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PHS Policy IV.F.3 requires that the ARC, through the Institutional Official, promptly provide OLAW with a full explanation of the circumstances and actions taken with respect to: (a) any serious or continuing noncompliance with PHS Policy; (b) any serious deviation from the provisions of the Guide for the Care and Use of Laboratory Animals; or (c) any suspension of an activity by the ARC.

In a February 24, 2005 document entitled Guidance on Prompt Reporting to OLAW under the PHS Policy on Humane Care and Use of Laboratory Animals (NOT-OD-05-034), a list of examples of situations that must be reported to OLAW is provided. However, the examples provided in this document “do not cover all instances but demonstrate the threshold at which OLAW expects to receive a report.”