f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 536 [Entry Date] 04/29/2011 at 08:27:48 PM [Affiliation] Self [Comments] 
Comment 1: I am registering strong opposition against the proposed revision of the Guide, for the following reasons: 1. The revised Guide will have major negative impact upon the NIH-funded research by enormously increasing costs and administrative burdens and reducing availability of animal holding space across the U.S. WITHOUT ANY SCIENTIFICALLY BASED BENEFIT TO THE ANIMAL WELFARE. 2. The revised guide will reduce the efficacy of animal breeding and will potentially lead to deaths of many of the newborn mice because it prohibits duo and trio breeding, despite the fact that this arrangement, currently recommended in the 7th edition of the Guide, has been shown to be the most conducive to litter survival and animal welfare. 3. The new restrictive policy is inconsistent with data from multiple peer-reviewed publications evaluating the effects of cage density. Data in peer-reviewed papers published since the 7th edition show that a number of common mouse strains can be housed at twice the density recommended by 7th edition of the Guide, in some cases with apparent benefits to health. Therefore, it is troubling from both animal health and financial perspectives that maximum recommended caging densities were not relaxed to reflect this new information. 4. The new guide has not been vetted by the scientific community it is meant to serve. In too many cases changes have been mandated without scientific justification, and in many cases new scientific information has been ignored. And too often, the new Guide makes generalizations and creates ambiguities both in lines of responsibility and logical application to specific laboratory organisms. Comment 2: In concert with the above comments, neither the Guide nor the facility evaluation recommendations should be adopted.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals