f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 14 [Entry Date] 03/03/2011 at 10:50:48 AM [Affiliation] Self [Organization City and State] Denver, Colorado [Comments] 
Comment 1: There is an important issue with the proposed 8th Edition of the Guide for the Care and Use of Laboratory Animals on which OLAW seeks comment. On page 57 of "The Guide", Table 3.2 lists recommended minimum cage floor space per mouse. The only change from the 7th edition is that breeding triads are not allowed in standard shoebox (77sq. inches) cages because it is recommended that a single female with a litter should have at least 51 sq. inches of space. The maximum recommended number of adult (>25 g) mice per shoebox cage remains at 5. However, there is no scientific basis for these recommendations. In fact, the references cited by authors of "The Guide" on p. 58 argue, if anything, that for many strains, more mice can be housed per cage than the minimum currently recommended by the 7th edition. I enclosed some of these citations for your perusal. One of these shows that C57BL/6 mice, housed at 10 per shoebox cage, are as healthy as those housed at 5 per cage. Another reference provides evidence of anxiety disorder in mice that are not sufficiently crowed. Therefore, on the basis of the science cited by the authors of "The Guide", I believe that breeding triplets (one male and 2 females) should be allowed, and that the minimum floor space per mouse should be halved relative to that currently recommended by the 7th edition, with the usual footnote that more space may be required for some strains or in special circumstances. The cost of keeping a mouse colony has already reached an appalling level. I have a relatively small lab (6 people in total), and my research is based on genetically engineered mice. I routinely pay $5,000 to $7,000 a month for the mice. This is quite an absurd amount if you compare it to the average salary in the US. Implementing the space restriction recommended by the 8th Edition of the Guide would further increase the cost for mouse husbandry. The current NIH pay line for grant applications, in addition, is already significantly reducing the funds available to investigators with the risk that the scientific community is soon going to lose many genetically engineered mouse strains. I consider myself a very sensitive person regarding animal welfare issues. However, I really do not see any justification in the space limit recommendations of the 8th or even the 7th edition of the Guide. Thus, I recommend OLAW and AAALAC, and the scientific community not to implement the 8th Edition of the 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