f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 368 [Entry Date] 04/21/2011 at 04:27:53 PM [Affiliation] Organization [Organization Name] University of Virginia [Organization City and State] Charlottesville [Comments] 
Comment 1: I stand strongly AGAINST adoption of the new edition of the Guide. There is not adequate justification for supplanting the 1996 Guide as PHS Policy. There are also numerous problems with the new Guide as federal policy. In particular, I am opposed to the new guidelines for the use of medical grade compounds, newly introduced requirements for post-approval monitoring of IACUC-approved protocols and formal review of "unexpected outcomes". I also oppose the introduction of language cautioning against multiple survival surgical procedures per se on the same animal, in addition to cautioning against multiple major survival surgical procedures, as well as the section on "Food and Fluid Regulation" which requires that food and fluid consumption be recorded daily for all animals on either type of restriction. Each of these changes would force the use of more animals and/or drive up the research costs unnecessarily.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals