f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 256 [Entry Date] 04/20/2011 at 12:14:57 PM [Affiliation] Self [Comments] 
Comment 1: I do NOT think the New 2011 Guide should be adopted in its present form. I have listed my concerns below: 1) The use of non pharmaceutical grade chemicals (page 31). What had previously been restricted to anesthetic and analgesic agents, because of the language, could now theoretically be applied to ALL chemicals we administer to our subjects. This will dramatically increase the cost of resaerch without any scietific justification for this new requirement. 2) Food and water restriction and the level of monitoring of these animals that will be required (page 30). No distinction appears to be made between the monitoring required regardless of whether the subjects are food restricted OR fluid restricted. In other words, the language reads that daily food and water consumption and hydration must be monitored for both types of restrictions. Again - what is the scientific justification for these chagnes and if implemented this new requirement will greatly increase the record keeping requirements. 3) Cage sizes - particularly for breeding animals. Basically, there is room only for a mouse dam and litter, no harem breeding. For rats, I do not believe that many single cages are large enough for the dam and pups (ventilated rack cages are definitely not large enough), it will require oversized cages. These issues bring up concerns about additional costs and crowding in our already overcrowded facilities. 4) While many of the changes are listed as "should"s versus "must"s there is also a great deal of concern about OLAW's distinction between the two with several people saying that while the "Guide" makes the distinction OLAW does not. I also feel that while AALAC and many IACUC committees will take a reasonable approach regarding "must"s and "shold"s in the new Guide, I am concerned that outside animal activist groups will simply use these changes as addditonal "weapons" to impede research - perhaps by filing lawsuits to "enforce" these new regulations as THEY (or the courts) interpret them.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals