In just two weeks, over 400 members of the U.S. scientific community have signed onto our open letter denouncing the Environmental Protection Agency’s (EPA) September 10 directive. The directive, announced with continuing fanfare from anti-animal research groups, would reduce and eventually eliminate animal research and testing regardless of the availability of suitable alternative methods to ensure chemical safety and human, animal, and environmental health.
The signatories to our open letter include scientists with diverse expertise, including toxicologists, neuroscientists, biologists, psychologists, veterinarians, and others. Among them are individuals who have worked in federal agencies like the Food and Drug Administration and Department of Defense, in universities, health systems, the military, and pharmaceutical companies.
Have you signed onto the letter? If you have, thank you! Please also consider sharing it with your colleagues and members of the scientific community who are concerned about decisions that will have lasting consequences for public health.
The EPA’s directive runs counter to its stated mission to “protect human health and the environment” and “to ensure that national efforts to reduce environmental risks are based on the best available scientific information.” As these toxicologists, scientists, veterinarians, technicians, and other experts attest, this decision was not based on the best available scientific information. As the Union of Concerned Scientists wrote last week, we in fact “have no evidence that the EPA’s science advisory board (SAB) was given an opportunity to weigh in on this policy change.”
Other experts – scientific societies, organizations, and individual experts – have also weighed in on this policy in the past two weeks, all reaching the same conclusion: the EPA’s policy is disastrous and ill-conceived:
- The National Resources Defense Council wrote on 9/10/19: Trump Administration Guts Collection of Data on Toxic Chemicals
- Former EPA scientist Tracey Woodruff, now a professor at UCSF School of Medicine, weighed in on this article in the New York Times on 9/10/19 (also in print on 9/11/19): P.A. Says It Will Drastically Reduce Animal Testing
- The Society of Toxicology wrote on 9/11/19: SOT Statement on the US EPA Memorandum “Directive to Prioritize Efforts to Reduce Animal Testing”
- The Federation of American Societies for Experimental Biology, a coalition of more than 25 scientific societies representing over 130,000 researchers, wrote on 9/11/19: FASEB Statement on the EPA’s “Directive to Prioritize Efforts to Reduce Animal Testing”
- Jennifer Sass, senior scientist for the Healthy People and Thriving Communities program at the National Resources Defense Council, wrote on 9/12/19: EPA Attack on Science Targets Animal Tests
- John Richard Schrock, emeritus faculty at Emporia State University, wrote on 9/16/19: Education Frontlines: EPA directive to eliminate mammal tests is disastrous
- Richard L. Revesz, professor of law and dean emeritus at NYU school of law wrote on 9/26/19: Trump’s E.P.A Chooses Rodents Over People
- Laura N. Vandenberg and Thomas Zoeller, toxicology experts at UMass Amherst wrote on 9/20/19: Op-ed: Thinking through the EPA’s commitment to eliminate the use of mammals in toxicity testing
Despite what anti-animal research organizations would try to have the public believe, there is nothing radical about wanting clean air, clean water, safe food, and safe chemicals. What is radical is eliminating the best methods we have for ensuring the health and chemical safety of our nation before alternative methods are ready to replace them.
We will soon be sending this letter to the EPA and media. Make your voice heard.
Research with animals is undeniably critical to the EPA’s mission. This fact runs contrary to Mr. Wheeler’s claim that “new approach methods” or NAMs “exist today that allow us to better predict potential hazards for risk assessment purposes” than animal models. In fact, there is not a single case of environmental risk assessment where a non-animal alternative or methodology can provide a comprehensive understanding of the risks of new chemical hazards and potential human exposures. To regulate chemicals, the EPA must demonstrate that there are adverse effects in whole living organisms. While the EPA has reduced its reliance on animal testing in certain areas where it is possible to do so (such as testing corrosive chemicals on skin grown in a Petri dish), the EPA has not provided the relevant experimental, peer-reviewed data which demonstrate that “NAMs” are better than animals in assessing the safety of chemicals for other animals, including people, and for the environment.
The EPA’s decision is appalling given that it is not backed by scientific evidence. Nor does it appear that it included input from experts in toxicology, but rather it is informed by personal feelings and campaigns by known absolutist organizations that are staunchly against all animal research. The fact that the EPA’s press release on this directive highlighted and quoted leaders of People for the Ethical Treatment of Animals (PETA), White Coat Waste Project, Physicians Committee for Responsible Medicine, and the Humane Society of the United States, yet did not quote a single scientist, is alarming. The fact that only one set of stakeholders were represented in this decision, and not other stakeholders including experts from relevant disciplines or organizations that represent various health and ethical interests (e.g., bioethicists, the American Heart Association, the American Cancer Society, etc.), raises serious concerns about how policies at the highest level of America’s government are developed and enacted.
We, the undersigned members of America’s scientific community, denounce the EPA’s directive to aggressively reduce animal testing and end research with mammals under arbitrary deadlines. We call on the EPA to withdraw this directive. We understand the important role that research animals have in determining what is safe for humans, for other animals, and for the environment. Any individual or group who purports to value animal lives should support the responsible study of a very limited number of animals to ensure the health of us all – human and animal alike.