f6098d8b__and_Use_of_Laboratory_Animals__Comments
[ID] 411 [Entry Date] 04/22/2011 at 10:32:28 AM [Affiliation] Self [Organization Name] Virginia Commonwealth University [Organization City and State] Richmond, VA 23298 [Comments] 
Comment 1: Many of the "guidelines," which usually end up becoming mandates by regulatory bodies, interfere with the conduct of research without enhancing or even harming the well-being of the animal subjects. Two examples follow: Page 56: "Floor space taken up by food bowls, water containers, litter boxes, and enrichment devices (e.g., novel objects, toys, foraging devices) should not be considered part of the floor space." This does not into consideration that the animal can walk or climb on or through the enrichment device or carry it around (paper cups, cardboard tubes). These new standards could greatly restrict research where space is at a premium and will require employing personnel who police this. Page 119: "Careful monitoring increases the likelihood of successful surgical outcomes (Kuhlman, 2008). Monitoring includes routine evaluation of anesthetic depth and physiologic functions and conditions, such as body temperature, cardiac and respiratory rates and pattern (Flegal et al. 2009), and blood pressure (Kuhlman 2008), and should be appropriately documented." I completely disagree with this statement. In rodents, successful surgical outcomes are best assured by clean, efficient surgeries that do not require supplemental anesthetic or longer exposure to gas anesthesia than necessary. Not only is it difficult to measure these physiological signs in rodents, doing so requires distraction from the surgery that increases anesthetic exposure and encourages break from aseptic technique. In surgeries involving pregnant or immature rodents it is especially important to limit the duration of the surgical procedure, as this will limit the overall exposure of the immature brain to anesthetic agents, which are known to adversely impact the developing nervous system (for a review, see Wang and Slikker, Anesthesia and Analgesia, 106: 1643, 2008).
Listing of Public Comments on Proposed Adoption and Implementation of the Eighth Edition of the Guide for the Care and Use of Laboratory Animals