In response to the questions posed in this scenario, the Office of Laboratory Animal Welfare (OLAW) and the United States Department of Agriculture, Animal and Plant Health Inspection Service, Animal Care (USDA, APHIS, AC) offer the following clarification and guidance:
The activities described in this scenario would require registration the USDA APHIS AC, as well as review and approval of the proposed animal activity by an IACUC. The training being conducted is considered to be biomedical, rather than agricultural, research (teaching). Agricultural teaching is conducted to improve farm or ranch management and includes such practices as hoof trimming and shearing. Biomedical teaching involves the training of human or veterinary medical personnel (e.g., veterinary technicians) in medical practices and methods (e.g., surgery, diagnostic techniques, anesthesia, and analgesia). When used for such teaching purposes, farm animals are considered to be regulated animals under the Animal Welfare Act.
In addition, as one respondent noted, if the Eastern Veterinary Conference sells the animals (or otherwise receives compensation in disposing of them), it may need to be licensed as a dealer. The conference would not be considered an exhibitor, because the compensation they receive is for providing medical training to the veterinary technicians, not for display of the animals.
If the Eastern Veterinary Conference was supported by the PHS, an appropriate Animal Welfare Assurance and IACUC review in accord with PHS Policy would be required.
Options regarding responsibility for IACUC review and oversight of the wet labs are aptly explored in the respondents' replies.
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Gipson, C., Wigglesworth, C. Response to Protocol Review Scenario: A word from OLAW and USDA. Lab Anim 35, 17 (2006). https://doi.org/10.1038/laban0406-17
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DOI: https://doi.org/10.1038/laban0406-17