Animal testing of chemicals raises emotions, understandably, as the idea of experimenting on animals is repulsive to most of us.

With the publication of the Commisson’s new chemical strategy, asking for more scientific knowledge and investigation of the chemicals that go into our everyday products, the moral dilemma of animal testing has leapfrogged to the forefront of the discussion.

What it all boils down to is that if we don’t want untested, potentially harmful, toxic chemicals in food packaging, home electronics and clothes – we need to test the chemicals. Apart from human testing, the most conclusive results can be achieved through animal testing, meaning there’s an apparent conflict between animal welfare and safe management of chemicals.

At ChemSec, we think it’s crucial to investigate the properties of chemicals designed for widespread societal use – preferably before they are put on market.

Fortunately, there’s a lot of information that can be gained though alternative methods, but there are also important properties that we cannot investigate without animal testing – yet.

“We are convinced that much more can be done to further reduce animal testing”

However, we are convinced that much more can be done to further reduce animal testing, even with the implementation of the new chemical strategy.

Use the precautionary principle and avoid paralysis by analysis

Having followed the process of the EU’s chemical legistlation REACH for years, it has become painfully obvious how easy it is to introduce doubt into discussions when identifying hazardous chemicals for regulatory action. The amount of evidence demanded before decision-making is often unrealistic and leads to what we call “paralysis by analysis” – no action is taken and hazardous chemicals stay on the market.

By asking for more data – more tests – one can postpone any decision for years, and this opportunity is frequently used. To a larger extent, regulators should be made to act on the data they have, which is many times plentiful, rather than ask for even more.

In other words: Make use of the precautionary principle to avoid unnecessary animal tests.

Let chemicals from the same family see the same regulatory action

Substances that are structurally similar and belong to the same chemical group tend to have similar hazardous properties. This fact has long been used by the industry to avoid testing costs when registering a new chemical from a known chemical group.

Now, regulators must also increase the use of this grouping approach when identifying chemicals for regulatory action.

Increase transparency and data sharing

Data sharing has been introduced in REACH in an effort to minimise costs and animal testing. Companies that produce the same chemical should share the costs and the results for the mandatory tests. If companies would also share non-mandatory data to a larger extent, in the public domain as well, repeated animal tests could be avoided.

Reduce, refine, replace

By applying “the three Rs”, even more could be done. Computer models are getting better and better, as are tests on lab-grown cells and tissues. Regulators must carefully consider when animal tests are needed, and when they are not. When assessing persistence, bioaccumulation or skin irritation, for example, animal testing is often unnecessary.

Once animal tests are performed, they should be used to gather the maximum amount of data. As many endpoints as possible should be measured, and potential future use kept in mind.

Animal tests are also called in vivo – in life. An important alternative to animal tests are tests on isolated cells, called in vitro – in glass. Much can be learned from studying how a chemical reacts within a cell; you can study mechanisms in great detail. There is a broad variety of cell types from different species and tissues commercially available.

In more recent times, opportunities to study the effects of chemicals in silico – using computer models – have also improved immensely. By introducing more and more test data into these systems, they get “smarter” and more accurate over time. For some endpoints, in silico models can be more reliable than in vivo tests, as you can avoid all kinds of methodological issues of “real” experiments.

However, effects involving larger parts of an organism, or extending over longer periods of time, such as growth, development and reproduction, are still not possible to fully capture and understand if not studied in vivo. In other words, serious adverse effects can be missed if all animal tests are avoided.

For that reason, we at ChemSec don’t see the possibility of completely avoiding animal tests today, if we want to understand potential threats to human health and the environment. Letting untested chemicals out on the market is exactly how we got here – with huge health and environmental problems linked to chemicals.

However, we are convinced that we can substantially reduce animal testing, without compromising the safety of human health and the environment.

Animal testing facts:

• About 10 million animals are used for scientific research and regulatory testing in the EU each year.
• 61% of these animals are mice, 13% fish and 12% rats.
• 23% of the animals are used for regulatory purposes.
• Out of these are 11% used for REACH (or 2,5% of the total number of animals).
• Animals without a spine (invertebrates) such as mussels, octopuses or crayfish are not counted.