f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 43 [Entry Date] 03/17/2011 at 10:50:07 AM [Affiliation] Self [Comments] 
Comment 1: I strongly support adoption of the eighth edition of the guide. The Guide has long provided a reasonable set of standards by which ethical research studies using animal models can be performed. Animal models are absolutely crucial to medical and basic research progress. ***** Comment 2: Two areas of the proposed implementation plan require further modification, in my opinion. Both are on pp 30-32 of the draft guide. First, the proposed language would require purchase of "pharmaceutical grade" chemicals for all studies with animals. The intent here is laudable - none of us who work with animals wants to administer poor quality compounds that might contain contaminants that might have undesirable side effects. However, the realities of research has taught us that chemicals that are purified to "pharmaceutical grade" are nearly always much more expensive than simply "analytical grade" or other non-pharmaceutical grade products. The further reality is, for many compounds, there is absolutely no safety risk to the animal. The requirement as currently proposed is backwards. It should be acceptable to use compounds of any reasonable purity unless there is reason to believe, for that specific compound, that to do so might be unsafe for the animals. The result of adopting a "pharmaceutical-grade" requirement will, quite simply, be that for nearly all compounds I will seek exemption to use a lesser quality in my protocols, and will waste a lot of my time and my IACUC's time. The other issue that should be discussed further is the apparent proposal that use of preferred foods as reinforcers should be preferable to the use of very mild food restriction in behavioral protocols. There is a very extensive published literature in the animal learning area that demonstrates quite clearly that these two sources of motivation are not behaviorally equivalent for animals. Mild food deprivation protocols that have no detrimental physiological consequences for the animals are well-understood. There is a large literature that even much more significant food restriction on a permanent basis has health benefits. So, making a default requirement that preferred foods should be used is unreasonable scientifically and will not protect or improve animal health. *****
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals