f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 483 [Entry Date] 04/24/2011 at 11:15:43 PM [Affiliation] Self [Comments] 
Comment 1: NO. The NIH should NOT adopt the eighth edition of the Guide for the Care and Use of Laboratory Animals. Many of the recommendations contained in the 2011 Guide are not based on empirical scientific evidence (e.g., cage sizes, food & liquid restriction) and would seriously impede or delay progress in scientific research that will benefit the public health. In addition, most recommendations will require significant, costly alterations for institutions and investigators. For example, there is no evidence that pharmaceutical-grade drugs would improve animal welfare. Moreover, research would be impeded because commercially available pharmaceutical-grade formulations are often single concentrations that make it difficult or impossible to manipulate drug dose or to compare different vehicles. Using pharmaceutical-grade drugs will also increase the cost of pharmacological research. Some nonhuman primates live for more than 25 years, and repeated measures are often necessary to answer important research questions using longitudinal designs. Constraints on multiple procedures in animals will make such studies increasingly difficult to complete. Further, repeated surgeries are often necessary to repair or prolong the life of surgically implanted experimental devices. Decreasing the number of manipulations permitted with individual animals will increase the total number of animals used in biomedical research. Paired housing of nonhuman primates, as recommended in the 2011 Guide, would place animals at risk for injury and death. Aggression in response to any surprise (a novel noise, person, pain, etc.) may lead the dominant member of the pair to attack/kill the weaker or more submissive cage mate. Studies that require implantation of any device such as an IV catheter to evaluate medication effectiveness could not be conducted. Further, researchers using nonhuman primates go to great lengths to provide various types of "enrichment" to the animals (i.e., toys, mirrors, food, etc). Comment 2: Implementation of any changes to the 1996 Guide should be delayed for at least five years to allow the NIH to gather scientific evidence to support or to refute the many questionable recommendations proposed in the 2011 Guide update.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals