f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 307 [Entry Date] 04/20/2011 at 06:50:12 PM [Affiliation] Self [Comments] 
Comment 1: I do NOT support NIH's adoption of the new Guide for the Care and Use of Laboratory Animals. Major organizations like the American Psychological Association (APA), the Association for Behavior Analysis International (ABAI), and the American Society for Pharmacology and Experimental Therapeutics (ASPET) have outlined many of the concerns that researchers in this country, like me, have with the new guide. I support their statements regarding the adoption of the new Guide and have little to add. In short, the major concerns I have deal with increased cost to institutions without any clear benefit or empirically supported improvement in animal welfare. The wording of the new Guide, if adopted, would result in virtual mandates (the "should" comments) that would increase expenditures, e.g., new caging, no multiple procedures, restrictions on food and water intake, increased paperwork, use of pharmaceutical-grade agents (Guide p. 31), without any data to suggest that the new policies are an improvement over the current practices. For example, many researchers have used non-pharmaceutical-grade drugs for decades with no ill effects to the animals. Switching to pharmaceutical-grade drugs would only add cost without improvement to animal welfare. This is just one example where the Guide's recommendations, which would become "law" for many IACUCs, are not empirically supported and would pose an unreasonable burden on researchers and institutions. While many animal researchers support guidelines for maintaining and improving animal welfare, the new Guide, which lacks empirical support for many recommendations, misses the mark. Of course, animal welfare is important to scientists, but asking institutions to change practices at enormous financial costs without data to support the necessity of the changes, is misguided. In sum, I strongly believe that the NIH should NOT adopt the new Guide. Comment 2: n/a
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals