f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 145 [Entry Date] 04/18/2011 at 03:15:50 PM [Affiliation] Self [Organization Name] University of Maryland School of Medicine [Organization City and State] Baltimore MD [Comments] 
Comment 1: I am writing regarding the Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals with specific reference to housing requirements for mice. I am fully supportive of maintaining animal health and well-being in a laboratory environment. However, it is not evident that the new guidelines that specify15 sq. in. of floor space per mouse have any basis in science or will in fact contribute to improved animal health and well being. In my institution each mouse cage has 63 sq.in. of floor space. Under the current guidelines that permit 5 mice per cage the proposed guidelines will restrict housing to 4 mice per cage and will only increase space per mouse by less than 20%. However, the increased costs of animal maintenance and facilities, in a time of reduced research funding will dramatically reduce the progress of research. Furthermore, it will have a negative impact on breeding of mice needed for research. Currently we use a breeding scenario in which two females are maintained with one male. This permits the females to share care of the pups, a situation especially critical when one of the females is a novice and needs to learn how to care for the pups. Otherwise there is significant loss of newborns. The new guidelines require that a female with litter would have to be housed individually, since there would only be 12 sq. in. remaining (63 sq in/cage – 51 sq in for mom with litter) – not "enough" space for a second adult mouse (which needs 15 sq in per these requirements). Thus, I would predict more loss of new-borns and, therefore, a situation that is not compatible with maintaining animal health and well-being that is the purported intent of the new guidelines. In addition, for a "standard" 2 female, one male breeding cage (which can currently remain together in a single cage as the females deliver pups and nurse them, and share care of the pups) this represents a > 200% increase in cages required over current standards with an associated increase in costs. For these reasons I am opposed to these new guidelines for mouse housing which: 1-have no basis in science and 2-do not promise an increase in animal health and well-being and 3-will result in significant cost increases at a time of reduced funding.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals