Comment Letter

COGR Comments on AAALAC's Proposed Revision to the definition of Lab Animal

The Council on Governmental Relations (COGR), representing over 190 research-focused institutions, provided feedback to AAALAC International concerning proposed changes to the organization's Position Statement on the "Definition of Laboratory Animals." COGR emphasizes that the existing language, particularly the inclusion of "any other animal designated by applicable legislation," is sufficient to account for international legal variations and covered species, making further modification unnecessary. The organization expresses concerns about explicitly adding cephalopods to the definition, as they are not currently subject to U.S. law or AAALAC oversight, and contends that such a change could create confusion within the research community unless accompanied by clear intent and opportunity for public input. COGR suggests that AAALAC maintain flexibility by either retaining the broad legislative reference or, alternatively, specifying "live vertebrate animals" and those covered by legislation in its definition. The council concludes by reaffirming its appreciation for the opportunity to contribute to the review process.

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