Must, Should, and May as defined by OLAW

OLAW has published a notice (NOT-OD-12-148) providing guidance on review and reporting requirements for departures from the Eighth Edition of the Guide:

OLAW defines a must statement as a minimum standard required of all Assured institutions. Deviation from these standards with IACUC approval is a departure from the Guideand must be reported in the semiannual report. Deviation from a must statement without IACUC approval is a noncompliance that must be reported to OLAW through the IO.

Reporting requirements for should statements in the Guide vary:

  • Should statements often involve performance standards. Well-established performance standards are not departures from the Guide and need not be reported in the semiannual report to the IO.
  • Deviation from a should statement with IACUC approval is a departure from the Guideand must be reported in the semiannual report to the IO.
  • Deviation from a should statement without IACUC approval is a noncompliance that must be reported to OLAW through the IO.

May statements in the Guide are suggestions that institutions can choose to implement if suitable for their program and deviations are not included in the semiannual report to the IO.

IACUC approval of departures from the Guide must be based on scientific, veterinary medical, or animal welfare issues. For additional information and examples of departures refer to OLAW FAQ C7.

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