f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 99 [Entry Date] 04/15/2011 at 05:26:45 PM [Affiliation] Self [Comments] 
Comment 1: I spent a couple hours skimming over the 240 pages of the proposed 8th edition of the NIH Guide. Much of the changes are common sense. Some interpretations of the Guide come not from those with the goal of increasing animal welfare but rather with the goal of restricting and ultimately eliminating animal research. As such the vague and subjective wording in the document opens investigators and institutions to frivolous litigation. My other concerns are with requirements that would hinder rather than support animal health and welfare. 1) Of great concern is where the wording of must (defined by the guide as a requirement) is followed by something vague and subjective such as ensure the "well-being" of the animal or "provide a high quality of care and ethical standards" that could expose Universities and investigators to frivolous litigation from groups that would like to entirely eliminate animal research. 2) Under surgery it states that, "Careful monitoring increases the likelihood of successful surgical outcomes. Monitoring includes routine evaluation of anesthetic depth and physiologic functions and conditions, such as body temperature, cardiac and respiratory rates and pattern (Flegal et al. 2009), and blood pressure (Kuhlman 2008), and should be appropriately documented." I completely disagree with this statement. In rodents, successful surgical outcomes are best assured by clean, efficient surgeries that do not require supplemental anesthetic or longer exposure to gas anesthesia than necessary. Not only is it difficult to measure these physiological symptoms in rodents, doing so requires distraction from the surgery that increases anesthetic exposure and encourages breaks from aseptic technique. 3) The new mechanical standards do not appear to allow for a breeder male mouse to stay in the cage with the female and litter and appear to prevent harem breeding in most standard cages; hence they are in conflict with requirements elsewhere in the guide indicated that social animals should not be individually housed. They also state that environmental enrichment (e.g. a paper cup) is to be subtracted from available floor space without taking into consideration that the animal can walk or climb on it or carry it around. The new mechanical standards could greatly restrict research where space is at a premium and will require the employ of personnel who police this. It was better to have standards, e.g. the animal should be able to turn around in its cage and not touch the lid when situated in a normal position. 4) Under food restrictions the guide requires "the least restriction necessary to achieve the scientific objective." This is counter to studies which show rodents are healthier and live longer under food restriction (more than the least necessary to perform a task) than they do under ad libitum schedules. The guide again mandates that the "well-being" of the animals be monitored. This is vague and subjective. In addition, this section is written in a way that could be interpreted as though both food and fluid intake have to be monitored daily even if only one or the other is regimented. This could require a significant increase in personnel effort without increasing the safe monitoring of the health of the animals. 5) "Disaster plans should be established in conjunction with the respon¬sible investigator(s), taking into consideration both the priorities for triaging animal populations and the institutional needs and resources. Animals that cannot be relocated or protected from the consequences of the disaster must be humanely euthanized." This could be interpreted to mean in an impending disaster supporting the unnecessary death of animals and is in conflict with the 3Rs. 6) A good addition in the surgery section is that craniotomy could be considered a minor surgery where most have previously considered it opening a body cavity and classified it as major surgery. This makes sense given how quickly rodents recover from this type of surgery.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals