The Council on Governmental Relations (COGR), representing prominent research universities and affiliated institutions, presents comprehensive comments in response to proposed federal actions aimed at improving coordination and harmonization of laboratory animal welfare regulations. Drawing on collaborative recommendations from previous reports and workshops involving stakeholders such as FASEB, AAMC, and NABR, COGR advocates for a shift toward a risk-based methodology in protocol reviews for animal research, aligning this approach with practices already established in human subjects research. This methodology, combined with harmonized review intervals and streamlined processes for low-risk protocols, is anticipated to reduce administrative burdens without diminishing animal welfare protections. In addition, COGR supports singular, unified annual reporting to both OLAW and USDA to further minimize duplicative efforts, while also endorsing harmonization of agency guidance to eliminate redundant requirements regarding alternatives to painful animal procedures.
COGR further recommends procedural changes such as a minimum 60-day comment period for new OLAW policy guidance, expanded use of best practice repositories, and tools to facilitate more efficient protocol reviews (e.g., designated member review, Veterinary Verification and Consultation). The organization urges the abolition or revision of outdated or unnecessarily burdensome practices—for example, requirements concerning protocol and grant congruency, incidence reporting, and the frequency of reviews—emphasizing flexibility, reduction of duplicative tasks, and better alignment with current science and regulatory frameworks. Throughout its response, COGR underscores the need for broad engagement with institutional experts and increased reliance on professional judgment, while maintaining a strong commitment to animal welfare standards. The document also promotes the value of external accreditation (such as AAALAC), training initiatives focusing on administrative efficiency, and the use of grants to promote and share effective practices with the goal of reducing regulatory burden and supporting high-quality, humane animal research.
