Chemical Testing Basics TSCA Reform

The Physicians Committee

21st-Century Chemical Regulation: Ensuring Protective Chemical Regulations That Avoid Animal Testing


Chemical Testing Basics

Toxicity Testing | Toxic Substance Control Act Reform 

About the Toxic Substances Control Act

mouse in lab gloved hand

The Toxic Substances Control Act (TSCA) was signed into law in 1976 and has been the prevailing legislation governing industrial chemical production and distribution ever since. TSCA requires a company to notify the Environmental Protection Agency (EPA) when it plans to manufacture a chemical. The EPA then assesses the potential hazards this chemical might pose to humans or the environment. When TSCA was enacted, however, chemicals on the market did not have to undergo any new safety evaluation. Instead, companies only had to submit information they had on hand. Many of these chemicals are still on the market today.

Some believe that this “backlog” of chemicals—estimates of the number of chemicals involved range from 7,000 to as many as 80,000—should be tested in animals immediately to discover whether any pose hazards to humans or the environment, and that revising TSCA is the way to accomplishing this.

But many scientists point out that a chemical-by-chemical approach using animal tests would be costly, inefficient, and virtually impossible given the number of chemicals involved. The best way to evaluate this backlog of chemicals is to use the human-relevant, high-throughput testing methods and strategies recommended in the National Research Council’s Toxicity Testing in the 21st Century: A Vision and Strategy.

About the Chemical Safety Improvement Act of 2013 (S. 1009)

To have no information is risky, but to have the wrong information is dangerous.

On On May 22, 2013, Sens. Frank Lautenberg and David Vitter introduced the Chemical Safety Improvement Act of 2013 (CSIA). The bill would extensively amend the existing law and require producers of industrial chemicals to better assess the potential hazards of chemicals before they reach the market.

For several years, PCRM and its allies have been working to ensure that any bill which reforms chemicals policy contains provisions that would prevent the suffering of potentially millions of animals in chemical testing laboratories. Because of the limitations of animal-based toxicity testing, the proposed legislative goals will not be accomplished through reliance on current toxicity testing methods. We told Congress that these efforts must provide the logistical and financial support needed to implement the NRC Vision, and must put in place strong protections for animals in laboratories, to reduce testing while the vision is being implemented.

Well, they listened.

CSIA contains a number of provisions designed to reduce the numbers of animals killed in chemical testing and direct the EPA to fund and develop nonanimal test methods, as recommended by the National Academy of Sciences.

The bill gives the EPA the authority and flexibility to modify testing requirements based on a chemicals characteristics or what might already be known about a chemical or groups of chemicals. You can read more details in PCRM’s statement on the CSIA.

While this is excellent news, these provisions are only a first step. Most importantly, the EPA must be given the authority to require nonanimal tests. Given the option between an animal test and a nonanimal test, a nonanimal test should always be conducted—it’s that simple. This requirement has transformed test method research and development in the European Union, and it can do the same here in the United States.