f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 537 [Entry Date] 05/01/2011 at 09:03:39 PM [Affiliation] Self [Organization City and State] Chicago, IL [Comments] 
Comment 1: This letter is submitted in response to the National Institutes of Health's solicitation of comments concerning the Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals (Guide) that appeared in the Federal Register on February 24, 2011 ((78 Federal Register 10279-80. As a clinical veterinarian with 14 years of experience "in the trenches" and on the front line to improve animal welfare in biomedical research, I strongly encourage OLAW to reject the recommendations for mouse breeding cages outlined in the Eighth Edition of the Guide. The Guide recommends 51 square inches for a single female mouse and her litter. When factoring in the requirements for the male (15 square inches), the total space requirement would be 66 square inches. The floor of a standard micro isolator cage at our facility is 66 square inches. These recommendations, if endorsed by OLAW would commit PHS-funded institutions to follow a monogamous pair breeding scheme for mice. There are major reasons why OLAW should reject this recommendation. I am sure that OLAW has received numerous comments from directors and managers describing how adoption of these changes will impose insurmountable costs to already financially stressed animal care programs. For example, to move from our current occupancy guidelines for mouse breeding cages which alllows for trio (1 male: 2 females) to monogamous (1 male: 1 female) breeding, we would literally need to double the number of breeding cages to maintain the same number of mice. We, as well as other institutions, do not have the finances or space to support these changes. These changes will negatively impact investigators who must breed genetically engineered mice to support their PHS-funded research programs. The investigators I have communicated with are seriously concerned about the proposed changes. Their concerns are that their budgets will not allow for it and many of their mice will not breed well as monogamous pairs. As scientists, they want to know what the scientific justification is for such dramatic changes. Unfortunately, there is no scientific justification to support the change to monogamous breeding of mice. It should be noted that the Jackson Laboratory, the number one vendor of genetically engineered mice, recommends that investigators breed their genetically engineered mice as trios. One reason for this is that breeding is a social activity in mice, and their extensive data on mouse breeding shows optimal breeding indices when mice are bred as trios. Another reason Jackson recommends trio breeding is that many mutant mice do not lactate well. Finally, the majority of mutant mice have smaller litters than outbred and even inbred strains of mice. Not only is the number of mice per litter smaller, but the mice themselves are smaller, and therefore take less space. As a result, trio breeding of genetically engineered mice does not result in overcrowding or unsanitary cage conditions. I urge OLAW to consider the negative impact these changes will have on animal welfare. In the wild, mice breed in single male: multiple female arrangements. It would make sense for the Guide to provide to provide recommendations to breed mice in a way that most closely mimics their natural history within the confines of the laboratory mouse cage. OLAW must consider how adopting the recommendations for mouse breeding cages outlined in the Eighth of the Guide will negatively impact not only the ability of institutions to support and investigators to perform quality research, but also the breeding performance and welfare of the laboratory mouse.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals