The Council on Governmental Relations (COGR), representing 190 U.S. research universities and affiliated institutions, submitted comments on the USDA APHIS proposed rule regarding contingency planning for the handling of research animals. COGR expressed strong support for the rule’s objectives, acknowledging the importance of robust contingency plans to ensure animal welfare during emergencies, a principle that is already embedded in existing accreditation standards and institutional practices. However, COGR highlighted several concerns and suggestions to enhance the rule’s effectiveness and practicality. Specifically, COGR advocated for greater flexibility in contingency plan templates to accommodate diverse institutional needs and urged that deviations from plans during emergencies should not be considered violations but, rather, adaptations to unique circumstances.
COGR also addressed the training provisions, emphasizing the complexity and scale of training required at larger institutions and calling for institutional discretion in determining the scope and delivery of training. It proposed extending training deadlines from the proposed 30 or 60 days to 90 days and limiting mandatory retraining to substantive changes only. Furthermore, COGR recommended explicit harmonization of the proposed contingency planning requirements with existing standards (such as the "Guide for the Care and Use of Laboratory Animals") to avoid redundancy. Lastly, COGR contended that the USDA significantly underestimated the time and resources needed to develop and implement comprehensive contingency plans and associated training, citing their experience that realistic estimates are substantially higher. The organization concluded by reaffirming its support for the rule’s intent and offering its expertise for further consultation.
