f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 131 [Entry Date] 04/18/2011 at 11:42:52 AM [Affiliation] Self [Comments] 
Comment 1: I have a several concerns regarding the proposed new (8th) edition of the Guide, but my comments below are specifically limited to two of the guidelines on Food and Fluid Regulation (pp 30-31). 1. The proposed Guide states that "The objective… …should be to use the least [food and/or fluid] restriction necessary to achieve the scientific objective while maintaining animal well-being" (pp. 30-31). This view runs counter to both good science and established animal husbandry and care practice. First, as noted in the publications cited in this section of the Guide, there is little or no evidence that moderate restriction protocols (e.g., in rodents, to 80-85% of free feeding weight for food restriction, or 24 hours for fluid restriction) have any adverse consequences under most circumstances. Second, some degree of food restriction or limitation is common practice for most laboratory species (e.g. – rabbits, dogs, primates), not to mention for pets and zoo animals. Indeed, the absence of any sort of restriction seems only to be usual practice with laboratory mice and rats, for which free feeding seems to have developed as a matter of convenience for husbandry staff. Third, there is ample scientific evidence across multiple species that long-term food restriction (e.g. – to 80-85% of free-feeding weight in rodents) confers significant health benefits, including longer life-span, fewer age-related diseases, and fewer neoplasms. In fact, even the Guide itself (Chapter 3, p. 67) describes the health benefits (even in mice and rats) of moderate caloric restriction. Hence, based upon the work cited in the Guide itself, there appears to be no scientific evidence for (and ample scientific evidence against) the apparent assumption that any degree of restriction is negative. 2. The proposed Guide states that "In the case of conditioned-response research protocols, use of a highly preferred food or fluid as positive reinforcement, instead of restriction, is recommended" (pp. 30-31). This recommendation, although admirable in theory, runs counter to decades of scientific research and practice, which show that animals will rarely if ever learn and perform food- or fluid-motivated behaviors in the absence of some degree of restriction. This point is made strongly in two of the publications cited in this section of the Guide (Toth and Gardiner 2000; Rowland 2007). More practically, however, one could infer the fact that highly palatable foods or fluids are not effective motivational tools for behavioral studies in the absence of restriction simply from the fact that they are not used. Food/fluid restriction procedures are time-consuming and add additional administrative burdens, both of which drive up the costs of conducting research. If it were at all possible to avoid restriction procedures when conducting behavioral experiments in animals, then they would be avoided.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals