f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 459 [Entry Date] 04/23/2011 at 12:27:16 PM [Affiliation] Self [Comments] 
Comment 1: I echo the concerns of my colleagues over the increased regulatory burden caused by the new version, without adequate justification. Many of these new policies constrain the exercise of scientific and professional judgment and add significantly to the paperwork burden for investigators and IACUCs. Many of these will result in higher costs to grants and to institutions. Most significantly, Restrictions against using animals in multiple procedures surely increases the number of animals needed. This goes in the wrong direction, in that logic would dictate that it is most ethical to reduce the numbers of animals used in research. Mandatory requirements for new cage sizes for rodent breeding will require large expenditures, which is not adequately justified. In summary, I recommend that the NIH not adopt the eighth edition of the Guide for the Care and Use of Laboratory Animals (Guide) as a basis for evaluation of institutional programs. Comment 2: Given the concerns outlined above, an opportunity to comment in greater detail on the substance of the new Guide and its financial consequences is necessary before a decision on Guide adoption and implementation strategy can be made.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals