When it comes to the needless sacrifice of tens of thousands of animals in chemical safety tests, public health advocates are not the problem. The real problem is the chemical industry, which conducts repeated animal studies that sacrifice hundreds of thousands of animals as a part of a deliberate strategy to delay government action against specific chemicals. This is nothing short of scandalous, but it will not be fixed until it is addressed head-on through changes in law and policy. Improving animal welfare and protecting public health are mutually reinforcing goals. EWG proposes several changes to current animal testing policies and methods that would accelerate meaningful health protections while minimizing animal testing and cruelty. Our strategy is five-fold: * Link animal testing to action, by creating a sound chemical policy that uses toxicity information to protect health. This will target testing efforts and avoid massive chemical testing exercises that produce no public health benefit. * Assure that all chemical toxicity data generated by industry or others is made public. This will avoid duplication of studies that waste test animals and it will minimize delays that flow from repeated testing for the same effects. * Develop and adopt a standard battery of studies with precise and specific protocols that EPA will use to determine chemical hazards and risks for purposes of regulation. * Use animal-based tests judiciously by taking full advantage of non-animal screening tests, and innovative proposals to modernize, streamline, shorten, drop or combine current animal tests. * Ensure that independent animal studies generate high quality data using modern methods that assess the most sensitive effects. One proposed mechanism is a prospective database of study proposals that is open to public comment. This will limit the ability of industry and others to conduct poorly designed studies that lack the power to detect sensitive effects. EWG often receives questions about our position on animal testing. Here are our responses. Q. What about the recent National Academy of Sciences report that said there are good alternatives for most animal tests right now. If that's true, why are we still testing animals? A. That's not what the report concluded. The panel laid out an exciting vision for greatly expanding the use of non-animal test methods, but concluded that for at least the next decade animal studies will be remaining essential to fully understand the dangers of chemicals to human health (NAS 2007). Q. PETA says that "no animal test method in use today has ever been properly scientifically validated to determine its reliability and relevance to humans." Is that really true? A. Not true. Every man-made pollutant ever found to cause cancer in humans is also identified as a carcinogen in animal studies (Melnick, 2008). Animal tests have averted huge amounts of human suffering by providing health authorities with the science they needed to ban the use of scores of toxic chemicals and drugs. Q. Aren't there some tests that are really cruel (LD 50, draize eye test, 1-year dog etc). Why do we need to do them? A. Substantial progress has been made to reduce the number of animals needed for these tests. The new proposal for the LD 50 test includes 70% fewer animals (NICEATM-ICCVAM 2008). Similar efforts by US and European Agencies are in place or nearly complete for the other tests, including all highlighted by PETA’s “Give them 5” program (NICEATM-ICCVAM 2008, ECVAM 2008). Q. There must be some non-animal tests that can substitute for most animal studies. A. There are a number of non-animal tests that can substitute for some types of animal studies. But for many important and complex health concerns like cancer, nervous, immune, or hormone system impacts there is no substitute for a well-designed animal study that provides as complete information about how a chemical can be toxic in a complex living organism. In these cases we must explore ways to improve study design to use fewer animals with out compromising the quality of the study. There are an array of techniques that will include more sophisticated analysis for subtle effects. We must also standardize protocols and require data sharing to avoid duplication caused by private or poorly designed studies. Q. Can't we improve the current test protocols to use fewer animals? A. Yes we can. A good example are the screening studies for impacts to reproduction and development. This study uses nearly one thousand animals but doesn’t follow the off-spring long enough to determine the full impacts of early life exposure. An alternative, the two generation study is the gold standard, but uses even more animals. A new proposal to use just one generation of animals but include a very thorough evaluation would provide much meaningful information, and save more than 1,200 animals in the process (Cooper 2006). Q. Shouldn't we try to eliminate all animals tests if we can? A. We should, and we support that goal, but it is a long way off and we need health and welfare protections for people and animals right now. Q. What can we do right now to reduce the number of animals in these tests? A. Support the Kid Safe Chemicals Act, which would focus animal testing and safety assessments on the chemicals that pose the greatest threat to human health and the environment, including those that accumulate in the bodies of people and animals. The Act also includes strict measures designed to make all health and safety studies public, eliminates incentives for duplicate studies, and requires EPA to revise animal testing protocols to use the fewest animals possible. References: Cooper RL, Lamb JC, Barlow SM, Bentley K, Brady AM, Doerrer NG, et al. 2006. A tiered approach to life stages testing for agricultural chemical safety assessment. Crit Rev Toxicol 36(1): 69-98. ECVAM. 2008. Validated Methods. Available: http://ecvam.jrc.it/ [1] [accessed 4/15/08]. Melnick RL, Thayer KA, Bucher JR. 2008. Conflicting Views on Chemical Carcinogenesis Arising from the Design and Evaluation of Rodent Carcinogenicity Studies. Environ Health Perspect in press (doi:10.1289/ehp.9989): online 7 Nov 2007. NAS. 2007. Toxicity Testing in the Twenty-first Century: A Vision and a Strategy: National Academcy of Sciences. Available: http://books.nap.edu/catalog.php?record_id=11970 [2] [accessed Access 2007]. NICEATM-ICCVAM. 2008. The NTP Interagency Center for the Evaluation of Alternative Toxicological Methods (NICEATM) and the Interagency Coordinating Committee on the Validation of Alternative Methods (ICCVAM). Available: http://iccvam.niehs.nih.gov/home.htm [3] [accessed 4/15/08].