The EPA Procrastinates
An Animal Rights Article from


Anai Rhoads
June 2003

"Animal testing seems to function mostly as a mechanism to frustrate demands for accountability [since] conflicting results beget endless studies that ensure inaction. It is the ambiguous results and subjective interpretations of animal studies that have created an atmosphere conducive to arbitrary and capricious decision-making, allowing regulatory agencies to be driven by pressures of market interests over concern for public health." -- American Association for Science and Public Policy.

Organisers for the People for Ethical Treatment of Animals (PETA) did not let the rain stop them as they gathered Friday May 9th in front of the United States Environmental Protection Agency's (EPA) headquarters in Washington, D.C. to protest the EPA's continued disregard for animals.

Holding signs that read "Animal Tests Kill People Too!" the organisers displayed two decomposed corpses (mannequins) to emphasise to the crowd that the EPA's mishandling of chemicals is hurting humans as well as animals.

Brandi Valladolid, who is a long-time organiser and supporter for PETA, arranged the protest along with seven others in hopes of shedding light on this very important issue. "Not only are animals unnecessarily abused and killed during the EPA's experiments, but is affecting humans as well. Our health is at stake because the EPA refuses to do anything about it," Valladolid expressed during our post-protest interview. "Scientists have spoken out on this subject as well, only solidifying the importance of resolution with regards to the EPA's policies."

The EPA claims certain animal testing programs are intended to protect our health by evaluating the risk of a variety chemicals that are deemed toxic to humans. This of course has become the biggest excuse for chemical companies to continue to conduct tests with the EPA backing them up.

The most common tests include:

  • skin corrosion
  • absorption testing
  • eye irritancy studies
  • lethal dose (acute poisoning) tests

These tests require forcing the animals to ingest, inhale, or receive the chemical via injection. According to PETA, the standard battery of animal tests for pesticides intended for our food, includes nineteen separate animal tests performed on thousands upon thousands of dogs, hamsters and rabbits. The very animals we consider pets for our children.

The EPA demands far more animal-based chemical toxicity testing than any other federal agency. Yet in more than ten years, the EPA has not banned a single toxic industrial chemical using its authority under the Toxic Substances Control Act, despite killing hundreds of thousands of animals and despite urgent calls to limit chemical exposures.[1]

Not long ago, the EPA had purposely excluded the animal welfare and protection communities from its policy directories. Basically, outside organisations had no say in the decision making process for fear that it would lead to exposure on the EPA's underground experimentation on millions of animals.

In 2002, PETA managed to convinced Congress to examine alternatives that would force the EPA to acknowledge and develop their own non-animal methods. Congress ordered the EPA to spend four million out of their big six hundred million dollar research and development budget to explore other options. The funds put aside have never been used as the EPA insists there is little evidence that this is needed.

The following is a brief overview [2] of the newer tests that may be used in the High-Production Volume (HPV) program to reduce or eliminate animal use:

Acute Toxicity can be studied using cell culture (in vitro) systems, since the actions of toxic chemicals are often focused at the cellular level.

For example, a series of four cell culture tests can predict toxicity in humans with nearly 85% accuracy (compared to 65% in acute toxicity studies using animals). This method should, within several years, be able to replace the use of animals in acute lethal poisoning testing.

Repeated Dose Toxicity can be studied using cells cultured from different body tissues to estimate the effects of a chemical on different organ systems. For example, human liver cells in culture could be exposed to repeated, low doses of a chemical in order to study how it is broken down and metabolised by the body and to identify any toxic by-products (metabolites) that may be produced in the process. Stable human cell cultures have been produced for kidney, nervous, immune, reproductive, and other essential organ systems. A tiered testing strategy that combines several of these tissues in culture with the use of computer and mathematical modelling, has the potential to do away with animal use in repeated-dose toxicity studies.

Reproductive Toxicity and aspects of male and female reproductive function can be modelled to some extent in vitro, and several cellular components of reproductive organs can be maintained in cell culture. Although no test method has yet been used or validated for routine use in reproductive toxicity studies, it is possible that a battery of such systems may in the future be able to model a large proportion of the male and female reproductive cycles, thereby reducing or replacing animal use in reproductive toxicity testing.

Developmental Toxicity (Teratogenicity) can be studied in cell culture using an embryonic stem cell test, which is currently being validated as a screen for birth defects.

Preliminary reports indicate that the in-vitro embryonic stem cell test can predict toxicity in humans with over 80% accuracy.

It is hoped that within several years, this method will be able to eliminate animal use in developmental toxicity testing.

Genetic Toxicity can be studied entirely without the use of animals. Three methods in particular (the Bacterial Reverse Mutation Test, In-Vitro Cell Gene Mutation Test and In-Vitro Chromosomal Aberration Test) have been accepted by government regulators world-wide as valid alternatives to using animals. As such, genetic toxicity testing in animals should be discontinued immediately.


Structure Activity Relationship (SAR) analyses use computers to seek to predict adverse biological effects of chemicals based on their molecular structure, weight and electronic charge. SAR data can be used to estimate whether a specific chemical produces a particular biological response, including toxicity, without recourse to animals. Such approaches have shown 85 to 97% accuracy in predicting dermal sensitisation, teratogenicity and carcinogenicity for related groups of chemicals.

Computer-based Mathematical Modelling involves the use of computers to model living biological systems, such as the human circulatory and respiratory systems. For example, physiologically based bio-kinetic models (PBBKs) use computers to study the absorption, distribution, metabolism and excretion of a chemical by the body. They can also be used to determine the relationship between the dose of a chemical and a particular metabolic effect. One such model, the ED01, studies tumour production in response to chemical exposure.

It can detect an increased tumour activity of 1%, and at doses of a chemical much lower than those customarily used in rodent studies.

Due to the EPA's lack of initiative with regards to research and implementing development of non-animal experiment options, they have displayed an unwillingness to co-operate in defusing an ever increasing distaste from the public.

The current Administrator of the EPA, Christine Todd Whitman, has delayed taking any measures. This has resulted in many animal deaths as well as put humans in harms way.

Contact Christine Todd Whitman at the head office of the EPA and urge her and the EPA to take action now! Put a stop to this senseless violence against animals. Ask Mrs. Whitman why she has not implemented non-animal testing even after Congress ordered it.

The Honourable Christine Todd Whitman Administrator (1101A) U.S. Environmental Protection Agency 1200 Pennsylvania Ave. N.W. Washington, DC 20460 Fax: 202-501-1450 E-Mail:  

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[2] PETA - HPV

Further Reading:

Mercury Inhalation

Metal Bio-availability

High-Production Volume (HPV) Chemical Testing Program

Endocrine Disruptor Screening Program (EDSP)

Voluntary Children's Chemical Evaluation Program (VCCEP)

Download a copy of PETA's DNT Fact Sheet (PDF required).

Copyright 2003 Anai Rhoads. Permission to reprint this article in its entirety may be granted with a written request to the author: Anai Rhoads She may be reached at (703) 491-0176

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