f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 277 [Entry Date] 04/20/2011 at 02:50:05 PM [Affiliation] Self [Comments] 
Comment 1: The major shortcoming of the new Guide is the lack of empirical data to justify the additional expenses that will be incurred by principle investigators (PIs) and their institutions to accommodate the proposed new changes. The chapter on veterinary care (Chapter 4 in the proposed new Guide) is no exception. In general, the proposed new changes clearly mandate increased consultation and oversight of veterinarians, beyond what the 1996 Guide required. In and of itself, increased veterinarian oversight of all aspects of care and use of animals may, indeed, be a good thing. However, the questions that are not addressed are why, and at what cost? Would hiring more veterinarians for consultation and supervision significantly increase animal care at institutions that are following the 1996 Guide? Is it worth the additional costs for PIs and institutions to employ this extra supervision, if they are experiencing no problems and if their IACUCs are satisfied with the present care and use of animals at their institution's facilities? Perhaps some institutions can afford this, but there are many others that are on the brink of closing their animal facilities because of the escalating costs, and the educational, societal, and economic impact these closings could have may far outweigh whatever unspecified shortcomings the proposed new guidelines have been created to address. The proposed new Guide (Ch 2, page 14) makes the attending veterinarian (AV) responsible for all animal care and welfare. If an IACUC interprets this strictly, they may decide to mandate the hiring of a full-time AV, which may be prohibitively costly for some institutions. The proposed new Guide also puts more emphasis on the role of the AV in reviewing the health status of animals from non-commercial sources (Ch 4, page 108), selecting anesthetics and analgesics (Ch 4, pages 116 and 121), use of neuromuscular drugs (Ch 4, pages 122-123), and standard methods of euthanasia (Ch 4, pages 124). Although few would object to having more AV involvement in animal care and use, there are no data to indicate that these changes are necessary, nor were any cost/benefit analyses for mandating such changes cited. Is the current AV oversight role insufficient for appropriate animal care? Haven't the trained animal care technicians, PIs, and the institutional IACUCs, who have been responsible for much of this monitoring of animal care during the past 30 years, been doing an adequate job? The cost burden of increasing the involvement of an AV may be too high for some institutions to continue to conduct animal research, and it seems grossly unfair to impose this on institutions whose animal care programs have been functioning extremely well under the present guidelines, when there is no evidence to indicate that many of the changes in the new proposed Guide is needed at all, let alone if they will result in a significant improvement to the welfare of the animals at these institutions. Comment 2: First, I do not see a need for this proposednew Guide. Is there a report or data that suggests that the existing Guide is not adequately protecting the welfare of laboratory animals? Is the added costs and burdens of the proposed new Guide resolving some problem of which many of us have not been notified? Adopting the proposed new Guide in time for inspections by March 31, 2012 is an excellent example of how out of touch the beauracracy is concerning the issues researchers using animals are facing. It is unreasonable to impose these measures in such a short time frame. It is especially onerous considering that most of the new stipulations are unncessary, restrictive, and costly. At the very least, a thorough cost/benefit analysis for implementing the new Guide should be mandated BEFORE any suggestion of an adoption date be forwarded.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals