f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 400 [Entry Date] 04/22/2011 at 07:14:08 AM [Affiliation] Organization [Organization Name] The Jackson Laboratory [Organization City and State] Bar Harbor, Maine [Comments] 
Comment 1: The Jackson Laboratory has long worked successfully through our IACUC to ensure appropriate implementation of the provisions of the Guide to safeguard animal welfare at our facility. The updated (8th edition) Guide contains some areas of concern. Previous comment opportunities on the new Guide pre-dated the availability of a published document. Now that it is in print, The Jackson Laboratory supports opening a comment period prior to OLAW adopting the updated Guide. Specifically, we support the use of performance standards rather than strict engineering standards as the best means of achieving optimal animal welfare within the unique environments of different institutions. The new guidelines as written could have unintended effects on research, and potentially on animal welfare. An example is the new space requirements for female mice with litters. The IACUCs are in the best position to develop appropriate performance standards, and we believe they should retain the flexibility that now allows them to make responsible animal welfare decisions at the institutional level. The fiscal impacts of the updated Guide could, depending on how the document is categorized for implementation purposes, have a major economic impact on biomedical research institutions throughout the country. For these reasons we respectfully request a more substantive opportunity for comment.
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals