f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 391 [Entry Date] 04/21/2011 at 07:35:20 PM [Affiliation] Organization [Organization Name] Louisiana State University Health Sciences Center, [Organization City and State] New Orleans, LA [Comments] 
Comment 1: I am strongly opposed to these new guidelines as they would add an unwarranted burden to researchers using laboratory animals. If the NIH adopts the new guidelines presented in the 8th edition of the Guide for the Care and Use of Laboratory Animals, this will place an enormously increased burden upon researchers performing many types of animal experiments. For example, the guidelines suggest the use of pharmaceutical-grade chemicals (which, in the case of pentobarbital is approximately ten times the price of its non-pharmaceutical counterpart!). Although I feel it is extremely important for researchers to always be open to improvements in the care and use of laboratory animals, I was unable to find any references in the 8th edition to documentation of any specific deleterious effects (either scientific or regarding unnecessary animal suffering) arising from current guideline practices to justify these burdensome changes. Although the 8th edition guidelines do not completely preclude the use of non-pharmaceutical grade chemicals, their alternative suggestion was for researchers to give consideration to at least twelve different parameters for each chemical used, without providing specific justification for each parameter. I am very concerned that this list would leave investigators open to an extremely burdensome justification process that, as noted above, I consider to be unwarranted.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals