f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 509 [Entry Date] 04/26/2011 at 10:48:52 AM [Affiliation] Self [Comments] 
Comment 1: Given the many and significant changes in the Guide, I believe it is premature to adopt this 8th edition without more opportunity for consideration, comment and revision. I am a former member of ILAR Council and have served on a variety of ILAR committees, including the committee that produced the 1996 Guide. Accordingly, I have both experience and perspective on this matter. Rather than a set of guidelines, the 8th edition is highly prescriptive with significantly increased directives that will increase the burden on researchers, IACUCs and animal care staff and administration without evidence that animal welfare will be improved. I am very disappointed in this ILAR product, which seems to have ignored the principle of evidence as a basis for moving forward. Comment 2: The changes, directives and significantly increased "should" and "must" in the new Guide make it unreasonable to implement it without further comment and consideration, which will certainly not be completed in a timely and careful way any too soon. In my opinion, because of the many new 'required' changes and including imposition of engineering standards for new cage sizes,the current Guide should be the basis of continuing oversight rather than implementing a flawed and imperfect new Guide.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals