Comment from Lee Jan, DVM, Texas Animal Health Commission

Regarding Mouse Safety Tests - in response to the notice's statement: "The subcutaneous and intraperitoneal routes of inoculation are considered equally sensitive for the purposes of the mouse safety test. Therefore we are also proposing to amend the regulations to provide that only one route of inoculation - either the subcutaneous route or the intraperitoneal route - be used in the test, rather than the two ruotes as is currently required, ..." Comment: Though the sensitivity for adverse systemic reaction may be the same, we are concerned that an adverse local reaction may be missed if the intraperitoneal route is the only route used. We recommend both routes continue to be required as is currently the case.