If your project involves live vertebrate animals, the U.S. National Science Foundation requires that one of the following must be in place before it issues an award:
- Approval from an Institutional Animal Care and Use Committee (IACUC) and Public Health Service (PHS)-approved Animal Welfare Assurance. Or:
- A determination by an organization's IACUC that the project is exempt from IACUC oversight.
NSF's policies on proposals involving live vertebrate animals are detailed in NSF's Proposal and Award Policies and Procedures Guide (PAPPG) II.E.4. NSF's award requirements for projects involving live vertebrate animals are detailed in PAPPG XI.B.3.
Some key information from the PAPPG is highlighted on this page for your convenience.
On this page
Justifying the involvement of vertebrate animals
If your proposed project will involve live vertebrate animals, you must provide sufficient information in your project description so reviewers can evaluate:
- The rationale for involving animals.
- The choice of species and number of animals to be used.
- The proposed use of the animals.
- Exposure of animals to discomfort, pain or injury.
- Any euthanasia methods to be used.
Timing of IACUC approval
Although a proposal can be reviewed without IACUC approval, NSF will not recommend projects involving live vertebrate animals for funding until the cognizant NSF program director has received a copy of the IACUC approval letter or an exempt certification.
If your proposal cover page included a valid IACUC approval date, no additional documentation is needed to meet NSF's IACUC approval requirement.
If your proposal cover page listed your IACUC approval as pending, you should submit your IACUC approval application to the organization that will provide IACUC oversight as soon as you learn from the cognizant NSF program director that your proposal is likely to be selected for an award.
Timing of PHS-approved assurance
Although a proposal can be reviewed without PHS-approved Animal Welfare Assurance, projects involving live vertebrate animals cannot be recommended for funding until your organization has PHS-approved assurance.
If your proposal cover page included a valid Animal Welfare Assurance number, no additional documentation is needed to meet NSF's PHS-approved Assurance requirement.
If your proposal cover page listed the PHS-approved Animal Welfare Assurance as pending, the NSF program director will contact the NSF animal welfare officer, who will initiate steps to negotiate this assurance with NIH’s Office of Laboratory Animal Welfare.
Additional information
The Office of Laboratory Animal Welfare (OLAW), housed in the Director's Office of the National Institutes of Health (NIH), provides guidance and interpretation of the Public Health Service (PHS) Policy on Humane Care and Use of Laboratory Animals, supports educational programs, and monitors compliance with the policy by assured institutions.
NIH/OLAW will now conduct PHS assurance and oversight of awardees' use of vertebrate animals in NSF-funded projects. This MOU allows NSF-funded projects using vertebrate animals to come under the purview of NIH/OLAW oversight, provides improved sharing of information between the agencies, and includes partnerships on animal welfare related outreach and educational activities.
Most academic and research institutions that receive NSF funds also receive NIH funds. As a result, the vast majority of NSF awardees are already PHS-assured as a requirement of receiving NIH funds. However, if an NSF awardee never had NIH funding, it is likely the awardee is not PHS-assured. As a result, prior to this MOU, NSF would work with the institution and issue a one-time, project-associated assurance. This situation created a burden for the awardee, delayed the award process, and resulted in inconsistency in requirements from awardee to awardee.
The MOU took effect October 1, 2015.
The Public Health Service (PHS) Policy on Humane Care and Use of Laboratory Animals requires that institutions have an OLAW-approved Animal Welfare Assurance before carrying out any activities involving live vertebrate animals. Part of this assurance is the requirement that the institution has an appropriate Institutional Animal Care and Use Committee (IACUC) with associated policies and procedures in place. Every NSF award that includes work with vertebrate animals requires an animal use protocol covering the proposed work to be approved by the awardee's IACUC prior to funds being expended. Both are still required for any NSF award that includes vertebrate animals.
Yes, if the project is NSF-supported, involves vertebrate animals, and alters or influences the normal activities of the animals. For an institution with field-based animal research to obtain OLAW-approved PHS Assurance, the research must be reviewed and approved by the institution's IACUC. The IACUC must insure that the studies are in accord with the Guide for the Care and Use of Laboratory Animals. Taxon-specific guidelines1 may be used as supplemental references. Departures from the Guide must be approved by the IACUC and based on scientific, veterinary medical, or animal welfare issues (for more information, see OLAW-Departures from the Guide).
1. Guidelines to the Use of Wild Birds in Research; Guidelines of the American Society of Mammalogists for the Use of Wild Mammals in Research; Guidelines for the Use of Fishes in Research; Guidelines for Use of Live Amphibians and Reptiles in Field and Laboratory Research.
Institutions proposing to use vertebrate animals in an NSF-funded project are required to list their PHS assurance number on the NSF proposal cover sheet. If there is no PHS assurance number listed, check the NIH/OLAW website for the current list of PHS assured institutions.
No. NIH/OLAW will only begin the PHS assurance process once NSF intends to make an award to that institution. PHS assurance is not required for the NSF review process, only for awarding funds. NIH/OLAW will not begin the PHS assurance process without a direct request from NSF.
NIH/OLAW will begin the PHS assurance process for all institutions that are currently assured through a one-time project-based NSF-issued assurance and have at least one year remaining on an active award.
Yes. Prior to this MOU, awardees were not required to include NSF-funded projects in their reporting to NIH/OLAW. Now that the MOU is in effect, NSF-funded projects must be included in an awardee’s reporting to NIH/OLAW.
More information can be found on NIH/OLAW's website.
Please feel free to contact the NSF Animal Welfare Officer, Dr. Edda (Floh) Thiels, with any questions or to schedule an informational meeting with your group.