f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 190 [Entry Date] 04/19/2011 at 02:36:31 PM [Affiliation] Self [Comments] 
Comment 1: NO. Please do not adopt the proposed 8th edition of the Guide. First of all, it goes way beyond what was originally recommened as an update to the 1996 edition and will increase costs associated with research for both researchers and institutions. Why these changes are being proposed is not based upon any scientific data and thus are not justified. The proposed Guide also infringes on the scientific decision-making process of PHS grantees, contractors, and IRG's in a number of significant ways. For example, it would insist upon the use of "pharmaceutical grade" drugs used in animal experimentation. There is no data to support this recommendation. Furthermore, this will drive up costs unnecessarily, and it is not clear how one is supposed to make the appropriate concentrations needed for experiments and maintain the "pharmaceutical grade" status of the preparation. Similarly, the constraints proposed on multiple procedures in animals, multiple surgeries, new requirements for food- or fluid-restriction, uninformed and constraining sections on the choices of chemicals and other substances, and specific guidelines on "post-approval" monitoring are not justified by any data or scientific rationale. The bottomline is that this new Guide seems to be driven by an animal welfare agenda and not based upon scientific data. Please do NOT adopt this proposed Guide unless you want to drive up the cost of research and kill the majority of medical research in this country. Comment 2: This new guide needs to go back to the drawing board and any proposed changes need to be based upon scientific data or deleted from the guide. Thus, it is my esitmate that this can not be done in less than a year, and I would propose that you do not require the use of any new guide until this is done. I suggest you shoot for something like an implementation date of March 31, 2015.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals