On January 15, 2020, the American Veterinary Medical Association (AVMA) issued and posted an updated version of the Guidelines for the Euthanasia of Animals. The 2020 Edition is available for download at https://www.avma.org/KB/Policies/Documents/euthanasia.pdf.
The PHS Policy, IV.C.1.g., requires that Institutional Animal Care and Use Committees (IACUCs) reviewing research animal activities determine that methods of euthanasia used will be consistent with the recommendations of the AVMA Guidelines for the Euthanasia of Animals unless a deviation is justified for scientific reasons in writing by the investigator.
Request for Information (RFI) on Implementation of the Updated AVMA Guidelines for the Euthanasia of Animals: 2020 Edition
Federal Register Notice 2020-03607 and NIH Guide Notice NOT-OD-20-069 Request for Information were issued to solicit input from the public on any concerns they may have with the 2020 Edition of the Guidelines.
The public comment period closed on April 29, 2020.
Implementation of the Updated Guidelines
OLAW encourages Assured institutions to begin using the 2020 Guidelines when reviewing research projects as soon as possible and expects full implementation after October 1, 2020. Previously approved projects undergoing continuing review according to PHS Policy, IV.C.5., which requires a complete review at least once every 3 years, must be reviewed using the 2020 Guidelines after October 1, 2020.
- How does OLAW expect Assured institutions to implement the new AVMA Guidelines for previously approved protocols?
After October 1, 2020, as a previously approved protocol is reviewed, the protocol's compliance with the 2020 Guidelines should be considered by the IACUC and any necessary amendments should be requested. This review may occur as part of annual review (as required by the Animal Welfare Act regulations), continuing review at least once every 3 years (as required by PHS Policy IV.C.5.), or when the IACUC is considering a significant change to an approved protocol. OLAW encourages institutions to begin this review as soon as possible but no later than October 1, 2020.
- Must every previously approved protocol that is currently active be re-reviewed and amended before October 1, 2020?
No, although OLAW encourages institutions to implement the new guidelines as soon as possible, the review of already approved protocols can be phased in as part of the review processes already in place at Assured institutions. This review should begin no later than October 1, 2020. For many protocols there may be no impact as the methods already being used are compliant with the 2020 Guidelines.
- Does OLAW consider already approved protocols that have not yet been reviewed for compliance with the 2020 Guidelines as departures from the Guide for the Care and Use of Laboratory Animals or noncompliant with PHS Policy?
As long as the IACUC has a reasonable plan and schedule for how the review of already approved protocols will occur, OLAW does not consider already reviewed protocols that have not yet been reviewed as departures or noncompliant. OLAW allows a phased in review to minimize the burden on institutions but encourages implementation of the review as soon as possible and no later than October 1, 2020.
- What should IACUCs do about existing euthanasia policies and standard operating procedures?
IACUCs are encouraged to review existing euthanasia policies and SOPs as soon as possible for compliance with the 2020 Guidelines. OLAW expects IACUCs to update existing program-wide euthanasia policies and SOPs to be compliant with the 2020 Guidelines during the next scheduled semiannual program review and no later than October 1, 2020.
- What if our next semiannual program review occurs this month?
Your IACUC should make every effort to consider existing policies and SOPs for compliance with the 2020 Guidelines and update the documents as necessary to ensure implementation on or before October 1, 2020.
- NOT-OD-20-143: Grant and Contract Submission Requirements Regarding the Updated AVMA Guidelines for the Euthanasia of Animals: 2020 Edition
- NOT-OD-20-132: Public Comments on the Implementation of the Updated AVMA Guidelines for the Euthanasia of Animals: 2020 Edition
- NOT-OD-20-069: Request for Information (RFI) on Implementation of the Updated AVMA Guidelines for the Euthanasia of Animals: 2020 Edition
- Responses received to NIH Guide Notice NOT-OD-20-069
- AVMA letter to NIH OLAW addressing responses to NIH Guide Notice NOT-OD-20-069
- Update on the AVMA Guidelines for the Euthanasia of Animals: 2020 Edition webinar
Call (301-496-7163) or e-mail (firstname.lastname@example.org) OLAW for answers to your questions.