f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 250 [Entry Date] 04/20/2011 at 11:48:08 AM [Affiliation] Self [Comments] 
Comment 1: The revised version of the Guide should NOT be approved in its present form. The new Guide, supposedly an update, is now twice as long and contains a great deal of new, highly-biased "policy." Compliance with these new mandates will do little for animal welfare but at the same time it will increase the expense to institutions (e.g., cage size) and the expense to investigators (e.g., drugs). Even worse, there are NO data to support any of these unfunded mandates. Adherence to the proposed Guide will unduly increase the paperwork burden since any deviations from "should" statements require justification ad infinitum. Moreover, the new "Guide" policies increased infringement on scientific decision-making by PHS grantees, contractors and IRGs. 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 (thus INCREASING the number of animals in an experiment), 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). Comment 2: Be serious....OLAW should require institutional compliance with the new Guide no sooner than March, 2015 to allow for the collection of relevant data on the validity of the plethora of regulations. It is the data that should guide policy decisions, not highly-biased anti-vivisection extremists.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals