f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 474 [Entry Date] 04/24/2011 at 03:38:45 PM [Affiliation] Self [Comments] 
Comment 1: I oppose adoption of the 8th edition of the Guide. Additional time is needed to revise the guidelines based on feedback from the scientific community. Implementing the 8th edition of the Guide will substantially increase the costs of conducting basic biomedical research. These increases will result from the more intricate rules and procedures proposed -- MANY OF WHICH DO NOT INCREASE ANIMAL HEALTH AND WELL-BEING -- that both researcher and already overburdened IACUC's will struggle to implement. Given the current global economic climate and the steadily climbing costs of R&D in health care, we SHOULD be determining ways in which animal research can be done more efficiently and inexpensively -- NOT THE OPPOSITE. The current Guide is more than sufficient in terms of ensuring health and well-being of animal subjects. Furthermore, many of the proposed changes related to repeated testing and multiple surgical procedures will result in INCREASED ANIMAL USAGE which is absolutely contrary to efforts to decrease the numbers of animals used in research. Comment 2: If the 8th edition is adopted, institutions and researchers will need at least FIVE YEARS -- not ONE -- to implement and evaluate. Unless Congress is prepared to underwrite the costs of this undertaking using American taxpayer dollars WITHIN THE NEXT YEAR (i.e., to hire more people to engage in oversight, and to support all U.S. NIH-funded researchers with supplements to their grants), it will be an exercise in futility.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals