f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 247 [Entry Date] 04/20/2011 at 11:29:13 AM [Affiliation] Self [Comments] 
Comment 1: NO it should not adopt this edition as a basis for evaluation of institutional programs.The new guide is not an "update" as originally proposed but contains a great deal of new "policy." Compliance with these new "policy" statements will greatly increase the expense to institutions (e.g., cage size) and expense to investigators (e.g., drugs). Moreover, the scientific data justifying these expense changes is non-existent. Adherence to the 2011 Guide will require large increase in paperwork burden. Adoption of the new guide may also negate the opportunity to diminish the burden resulting from over reactions to issues for which institutions already have "overregulated." Moreover, the new "Guide" policies increase infringement on scientific decision-making by PHS grantees, contractors and IRGs. The policy changes implemented by the new Guide will result in significant additional expenses to the institution and the investigator with no real enhancement of animal welfare. Some specific examples include constraints on multiple procedures in animals, constraints on multiple surgeries (per se), new requirements for food- or fluid-restriction, naïve and constraining section on choices of "chemicals and other substances" to give animals and specific guidance on "post-approval" monitoring (e.g., observation of procedures). In addition the new "Guide" requires an increased level of intra and post-operative surgical procedures. THE END RESULT WOULD BE TO SEVERELY IMPEDE ADVANCES MADE BY BASIC RESEARCH WITH NO GAIN IN ANIMAL WELFARE.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals