Source? Most universities have an IRB for non-human test subjects, and the federal funding requirements may require an IRB, but I can't find any federal requirements for an IRB on non-human subjects if you're not taking federal funding, even for FDA approval.

Thank you, it's not an IRB in the case of an animal, it's a different acronym (though not a classic FDA TLA, three letter acronym). It's a IACUC,

https://irb.utah.edu/guidelines/fda-requirements/animals.php....

So a similar process, similar requirement, just called something different.