Created by on 4/22/2011 12:00:00 AM

On Thursday April 14th, FASEB submitted comments to both the National Institutes of Health (NIH) Office of Laboratory Animal Welfare (OLAW) and to the Association for the Assessment and Accreditation of Laboratory Animal Care International (AAALAC) on the eighth edition of the Guide for the Care and Use of Laboratory Animals (Guide). The Guide is a resource document that institutions use to ensure humane care and manage their animal use programs. Comments to NIH addressed two questions: 1) Should NIH adopt the new Guide as a basis for evaluation of institutional programs receiving or proposing to receive Public Health Service (PHS) support for activities involving animals? and 2) If NIH decides to adopt the eighth edition of the Guide, shouldthe agency use it as the basis for evaluation by March 31, 2012?
FASEB recommended that NIH indeed adopt the Guide; however, the endorsement came with two caveats. The first caveat was that NIH should place greater emphasis on performance based standards rather than engineering standards. Performance based standards provide flexibility to researchers, institutional animal care and use committees, and animal care personnel in implementing animal care and use guidelines Engineering standards, on the other hand, are prescriptive and rigid, allowing limited flexibility in implementation. FASEB argued that flexibility is important in providing optimal care to laboratory animals and ensuring the integrity of scientific research. The federation was also particularly concerned about the new cage size requirements for rabbits and rodents. The FASEB letter encouraged NIH not to adopt the new rabbit cage height increase and to provide additional guidance for interpreting the new rodent housing standards with particular emphasis on females plus their litters and other types of breeding configurations.
Concerning question two, FASEB suggested that NIH delay adoption of the Guide until March 31, 2013 instead of March 31, 2012 as NIH proposed. The federation also suggested that institutions unable to implement all the changes recommended in the new Guide at once should be allowed to develop and submit a plan to implement the changes over a predefined period of time. FASEB’s letter to NIH can be viewed here.
In its letter to AAALAC, FASEB commented on two of the six proposed position statements the organization developed to advise institutions on AAALAC’s expectations for implementation of an accreditable animal care and use program and provide AAALAC's interpretation of recommendations in the Guide. As in the letter to NIH, FASEB recommended that AAALAC place a greater emphasis on performance based standards and professional judgment rather than prescriptive engineering standards when assessing and accrediting an organization’s animal care program. Comments to AAALAC on cage space were also similar to those communicated to NIH. With regard to the social housing, FASEB strongly encouraged AAALAC to modify the language in the position statement so that social housing is not specified as the default method of housing and that pragmatic concerns, such as social incompatibility of animals, are specified as valid reasons not to house animals socially.