Animal Experimentation Issues

The High Production Volume (HPV) Chemical Testing Program: A Toxic Blunder

The Environmental Protection Agency (EPA) high production volume (HPV) chemical testing program is government policy gone awry. It is an effort by Vice President Gore to win back the environmental vote with a good political sound bite masking an ineffective program. He is pushing the HPV program in place of projects that have a real chance at protecting the public and the environment. The program calls for crude animal tests on thousands of chemicals manufactured or imported in quantities exceeding one million pounds per year. Yet the program will not lower exposures, stop spills, or actually protect the public. The HPV program is mired in politics, not based in science. Please let the vice president know that poisoning animals for political gain is a toxic political blunder.

A Step Backwards for Public Safety

While millions of animals will die excruciating deaths in the HPV tests, public safety will not be advanced. EPA officials admit that the only result of this massive testing program will be to prioritize chemicals for further testing. The program specifically excludes exposure and risk assessment, and will do nothing to protect the public or the environment. To the contrary, it will most likely drain resources from EPA’s efforts to monitor toxic releases, clean up Superfund sites, and administer other valuable programs. Furthermore, faulty animal tests may actually work in favor of the chemical industry because they are frequently inconclusive. Animal tests could actually clear chemicals already known to be hazardous and be used to delay the regulation of those chemicals.

No Public Input

The HPV program is the result of closed-door negotiations between the EPA, the Chemical Manufacturers Association, and the Environmental Defense Fund (EDF). There has been no public notice and, therefore, no chance for public or Congressional review of the program. Public health groups, the animal protection community and many environmental organizations were taken by surprise with the October 1998 announcement of the program. Because of its heavy reliance on outdated animal tests, the HPV program will roll back recent strides towards alternative tests.

A Flawed Analysis

The data analysis upon which this program is based is seriously flawed. The claim that there is a “virtual information vacuum” for these chemicals is unfounded. An enormous amount of hazard data already exists for many of the 2,800 high production volume chemicals. Many of them have been known for decades to be extremely hazardous. Others on the list, such as sorbitol (a common chewing gum ingredient) and citric acid, are recognized as safe food ingredients by the Food and Drug Administration.

We Know These Chemicals Are Dangerous

The list of substances slated for testing on animals includes well-known hazardous chemicals such as tetraethyl lead and carbon tetrachloride. Exposures to these chemicals are already regulated and severely restricted by other government agencies (including the Occupational Safety and Health Administration) due to their acknowledged dangers. The EPA even wants a substance used as rat poison to be tested on animals. Other materials on the list, such as turpentine, have been in commerce since the early 1900s and there are already extensive data on them.

A Rushed Schedule Means Bad Science

Vice President Gore has placed this program on a fast time table that does not allow for proper oversight. A diverse range of experts has criticized the rushed schedule. The American Industrial Health Council, for example, has stated that “the speed with which the EPA has been asked to propose and finalize the rule [is] a reflection of a non-scientific, political agenda.” Even EPA officials have admitted that the hurried schedule being pushed for by Vice President Gore does not allow for a scientifically sound and defensible testing strategy.

Alternatives to Animal Tests

Where gaps in information about HPV chemicals exist, alternatives to animal tests can and should be used. New and more reliable tests using human cell lines can replace the cruel and scientifically flawed Lethal Dose (LD50) test in which animals are forced to ingest or inhale toxic substances until half of them die. The nonanimal tests are faster, cheaper, and more predictive of actual hazard. The EPA is rejecting internationally accepted nonanimal tests.

A Reevaluation Is Needed

Both the Chairman of the House Committee on Science, Congressman James Sensenbrenner, and the ranking minority member, Congressman George Brown, have expressed serious concerns over the HPV program and called for a delay in its implementation. Many other Congressional leaders, from both major parties, have echoed these concerns and spoken out against the program in an effort to ensure that good science prevails.

What You Can Do

Contact EPA Administrator Christine Todd Whitman and ask her to::

• delay the HPV program until the existing test data and human exposure information are thoroughly reviewed;
• use modern cellular tests, rather than animal tests. If some tests need validation, she must allow that to happen first.

Christine Todd Whitman, Administrator
U.S. EPA
1200 Pennsylvania Ave., N.W.
Room 3000
Washington, DC 20460
T: 202-564-4700
F: 202-501-1450

Please contact your Representative and Senators as well. Tell them you want the EPA to start using nonanimal tests and that Congressional oversight hearings need to be held on the HPV program to ensure that our government’s decisions are made in the light of day, with due public notice and input.

Information on how to contact them can be found on the Internet at www.house.gov/writerep/ and www.senate.gov/ or by calling the Congressional Switchboard at 202-224-3121.

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