Whether or not IACUC approval is required for the CAFE club’s activities depends on several factors. The first consideration is whether the animals are under the auspices of the Animal Welfare Act Regulations (AWAR) and/or Public Health Service (PHS) policy. The pet animals used by the CAFE club to teach members how to groom, train, and exhibit animals in show are not owned by the university. Therefore, the regulations do not apply and IACUC approval is not required. Per PHS Policy, the requirement for IACUC approval of the CAFE club’s activities depends on whether Great Eastern University has an Animal Welfare Assurance and voluntarily includes all animals under their Assurance. If they do, then IACUC approval would be required1,2,3,4.

A second consideration involves how the CAFE club and its activities are funded. If funding is provided by a private agency, there are no federal or state laws that require the agency to obtain IACUC approval of animal use projects if the animals are not AWAR-regulated covered species. Nonetheless, private or public agencies may specifically require IACUC approval prior to release of funds. If the university has an Animal Welfare Assurance that commits the institution to comply with the PHS Policy for all animals, IACUC approval would be required regardless of funding source1,2.

A final consideration is the university’s ethical responsibility for the use of animals by the CAFE club. If there are no regulatory or funding agency requirements for IACUC approval, the university should have a mechanism in place to address all animal related activities on it campus, such as a written policy that covers the use of pets or other privately owned animals used for CAFE club’s activities2.