f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 168 [Entry Date] 04/19/2011 at 11:48:50 AM [Affiliation] Self [Comments] 
Comment 1: No, NIH should not adopt the eighth edition of the Guide. Although this edition was intended to be an update of the 1996 Guide, the final product is twice as long and contains a great deal of new policy, suggesting that the eighth edition of the Guide is more than an update. Compliance with new policy statements will increase expense to institutions (e.g., cage size) and to investigators (e.g., drugs). Importantly, scientific data supporting the need for these changes do not exist; thus, the additional expense to institutions and investigators will be incurred with no real enhancement of animal welfare. Some specific examples include constraints on multiple procedures and multiple surgeries in an individual animal, new requirements for food- or fluid-restriction, significant constraints on choices of "chemicals and other substances" given to animals, and specific guidance on "post-approval" monitoring (e.g., observation of procedures). Adoption of the eighth edition of the Guide will substantially increase in paperwork burden (i.e., all deviations from "should" statements contained in the new Guide will need to be justified) and negate the opportunity to diminish the burden resulting from over reactions to issues that are already "overregulated" by institutions. Moreover, policies in the new Guide will dramatically increase infringement on scientific decision-making by PHS grantees, contractors and IRGs. Comment 2: OLAW should require institutional compliance with the eighth edition of the Guide no sooner than March, 2015 to allow for the collection of relevant data, which should guide all 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