Unnecessary test proposals are withdrawn following our comments
Since the beginning of the EU’s REACH chemical safety programme, the European Chemicals Agency (ECHA) has published over 1,500 animal test proposals for chemical substances, giving third parties the chance to offer feedback.
Thanks to the generosity of our supporters Cruelty Free International’s science team were able to comment on 540 of these proposals.
We can now reveal that that our advice was influential in 76 cases, helping to save over 80,000 animals from tests that should never have been suggested in the first place.
Overall, our comments were adopted by ECHA or the company conducting the tests in about 14% of cases, including tests for repeated dose toxicity, reproductive toxicity, and long-term toxicity and mutagenicity, typically involve mice, rats, rabbits, birds or fish.
Tests successfully withdrawn after our comments included: a test where a company wanted to conduct a 90-day repeated-dose study of 2,4,6-trinitrotoluene via inhalation. This substance is actually TNT! We argued that it is explosive and already considered harmful to humans so testing was dangerous, difficult and unnecessary. The proposal was withdrawn.
In another example, a company had proposed to test Slimes and Sludges from blast furnace and steelmaking in a two-generation reproductive test. We pointed out that the substance was actually of low toxicity, despite its name, and it was not registered at a tonnage level where the test was necessary. The company agreed and withdrew the testing proposal saving 2,200 rats.
Dr Katy Taylor, Director of Science and Regulatory Affairs at Cruelty Free International, says: “This outcome shows that animal protection organisations can play a vital role in helping companies avoid animal testing. Some of the proposals were made in error and were not even necessary according to the legislation. It is worrying to think that these tests may have gone ahead if we had not intervened.
“Renewed calls for an even tougher chemicals strategy in Europe could generate even more animal testing requirements, so the threat to animals is not over yet”.
For a more detailed review of test proposals and REACH regulation from an animal testing perspective, please see our papers: Taylor, K. Ten Years of REACH — An Animal Protection Perspective (2018) ATLA 46, 347–373 and Taylor K, Stengel W, Casalegno C, and Andrew DJ. Food for thought…Experiences of the REACH testing proposals system to reduce animal testing. (2014). ALTEX, 31: 107-128