COGR Responds to Request for Information (RFI) on an Update to the Current OLAW Guidance Disclaimer

COGR responded to the Office of Laboratory Animal Welfare’s (OLAW) Request for Information regarding its proposed guidance disclaimer, expressing concern that the current wording incorrectly suggests OLAW can expand regulatory requirements beyond Congressional authority. COGR recommends that OLAW revise the disclaimer to clearly state that guidance documents are recommendations, not binding requirements, unless specific statutory or regulatory mandates are cited, and suggests adopting language similar to disclaimers used by the FDA or OHRP to ensure institutions understand the advisory—not obligatory—nature of such guidance. This clarification, COGR argues, will help institutions appropriately utilize OLAW guidance while sustaining vital research and animal welfare.