f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 292 [Entry Date] 04/20/2011 at 04:18:17 PM [Affiliation] Organization [Organization Name] Lycoming College [Organization City and State] Williamsport, PA [Comments] 
Comment 1: I am writing as the chair of the Animal Care and Use Committe, and as a small animal researcher at Lycoming College, a small, exclusivley undergraduate, private liberal arts and sciences college in northcentral Pennsylvania. I have grave concerns over the proposed changes to the GCULA. First, there is no justification provided as to why the GCULA needed updating: what problems with animal welfare are the proposed changes supposed to address? Second, there are no data provided indicating the the proposed changes will in fact improve animal welfare significantly. Third, and most ominously, the added burden on small institutions such as Lycoming College, in terms of time, space, and money, is significantly increased by the proposed GCULA changes. If the changes are passed, it may no longer be feasible to conduct publishable animal research or provide animal research training for undergraduates at small institutions such as Lycoming College. I share these concerns with other faculty at small undergraduate institutions through my service as a Counselor with the Faculty for Undergraduate Neuroscience. We believe the current (7th) version of the GCULA serves the animals, the students, the colleges, and the nation's biomedical research enterprise quite well. We also believe that any significant changes to the GCULA must be justified by scientific data, which are lacking in this proposal. Moreover, we believe that the impact of changes on the nation's education and research infrastructure must be studied and taken into consideration before any changes are enacted. Comment 2: The proposed requirement for semiannual program and facility evaluation represents a significant burden for small undergraduate colleges. Who will pay for this review, which goes above and beyond what our own IACUC already does? And what scientific benefits will come from forcing more frequent reviews and documentation? Many small colleges like my own already struggle to do their animal research training under their teaching budgets, not subsidized by large national-level grants that provide "overhead" to the administration to defray such bureaucratic expenses. Mandating annual reviews will result in fewer undergraduate colleges providing animal research training to their students. This would not be in the nation's best interests, or in the best interests of animal research itself. If such a requirement is instituted, at the very least, there must be some sort of mechanism for smaller institutions to do their reviews at a different interval from the large, nationally-funded ones. Otherwise, substantial damage to the training opportunities for undergraduates will be the result.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals