Comments and Letters
An archive of comments and letter the APS has issued on a variety of science policy issues.
Archive

APS Responds to NIGMS RFI on Strategies for Modernizing Biomedical Graduate Education

In response to an NIGMS RFI on Modernizing Biomedical Graduate Education, the APS Science Policy and Education Committees jointly developed a response that emphasized the need for students to develop a range of core skills that will serve students well in their future careers.

APS Suggests Ways for USDA to Reduce Regulatory Burden

The APS submitted these comments in response to a request for information by the USDA (Docket USDA-2016-0001-0001) on regulatory burden.

APS Statement on International Regulation of Ketamine

APS comments on FDA request for comments on a proposed scheduling change of ketamine.

APS Responds to RFI on Amending USDA Reporting Requirements

APS tells USDA that proposed changes to research animal reporting requirements would not benefit animals but will increase administrative burden.

APS Urges USDA to Reject New Nonhuman Primate Standards

The APS submitted comments urging USDA to reject a request from several animal rights groups to develop specific ethologically appropriate standards for nonhuman primates in research. The APS noted that the supporting evidence for this request consisted of a biased review of outdated reports about the treatment of nonhuman primates in research. In fact, research facilities provide social housing for the majority of nonhuman primates and otherwise ensure their psychological well-being by providing foraging opportunities, manipulanda, and sensory and cognitive stimulation, as well as positive reinforcement training and other kinds of behavioral management.

APS Comments on NIH Strategic Plan Framework

On July 22, 2015, the NIH issued a request for information on the framework for their first ever agency-wide strategic plan. The NIH’s goal in this effort is to identify cross-cutting research priorities and outline a set of unifying principles to guide the NIH. The APS provided comments on the framework, endorsing the emphasis on fundamental science and developing a diverse workforce and offering suggestions to broaden the scope of the document.

APS Urges Senate to Authorize NIH Funding Increases

APS offered the Senate Health, Education, Labor, and Pensions (HELP) Committee suggestions on reauthorizing programs at the NIH. APS underscored basic research as the foundation for the development of cures and urged easing burdensome regulations.

APS Comments on Alternatives Search Requirements

APS's full comments on the USDA’s RFI regarding a petition asking the agency to issue new regulations on the consideration of alternatives to procedures that may cause pain or distress to laboratory animals.

APS Suggests Ways for USDA to Reduce Regulatory Burden

The APS submitted these comments to the USDA providing examples of regulations that could be modified, streamlined, expanded, or repealed to reduce regulatory burden in response to a request for information (RFI) by the USDA.

APS Comments on Sustaining the Research Enterprise

APS provided these comments in response to an NIH request for information (RFI) on strategies to optimize the impact and sustainability of biomedical research.

APS Comments on Field of Degree Question

In response to a request for comment from the United States Census Bureau, APS spoke out in support of retaining a question about undergraduate field of degree on the annual American Community Survey. The data gathered in response to this question is used by the National Science Foundation to prepare their Science and Engineering Indicators and Women, Minorities, and Persons with Disabilities in Science and Engineering reports. The National Science Board has also submitted a letter opposing the removal. For more background on this issue, including the politics that led to the proposed elimination, see this article in ScienceInsider.

APS Advises NIH on Sex as a Biological Variable

On September 11, 2014 NIH issued a Request for Information (RFI, NOT-OD-14-128) to assist NIH develop policies for the inclusion of sex as a biological variable in pre-clinical research studies involving animals and cells. The APS response recommends starting with accurate reporting of the sex of animal subjects and organisms from which biological materials were derived. NIH should provide training for investigators and reviewers before implementing the policy. APS also said additional resources will be needed to implement this policy without detriment to ongoing research.

On Proposed NIGMS Program

In response to a request for information from the National Institute for General Medical Sciences, APS submitted comments on the proposed Maximizing Investigators’ Research Award (MIRA). This award would be a grant in support of all of the research supported by NIGMS in an investigator’s laboratory.

The American Physiological Society Statement on H.R. 4879

The American Physiological Society (APS) supports the efforts of Representative Cooper and the cosponsors of this legislation to promote high quality research through H.R. 4879, the “Research for All Act of 2014.”

On Benefits of SEPA Program

In a letter to the NIH Scientific Management Review Board’s working group on pre-college engagement in biomedical science, APS President David Pollock shared the many benefits experienced by teachers participating in programs supported by the science education partnership awards (SEPA). Dr. Pollock urged the working group to consider including SEPA in future plans to foster the next generation of researchers. (PDF)

On OLAW RFI on Changes to Ongoing IACUC Protocols

On March 11, 2014, OLAW published a request for comments on proposed guidance about what constitute “significant” changes to ongoing animal research activities. APS urged that a proposed revision to the guidance be revised to avoid “increase[ing] administrative burden rather than reduc[ing] it.” (PDF)

On Federal Travel Restrictions

The APS letter to the Office of Management and Budget regarding 2012 restrictions on travel for federal employees. (PDF)

On Pro-Test Italia Rally

The American Physiological Society commends Italian scientists for drawing attention to the unjustified restrictions that recent legislation would impose on life-saving research. (PDF)

On Chimpanzee Research, to the Fish and Wildlife Service

APS comments to the U.S. Fish and Wildlife Service in response to a proposal that would classify captive chimpanzees as endangered under the Endangered Species Act. (PDF)

On NSB Administrative Burden RFI

Comments submitted by the APS in response to the National Science Board’s Request for Information on reducing administrative burden. (PDF)

On Biomedical Workforce

The APS submitted comments in response to a request for information from the National Institutes of Health about implementing recommendations from the working group on the biomedical workforce. (PDF)

Letter to Dr. James Anderson

APS President Dr. Susan M. Barman letter to the Working Group on chimpanzees in NIH-funded research. (PDF)

On Research Animal Transportation (To UPS)

On October 26, APS President Sue Barman sent letters thanking the CEOs of UPS and FedEx for their companies’ continued shipments of research animals. Recent campaigns by animal rights groups have sought to pressure various carriers to curtail the shipment of various species. In her letters, Dr. Barman points out the many layers of protection in place to ensure the humane treatment of research animals. She also underscores the fact that biomedical research involving animals is intended to relieve suffering by finding cures for disease. (PDF)

On Research Animal Transportation (To FedEx)

On October 26, APS President Sue Barman sent letters thanking the CEOs of UPS and FedEx for their companies’ continued shipments of research animals. Recent campaigns by animal rights groups have sought to pressure various carriers to curtail the shipment of various species. In her letters, Dr. Barman points out the many layers of protection in place to ensure the humane treatment of research animals. She also underscores the fact that biomedical research involving animals is intended to relieve suffering by finding cures for disease. (PDF)

On the Great Ape Protection and Cost Savings Act

This legislation will not save money; it contradicts the recommendations of the Institute of Medicine; and it would end research to benefit human and animal health. (PDF)

On Research Chimpanzee Colonies and Conservation

The APS told the U.S. Fish and Wildlife Service (FWS) that chimpanzees in biomedical research colonies are “responsibly managed, well-regulated, and offer a resource of international value that benefits the health of humans and supports wild ape conservation efforts.” (PDF)

On Publications Access OSTP RFI

APS submitted comments to a Request for Information from the Office of Science and Technology Policy concerning public access to peer-reviewed scholarly publications resulting from federally-funded research. (PDF)

On Building a 21st Century Bioeconomy

The APS responded to a request for information from the Office of Science and Technology Policy soliciting input on “harnessing biological research innovations to meet national challenges in health, food, energy, and the environment while creating high-wage, high-skill jobs.” (PDF)

On Managing NIH Resources

In response to a request for input from the NIH on how best to manage resources in fiscally challenging times, the APS submitted a response recommending that the NIH consider the long term consequences of any changes to funding policy and focus on maintaining success rates at a level of at least 30%. APS also recommended using a diversity of approaches to alleviating the funding crunch, and continuing to prioritize funding for early stage investigators. (PDF)

On Human Subjects Rule

The APS responded to an advanced notice of proposed rulemaking issued by the Department of Health and Human Services entitled Human Subjects Research Protections: Enhancing Protections for Research Subjects and Reducing Burden, Delay, and Ambiguity for Investigators.

On Biomedical Workforce

In response to a request for information from the National Institutes of Health, APS submitted comments to the working group of the Advisory Committee to the Director that is examining the future of the biomedical workforce. (PDF)

On the Pet Safety and Protection Act of 2011

The APS sent a letter to cosponsors of the Pet Safety and Protection Act of 2011 (HR 2256) asking that they allow the NIH program to replace Class B dealers to finish implementing instead of passing an immediate ban. (PDF)

On Nonprofit Participation Ethics Regulation

The Office of Government Ethics proposed to change existing regulations such that federal employees would no longer have to obtain waivers to participate on non-profit boards as long as they comply with all conflict of interest rules set forth by their agency. The APS submitted comments in support of the rule change. (PDF)

On the New Guide

APS submitted comments May 17 on NIH’s plans to adopt the 8th edition of the Guide for the Care and Use of Laboratory Animals. While supporting most of the Guide’s updates, APS expressed concerned that NIH’s enforcement strategies undermine the use of the Guide as performance standards. (PDF)

Opposing Ban of Great Ape Research

The Great Ape Protection and Cost Savings Act is based on false assertions about the treatment of chimpanzees in research, fails to take into account scientific needs for chimpanzee studies of human and animal diseases, and cannot substantiate its claims of cost-saving. (PDF)

On Proposed Changes at NIH

The APS has sent a letter to Director Collins outlining our concerns regarding elimination of National Center for Research Resources (NCRR) so that the National Center for Advancing Translational Science (NCATS) can be created. (PDF)

On Proposed Financial Conflict of Interest Rules

The APS submitted comments on the NIH’s notice of proposed rulemaking on financial conflicts of interest for extramural researchers. (PDF)

Letter to Dr. Chester Gipson

A letter from APS to the Deputy Administrator for Animal Care of the Animal and Plant Health Inspection Service, Dr. Chester Gipson, concerning the educational value of animal teaching laboratories. (PDF)

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