Zebrafish

Yes, larval forms of fish and amphibians have vertebrae and are covered by the PHS Policy. As noted in FAQ A4, the PHS Policy applies to the offspring of egg-laying vertebrates only after hatching. Zebrafish larvae, for example, typically hatch 3 days post-fertilization. [A21]

PHS Policy is intentionally broad in scope and does not prescribe specifics about the care and use of any species, assigning that task to the IACUC and allowing for professional judgment. Many of the principles embodied in the Guide can generally be adapted to the care and use of various kinds of nontraditional research animals. IACUCs may seek the advice of experts when necessary, and refer to scientific-based publications prepared by professional organizations with interest in various species. Appendix A of the Guide references many such publications. [A7]

The PHS Policy defines an animal as any live, vertebrate animal used or intended for use in research, research training, experimentation, or biological testing or for related purposes (PHS Policy III. A). Therefore, all live vertebrate animals, including their offspring, should be accounted for in a timely manner that ensures the animal numbers approved by the IACUC are not exceeded. Animals born or hatched should be accounted for at the first opportunity without compromising the health and welfare of the animals. Pre-weaned animals from litters are to be tracked at the time of first manipulation, e.g., first cage change. The PHS Policy applies to amphibians and fish upon hatching (see FAQ A4, A5). For example, zebrafish typically hatch 3 days post-fertilization, subject to environmental conditions. Per the Guide (page 87), because it can be difficult to individually identify some small aquatic species throughout their lives, group identification may be more appropriate in some situations or an approximate number of animals may be used.

While the PHS Policy has no explicit requirement for investigators or the IACUC to track animal usage, it does require that proposals specify a rationale for the approximate number of animals to be used and for the appropriateness of the species and numbers used to obtain valid results (US Government Principles, III; PHS Policy IV.D.1.b). This implicitly requires that institutions establish mechanisms to document and monitor numbers of animals acquired, born, and used. Institutions have adopted a variety of administrative, electronic, and manual mechanisms to meet institutional needs as well as PHS Policy requirements.