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EU chemical testing on animals

EU chemical testing on animals

*    Millions of wild animals are exposed to thousands of man-made chemicals that contaminate their environment. Friends of the Earth wants tough new regulations to dramatically reduce this contamination.

*    It has been suggested that, in order to achieve this, Friends of the Earth supports an EU programme of increased animal testing. This is untrue.

*    Friends of the Earth is calling for a reduction in the use of animal testing through tighter regulation, banning risky chemicals without the use of animal tests, and increased research into alternative, non-animal, testing methods.

*    Current EU legislation on chemical testing relies heavily on animal experiments. Friends of the Earth does want safety assessments for all chemicals in use. We do not, however, support an extension of the current testing and regulatory system to all existing chemicals. Instead we are campaigning for an open and precautionary regulatory system which will both reduce the risks posed by chemicals and reduce animal testing.

Chemicals threaten wildlife

Chemical pollution is damaging a wide range of wildlife, including whales, dolphins, otters, polar bears, birds, fish and other sea life. Persistent chemicals (which do not biodegrade easily) and bioaccumulative chemicals (which build up in body fat) are of particular concern. Wildlife is exposed to thousands of chemicals from consumer products, industrial processes, sewage effluents and waste disposal. Only 14 per cent of the chemicals used in high volumes in the EU today (over 1,000 tonnes per year) have a full minimum set of safety data, whilst 21 per cent of these have no publicly available safety data at all; there is even less safety data available for more than 25,000 other chemicals on the market which are used in smaller volumes.[1]

Brominated flame retardants (widely used in electronic equipment and textiles) have been found to contaminate the blubber of sperm whales in the remote deep waters of the Atlantic. [2] Fluorinated organic compounds (used as pesticides and refrigerants) break down to produce a highly persistent acid which accumulates in lakes and wetlands and threatens wildlife.[3] Hormone-disrupting industrial chemicals have been found to cause falling fertility (in birds, fish, shellfish and mammals); birth deformities (in birds, fish and turtles); demasculinisation and feminisation (of fish and birds) and also damage to the immune system (in both birds and mammals).[4]

Better regulation is needed

In the light of this serious threat to wildlife and humans, Friends of the Earth believes that the current system of chemicals regulation is inadequate. The EU is currently in the process of a 'once in a lifetime' review of this system, and Friends of the Earth, along with other groups across Europe, has formulated the 'Copenhagen Chemicals Charter' - our proposals for an open and precautionary regulatory system (see below). The RSPCA's European umbrella group, Eurogroup for Animal Welfare, has published a position paper [5] describing how the Copenhagen Charter can be implemented whilst reducing animal testing; this position is supported by Friends of the Earth.

The Copenhagen Chemicals Charter

1)         A full right to know, including which chemicals are present in products.



2)        A deadline by which all chemicals on the market must have had their safety independently assessed. All uses of a chemical should be approved and should be demonstrated to be safe beyond reasonable doubt.

3)         A phase-out of persistent or bioaccumulative chemicals.

4)        A requirement to substitute less safe chemicals with safer alternatives.

5)        A commitment to stop all releases to the environment of hazardous substances by 2020.

The role of these principles in reducing animal testing

*    A phase-out of all persistent or bioaccumulative chemicals. Persistence can be established without animal experiments; bioaccumulation can be determined by simple chemical tests and environmental sampling. Such chemicals will then not have to go through toxicity testing on animals.

*    The requirement for all uses of a chemical to be 'safe beyond reasonable doubt' reduces the amount of evidence required to phase-out a chemical. This should prevent more and more animal experiments being done by industry to rescue a chemical from a ban, and could allow 'reasonable doubt' to be created by in vitro tests (test-tube based experiments).

*    The provision of a deadline for safety assessment will remove many chemicals from the market without further testing. We also believe that industry must pay the full costs of any tests and for an independent assessment of the safety of their chemicals. Similar provisions in pesticides legislation have got rid of many chemicals without any testing at all, because industry doesn't consider it financially worthwhile to spend the money necessary to test them. In addition, testing should be done in a step-wise manner, starting with persistence and bioaccumulation, existing data, computer-based techniques and in vitro techniques, as proposed by Eurogroup [5].

*    The substitution principle should lead to the phase-out of a less tested chemical if:
    a) low-toxicity alternatives are available    
    b) it can be replaced by a non-chemical technique, without any further toxicity testing.

*    We want much more rapid development and use of in vitro tests, computer-based (QSAR) methods, and the grouping of chemicals to reduce animal testing requirements. The reduction in the burden of proof for the phase-out of a chemical is a crucial step in enabling these techniques to displace animal testing.

Friends of the Earth (FOE) considers that the continued use of chemicals which have had little or no safety testing is a threat to humans and to wildlife. Countries such as Sweden and Denmark are already adopting policies similar to those proposed by FOE. In contrast, both the UK Government and the chemical industry refuse to move away from a policy that requires that chemicals must be proven dangerous - through animal testing - before they are banned.
FOE believes this approach is not acceptable. The Copenhagen Charter, implemented as laid out by the RSPCA/Eurogroup [5], will lead to an avoidance of animal testing to the utmost extent, and

make the regulatory system open and precautionary - so protecting both wildlife and people from unsafe chemicals.

References

1.    European Chemicals Bureau
    www.ei.jrc.it/report/ecb.html
2.    Do flame retardants threaten ocean life? Nature 394, p28-29, 2nd July 1998
3.    Fluorinated organics in the Biosphere, Howell and Criddle (1997) Environmental Science and Technology 31:2445-2544
4.    Colborn et al (1992) Advances in Modern Environmental Toxicology, vol 21, Chemically-induced alterations in sexual and functional development: The Wildlife/Human Connection, Princeton, Princeton Scientific
5.     http://www.fbr.dk/chemaware/newslet/issue12/article13.html

Further reading

Crisis in Chemicals                FOE briefing
Poisoning our children                FOE briefing

The Royal Society Report on endocrine disrupters:
www.royalsoc.ac.uk/templates/statements/StatementDetails.cfm?statementid=111

WWF Report on endocrine disrupters & wildlife (with a list of wildlife impacts):
www.worldwildlife.org/news/pubs/toxics/tox.htm
December 2000



For further information on our Safer Chemicals Campaign please contact:
Friends of the Earth
26-28 Underwood Street
London N1 7JQ
Freephone:     0808 800 1111
Email:     info@foe.co.uk
Web:         www.foe.co.uk/campaigns/safer_chemicals/