f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 260 [Entry Date] 04/20/2011 at 12:45:29 PM [Affiliation] Organization [Organization Name] Univeristy of California, San Diego [Organization City and State] La Jolla, CA [Comments] 
Comment 1: The 8th edition of the guide is flawed, and should not be adopted for a number of reasons. I will list the primary three: The first is a substantial increase in research costs due to the housing requirement changes, that have no scientific backing in terms of improving animal health over the current housing recommendations. The second is even more important, the requirement to use pharmaceutical grade drugs in research. Not only do very few commercially available preparations exist that are suitable as tools for experimental research, but also, commercial solutions themselves are subject to formulation errors, as evidenced by recent recalls. Even with solutions that may be useful for a particular project, the need to conduct dose-effect evaluations inevitably means the commercial solution would need to be diluted in the laboratory to accomplish this purpose. Third: by changing the already very rigourous recommendations of the guide yet again, the paperwork/implementation/regulatory burden that is created is astronomical. I am an IACUC member of my institution and the added burden of complying with the new recommendations (some of which are written in very vague or downright illogical manners) will be extensive on an already "tipped to the breaking point" group of scientists and administrators. Scientists already have to spend more and more time writing grants becuase of the reduced payline, more and more time on regulatory paperwork and administrative duties required by funding and other agencies, the time alloted to research and scientific discovery is shrinking continuously. The guide's consequences of reducing time devoted to research for no clearly defined benefit to the quality of research will only undermine further health care research, and does not support the NIH mission. Comment 2: Why, in a time of reduced funding to NIH are we requiring yet more time wasted from already incredibily burdened NIH and other institutional adminstrators and scientists? The amount of time spent already on protocol review, laboratory and vivarium inspections is more than enough to ensure proper animal care and handling in research. Animals in laboratories are the MOST well cared for animals on the planet. At this time, adding yet more contraints and regulations to research in the form of changing animal research guidlelines with no clear reason to do so at a time of 8% funding paylines does not seem logical or helpful. These changes will require NIH funded scientists to spend yet more time NOT on science but on paperwork, committees, and administrative reviews. This is, in my opinion, not the time for NIH to be focusing on poorly considered changes to animal regulations, but instead on things more important to the core NIH mission, which is conducting and supporting the best scientific research for improving human health.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals