f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 409 [Entry Date] 04/22/2011 at 10:14:20 AM [Affiliation] Self [Comments] 
Comment 1: As an investigator at a primarily undergraduate institution, I have serious concerns about the new restrictions and costs that adopting the new Guide will impose upon researchers. This guide was clearly intended for large, research-first institutions that have many animal colonies overseen by professional staff, and that have adequate institutional or grant funding to incur additional administrative costs. Of particular concern to me is that these guidelines will make it prohibitively difficult for smaller institutions to establish and maintain quality research facilities. Many thousands of research laboratories exist at such institutions, and they are often capably staffed by the investigators themselves, not a professional staff. The animals under such care are not "warehoused" as they may be at other institutions, and receive careful, humane treatment and care under the current guidelines. The additional guidelines in the new version of The Guide will not change animal care at such institutions, but will mandate additional costs that could jeapordize the willingness of administration to have animal colonies on campus. Is there data to indicate that the Guide needs changing? What is that data? If the guide is adopted, it could mean the end of research for many investigators, thus taking away the opportunites for undergraduate students who want to pursue a career in the biomedical sciences. My fear is that the additional costs and paperwork required by the new guide will be unduly burdensome, especially for those institutions that teach undergraduates and have limited funds. Comment 2: The additional burdens placed on researchers and institutions by implementing this guide could mean the end of research for many investigators, especially at smaller, primarily undergraduate institutions where support for animal research facilities is not as strong as "research-first" institutions. This would mean taking away the opportunites for undergraduate students interested in the biomedical sciences. My fear is that the additional costs and paperwork required by the new guide will be unduly burdensome, especially for those institutions that teach undergraduates and have limited funds.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals