The NIH Office of Laboratory Animal Welfare (OLAW) is seeking comments on its proposal to require annual reporting of all live vertebrate animals used under PHS Assurances.

If you are able, please submit a comment before December 21 to support the proposal.

The Physicians Committee for Responsible Medicine is hosting a live webinar on November 17 at 12:00 p.m. ET to give step-by-step instructions on how to respond to this request and help bring animal experiments out of the shadows. Please register for the webinar and pass the information along to anyone with scientific, medical, or veterinary training or experience with animals in laboratories.

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We have included a list of talking points and important items to consider, but please personalize your comment to increase its visibility to the agency.

• The final policy must include reporting of specific annual animal use numbers by species and USDA pain/distress category. These data represent the minimum level of detail necessary to understand the scale, nature, and severity of animal use and to evaluate trends over time.
• The final policy must include all vertebrate animals covered by the PHS Policy. Reporting should not be limited to species covered by the Animal Welfare Act as these animals are already counted by the USDA. Excluding mice, rats, fish, birds, and other non-AWA species is arbitrary and would omit the majority of animals used in NIH-funded research.
• The final policy must ensure that institutional reports are promptly made available to the public. Transparency is essential for accountability in taxpayer-funded research and allows independent analysis of animal use trends.
• The final policy must include foreign as well as domestic institutions. Taxpayer-funded research should be subject to the same transparency standards regardless of where the work is conducted.

Additional Points

• Comprehensive animal use data are necessary for evidence-based policymaking and strategic planning.
• NIH cannot effectively evaluate efforts to reduce animal use or expand the adoption of non-animal methods without reliable baseline and trend data.
• Institutions already maintain records of animal use for compliance and oversight purposes. The modest burden added by these reporting requirements is overwhelmingly outweighed by the substantial benefits to transparency and accountability.
• Public reporting will improve transparency and could begin to restore public trust in NIH-funded research.
• Information on pain and distress categories is important because the number of animals alone does not capture the severity of procedures being conducted.
• Animal use data will allow NIH to assess whether investments in non-animal methods are translating into measurable reductions in animal use and animal suffering. Without comprehensive reporting, the agency cannot evaluate the real-world impact of these investments and whether it’s delivering on its promises to the administration or the public.
• NIH routinely tracks funding, publications, patents, and other research outputs. Animal use data is an even more important metric.
• Taxpayers fund NIH research and deserve access to information about how and how many animals are used in federally funded experiments.
• Independent researchers, policymakers, journalists, and members of the public should be able to analyze animal-use trends without submitting FOIA requests.
• Knowing how many animals are used is important, but knowing the severity of procedures is equally important. Pain and distress categories provide critical insight into the welfare impacts of NIH-funded experiments.
• Animal use statistics should not only quantify animals used but also help illuminate the degree of pain and distress that animals experience.
• Any additional reporting effort is modest compared with the public accountability benefits generated by the data.
• Meaningful oversight begins with acknowledging and counting the animals who are used. If NIH cannot provide an accurate count of the animals whose lives are spent in taxpayer-funded experiments, it cannot credibly evaluate efforts to reduce animal use or animal suffering.