APS’ response to a request for information from the National Institutes of Health (NIH) Office of Laboratory Animal Welfare (OLAW) on Proposed Guidance to Assured Institutions on Cephalopod Care and Use (NOT-OD-23-176)
Topic 1
Proposed Guidance: Assured Institutions are expected to ensure that cephalopod activities are subject to review and approval by IACUCs or other oversight bodies, and subsequent post-approval oversight, in accordance with U.S. Government Principles. This would involve including cephalopod programs and facilities in semiannual evaluations. Institutions may also choose to include cephalopod programs in other methods of post-approval monitoring used by the institution and may choose to voluntarily self-report any deficiencies to OLAW. Ad hoc consultants may be invited to assist with oversight activities. Institutions using cephalopods are expected to provide appropriate husbandry and veterinary care by employing research, husbandry, veterinary care, and physical plant staff with qualifications and training relevant to the species being used, as determined by the IACUC or other oversight body.
The American Physiological Society thanks OLAW for the opportunity to comment on this proposed guidance to assured institutions on cephalopod care and use. The Society concurs with the proposed guidance outlining expectations for IACUCs to review, approve, and oversee research activities with cephalopods. This guidance would align with the standard practice in place at many institutions which already conduct such review and oversight. We appreciate OLAW’s efforts to clarify expectations regarding these species and acknowledge that AAALAC Accredited institutions are already meeting or exceeding. Given that this guidance is new to OLAW, we encourage OLAW to expand the current Cephalopods in Research webpage and develop new resources with the help of experts, in addition to citing the work of others. Cephalopod-related resources should include resources for IACUCs that may not already be familiar with reviewing cephalopod protocols.
Topic 2
IACUCs and oversight bodies are encouraged to develop institutional policies and Standard Operating Procedures (SOPs) that summarize expectations and promote consistency and quality of cephalopod care and use. OLAW recognizes that there is tremendous variation in the life history, reproductive strategies, development, and captive breeding challenges among the several hundred known cephalopod species. Care requirements will necessarily differ based on these biological and environmental factors. In addition, cephalopod use varies with research aims (please see the OLAW Cephalopods in Research webpage for selected resources on these topics). Institutions have the discretion to develop institutional guidance that works best for their needs but should base their requirements on the U.S. Government Principles, as well as the most current data and professionally accepted standards. The Guide for the Care and Use of Laboratory Animals, 8th edition includes a section on aquatic animals with information on water quality and life support systems that can assist with some aspects of cephalopod care. In addition, information on current practice standards may be found on the AAALAC Resources page. The AVMA Guidelines for the Euthanasia of Animals provide guidance on the humane euthanasia of invertebrates, and institutions are expected to follow the most current version of these guidelines for the euthanasia of cephalopods. Practice standards will evolve based on new information in this expanding area of interest, and institutions are expected to keep apprised of the most updated information. Institutions are also encouraged to share their knowledge on the welfare of these research animals in conferences and publications.
APS appreciates the flexibility provided to IACUCs to develop institutional guidance related to their individual program needs. While this flexibility is essential to good IACUC practice, such institutional guidance should be based on the latest data and research. However, large gaps exist in the care needs of many types of cephalopod species. OLAW should seek opportunities to bridge these gaps, such as promoting research into the care and use of cephalopod species in the lab. Promoting such research would not only improve animal care but increase knowledge and understanding of cephalopod physiology and how it might translate to human disease.
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