f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 505 [Entry Date] 04/25/2011 at 03:51:15 PM [Affiliation] Organization [Organization Name] University of Utah [Organization City and State] Salt Lake City, UT [Comments] 
Comment 1: No it should not. It is not clear what the basis is for the extensive list of revisions made in this Guide. As per the report (NOT-OD-07-016) issued by the working group convened in 2006 to evaluate public comment in reply to the request (NOT-OD-06-011) for such comment on updating the animal welfare standards in the guide. Given the recommendations of that working group (NOT-OD-07-016), the justification for the extensive revisions made in the current Guide is unfounded. In addition to making changes/revisions beyond those put forth by the working group as reflecting the public comment submitted at that time, the new Guide clearly goes beyond the traditional role of the Guide to serve as that--a guide for institutions, verterinarians, and scientific investigators to use to promote animal welfare. Rather, it contains new policies and requirements that will necessitate considerable burdens in terms of financial and paperwork requirements and restrictions on research design and the exercise of scientific judgement on the part of federally supported investigators and institutions. These burdens are being put in place with absolutely no apparent documentation supporting the contention that implementation of such policies will promote animal welfare. Comment 2: First, as noted above, the 8th edition as currently written should NOT be adopted for the reasons noted above. However, if it is adopted, given the considerable financial and paperwork burden it will impose on individual investigators and institutions, the date for required institutional compliance should be NO EARLIER than March, 2015. In the meantime, data supporting the policy revisions to be required should be collected by the NIH to justify the proposed changes.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals