f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 69 [Entry Date] 04/14/2011 at 04:59:04 PM [Affiliation] Self [Organization City and State] Richmond VA [Comments] 
Comment 1: No--I recommend that NIH not adopt the New Guide. My rationale for this recommendation is based on multiple factors that include: -the financial and administrative cost of complying with new regulations and the resulting disruption in research -the burden of guidance to either use pharmaceutical grade chemicals or to justify not using them, despite a lack of evidence to suggest that pharmaceutical grade chemicals improve animal welfare or science -vague language subject to multiple interpretations on many issues such cage sizes, use of restraint, and use of food restriction Comment 2: Implementation should be delayed until at least March 2015. My rationale for this recommendation is based on my view of the extensive revisions promulgated by the New Guide and the extensive changes in research procedures, administrative procedures and infrastructure that will be required to comply with the New Guide.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals