f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 61 [Entry Date] 04/14/2011 at 03:24:55 PM [Affiliation] Organization [Organization Name] Drexel University College of Medicine [Organization City and State] Philadelphia, PA [Comments] 
Comment 1: The eighth edition of the Guide should NOT replace the 1996 edition. The sheer burden of many of the proposed modifications do nothing to increase the care, use and welfare of laboratory animasls and add substantial expenses to both the institution and to the individual investigator. In a time of severely diminishing budgets for research, in a time of substantial cuts to academic institutions, these proposed changes will only further diminish our competitive stance in the healthcare community, will impact on the discovery of new drugs and will further debilitate our younger scientists - all without any derived benefit to the laboratory animals that are so vital - and so adequately cared for under the present guidelines - to our research enterprise. Finally, I wish to comment on the proposed modification on the use of "nonpharmaceutical grade" drugs. THere is virtually no evidence whatsoever, that using pharmaceutical grade drugs would improve animal welfare or science. This is another instance of an attempt to implement a strategy that, on the surface may sound reasonable but, in reality, is completely without benefit to animal welfare. Moreover, the costs incurred are substantial - again, reducing funds available for meaningful research, delaying productivity and increasing the burden of extraneous activity to our investigators. Comment 2: OLAW should require any institutional compliance with the new Guide not sooner than 2015.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals