f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 530 [Entry Date] 04/28/2011 at 02:29:30 AM [Affiliation] Organization [Organization Name] Cascades Biosciences Consultants, Inc [Organization City and State] Sisters, Oregon [Comments] 
Comment 1: The eighth Guide adds unnecessary administrative burdens, regulatory compliances, and substantial capital costs for caging of rabbits, breeder rodents, and primates. The seventh edition of the Guide has proven well in advancing animal care, welfare, and support for animals in research. Edition 8 falls short on concrete evidence of improving animal welfare. It discourages investigators who are dedicated with improving animal welfare and advancement in science. An economic impact document is needed The Guide is a USA regulatory document since it is cited by the US Public Health Service Policy authorized by HHS Law. In this sense, a legitimate question is raised as why 4 of the 14 ILAR committee members were not US Citizens. Comment 2: The 8th edition must not be adopted. In essence, a new committee is needed if an 8th edition is deemed necessary by the Institutes of Medicine, NAS.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals