f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 7 [Entry Date] 02/28/2011 at 03:14:47 PM [Affiliation] Self [Comments] 
Comment 1: The new Guide was based largely upon perception rather than science. Several things in the guide are actually harmful to animals. For example the group housing is the default for all species. This is contraindicated in a number of conditions. Rabbits fight when housed together. Large animals, such as pigs, when group housed post surgically will cannibalize less dominant pigs if the incision is bloody. For behavioral studies rodents have changed behavior when group housed. There is not any scientific evidence that changing the height of rabbit cages from 15 to 16 inches has any positive effect on animal welfare. The new guide is voluminous and will require a great deal of effort on the part of the research community to determine how to be in compliance with the numerous vague sections. This guide should be thoroughly reviewed and rewritten from its present form and content. Comment 2: I do not believe that institutions will be able to even determine proper procedures and protocols for reviewing facilities under the new guide within a year. Several organizations such as AAALAC and AALAS have been struggling to make comparisons and develop guidelines for compliance since last summer. There are not any training programs scheduled to train institutions in compliance issues with the new standards.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals