f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 50 [Entry Date] 03/25/2011 at 02:28:56 PM [Affiliation] Organization [Organization Name] American Farm Bureau Federation [Organization City and State] Washington, DC [Comments] 
Comment 1: American Farm Bureau Federation 600 Maryland Avenue SW Suite 1000W Washington, DC 20024 March 25, 2010 Office of Laboratory Animal Welfare Office of Extramural Research National Institutes of Health RKL1, Suite 360 6705 Rockledge Drive, Bethesda, MD Re: Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals As the organization representing the largest number of American livestock, dairy and poultry producers, the American Farm Bureau Federation has a deeply vested interest in ensuring that science-based principles are available to guide the proper care and treatment of animals in agricultural production. We appreciate the opportunity to comment on the proposed adoption and implementation of the January 2011 eighth edition of the Institute for Laboratory Animal Research (ILAR) Guide for the Care and Use of Laboratory Animals (ILAR Guide) as a basis for evaluation of institutional programs receiving Public Health Service support involving animals. After reviewing the updated guide, it has come to our attention that the document has many technical flaws related to agricultural animal care. Farm Bureau opposes the adoption by the National Institutes of Health (NIH) of the ILAR Guide as currently published. As we discussed with NIH representatives on Feb. 1, we agree with numerous scientific experts and animal science researchers that the ILAR Guide is flawed in its ethical position. Many of its elements are inconsistent with scientific recommendations for the care of farm animals. Perhaps most important, strict use of the guide would negatively impact animal care. Scientists that work in the field of large animal welfare have pointed out specific deficiencies in the requirements listed in the ILAR Guide for these animals' needs. Unscientific animal care guidelines pose a threat to animals as well as the producers and researchers responsible for their well-being. We are concerned that the adoption of inaccurate standards by NIH would harm agricultural animals in the care of the Public Health Service, and by precedent, animals in academic research and the private sector. This precedent is not only confusing but potentially dangerous, as it starts down the slippery slope of basing care standards on something other than science. In January 2010, the Federation of Animal Science Societies (FASS) published an updated Guide for the Care and Use of Agricultural Animals in Teaching and Research (Ag Guide). This document was written by 64 professionals with expertise in farm animal care and contains a wealth of substantive technical information about the care of farm animals in teaching or research (agricultural or biomedical). Unlike the ILAR Guide, the Ag Guide contains appropriate, tested and practical protocols for such criteria as sanitation protocols, air temperatures and floor space, to name just a few. All recommendations in the Ag Guide are based upon peer-reviewed research. The Ag Guide is the most scientifically valid, current resource document for agricultural animal care. We strongly urge NIH to adopt and recognize it as the sole reference for farm animal care. Sincerely, Mark Maslyn Executive Director Public Policy
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals