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The Physicians Committee



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

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PCRM STATEMENT ON THE TOXIC CHEMICALS SAFETY ACT OF 2010 (H.R. 5820)
Key Improvements Needed: Effective Public Health Protection is Dependent on Modern and Efficient Toxicity Testing Methods

The Toxic Chemicals Safety Act of 2010 (TCSA), introduced last week by Rep. Bobby Rush, chairman of the Subcommittee on Commerce, Trade, and Consumer Protection, would revise the Toxic Substances Control Act, a 34-year-old chemical regulation law.

TCSA would require companies to test chemicals for potential health effects more extensively than currently required; it would also require all chemicals in the U.S. marketplace to be tested extensively by 2015. However, since some tests—such as cancer and reproductive toxicity—in animals can take several years per chemical, more efficient test methods must be relied upon.

The bill makes it part of U.S. policy to "replace, reduce and refine testing on animals by promoting and funding the development of more efficient test methods and strategies." It also requires the EPA to fund the development of nonanimal methods, and details other measures, such as the sharing of data between companies, that will help reduce animal testing overall.

But making such laudable policy a reality will require several key improvements. The bill should:

  • Require the use of nonanimal methods where appropriate. The EU has done this since 1986, and the policy has proven to stimulate research and innovation.
  • Direct Congress to appropriate a specific dollar amount to further the development of nonanimal testing methods.
  • Provide for an advisory committee on nonanimal methods with members of the public with expertise in their development and use. Reference to the Interagency Coordinating Committee for the Validation of Alternative Methods (ICCVAM) in Section 34 should be removed. ICCVAM members do not necessarily have expertise in toxicology testing or nonanimal methods development. Moreover, ICCVAM is recognized as a barrier to the development and use of nonanimal testing methods and will not provide appropriate advice to the EPA.
  • Allow for testing exemptions for chemicals that are not released into the environment.
  • Provide for a flexible minimum data set for new chemicals and a chance for manufacturers to consult with the EPA and propose strategies that would reduce testing at the outset.
  • Direct the EPA to update the “list of alternative methods” on an ad-hoc basis as new methods become available but at least annually—not triennially, as Section 34 currently states.

Toxicology testing reform was addressed in a 2007 National Research Council report, Toxicity Testing in the 21st Century: A Vision and a Strategy. The report endorsed tests based on human cells and cell components instead of animals as a way to more quickly and accurately predict the risks chemicals may pose to human health. Indeed with the right investment, we could modernize toxicology testing.

Because evaluating every industrial chemical using animal tests could take decades, the bills’ provisions to streamline and modernize testing methods mean better protection for people and wildlife. From nanomaterials, to low-dose exposures, to mixtures of chemicals, many of the challenges of chemical regulation can be addressed by modern, nonanimal methods. Even the replacement of dangerous chemicals with safer alternatives—a tenet of “green chemistry” innovation—requires methods that can quickly test promising new chemicals and products.

TCSA is a good start, but we need to do better. PCRM member physicians and scientists will continue to work with Congress and other stakeholders to make essential improvements to the legislation that will modernize chemical testing and protect humans and animals for decades to come.

Members of the media: For more information or an interview with a PCRM expert, contact Vaishali Honawar at 202-527-7339 or vhonawar@pcrm.org.



 

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