animal and data losses caused by events like natural disasters, system failures, and pandemics. You can visit the OLAW Disaster Planning and Response Resources page for more information.

Many unanswered questions still remain. And, we know the community is still working hard to address the on-going consequences of COVID-19 on their animal programs. OLAW strives to foster more resilient animal care and use programs, continue to promote streamlined processes for IACUCs, and encourage institutions to reevaluate how business is conducted. Please don’t hesitate to reach out to OLAW with your questions on these topics.