IACUC review of federal grant funded animal research

PHS Policy regarding review and approval of animal studies state that "the IACUC shall conduct continuing review of activities covered by this policy at appropriate intervals as determined by the IACUC but not less than once every three (3) years". UMBC animal research protocols are approved for a three-year term. The investigator or instructor must resubmit a new application for Committee review in order to continue research activities.

What doe this mean if the proposed research, at the time of grant award, will not involve animal research until years 4 or 5 of an award?

The Office of Laboratory Animal Welfare (OLAW) recently issued guidance about this (http://grants.nih.gov/grants/olaw/faqs.htm#proto_20). If this occurs, the PHS awarding unit will not make an award unless the institution provides "..verification of approval by the IACUC of those components of the application or proposal related to the care and use of animals".

IACUC review must be performed prior to the conduct of any PHS-supported animal activity; this usually means approval must be obtained before an award is made and well before any animal research activity can begin. But, an IACUC can review activities if they will occur later in the life cycle of a grant. OLAW says that during these rare cases, the grant application must clearly explain when these activities will occur and that the PHS awarding component will issue a Notice of Award with a special term and condition indicating that no funds may be drawn from the grant or contract until a valid IACUC approval date has been issued by the IACUC.

Be sure to discuss any and all components with your OSP contact during the UMBC routing process or with the Human and Animal Research Protections Office.