[Counting in animals].

317.1 Background Neither the PHS Policy nor the Animal Welfare Act Regulations (AWAR) explicitly require an institutional mechanism to track animal usage by investigators under IACUC approved activities, but both require that applications to the IACUC specify and include a rationale for the approximate number of animals proposed to be used (AWAR §2.31,e,1; §2.31,e,2; PHS Policy IV,D,1,b; Guide p. 25) and implicitly require mechanisms to monitor and document the number of animals acquired or produced and used in approved activities. This expectation includes any number of animals that are kept for breeding purposes, produced and culled prior to research use and not subjected to any experimental manipulations, held in unassigned pools, or used in field research. The use of dogs and cats specifically requires that acquisition and disposition records be maintained in compliance with federal law (AWAR §2.35,b,1– §2.35,b,7 8). The AWAR require that annual use of regulated species be reported by pain/distress category (AWAR §2.36,b,5–§2.36,b,8), while NIH, through its Office of Laboratory Animal Welfare (OLAW), requires reporting of average daily inventories of animals, by species, in new and renewal Animal Welfare Assurances.