f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 265 [Entry Date] 04/20/2011 at 01:29:20 PM [Affiliation] Self [Comments] 
Comment 1: NO. The new guide contains a great deal of new "policy", in which compliance with these new "policy" statements may increase the expense to institutions and investigators (e.g., drugs). However, the scientific data justifying these expense changes is non-existent. Adherence to the 2011 Guide will require large increase in paperwork burden. 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." 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. Comment 2: OLAW should require institutional compliance with the new Guide at a much later date to allow for the collection of relevant data. It is the data that should guide policy decisions.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals