change in procedure will require FCR or DMR for approval. Thorne believes that Veterinary Verification and Consultation (VVC) is appropriate in this instance. Guidance of Significant Changes to Animal Activities1 states that the VVC may be used for “review and approval of proposed significant changes to animal activities.” The investigator has requested an additional procedure to the protocol, which was not in the original submission. The VVC guidance was meant to alleviate administrative burden on both the IACUC and the researcher. However, it does not remove the IACUC’s responsibility to review procedures added to a protocol, regardless of whether the procedure is being viewed as major or minor. If the investigator wanted to change the method of implant from a small incision to say an injectable method, and the IACUC has an already approved policy for these types of procedures, than the significant change in procedure could be administratively handled via the VVC 1. National Institutes of Health. Guidance on Significant Changes to Animal Activities. Notice NOT-OD-14-126. (National Institutes of Health, Washington, DC, 26 August 2014). 2. Public Health Service. Policy on Humane Care and Use of Laboratory Animals (US Department of Health and Human Services, Washington, DC, 1986; amended 2002).