f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 37 [Entry Date] 03/13/2011 at 12:04:58 PM [Affiliation] Self [Comments] 
Comment 1: I have been involved in the care and use of laboratory animals since 1982 = 28 years. My comments with regard to the above question is: NO, the 8th edition of the Guide for the Care and Use of Laboratory Animals should NOT be adopted by OLAW. It was not properly reviewed according to standard Federal government procedures, so we do not know if all aspects of it are even legally defensible. Apparently no one bothered to even try to calculate the costs to the regulated entities of the mandated changes to animal cages (rabbit cages at least) is disingenuous and deceitful. The fact that the Director of NIH had to be the one to insist that proper procedures be followed (after he became aware of the added costs of adopting the 8th edition to just the intramural program - not to mention all the grant recipients) shows how flawed the whole process has been. In the current economy of universal budget cuts, now is NOT the time to require institutions to spend even MORE money to comply with new regulations. Stay with the 7th edition until the 8th edition can be made acceptable to the regulated entities and then only after following all standard Federal review processes, including a public comment period that is not limited to two questions and nothing else, should the 8th edition ever see the light of day again. Do NOT adopt the 8th edition until it can be done correctly, and do NOT adopt it when it increases financial burden on the regulated entities at a time of severe fiscal crisis. Miserable timing. Comment 2: This question assumes that the first question will be answered in the affirmative. This is very poor survey construction. My comment: NO = There should be NO implementation plan until the 8th edition can be re-written to be less burdensome and then properly routed for reviewed according to standard Federal government procedures. Go back to the drawing board, make the 8th edition LESS burdensome rather than MORE burdensome, and then go through the proper procedures to get it accepted by all before even considering adopting it. Do it right or don't do it at all!
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals