The Public Health Service (PHS) Policy on Humane Care and Use of Laboratory Animals requires each Institutional Animal Care and Use Committee to review all projects using live vertebrate animals. The NIH Office of Laboratory Animal Welfare (OLAW) has interpreted the term "live vertebrate animal" to apply to egg-laying species only after hatching[1].

Although this is an imprecise stage for zebrafish it can be approximated at 72 hours post fertilization. Current OLAW interpretation of PHS policy considers zebrafish a vertebrate animal at all stages of development three days past fertilization. As such, formal ARC approval is required for zebrafish embryos after the third day of development.

Conversely, formal ARC approval of activities utilizing embryos of non-zebrafish, non-mammalian, oviparous (egg-laying) species is not required. However, if oviparous embryos will be permitted to hatch, or if embryos will be extracted from live-bearing species, submission of an ARC protocol is required. ARC approval is also required if adult animals will be maintained for the purpose of laying or fertilizing eggs.

Research with fertilized non-zebrafish, non-mammalian embryos in the final one-third of incubation requires the submission of an informational memo to the ARC stating the following:

  • The animal species to be studied[2].
  • A brief description of the research you will conduct using the embryos.
  • The source of the embryos (e.g., obtained from commercial aviaries, collected in the wild)[3].
  • An assurance that:
    1. Embryos will not be permitted to hatch.
    2. If any embryos hatch unexpectedly, a member of the veterinary staff (x42571 or pager #96545) will be contacted immediately to euthanize the animal.
    3. In accordance with University Policy, all personnel handling embryos will submit a Medical History Questionnaire (MHQ) form to the Occupational Health Facility on an annual basis.

Please note that the ARC reserves the right to require additional information, including submission of a research protocol, if the Committee determines this is warranted.

Investigators using embryos injected with biohazardous agents or treated with carcinogens, radioisotopes, or covered DNA must meet the requirements of, and obtain appropriate approvals from, the Biosafety Officer and/or Radiation Safety Officer.

[1]  National Institutes of Health Office of Laboratory Animal Welfare FAQ
[2] Additional requirements may be enforced for the use of embryos of exotic, endangered, or restricted animal species. For information on use of embryos from these species, please contact the Division of Laboratory Animal Medicine (x42571).
[3] If eggs will be obtained from the wild, collection permits may be required from state, federal, or foreign regulatory agencies.


Approved 9/25/06; Revised 9/12/11
Replaces ARC Policy on Use of Avian Embryos 7/01