• Why has a massive chemical-testing requirement been proposed in the new EU chemicals policy?
• What are environmental and consumer organisations demanding in a new EU chemicals policy?
• What is the position of the animal protection community on the demands of environmental and consumer organisations?
• Is it true that little or nothing is known about the toxic effects of most chemicals in use today?
• How much would it cost to fill perceived ‘gaps in knowledge’?
• Which animal tests are being required?
• How many animals could be used for the proposed testing?
• Are the results of animal tests relevant to humans?
• Can chemicals be tested without using animals?
• How can the EU’s new chemical policy be improved?
Why has a massive chemical-testing requirement been proposed in the new EU chemicals policy?
In 1998, the European Commission made a commitment to review the current EU policy on chemicals, following increasing concerns about chemicals in our environment. These concerns had been raised largely as a result of intense government lobbying by European environmental and consumer organisations, which claim that little or nothing is known about the health or environmental effects of most chemicals in use today. These organisations met in Copenhagen, Denmark, in October 2000, to discuss issues they wanted to see addressed in a new EU chemicals policy. In February 2000, the Commission published its White Paper: Strategy for a Future Chemicals Policy, which sets out its proposals for a new EU policy on chemicals.
What are environmental and consumer organisations demanding in a new EU chemicals policy?
The top five demands of environmental and consumer organisations––as outlined in the Copenhagen Chemicals Charter––are as follows:
1. A full right to know––including what chemicals are present in products.
2. A deadline by which all chemicals on the market must have had their safety independently assessed. All uses of a chemical should be approved and should be demonstrated to be safe beyond reasonable doubt.
3. A phase-out of persistent or bio-accumulative chemicals.
4. A requirement to replace less-safe chemicals with safer alternatives.
5. A commitment to stop all releases of hazardous substances into the environment by 2020.
What is the position of the animal protection community on the demands of environmental and consumer organisations?
The animal protection community supports all but one of the demands in the Copenhagen Chemicals Charter. We stand behind environmental and consumer organisations in calling for severe restrictions or prohibitions on the use and/or release of chemicals that do not break down in the environment (persistent) or that become more concentrated as they move up the food chain (bio-accumulative). We also agree that all uses of a chemical should be demonstrated to be both safe and necessary, that use of the least-hazardous chemicals available should become a requirement and that the public should have access to timely and relevant information about the chemicals to which they are exposed in consumer products.
We do not, however, support the creation of fixed and arbitrary deadlines for the testing of chemicals (and, of course, only support testing using non-animal methods). Deadlines established for similar programmes in other countries have allowed almost no time for the development or incorporation of new non-animal methods into testing strategies. This has effectively removed any possibility of minimising animal suffering and death and has resulted in chemical-testing programmes that rely almost exclusively on information derived from cruel, unreliable and irrelevant animal tests.
Is it true that little or nothing is known about the toxic effects of most chemicals in use today?
This is only an assumption––and an unproven one––based on a small handful of reports published in the USA. These reports greatly underestimate what is known about existing chemicals and, as a result, present conclusions that are seriously flawed and misleading. For example, one of these reports argued that a ‘lack’ of animal toxicity information for wood shavings is a threat to public health. Another study claimed that vinyl chloride has never been studied for its long-term toxic effects, despite other government documents showing that vinyl chloride has been the focus of hundreds of human population and animal studies. During an ‘amnesty’ period in the USA––under which companies could share previously withheld information on chemicals without penalty––government regulators received more than 10,000 submissions of chemical data that they would have otherwise assumed did not exist. The fact is that an enormous amount of chemical toxicity information does exist, both in publicly accessible databases and in the hands of chemical companies. What can be difficult is gaining access to this information. PETA and the BUAV believe that instead of proposing legislation involving the suffering of millions of animals in laboratories to gather data that may already exist, the European Commission should require companies and countries to share data in order to ensure that all sources of existing information on chemicals are fully utilized.
How much would it cost to fill perceived ‘gaps in knowledge’?
The financial cost of filling perceived information gaps for tens of thousands of existing chemicals, as well as their breakdown products and relevant mixtures, by initiating a new testing programme would be astronomical. For example, the Institute for Environment and Health in the UK estimates that the chemical-testing proposed by the European Commission could cost more than £ 8.5 billion using the standard battery of animal tests.
Which animal tests are being required?
The European Commission is proposing that chemicals be subject to a ‘tiered’ testing strategy based on the volume in which they are produced or imported. The higher the production volume, the more extensive the testing that would be required. Click here to see the standard checklist of animal-poisoning tests.
How many animals could be used for the proposed testing?
Producing exact figures for the number of animals likely to be used as part of an animal-based strategy for the EU would depend on a number of factors, including the results of previous tests. There can be no doubt, however, that traditional animal-based methods for testing chemicals involve a massive amount of animal suffering. Based on the typical experiments required for chemical-testing, the BUAV has estimated that more than 2,000 animals could be used to test each High Production Volume (HPV) chemical. And in a report by the Institute for Environment and Health for the UK’s Department of the Environment, Transport and the Regions (now DEFRA), calculations suggest that, at a minimum, 12.8 million animals (8.4 million mammals and 4.4 million fish) would be required to test 30,000 substances. This estimate would rise to 50.2 million animals (45.8 million mammals and 4.4 million fish) if the offspring produced in reproductive studies and animals used in some higher-tier tests were taken into account.
Are the results of animal tests relevant to humans?
Traditional animal toxicity tests have never been subjected to rigorous scientific validation studies in order to actually prove their reliability and relevance to humans. Their continued use is based on tradition rather than sound science. There is much scientific evidence documenting the failure of animal-based toxicity tests to accurately predict human reactions to chemicals. Such errors are not surprising, given the many differences that exist between species in terms of their anatomy, physiology, biochemistry and metabolism. Such variables make the cross-species extrapolation of test results an extremely uncertain exercise. Click here for more information about scientific problems with animal tests.
Can chemicals be tested without using animals?
Yes. There have been many advances in the development, validation and use of non-animal test methods in recent years. One method that has emerged uses cells in culture to measure a chemical's ability to damage genetic material. There also are a number of other non-animal tests that, after years of research and development, are nearing completion. With sufficient funding and political will, validated non-animal test methods could be made available for the European Commission’s chemical-testing strategy to meet all necessary endpoints. Click here for more information about non-animal methods.
How can the EU’s new chemicals policy be improved?
The current review of the EU chemicals policy provides a unique opportunity for the European Commission to reassess its current approach to chemical-testing and correct many of the problems associated with this largely animal-based approach. Click here to view BUAV’s and PETA’s recommendations for a new EU chemicals policy.
