National Anti-vivisection Society


National Antivisection Society

EU chemicals testing: Environment Committee vote

The Environment Committee vote

Our campaign activity built up to 4th October 2005, when REACH came before the EU’s Environment Committee.

In March, ‘Keep animals out of REACH’ provided MEPs with a detailed non-animal testing strategy in place of the animal testing. Importantly this did not call for the abandonment of REACH altogether, but rather heralded it as an opportunity to modernise testing across Europe with the very latest methods. Indeed, we called for REACH to become the catalyst for accelerating the development and acceptance of new, more reliable science. The report proved so popular that we had to reprint it!

We followed this with a report of an exposé of experiments at Inveresk Research in Scotland – a contract research organisation already advertising to take on tests that would be required by REACH. This gave MEPs the grim reality of animal testing – crude, brutal, unscientific. A vote for REACH in its current form was a vote for the horrors outlined in our report.

In September, immediately prior to the Environment Committee meeting, we published a new report specifically on acute toxicity testing. An experiment at Inveresk in which rats choked to death on paint was analysed in detail the context of the Annex V proposals of REACH, and we explained why it should never have been allowed to take place. We were able to show: species differences, discrepancies in the experimental report; a lack of relevance to the human situation; that data was already available; that it should not have been allowed under the Dangerous Preparations Directive (1999/45/EC); and that alternative, non-animal, testing methods were available.

With the launch of our REACH Acute Toxicity report, we urged support for a non-animal alternative strategy, which not only proposed and justified alternatives to animal tests for acute toxicity, but also alternatives to the skin sensitisation, reproductive toxicity, eye irritation, and repeated dose toxicity animal tests, amongst others. Green Party MEP Caroline Lucas should be commended at this point for her determination throughout the REACH campaign to remove the animal tests it called for.

After years of lobbying, we did not get everything we wanted at the Environment Committee, but we did achieve some significant victories–

  • Mandatory Data Sharing – no sharing of animal test data leads to loss of right to register a substance. This means that, as a condition of registering their chemical for use in products sold in the EU, companies using the same chemicals would have to share animal test data with each other as a requirement of registration. This is critical for avoiding the duplication of animal tests between, often competing, commercial companies.
  • ‘One Substance, One Registration’ (OSOR) a proposal from the UK and Hungarian governments, backed by NAVS/ADI. All companies wishing to register for manufacture or import of the same chemical, must share data and register together, thus avoiding the risk of duplication of animal tests.
  • REGISTRATION FEES – part of the registration fee to be used for development of alternative test methods
  • EXISTING test data to be published to prevent duplication.
  • AUTOMATIC replacement of animal tests with alternatives as soon as alternatives become available
  • A NEW COMMITTEE ON ALTERNATIVES at the new European Chemicals Agency (ECA), with a range of stakeholders involved, to progress introduction of alternatives
  • REPLACEMENT OF ANIMAL TESTS listed in ANNEXES V and VI of the REACH document to be replaced by the non-animal testing strategy – this victory indicated a quantum shift on attitudes to animal experimentation. The 20 amendments passed by the Environment Committee covered: replacement of animal test for skin sensitisation; replacement of animal mutagenicity studies; in-vitro test strategy for acute toxicity; replacement of animal test for skin irritation; deletion of animal test for eye irritation; addition of further in-vitro mutagenicity studies; replacement of animal tests for repeated dose toxicity; replacement of animal test for reproductive toxicity; replacement of animal test for fish toxicity; non-animal mutagenicity tests; repeated dose toxicity; replacement of animal test for reproductive toxicity; deletion fish toxicity testing; mutagenicity; deletion of long term animal repeat dose toxicity test; deletion of animal test for reproductive toxicity; replacement of animal test for carcinogenicity; deletion of long term bird reproductive toxicity study.

The list of successes here almost replicates our campaign demands, as outlined on our postcard – so be aware you played a role helping this happen.

However, there were many more hurdles to go, and the next one was the First Reading of the REACH proposals in the full European Parliament on 17 November, 2005.

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