COGR's Response to Request for Information (RFI) on Update to NOT-OD-05-034 Guidance on Prompt Reporting of Noncompliances to OLAW (NOT-OD-23-063)

COGR submitted a letter to the National Institutes of Health’s Office of Laboratory Animal Welfare (OLAW) regarding the proposed update to guidance on prompt reporting of noncompliance in animal research. COGR acknowledges the importance of clear and unambiguous reporting standards, which balance the protection of animal welfare with minimizing unnecessary administrative burden for researchers. While the organization appreciates some positive changes, such as the removal of the requirement to include Public Health Service grant numbers in noncompliance reports, it expresses disappointment over the lack of substantive updates to examples of reportable incidents in the new guidance, which still include non-serious or technical events not aligned with the intent of federal policy. COGR urges OLAW to work with other federal agencies to achieve consistency and further streamline reporting requirements. In its specific feedback, COGR commends the flexibility allowing institutions to consult OLAW on reporting ambiguity but maintains that institutions should primarily rely on their own internal procedures. The association suggests eliminating overly restrictive or unclear provisions, particularly those that may lead to excessive reporting of minor or routine incidents, such as minor injuries during animal socialization or incidents leading to necessary euthanasia or separation of animals without broader programmatic concerns. Overall, COGR encourages OLAW to continue efforts to refine reporting requirements to reduce duplicative or unnecessary administrative burden while upholding high standards for animal care, and offers its continued input to support these regulatory improvements.