f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 355 [Entry Date] 04/21/2011 at 02:56:11 PM [Affiliation] Self [Comments] 
Comment 1: As a practicing scientist, I applaud the efforts to maintain the highest levels of care for animals in research. There are a number of specific concerns, however, with the latest version of the Guide. To begin with, the new Guide is nearly twice as long as the 1996 version, and contains a great deal of new policy that promises to significantly increase (a) the expense of research, (b) the paperwork burden on researchers, and (c) the authority of local IACUCs to restrict already peer-reviewed research. Some of the new recommendations are based on empirical research, but many are not (e.g., cage sizes, food and liquid restriction). There are no reasons to suspect that these additional burdensome and costly requirements would produce any improvement in animal care and welfare, although it would likely produce erosion in the quality of research and the number of top scientists working in areas that have significant benefits for both humans and animals. Researchers care deeply about their animal subjects, and the protection and care has served science and the animals well. There is little compelling reason to adopt new guidelines when those in the 1996 Guide continue to serve the community and the animals so well. Comment 2: If the 2011 Guide is adopted as PHS policy, then the deadline for full compliance that is proposed in the Federal Register is March 31, 2012. Such a date places extreme burden and excessive costs on institutions (including government funding). At least 4 years (e.g., 2015) seems not unreasonable given the expense of a variety of cage size and housing requirements at a time of great financial difficulty for research institutions.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals