Comment Letter

COGR Submits Letter to USDA APHIS on Proposed Rule Regarding AWA Research Facility Registration, Updates, Reviews, and Reports

The Council on Governmental Relations (COGR), representing 190 major U.S. research institutions, submitted comments to the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) concerning proposed amendments to the Animal Welfare Act (AWA) regulations governing research facilities. COGR broadly supports the proposed changes, which aim to reduce regulatory redundancy and administrative burden while maintaining high standards for animal welfare and research integrity. Specific endorsements include: eliminating the requirement for triennial facility registration renewal, simplifying notification of changes via APHIS Form 7033, and removing the infrequently used provision allowing facilities to request inactive status, all of which streamline regulatory processes for both institutions and USDA.

COGR also supports the proposed amendments related to the duration and cancellation of facility registration, although it recommends more concrete standards for cancellation decisions and allowances for facilities to appeal erroneous cancellations. Notably, COGR endorses the shift from mandatory annual IACUC protocol review to a more flexible schedule, with reviews at least every three years, aligning the rule with other federal standards and allowing resources to be reallocated to more impactful oversight and training activities. COGR concurs with modernizing report submissions by permitting electronic filings, which aligns with current business practices and contingency needs demonstrated during the COVID-19 pandemic. Overall, COGR affirms the proposed rule as a crucial advancement in regulatory reform that balances the reduction of unnecessary administrative work with continued robust protections for animals used in research.

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