Better Science
VIII. CHALLENGES TO ALTERNATIVES
In addition to the resistance described above,
more direct threats to the adoption of alternatives and promotion
of animal-based testing protocols may come from massive new testing
programs being proposed by such federal regulatory bodies as the
Environmental Protection Agency (EPA).
For the past few years, under pressure from politicians as well
as consumer and environmental organizations, the EPA has proposed
new testing requirements that will kill millions of animals, tailored
to:
-
High Production Volume Chemicals (HPV)
-
Endocrine Disruptors (ED)
-
Children's Health Initiative (CHI)
Nearly identical programs have also been proposed for the European
Union (REACH) and internationally (OECD). In all cases the respective
regulatory agencies have used the new testing mandates to promote
existing or create new animal-based testing procedures - usually
without the rigorous levels of validation and proof of principle
still required for in vitro replacement alternatives. If needed,
the new testing requirements could be used as incentives to finally
create an alternatives-based, humane approach to assessing human
health and safety. The fact that tens of thousands of chemicals
have been and continue to be produced without adequate safety/risk
assessments is a clear indication of the historical failures of
in vivo approaches and not a reason to massively expand such inappropriate
approaches to testing.
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