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

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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