f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 241 [Entry Date] 04/20/2011 at 11:22:53 AM [Affiliation] Self [Comments] 
Comment 1: I believe OLAW should retain 1996 Guide as PHS Policy. My general concerns about the new edition include increased expense (e.g., new cage sizes for rodent breeding; larger cages for newly mandated social housing), increased paperwork burden (For example, all deviations from "should" statements contained in the new Guide will need to be in an approved protocol), and the increased power of local IACUCs to restrict already peer-reviewed research. Futhermore, I am specifically concerned about the constraints on multiple procedures in animals, constraints on multiple surgeries (not just multiple major survival surgeries), increased constraints governing food- or fluid-restriction, and poorly conceived instruction dictating the use of "chemicals and other substances" in laboratory animals. Comment 2: I recommend at least 4 years (e.g., 2015) given the expense of a variety of cage size and housing requirements that are being required at a time of great financial difficulty for research institutions.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals