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Millions of Animals Condemned to Die in Unnecessary
Toxicity Testing of Industrial Chemicals Already in Use
from  Winter 98-99 issue of The Civil  Abolitionist
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The Environmental Protection Agency (EPA), the Chemical Manufacturers Association, and the Clinton Administration have endorsed the
Environmental Defense Fund's Cooperative Program for High Production Volume (HPV) U.S. Industrial Chemicals which would conduct new toxicity tests on all of the 2800 chemicals imported or manufactured in amounts exceeding one million pounds a year.

This means that millions of mice, rats, guinea pigs, birds, and fish will be subjected to painful forced feeding, inhalation, and skin and eye exposure tests that won't tell us anything we don't already know about the effects on humans of chemicals in use; and, as readers of this newsletter are aware, won't tell us whether these chemicals will have the same effects on humans as they do on the test animals.

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"We don't know what the findings really mean." - Dr Robert Marenpot, NIEHS

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In addition to being irrelevant for humans, many of these tests are just plain idiotic.  The purpose of the LD-50 (lethal dose for 50% of the test animals), for instance, is to come up with a number that indicates the degree of toxicity of each chemical in relation to all the other chemicals tested.  To achieve this, the animals are subjected to increasing doses of a substance until the dose that kills half of them is determined.  The volume of that dose becomes a number indicating the degree of toxicity of that chemical but it actually applies only to the particular species poisoned in the test.  Despite being designated "scientific", extrapolation of these results to humans is little more than guesswork.

The degree of idiocy becomes even more obvious when the test substances happens to be of a benign nature.  In this case, in order to get half the test group of animals to die, they have been plied with such large quantities of an inert test substance that they die from ruptured stomachs, an indication not of toxicity but of the sheer volume forced into the animals' stomachs faster than they can eliminate it.

The idiocy is also apparent in the case of substances already known to be toxic.  There is no practical value in learning that it takes 0.78 milliliters of one product to kill guinea pigs in a particular test and 1.2 milliliters of another produce.  As the test results can vary, the numbers might very well be reversed if the test were to be repeated. 

Ordinary common sense dictates that poisonous products should be avoided if at all possible or used with caution and adequate protection for the user when expediency overrides safety considerations.  Knowing the exact dose it took to kill half a group of rabbits is not going to make any difference in how a toxic product is handled.

Ironically, more scientific testing methods have been available for some time.  The Ames mutagenicity test, which employs
salmonella bacteria, has been available since 1996, for instance.  It is more accurate in detecting carcinogens than studies that use whole animals with all their physiological variations.  It is also faster and cheaper and is only one of a number of in vitro tests employing cell and tissue cultures.

Scientists have even cultured human skin and eye tissue in which they can observe and measure how individual cells react to a test substance with much greater accuracy than they can assess toxicity by consulting a chart showing different degrees of irritation in rabbits' eyes and pick the one they judge most closely resembles that of the individual animal they are examining.  Judgements of the degree of injury differ between individual observers.

When Dr Kenneth Olden became director of the National Institute of Environmental Health Services (NIEHS) in 1991, he set up a panel to evaluate the agency's toxicology research procedures.  The panel questioned the validity of rodent assays and the relevance of the maximum tolerated dose (MTD) test.which could find a product harmful at high dosage levels that might be acceptable at normal doses.

"The problem is we don't know what the findings really mean;," said Dr Robert Maronpot, chief of the NIEHS pathology laboratory.


In the institute's study of the industrial solvent 1,2,3-trichloropropane. all the test animals developed cancers, usually in several organs, but workers continued to use it to clean paint and grease from their hands.  A study of those workers' medical records would have been more
relevant.

A report in
Science 271m 12 January 1996, described one of the difficulties of "dozens" of non-animal testing methods confronting manufacturers.  Government agencies have been reluctant to accept new methods except on a "case-by-case basis".  E.g. In Vitro International's collagen matrix for assessing corrosiveness was approved for testing skin by the Department of Transportation, but the company had to resubmit its application to all the other agencies that might be involved.  Steps toward standardizing testing methods being taken by the EU might help the process along.

But this will not help protect humans from dangerous chemicals until scientists stop trying to relate results of these newer tests, which apply to humans, to the results obtained from animal testing.  Ironically, the results of animal tests, held up as a criterion that must be matched, have themselves never been validated.

Even if the information obtained from animal tests were valid for humans, which it isn't and never can be, there is no need to repeat tests that have already been performed.  It is only necessary to consult archived data from past testing.

The proposal to test or retest these common chemicals is symptomatic of a bureaucratic disease that imposes regulations upon entire human populations for the benefit of a vested interest, in this case, the animal research and chemical/pharmaceutical industry, or what Hans Ruesch dubbed the "CHE-ME-VI syndicate" in
Naked Empress.

Americans experienced it when it was decreed that all children's sleepwear must be impregnated with the fire-retardant (TRIS) in spite of the fact that it is classified as a carcinogen and in spite of the fact that children are no more likely to catch fire in their sleepwear than in their play clothes; also in spite of the fact that there is no requirement for treating their bedding.  One can't help but feel this requirement was instigated by the manufacturers of TRIS and similar chemicals.

British furniture manufacturers received a big boost in business when it was decreed that all upholstered furnishings and mattresses in rental properties must have been treated with a fire-proofing agent.  Landfills were choked with perfectly good furniture after the used furniture market became glutted with an oversupply while familes with helpless infants and infirm oldsters continued to live happily with older untreated furniture.

The Environmental Defense Fund proposal to submit or resubmit 2800 chemicals to animal tests that have no relevance for humans appears to be a similar maneuver.  It can only be prevented by intelligent opposition from informed citizens.  Alix Fano's scholarly , but eminently readable, book
LETHAL LAWS Animal Testing, Human Health and Environmental Policy  (click here for review) has turned out to be almost written to order for this issue whether for self-education or educating legislators and agency officials who are still unaware of how useless animal testing is for predicting human reactions.

The chapter headings and convenient subheadings tell the story:


1. Fatal connection: cancer and animal testing
The politics of cancer /7 
The debate over the causes of cancer /8 
Turning to animal testing for answers /9 

(Continued on page 85)