f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 4 [Entry Date] 02/25/2011 at 12:33:12 AM [Affiliation] Self [Comments] 
Comment 1: This updated edition of the Guide seems very thoughtfully considered, and I thank the Committee for all their hard work and dedication. I offer only two recommendations relating to past tragedies at my own institution: Requirements for automated environmental monitoring must be updated given the increasing availability of low-cost technological solutions. Automated temperature monitoring and alerting must by now become mandatory for most facilities rather than merely recommended. As stated in OLAW's FAQ, "Sole reliance on employees to identify changes in animal room conditions or the use of high-low thermometers to track changes in temperature may not be sufficient to allow timely intervention and prevent catastrophic loss." In addition, video surveillance should be considered not only for building security, but also to facilitate independent oversight of animal housing conditions and help ensure that experimental procedures follow approved protocols. Comment 2: NIH extramural research programs are themselves institutional programs receiving Public Health Service support for activities involving animals, and must comply with the same federal principles expected of individual grantees. NIH has placed the burden of applying the "Three Rs" squarely upon individual researchers, while neglecting these principles entirely in decisions of funding. Given multiple proposals of comparable merit as scored by expert scientific review groups, NIH currently gives zero weight to differences in the numbers and types of animals used, or the relative levels of pain and distress that would be caused by the proposed experimental methods. No implementation plan will be adequate that exempts the NIH administration itself from its responsibility to apply the ethical principles described in the Guide to all decisions determining which animal experiments or alternative studies will be supported by taxpayer funds.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals