f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 200 [Entry Date] 04/19/2011 at 03:13:35 PM [Affiliation] Self [Comments] 
Comment 1: No, the Eighth edition ofthe Guide should not be adopted. This new guide was supposed to be an "update" of the 1996 Guide, however the final product is twice as long and contains a great deal of what can only be called new "policy." Compliance with these new policy statements will increase the expense to institutions (e.g., changes in cage sizing) and expense to investigators (e.g., drugs). However, the scientific data justifying such changes is non-existent. The 2011 Guide will require a large increase in the paperwork burden (e.g., all deviations from "should" statements contained in the new Guide will now need to be justified). Adoption of the new guide may also negate the opportunity to diminish the regulatory burden resulting from reactions to issues for which institutions are already heavily regulated. Moreover, the new "Guide" policies constitute increased 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 institutions and to investigators 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" administered to to 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. Comment 2: The evaluation is to take place within one year of adoption of the new Guide. OLAW should require institutional compliance with the new Guide no sooner than March, 2015 to allow for the collection of relevant data. It is the data that should guide policy decisions.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals