f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 436 [Entry Date] 04/22/2011 at 03:02:13 PM [Affiliation] Self [Organization City and State] Philadelphia, PA [Comments] 
Comment 1: The 8th edition departs significantly from the 7th,,which has served us well since 1996. Of particular concern is the extent to which the 8th edition introduces new policies that go beyond the earlier edition. Many of these new policies constrain the exercise of scientific and professional judgment and add significantly to the paperwork burden for investigators and IACUCs. Many of these will result in higher costs to grants and to institutions. I am against adopting the the 8th addition of the Guide. Comment 2: The 2011 Guide represents a significant "guidance document," as defined by the Office of Management and Budget which "may reasonably be anticipated to lead to an annual effect on the economy of $100 million or more. . ." Therefore, a meaningful opportunity to comment in greater detail on the substance of the new Guide and its financial consequences is necessary before a decision on Guide adoption and implementation strategy can be made.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals