Statement of Kristie Sullivan, M.P.H., director of regulatory testing issues for the Physicians Committee on the Frank R. Lautenberg Chemical Safety for the 21st Century Act
The Frank R. Lautenberg Chemical Safety for the 21st Century Act introduced by Sens. Tom Udall and David Vitter on March 10, 2015 is a step in the right direction, but the bill misses an opportunity to promote human health and safety by not requiring the chemical industry to use more advanced, human-relevant methods.
The new legislation contains many provisions that are consistent with a shift away from a heavy reliance on animal tests. Principles to replace and reduce animal-based test methods and to increase the use of information from human-based and mechanistic tools are integrated into the heart of the legislation.
However, the drafters have missed an important opportunity to protect health and reduce the numbers of animals used by failing to require that the chemical industry use nonanimal methods when available. This simple requirement is in place in other regions, such as the European Union, and it is crucial to the rapid development and use of new methods and the continued improvements in toxicity testing required to offer superior protection for public health and the environment.
Since 2005, the Physicians Committee has been working with Congress on the importance of fixing an integral part of the regulatory process – toxicity testing. There is a lack of information on many chemicals and how they affect a diverse human population, because current chemical management regulations are inadequate and because we rely too heavily on slow, unreliable, and expensive animal tests. To ensure robust protection of public health and the environment, industry and regulators need to shift away from the current heavy reliance on animal tests and toward more human-relevant methods.
This is echoed in the National Research Council’s 2007 report, Toxicity Testing in the 21st Century: A Vision and a Strategy, which recommends a shift away from this heavy reliance on animal tests and toward efficient and human-relevant methods.
Inertia can be a powerful force. Too often, risk assessors at chemical companies and regulatory agencies default to their comfort zone—animal tests—and do not know of more effective, human-relevant methods. By requiring that human-relevant methods and strategies be used first, the focus of toxicity testing returns to human health effects and ways to prevent them.
Founded in 1985, the Physicians Committee for Responsible Medicine is a nonprofit health organization that promotes preventive medicine, conducts clinical research, and encourages higher standards for ethics and effectiveness in research and medical training.