The Council on Governmental Relations (COGR), representing 190 U.S. research universities and related institutions, submitted formal comments to the National Institutes of Health (NIH) in response to a request for information (RFI) regarding the application of Public Health Service (PHS) Policy on animal care to zebrafish larvae immediately after hatching. While COGR supports the administrative flexibilities proposed in the RFI, it challenges NIH's decision to apply the PHS Policy from the moment of hatching, arguing that the evidentiary standard used—“beyond a reasonable doubt”—is inappropriate for this scientific context and is not stipulated by relevant statutes or guidelines. COGR contends that a “preponderance of the evidence” standard would be more suitable, and asserts that NIH should base policy decisions on clearly articulated scientific evidence, particularly in the context of specific procedures performed on the animals.
Additionally, COGR highlights practical challenges associated with counting and managing zebrafish larvae due to their small size and transparency at hatching, supporting the flexibilities for estimating animal numbers and involving subject matter experts as outlined in the RFI. The organization echoes the importance of animal welfare and the reduction of administrative burden as mandated by the 21st Century Cures Act, ultimately urging NIH to re-evaluate the timing and evidentiary basis for applying the PHS Policy to zebrafish larvae. Despite its concerns regarding policy applicability, COGR endorses the proposed flexibilities to facilitate more efficient research practices while maintaining animal welfare standards.
