Replacing Animals
in Chemical Testing

EPA Wants Your Comments
Your actions do make a difference for animals in labs and government agencies can be responsive to public concerns. After decades of requiring animal use in painful, lethal testing, the Environmental Protection Agency (EPA) is making an effort to replace many animal tests with alternative methods. And the EPA wants you to comment on its proposed plan.

This strategic plan is in response to the Lautenberg Chemical Safety for the 21st Century Act, which passed last year and amends the 40-year-old Toxic Substances Control Act. Now we must continue to be proactive to help ensure the changes EPA eventually adopts are meaningful.

EPA aims to modernize chemical testing by promoting alternatives that “provide information of equivalent or better scientific quality and relevance for assessing risks of injury to health or the environment.” Overall, AAVS supports this effort, but cautions that communication, co-operation, data sharing, promotion of existing alternatives, and funding will be necessary for there to be a smooth and timely transition to the use of modern, non-animal testing methods.

EPA’s plan must be implemented in just seven months, so we must continue to voice our opinions on this issue.

What you can do!
Please contact the EPA and tell the agency that you support chemical testing reform and efforts to replace the use of animals to evaluate chemicals. You can use the sample letter below. Deadline to submit comments is January 10, 2018.

DIRECTIONS TO SUBMIT COMMENTS TO THE ENVIRONMENTAL PROTECTION AGENCY:
To submit your comments to EPA, go to:
“The Environmental Protection Agency (EPA) Other: Memo authorizing the opening of a comment period for this docket.

  • Click on the dark blue “Comment Now!” button on the right.
  • In the comment box, tell the EPA that you support chemical testing reform and efforts to replace the use of animals to evaluate chemicals. You may copy and paste AAVS’s sample letter below or submit your own personal comments.
  • Under the comment box, click the blue “Continue” button.
  • Preview your comments. Scroll down and check “I read and understand the statement above.” Click “Submit Comment.”
  • You should receive a notice that “Your comment was submitted successfully!”

SAMPLE LETTER
I support the EPA’s proposed strategic plan to incorporate the development and use of alternatives to refine, reduce, and replace animals in chemical testing. Because toxicity testing often involves severe animal suffering, particularly in lethal dose testing, I’m encouraged by the EPA’s desire to modernize chemical testing in the U.S., which will not only be good for animals but science as well.

There are some important points I want to emphasize. First, EPA should define and thoroughly explain the information that companies need to meet regulations to help prevent unnecessary animal testing. Promotion of already existing non-animal protocols, particularly in the early stages of implementing EPA’s proposed strategy, should be included with this information.

I also ask EPA to continue to have an inclusive environment in which other agencies, industry, animal advocates, international regulators, and academia all feel comfortable and welcomed to contribute to this matter. I think this would help facilitate harmonization of international laws.

I support EPA’s effort to refine, reduce, and replace animals in chemical tests. I believe that the public benefits when EPA encourages use of alternatives to replace animal testing.
Thank you for your time and attention.