f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 253 [Entry Date] 04/20/2011 at 12:04:36 PM [Affiliation] Self [Organization Name] University of Arkansas for Medical Sciences [Organization City and State] Little Rock, AR [Comments] 
Comment 1: NO. The new guide was originally supposed to be an "update" of the 1996 Guide, however the final product is twice as long and contains a great deal of new "policy." Compliance with these new "policy" statements are likely to increase the expense to institutions, particularly in implementing new cage size limits; as well as expense to investigators to pay for increased cages. Investigators will also need to purchase drugs at increased costs to meet the new regulations. In neither case is there any scientific data justifying these new regulations. Without data showing that current guidelines are inadequate, there is little basis for changing them. Adherence to the 2011 Guide will require large increase in paperwork burden (all deviations from "should" statements contained in the new Guide will need to be justified). Adoption of the new guide may also negate the opportunity to diminish the burden resulting from over reactions to issues for which institutions already have "overregulated." The policy changes implemented by the new Guide will result in significant additional expenses to the institution and the investigator with no real enhancement of animal welfare. Some specific examples include constraints on multiple procedures in animals, constraints on multiple surgeries (per se), new requirements for food- or fluid-restriction, naïve and constraining section on choices of "chemicals and other substances" to give animals and specific guidance on "post-approval" monitoring (e.g., observation of procedures). In addition the new "Guide" requires an increased level of intra and post-operative surgical procedures. Comment 2: OLAW should require institutional compliance with the new Guide no sooner than March, 2015 to allow for the collection of relevant data to justify the new regulations. Without data showing that current guidelines are inadequate, the new regulations are questionable at best.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals