f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 138 [Entry Date] 04/18/2011 at 01:40:10 PM [Affiliation] Self [Comments] 
Comment 1: I have been a veterinarian for 25 years working in private practice, then becoming an emergency medicine clinician for 16 years and have now worked in laboratory medicine the past 7 years. I teach human handling classes, provide required veterinary reviews of animal use protocols for both our institution as well as for another institution and serve as a clinical veterinarian. During my time as a laboratory animal veterinarian, I feel I have been effective in improving researchers understanding that research animals are a small living environment rather than a petri-dish with legs. I have helped many understand that improvements in techniques, though some may take more time, are better for the animals well being or reduces their stress exposure and hence improve research efforts. I am a fervent believer in the application of the scientific method in that all practical efforts should be made to remove as many variables or subjective data related to determine accurate data related to the aims of the experiment. However I do not see or appreciate such scientific justifications for the proposed changes in the new GUIDE. There is apparent lack of logic in some of the changes proposed, such as the requirement in rabbit cage height. As written, thousands of cages would no longer be useable per the new requirement. If a scientific basis is provided to make such a change in additional height, it would be logical to set a weight value (or rump to head length measurement) to determine when larger cages are required to be used, just a mass value is assigned to caging for use with NHPs. This would allow many the current cages (most purchased with taxpayers dollars) to be used for rabbits smaller than the cut off weight for new height requirement. It is wonderful to consider changes for the well being of animals, but we should not do them based on personal opinions alone but rather based on scientifically proven benefit to animals health or well being ( given as they are used scientifically, this would be logical). If such changes as proposed in the Current Draft, are finally approved by PHS, a logical grace period should be given 1) Based on the current economic environment of our nation there are no magic dollars to make required changes rapidly for many institutions unless PHS plans to provide needed grants. 2) Changes may require more than just acquisition of 'new caging' but include major physical plant changes, new housing rooms be built, HVAC upgrades to meet human and animal health exposure requirements, none of which can be accomplished rapidly or often requireing over a year to implement. If the panel that reviewed/ updated the new GUIDE can provide me with scientific data for the proposed changes, I would be happy to re-consider my stated views, otherwise let us not burden the taxpayer with changes that only make people 'feel better' as to the use of animals but provide no scientific benefit to the health or well being of those animals. Comment 2: As stated in my response to the prior section, many faclilities may require physical plant upgrades not just the purchase of new cages, hence if the draft of the NEW GUIDE is approved, I would suggest 2 year grace period before full implementation of the 'New GUIDES" requirements would be more logical given the current economic status of our country, unless PHS if willing to provide needed funding for any such neeeded facilities changes.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals