f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 233 [Entry Date] 04/20/2011 at 09:59:28 AM [Affiliation] Self [Comments] 
Comment 1: I appreciate the focus of the new Guide remaining on performance standards rather than engineering standards. Having said that, there are a couple of items which appear to apply engineering standards in a manor which will have a signficant economic impact on the animal care program at the institution I am employed at. Specifically, the implied requirement to eliminate mouse harem breeding will significantly impact the requirement for ventilated mouse caging as well as impact the per diems needed to accomplish the aims of existing NIH grants since we charge for daily animal care by the mouse cage, not the individual mouse. Both of these items represent a signficant cost to our animal care program. We currently have 20,000 mouse cages, approximately half of which are breeding colony cages. The new Guide would double the number of cages needed for breeding colonies, representing an additional 71 ventilated racks of 140 cages each. The cost of this caging is currently $2.5 million for the 71 racks. The animal care budget of our existing NIH grant utilizing mouse breeding colonies would need approximately 2.6 million annually for the remainder period of the grant (10,000 cages x 0.72/cage x 365 days/yr) The estimated total direct economic impact at our institution would therefore be anywhere from $5.1M to $10.3M depending on the duration left on the grants. While this is a staggering amount when multiplied by the number of institutions that may be impacted, if there was scientific evidence to support this change, I would not object to the expense in the long run. HOWEVER, since there is NOT scientific evidence to support this change in mouse breeding cage space, I am not in favor of this guideline revision due to the significant negative economic impact it will have. Finally, it would appear that IACUC would no longer be able to approved programmatic exceptions to the Guide, but rather have to do that on an individual protocol basis. This too would appear to enhance the regulatory burden on the IACUC and decrease IACUC efficiency without benefit to the overall animal care and use program. I hope you will consider these two items and reword the 8th Guide document to relieve the economic and regulatory burden posed by this new edition when it would not enhance the animal care program in my professional opinion. Comment 2: Due to the economic impact of the new Guide as it applies to rodent breeding cage density, it is not feasible to obtain the funding or the caging in time to meet the March 2012 timeframe of implementation.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals