COGR Responds to NIH Request for Information (RFI) on Proposed Guidance to Assured Institutions on Cephalopod Care and Use (NOT-OD-23-176)

COGR submitted a response to the NIH Office of Laboratory Animal Welfare’s (OLAW) Request for Information on Proposed Guidance to Assured Institutions concerning the care and use of cephalopods in research. While COGR supports the advancement of animal welfare and recognizes the evolving scientific understanding of cephalopod care, it expresses significant concerns about the scope and basis of OLAW’s proposal. Specifically, COGR asserts that OLAW lacks the authority to unilaterally extend the U.S. Government Principles for the Utilization and Care of Vertebrate Animals to cephalopods, which are invertebrates and are not covered under existing federal regulations or the PHS Policy. Additionally, COGR highlights the premature nature of prescribing detailed institutional policies and standard operating procedures for cephalopod care, given the limited and still-developing scientific foundation for species-specific guidance. To address these concerns, COGR recommends that any advice from OLAW be framed not as binding guidance, but as suggested approaches for institutions conducting PHS-supported cephalopod research. The association proposes specific textual modifications to the proposed guidance, advocating for greater institutional discretion and emphasizing reliance on the latest professionally accepted standards and emerging scientific data. Furthermore, COGR encourages NIH to support further research into cephalopod physiology and behavior as a prerequisite for developing robust, evidence-based care standards. The letter underscores COGR’s commitment to animal welfare in research and its willingness to collaborate in the development of appropriate policies, while urging careful alignment of regulatory guidance with statutory authority and current scientific knowledge.