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The Physicians Committee

Arm Wrestling the EPA

By Kristie Sullivan, M.P.H.

As part of an ongoing effort to monitor the EPA’s High-Production Volume Challenge (HPV), PCRM researchers have uncovered industry plans to perform duplicative animal tests.

Arch Chemicals, Inc., worldwide manufacturer of sealants, adhesives, coatings, and other chemicals, was preparing to perform toxicity tests on the industrial chemical 2-chloropyridine, an ingredient used in pharmaceutical and agricultural products, even though the National Institute of Environmental Health Sciences was already testing the chemical. PCRM notified EPA officials, who intervened and are working to have the experiments called off. Fifty rats are scheduled to undergo painful forced ingestion of chemical agents in this particular test. But this is just one example among many.

When chemical manufacturers blunder ahead with new animal tests, without examining existing data, the EPA has often been slow to step in.

By focusing exclusively on non-human data, the HPV program ignores a wealth of information from human toxicity, exposure, and epidemiological studies already performed for many of the listed chemicals. Available in-vitro tests are all but neglected. And when chemical manufacturers blunder ahead with new animal tests without investigating existing data, the EPA has often been slow to step in. As for protecting human health, results from tests performed on animals present many problems. They must be extrapolated from high to low doses, and then from rats and mice to humans, greatly reducing the validity and accuracy of risk assessments. They are not intended to reduce any toxic exposures. Moreover, mandatory animal testing continues to impede progress for nonanimal methods.

At the 12th Meeting of the OECD Task Force on Existing Chemicals, PCRM’s research and toxicology director Chad Sandusky, Ph.D., challenged HPV’s reliance on hazard data alone. In reality, the degree of exposure is a more important factor in determining effects of a substance than the hazardous nature of that substance. In other words, even a highly toxic substance that is unlikely to reach many humans may present negligible risk. Conversely, a low-risk chemical that saturates an environment may cause serious harm over time. Dr. Sandusky pointed out to task force members that the continual generation of toxicity data from animal tests—without some measure of probable exposure—is not only a needless infliction of pain on animals and waste of financial recourses, but it ultimately fails to protect people or the environment.


Winter 2004
Volume XIII
Number 1

Good Medicine

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