A NEW directive from the European Union could result in a number of familiar, household chemicals being re-tested on animals for safety purposes, simply to be manufactured or imported to the UK legally.
Representatives from the Kennel Club recently attended a meeting of the Government’s Parliamentary and Scientific Committee, which was discussing the proposed EU Chemicals Directive and its implications for research on animals.
The proposed REACH (Registration, Evaluation and Authorisation of Chemicals) regulation would require businesses that manufacture or import more than one tonne of chemical substance per year to register it on a central database.
It is expected that the introduction of REACH will ensure that the current ineffective and cumbersome system of regulating chemicals will become more coherent and give greater responsibility to industry to manage the risks from chemicals and provide safety information on the substances, as presently there is a lack of knowledge about the dangers of many chemicals on the market.
The introduction of REACH will mean that ‘existing substances’ will need to be registered to ensure their safety. It is estimated that there are around 30,000 chemicals in existence today that may need re-assessing with regard to their safety and potential hazardous effects when humans are exposed to them.
However, whilst there is some existing information for a large number of these chemicals, many of them have either insufficient evidence available or have not been tested at all. This would mean that those chemicals with little or no information would need to be re-tested, with the probability of these tests being carried out on animals.
Although the directive states ‘programmes using animal tests should be curtailed as far as possible and the development of new methods of non-animal testing promoted’, many of the alternative tests mentioned, such as computational techniques made up of chemical and molecular testing, do not in fact exist at present.
This could therefore result in many ‘everyday’ chemicals contained in household products, being re-tested on animals, when in fact there is no danger to the public.
The Kennel Club is supporting the Fund for the Replacement of Animals in Medical Experiments (FRAME) in their campaign that advocates a sensible approach to testing. For example, there is little merit in re-testing chemicals, for other problems, when it is known that they are carcinogenic in their make up.
Furthermore, FRAME supports the development of chemical and molecular computational techniques and that in vitro, or cell structure testing is strongly featured as an alternative to animal testing.
During discussions on the directive, the Kennel Club was concerned to learn that dogs are used as the default ‘second species’ in laboratories, just after rats. The reasoning for this is that should a second species be required for testing purposes, scientists do not need to justify the use of a dog unlike the use of other species, such as a non-human primate. The Kennel Club is not endorsing the use of any one animal in testing procedures over any other, but we are troubled by the possible use of thousands of dogs to test many chemicals that are clearly not hazardous to humans.
The Fund for the Replacement of Animals in Medical Experiments initiative on the EU’s chemicals policy is outlined on the organisation’s website and says:
‘The FRAME initiative is intended to ensure that non-animal methods such as computer modelling and cell culture are strongly featured in any strategy for assessing the circa. 30,000 existing chemicals for which safety data are deemed to be inadequate.
Recently FRAME has established a number of initiatives, including:
1. A report from ECVAM (European Centre for the Validation of Alternative Methods) has been published in ATLA and will form the basis for FRAME's proposals relating to the use of non-animal approaches in toxicity testing.
2. The FRAME Toxicity Committee has formed a working group to discuss ways in which in vitro data can be used for risk assessment purposes, instead of or as a complement to animal data.
3. Funding is being sought for a FRAME research project on the development and validation of computerised QSAR and expert systems for hazard prediction and prioritisation of chemicals for testing.
Meanwhile, the British Union for the Abolition of Vivisection (BUAV) was one of several animal rights groups from the European Coalition to End Animal Experiments (ECEAE) held a demonstration on April 20th outside the Chemicals Industry Association (CEFIC) in Brussels, Belgium, to mark World Week for Laboratory Animals 2004 to protest against the use of cruel animal tests by chemical companies.
The BUAV attended the demonstration as part of their ‘Harmful If Swallowed’ campaign opposing the use of animal toxicity tests.
A BUAV spokesperson said: "Chemical testing has been in the spotlight since the European Commission published proposals for a future chemical strategy (REACH) in October 2003.
"REACH aims to introduce a new framework for chemicals regulation, but at its heart is a collection of some of the cruellest animal tests used. Millions of animals will be force-fed toxic substances and suffer sudden or gradual poisoning. Although a few animal tests have already been replaced by modern non-animal techniques, millions of animals will still suffer in outdated and discredited poisoning tests unless urgent action is taken.
"Whilst the ECEAE supports the need for a new chemical regulation, it demands the use of an entirely non-animal testing strategy and calls on CEFIC to do more to develop non-animal tests in time for REACH."
The ECEAE and the BUAV have stated that animal tests are not only cruel but also unreliable and lacking relevance to real toxic effects in human beings.
A BUAV/ECEAE published a paper in March 2004 demonstrated that animal test data can confuse regulators because of the lack of relevance to human health effects and the difficulties extrapolating results from animals to people or from laboratory doses to real life exposure. In the very worst cases, substances thought to be safe after animal testing can be released onto the market, endangering human populations and the environment.
The Kennel Club, along with other concerned organisations, is keen that Government debates the detail of the directive fully when it is put before the House of Commons on May 12th and consider the necessity of allowing animal testing to take place where it is not essential.
A KC spokesman said: "Time is obviously against us, and a primary concern is that this could go through ‘on the nod’, without being debated thoroughly and all avenues explored. We would request that dog owners consider writing to their MPs to ensure that they attend the debate, thoroughly discuss the issue, and vote against the directive in it’s current form.
"We fully appreciate that the issue of animal testing is a ‘hot potato’, but we really believe that this issue needs to be discussed thoroughly prior to any decision being reached, as it has welfare implications for a great number of dogs."