f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 324 [Entry Date] 04/21/2011 at 11:07:45 AM [Affiliation] Self [Comments] 
Comment 1: I feel that the guide should not be accepted in its present form. I specifically have issues with the non-pharmaceutical grade drug policy. There is no reliable data suggesting that the mandated use of pharmaceutical grade drugs (PGD) will increase the health or welfare of research animals. The use of PGDs will have several negative consequences. 1) needless expense, there are huge differences in the cost of PGD vs chemically pure versions of the same drug. Cost is a major issue in view of the diminishing research dollars that are provided at taxpayers expense. Pure cost-benefit analysis alone makes this a ridiculous policy. 2)PGDs are less readily available. The commercial formulations of PGDs make precise and accurate pharmacological studies (dose-response, toxicology) very difficult because of the inactive and active ingredients, difficulties in dilution, administration, compounding etc. 3) New/experimental compounds are not PGD, the time and bureaucratic expense of documenting and justifying non PGDs in unnecessary and unwarranted and does not provide any benefit to the animals involved.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals