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EU CHEMICALS POLICY - Make your voice heard
Posted 1 July 2003
European Citizens have an opportunity to join in the European Commission's "Your Voice In Europe" internet consultation about the new EU Chemicals policy. What follows is a guide to taking part in the consultation, produced by the BUAV.
The EU Chemicals Policy as it is currently proposed will mean subjecting millions of laboratory animals to painful chemical poisoning experiments. These animal toxicity tests are not only hideously cruel, they are also outdated and scientifically unreliable, being poor predictors for human beings.
The Commission has launched the internet consultation (closing date 10th July 2003) so this is your chance to get your views heard.
The two website pages that have been set up by the Commission to receive responses are both unnecessarily complicated and unreliable. Therefore the BUAV recommends that instead you follow the instructions below and send your submission to the following email address: firstname.lastname@example.org
How to take part online
- Your submission should be pasted into the main body of the email (do not send an attachment).
- At the top of the email detail your name, full address (including country), telephone, fax and email (where relevant), each on a separate line.
- If you do not wish your name to be published along with your submission on the Commission's website, type in bold "I would like my identity to be kept confidential"
- On the next line type "Primary activity: EU Citizen"
- Read the section below called "Background Information" - this section is for your use only and not for submission. It will provide you with some helpful background information on areas you may not be familiar with. It also includes background notes relating to the specific submissions.
- Next, type in your submission by copying the BUAV's "Internet Consultation Submission" section. Make sure each comment section is under the appropriate title provided.
- Send your email to email@example.com
This is for reference, do not send this section as part of your submission
The BUAV will be submitting a highly detailed and full response to the consultation document, in which we will outline a non-animal testing strategy similar to that already published in our document 'The Way Forward: A Non-Animal Testing Strategy for Chemicals'.
It is important to note that, whilst recognising our collective opposition to all animal testing and promoting a strictly non-animal test strategy for the EU Chemicals Policy, the EU Commission's draft consultation document is assuming that animal testing will indeed form a significant part of the overall strategy. As stakeholders it is our duty to comment on all issues that have relevancy for laboratory animals.
In some sections, therefore, such as the section on Chemical Safety Assessment, we are commenting on measures relating to a system of animal testing that we do not endorse, but that nevertheless requires input from animal advocates to ensure that even in these areas, important measures that could stop duplicate animal testing, for example, are included in the final proposals.
The Commission's proposed system for chemicals is known as REACH, which stands for 'Registration, Evaluation and Authorisation of Chemicals'. You will see these terms used throughout this mailing. Each chemical substance will pass through Registration (where test data or test plans will be made available to authorities), many will be evaluated ((where test proposals and data are checked by the authorities) and some - those with particularly damaging properties - will be 'authorised' for specific uses or taken off the market where their use cannot be justified.
The new system also emphasises a 'duty of care' placed upon industry to use and market chemicals safely. In order to fulfil the duty of care requirement, companies must carry out a chemical safety assessment for each substance, and for that they must gather data that can be passed on to other companies using the substance. Animal testing is currently required to compile a Chemical Safety Report. The BUAV will of course be opposing the requirement for animal testing, but even if we are unsuccessful, we must ensure that there is a clear guarantee that such testing will be subject to data sharing and other measures designed to avoid animal tests.
The Commission has highlighted a number of different sections on which submissions can be included. Not all of these are relevant to the animal testing issue and so here we have only asked you to send in comments on the most relevant areas. This Background Information section includes notes on some of these areas (below) which may be helpful to you.
A. Chemical Safety Assessment: In the proposals at present, animal testing required for the Registration phase of the EU Chemicals Policy is subject to data sharing provisions, stepwise testing strategies and other measures designed to make the use of animal tests 'a last resort'. By contrast, any animal testing proposed to be carried out for the purposes of completing Chemical Safety Reports is not explicitly subject to the same provisions. There can be no doubt that, if a large programme of chemical animal testing does go ahead, measures such as data sharing and stepwise strategies etc will greatly reduce the number of animal experiments performed. Therefore these measures must be imposed in all areas.
C: Data Requirements: Unless non-animal tests are brought into use at the earliest possible opportunity, the proposed EU Chemicals Policy will lead to a massive increase in cruel toxicity testing. Because traditional animal toxicity tests also lack scientific credibility, there is no guarantee that harmful substances will be properly identified and controlled by testing on animals.
E: Evaluation: At present, animal advocates such as the BUAV would not have the opportunity to scrutinise any proposed test strategies that include an element of animal testing. If we were given the opportunity, we may be able to demonstrate that sufficient data already exists for that chemical and therefore further testing is not required, or that a suitable non-animal test method exists to replace the animal test.
G: The Agency: Measures to prevent duplicate animal testing, must be centralised and open to the scrutiny of animal protection organisations.
Internet Consultation Submission
Send this section in your submission to the email address above
A: Chemical Safety Assessment
Animal testing should not be carried out for the purposes of completing Chemical Safety Reports. If any animal tests are carried out, all such testing must be subject to rigorous data sharing provisions, stepwise testing strategies, and other measures designed to avoid animal testing.
C: Data Requirements
Animal based toxicity testing is scientifically flawed as well as ethically unacceptable. Animal test results are unreliable when applied to human beings and misleading when compared to real life exposure. Animal toxicity tests have also not been validated to modern standards. The proposed Chemicals Policy offers the EU an opportunity to lead the world in the use of modern non-animal tests. By using fast & efficient non-animal tests, it is possible to gather enough relevant information on large numbers of chemicals to classify and regulate harmful substances. For a detailed proposal on how data-requirements can be met using non-animal test methods, please see the submission made by the BUAV (British Union for the Abolition of Vivisection).
D: Data Sharing/Consortia formation
For registering either phase-in or non phase-in substances (those in use already and those marketed for the first time), if a company will not participate in data sharing arrangements that company must be subject to penalties for non-compliance with measures designed to prevent duplicate animal testing. If a company refuses to share data, the registration should be refused.
All proposals for animal testing should be made public for 120 days (as happens in the USA under the High Production Volume Challenge Program). This public comment period would allow public scrutiny of test plans, so that further data can be brought forward in order to prevent duplicate animal testing.
Where chemicals are Authorised because they possess a particular hazardous property, animal testing to investigate other properties should stop on the grounds that the chemical is already known to be hazardous and its use should be restricted.
G: The Agency
A central unit should exist within the Agency to handle prevention of duplicate animal testing including overseeing arbitration set up to mediate between companies unwilling to share data. Only a centralised system is guaranteed to prevent duplication of animal testing. There must be appropriate contacts between the Agency and representatives of animal protection organisations, in addition to those already proposed for industry and environmental/consumer groups.
The use of animals to test chemicals is immoral, and whilst rapid action is needed to restrict the use of harmful substances, animal testing is not an appropriate way to achieve that end. Non-animal tests do exist, and our knowledge of these non-animal tests is growing all the time. Non-animal testing and proper use of pre-existing data (including from human exposure) is the only ethically acceptable way to restrict the use of harmful substances.
There are countless substances marketed today that are known to be harmful to people and the environment. Animal testing has not helped to prevent their use.
For new chemicals, the actual 'need' for a substance must also be measured: we can do without another brand of paint or oven cleaner, or any other 'new improved' chemical product when its development means the death of thousands of animals.
The European Commission must also increase efforts to hasten the development and validation of new non-animal tests. At present EU funding in this area represents only a tiny fraction of the overall research budget, and far more can be done. The Chemicals Industry should be compelled to meet its obligation to provide funding, laboratory space, personnel and data to be used in non-animal test validation studies. There is widespread agreement that non-animal testing is the way forward: it is time to make the vision a reality.