f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 48 [Entry Date] 03/25/2011 at 08:23:35 AM [Affiliation] Self [Comments] 
Comment 1: *REVISED* Comments on Laboratory Animal Welfare: Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals Submitted for the record by Roscoe G. Bartlett Member of Congress Sixth District of Maryland I would like to highlight the concerns I have of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals. The University of Maryland, School of Medicine and a small business located in my district, Spring Valley Laboratories, have contacted me regarding the proposed new laboratory guidelines. Addressing the complete set of guidelines Louis DeTolla, V.M.D.,Ph.D.,DACLAM of the University of Maryland, School of Medicine states that, "There are no deficiencies in the currently used 7th Edition of the Guide, so its continued use fully supports animal welfare, best practices, and quality biomedical research. The proposed changes to the Guide in the 8th Edition are not supported by data that demonstrate any improvement in scientific outcome of animal studies or benefits in animal welfare as a result of these changes." Specifically, I am concerned that the costs to academia and small businesses do not justify the negligible benefits to the laboratory animals regarding cage sizes. The additional size requirements (i.e. increasing the height requirement for rabbit cages from 14" to 16") will be very costly to labs and small businesses. For example, the cost to the University of Maryland would be $230,000 to replace existing caging. The impact to Spring Valley Laboratories will be more profound. The dollar cost could be as much as $400,000 but final result of these regulations could drive them out of business. As you grapple with developing new guidelines, please consider the following: 1. The Regulatory Flexibility Act of 1980 (amended in 1996) requires that the rulemaking process include cost/benefit analysis of new regulation to small businesses. In this case, the cage size increases compared to the reductions in the amount of money available for advances in medical research and the cost of jobs; 2. The size of the animal in relation to the newly proposed cage size (for example all rabbits are not the same size); 3. A plan to grant exemptions to the Eight Edition guidelines for institutions and businesses with existing cages which meet the specifications of the Seventh Edition of the Guide for the Care and Use of Laboratory Animals. *** Comment 2: *REVISED* Comments on Laboratory Animal Welfare: Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals Submitted for the record by Roscoe G. Bartlett Member of Congress Sixth District of Maryland I would like to highlight the concerns I have of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals. The University of Maryland, School of Medicine and a small business located in my district, Spring Valley Laboratories, have contacted me regarding the proposed new laboratory guidelines. Addressing the complete set of guidelines Louis DeTolla, V.M.D.,Ph.D.,DACLAM of the University of Maryland, School of Medicine states that, "There are no deficiencies in the currently used 7th Edition of the Guide, so its continued use fully supports animal welfare, best practices, and quality biomedical research. The proposed changes to the Guide in the 8th Edition are not supported by data that demonstrate any improvement in scientific outcome of animal studies or benefits in animal welfare as a result of these changes." Specifically, I am concerned that the costs to academia and small businesses do not justify the negligible benefits to the laboratory animals regarding cage sizes. The additional size requirements (i.e. increasing the height requirement for rabbit cages from 14" to 16") will be very costly to labs and small businesses. For example, the cost to the University of Maryland would be $230,000 to replace existing caging. The impact to Spring Valley Laboratories will be more profound. The dollar cost could be as much as $400,000 but final result of these regulations could drive them out of business. As you grapple with developing new guidelines, please consider the following: 1. The Regulatory Flexibility Act of 1980 (amended in 1996) requires that the rulemaking process include cost/benefit analysis of new regulation to small businesses. In this case, the cage size increases compared to the reductions in the amount of money available for advances in medical research and the cost of jobs; 2. The size of the animal in relation to the newly proposed cage size (for example all rabbits are not the same size); 3. A plan to grant exemptions to the Eight Edition guidelines for institutions and businesses with existing cages which meet the specifications of the Seventh Edition of the Guide for the Care and Use of Laboratory Animals. ***
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals