f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 464 [Entry Date] 04/23/2011 at 05:56:40 PM [Affiliation] Self [Comments] 
Comment 1: I do not think that NIH should adopt the 8th edition of the Guide because of numerous controversial items and obvious inconsistencies. Additional time is needed to allow for commentary from the scientific community and the resulting editing of the 8th edition that will result from such commentary. Just one example of the problems associated with the 8th edition of the guide are the substantial increase in costs to conduct basic research that will result. These increases will be seen on both the researcher and oversight sides of the overall research enterprise. Given the current global economic climate, oversight committees related to animal research should be trying to identify ways in which research can be done in a less expensive manner while still protecting the health and safety of the animals. Furthermore, many of the proposed changes related to repeated testing and multiple surgical procedures will result in increased animal usage which is absolutely contrary to the mission that many researchers have engaged in for their entire careers (i.e., the attempt of researchers to reduce the number of animals used while still maintaining statistical power for their data analysis). Comment 2: I do not think that the first inspection for which researchers will be accountable to the standards of the 8th edition of the Guide should occur by 3/31/2012. Given that researchers do not have the ability to modify their budgets to accommodate a situation, such as this, that will alter the way in which they conduct research by adding considerable expenses, I believe that if the Guide is adopted, the first inspection utilizing the Guide should not occur for at least 5 years given that the typical duration of an R01 is 5 years.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals