f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 70 [Entry Date] 04/14/2011 at 05:07:10 PM [Affiliation] Organization [Organization Name] Columbia University Psychiatry and the NYS Psychiatric Institute [Organization City and State] New York, NY [Comments] 
Comment 1: The new guide , if fully adopted by OLAW as policy would have SIGNFICANT SCIENTIFIC and ECONOMIC impact on our research. There has not been sufficient time to completely assess this impact and the space limitations for comments is too restrictive to allow meaningful feedback. For example, at our institution the new space requirements for mouse breeding would require new caging (major expense), or a change from social 'dam' housing (mice) to housing single dams with litter more space. The latter is a significant economic burden. The latter solution forces us to change an important aspect of our experimental design (social parenting) which we believe benefit our mice. Either solution will require more space, which, in turn requires major programmatic changes that may take years to complete. I think I speak for most investigators and our IACUC in strongly recommending that 1) more time be given for the scientific community to evaluate the impact of the guide and provide meaningful feedback. Comment 2: It is unlikely that institutions can implement all of the major changes (the 'musts') outlined by the guide by March 2012. It is recommended that NIH implement instead a 'evaluation period' in which institutions are encouraged to begin using the guide for evaulations and give feedback to NIH. During this time the current guide should be the basis for the official semiannual IACUC evaluation. As stated above, new policies based on the 8th edition would force major changes to experimental design, caging and/or the physical plant. Any implementation deadlines should be set with full consideration of the time needed to make these major changes.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals