Environmental Defence on Animal testing

[Guest guest]

Hello everyone,

I recently wrote a letter to Environmental Defence in the USA in regards to their position on animal testing

and suggested they support without stepping on the toes of PETA.

here is the response I got 3 months later.

at the bottom of the page is his email address feel free to follow up

all the best

Craig

 

 

Thank you for contacting us regarding the High Production Volume Challenge

Program. Environmental Defence welcomes efforts to prevent unnecessary

animal testing in that program. This letter responds first to the specific

points in your email, then offers some additional observations.

First, please note that several provisions designed to minimize the need

for additional animal tests are built into the HPV program:

· the program calls for use of existing data wherever possible

(occasionally, older data may be of inadequate scientific quality to be

used);

· even where data don't exist for a particular chemical, the program calls

for grouping similar chemicals into "categories" wherever scientifically

appropriate, and then extrapolating results within the category rather than

conducting separate tests for each member of the category; and

· the program expressly calls for non-animals tests where relevant

non-animal test protocols exist. Unfortunately, non-animal tests don't

yet exist for several critical health and ecological effects, which

sometimes necessitates tests on laboratory rodents or fish.

Your message urges that the HPV program should be delayed until the

existing test data and human exposure information are thoroughly reviewed.

With regard to existing data, please note that the HPV program requires

that the sponsor of a chemical first submit a "robust summary" of existing

data; only if data are not available is additional testing to be conducted.

Environmental Defence carefully reviews the draft test proposals submitted

by the companies that sponsor particular chemicals. In many cases, we have

agreed with sponsors who concluded that no additional testing was needed.

In a number of other cases, we disagreed with sponsors that additional

animal testing was needed, and argued against their proposal to conduct

those tests. In short, we conduct a careful scientific review of the facts

in each case, and call for new testing only when it is needed to understand

a chemical's hazards.

We respectfully disagree with the suggestion that it is also necessary to

first review human exposure information; in our view, such data cannot

obviate the need for toxicity data on for these high-volume chemicals

(I.e., ones produced in quantities exceeding one million pounds annually).

In fact, it is these toxicity data that help establish which exposures are

and are not acceptable.

Finally, we also respectfully disagree with the implication that any

chemical that is regulated should automatically be exempt from additional

testing. The fact that a chemical is "regulated" in some way does not

necessarily indicate that anything like adequate data exist for that

chemical. For example, chemicals may be regulated because they are known

to be poisonous at high doses, but this says nothing about whether lower

doses can cause chronic effects such as mutations (which indicates

cancer-causing potential), effects on the reproductive system or on

development, or other serious health effects. In the absence of data,

these lower-level exposures that cause chronic effects are the ones most

likely to go unnoticed and uncontrolled. And so it is necessary to carry

out tests for those effects even on chemicals known to have acute impacts.

Moreover, animal data and other information on chemical risks can be highly

effective in reducing our exposure to toxic chemicals even outside of

formal regulatory settings. When such information is made public, the

resulting pressure to correct the problem often prods companies that make

and use chemicals to change their practices far more quickly than

regulators can act. The dramatic results of the federal Toxics Release

Inventory (TRI) and California's Proposition 65 ? programs highly dependent

on having reliable data on chemical hazards ? demonstrate that information

disclosure itself triggers steps to reduce exposures. Air emissions of

carcinogens and reproductive toxicants covered by TRI fell by approximately

50% percent nationwide between 1988 and 1997, while in California, where

the same chemicals were also covered by the disclosure requirements of

Prop. 65, the same air emissions fell by approximately 85%. These

important risk-reducing incentive programs would not have happened without

strong data on toxicity, since both TRI and Prop. 65 apply only to

chemicals classified as toxic. Likewise, 3M moved voluntarily to withdraw

a range of widely used products after finding that the chemicals they

contained were toxic based on animal tests.

We would also like to offer a number of additional observations. First,

there is good news: far less new animal testing may be required under the

program than had originally been expected. EPA analysed the HPV

submissions covering the first 850 chemicals, and found that new testing

was proposed as the means to fill only about 3.5% of the health data gaps

that were identified, and 6.7% of the ecological data gaps; the new testing

would be conducted on rats and mice for health effects, and on fish and

invertebrates for ecological effects. The remaining information was

proposed to be provided from existing data (some of which had not

previously been published but has been brought to light by this program) on

the same chemical, or by extrapolating from data on similar chemicals.

While some of these proposals may turn out not to pass scientific muster,

it's clear that everyone involved in the program has been making major

efforts to minimize use of animal testing.

More generally, we believe it is important to note that the HPV program was

established after we documented, and EPA and industry both separately

confirmed, that there were massive gaps in the public availability of even

basic toxicity data on widely and heavily used chemicals. We continue to

believe that such gaps are unacceptable, because they keep consumers as

well as government from acting to reduce unnecessary risks to health and

the environment. And if industry has the data but they aren't public, then

industry has little incentive to take action on its own.

The HPV Challenge Program was created to address the appalling lack of

public access to data on the hazards posed by industrial chemicals that are

released into the environment and to which people ? and animals ? are

likely to be exposed. The program asks chemical manufacturers to start

living up to their responsibility to know ? and tell the public ? about the

toxic effects of the chemicals they make and use in their products.

Because of the vast number of chemicals now on the market, HPV focuses on

the ones produced in the highest volumes (one million pounds or more

annually). Far from being uninformative, the test protocols used under the

program provide the basic data needed to screen chemicals for their

potential hazard to humans and other living organisms.

The real controversy is the use of laboratory animals in some of this

testing. Everyone who works on chemicals wishes there were a set of

reliable non-animal tests that could be used for all toxicity-evaluation

purposes, but the fact is that such tests don't now exist for several

serious health and ecological effects. And there is abundant scientific

evidence that data from appropriate animal tests are critical to predicting

impacts on humans and other organisms. This is true both in evaluating

toxicity, and in developing drugs to treat human and animal illness.

Recent advances in genetic information make it clearer than ever that

animal and human biology are fundamentally similar at the cellular level

(which is where toxic effects are generally exerted).

It is worth noting that animal rights and animal welfare organizations have

been instrumental in making sure that unnecessary animal testing is

avoided. A good case can be made that in years past too little effort went

into developing and implementing non-animal alternatives to traditional

animal testing procedures. While there may still be differences of opinion

about the necessity for particular animal tests, there is no longer

disagreement about the importance of doing animal tests only when there is

no viable alternative.

We fully recognize that the use of animal testing to protect the health of

humans and other living organisms is a difficult issue. Some animal rights

activists take the coherent, but in our view extreme, position that no

animal testing, however useful or even essential, is morally acceptable.

Others see a need to balance animal welfare against health and

environmental quality concerns. We should work hard to listen to and

respect each other's opinions, and to avoid misrepresenting them. We do

not believe in, and would never advocate for, animal testing unless it

provides information that is critical to understanding chemical hazards.

We respect the values that lead some people to oppose all animal testing,

even where there are no scientifically valid alternatives and no matter how

useful that information is in protecting human health and the environment.

We recognize the deeply held moral conviction of some that humans do not

have the right to use any living creature for human purposes, although we

do not share that position. While Environmental Defence believes that

limited animal testing at present remains necessary within the constraints

described above, we share a common interest in avoiding unnecessary testing

on animals and in advancing technologies that will further reduce the need

for animal testing. Although some of our differences may never be fully

reconciled, animal-welfare concerns are very much a part of our thinking

and continue to help shape our focus and priorities as we work to protect

the health of all of the living things on our planet.

Some bottom-line conclusions on this complex issue:

1. Animal testing can help establish important information about chemical

toxicity, information that meaningfully influences the decisions of

manufacturers, regulators, and consumers.

2. In some cases the needed information can be obtained without animal

testing ? and in such cases it is morally wrong to subject animals to

unnecessary tests. Animal-rights and animal-welfare organizations played a

crucial role in raising consciousness about this moral imperative, and

continue to hold us all to this standard: No unnecessary animal testing.

3. In many cases the needed information cannot be obtained without animal

testing. In these situations, some organizations nonetheless oppose animal

testing, arguing that it is immoral to acquire toxicity information at the

expense of animals under any circumstances. Other organizations, including

Environmental Defence, believe that test animals' needs must be balanced

against other needs, including the protection of humans, wildlife, and the

environment. In short, this is an area where Environmental Defence must

respectfully but vigorously disagree with some other organizations.

4. Disagreements will inevitably arise about which specific testing falls

under #2 above and which falls under #3. It should be a high priority for

scientists to develop new non-animal approaches to toxicity evaluation, and

for the relevant scientific and governmental authorities to approve the

non-animal tests for use. As viable non-animal options become available,

previously debatable testing (described in #3 above) moves into #2, and

becomes unacceptable in the view of all.

Yours truly,

Fred Krupp, President

Environmental Defence

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