f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 460 [Entry Date] 04/23/2011 at 12:42:42 PM [Affiliation] Self [Comments] 
Comment 1: This current effort that seems largely driven by the unwarranted notion that somehow dire change is needed, while insufficient evidences are offered supporting this status, is frankly frustrating. Once again, caring scientists who treat animals with the utmost respect are being characterized unfairly in a manner opposite to the evidence. What is missing, it seems to me, is a healthy dose of reasonableness that slips right out the window once bureaucratic mandates come down on the scientific community. Already, decisions about research progress are being made for researchers by veterinarians using simplistic and presumptive rules of thumb regarding pain management, animal housing requirements, feeding restrictions, drug use, and general items of care while the contrary evidence is scoffed at. Why listen to the collected wisdom of researchers who have worked with animals in the very conditions they propose for years when presumptions can be made that seem reasonable based on whether a human being "might" be uncomfortable under similar conditions? How has the value of simply observing animals in the conditions proposed to see if any signs of distress arise been so thoroughly demoted? Mostly, the rapport that doctoral and medical practitioners once had with the veterinary staff, which used to be one of mutual support of the goals related to animal research, seems to be eroding into increasing challenges, terribly long deliberations, and the minutia of paperwork that is already having a significantly diminishing impact on research progress. This seems totally backwards. People within the business of preclinical research who we would all think would want to help promote it, are consistently disrupting it by introducing stronger arm legislation such as what is easily found throughout this document. There are obvious cases during the course of some more invasive research where social housing makes absolutely no sense. When researchers can just explain this, and reasonable people are at the helm, easy accommodations can be made. There are also other obvious cases where certain analgesics will have an interfering effect on, and easily confound, research efforts even in protocols where no evidence for pain or distress have ever arisen... but the mandate precludes reasonableness. In my humble opinion, this is going to destroy the business of saving lives or improving human lives for no good reason. No good evidence for the increased burden this document represents has been put forward, and yet we are supposed to swallow it whole. A huge impact will result on the jobs of my fellow admirable human beings who simply wish to explore the principles of health at a reasonable and permissible cost. Smaller universities will not be able to bear the burden and excellent research programs that train our Americans and bring new minds into the field of biological health will be shut down. Comment 2: Implementing this plan onto the backs of any institution in its current form seems to be a recipe for an unbearable burden for many smaller universities. While it may be a decision worth discussing whether to simply eliminate the smaller players, this will come at a huge cost to progress in the science of medicine. Big institutions are already concerned, at a time when grant funding is becoming increasingly challenging to procure, about the bottom line that defines whether scholarly research should be a part of the program. Shuffling of positions while trying to bear the burden of all the extra paperwork and regulation, and being forced to purchase new housing when evidence that the older housing is insufficient is incredibly weak, and other of the mandated changes are implemented will be an unwarranted slap to institutions that are currently able to contribute to this area.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals