f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 506 [Entry Date] 04/25/2011 at 04:35:40 PM [Affiliation] Self [Comments] 
Comment 1: As per request, I hereby submit my comments on the proposed Adoption and Implementation of the Guide for the Care and Use of Laboratory Animals: Eighth Edition First of all, let me state that the Guide for the Care and Use of Laboratory Animals is an excellent document that serves as a very useful resource to use when communicating to the facilities management personnel as to what requirements we have for our animal program. It is concise and effective as a communication tool and has served us well in the past. However, one of the changes in the Guide will cause significant economic hardship to our research program if implemented. Our animal facility has recently purchased a very large number of racks and cages for a recently expanded facility. We have an active mouse breeding program with dozens of different strains of transgenic mice. Many of the mice are difficult to breed because of sub-optimal maternal skills in the breeders. Despite the difficulties in producing sufficient litters of pups from these lines of mice, we have managed to keep our program operating through the careful monitoring of breeding trios. Once pregnancies have been established, we find that fecundity is increased by leaving both mothers with pups together in the same cage until it is time to wean the litters. When one mother exhibits poor/aberrant nursing behavior the other frequently will supply the necessary intervention to properly raise the pups. In the Environment, Housing and Management section of the guide on page 57 TABLE 3.2, Recommended Minimum Space for Commonly Used Laboratory Rodents Housed in Groups states that Female+Litter space requirements are 51 in² floor space per Female+Litter. Therefore, under the new guidelines our rodent cages would need to have 102 in² bottoms to house two litters. Unfortunately our new rodent cages only have 78 in² bottoms which are more than sufficient to house five adult mice. Our animal care staff is very good about performing extra cage changes to prevent any cage sanitation issues, and this SOP is a very important part of our breeding program. I would hate to have a requirement in the guide that would be detrimental to our breeding program by requiring us to house only one litter per cage, but I can't see us purchasing new cage racks and cages just because we are a few square inches short of what has been "suggested" as appropriate in the guide. I am quite certain that there are many other institutions that have the same caging that we use and so this will be a big issue for many facilities. Perhaps the wording could be changed to allow for additional operational controls such as more frequent cage changes be an acceptable alternative? As our accrediting agencies will expect us to adhere to the standards as set forth in the guide, these considerations are very important to us. Comment 2: If the restrictions on minimum space allocation for rodent breeding are addressed as outlined in the comments above, I would have no problem with implementing the guide by March 31, 2012. If the restrictions stand as is, we would be unable to meet this deadline.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals