The Trump EPA is planning to significantly reduce the number of animals used in chemical testing over the next 16 years. Administrator Wheeler has signed a directive that will eventually eliminate these tests and reduce study requests and funding for some animal testing by 30%. To that end, the agency has awarded $4.25 million to scientists at universities to help develop alternative methods for testing chemicals. This is part of a shift by many federal agencies toward comprehensive testing strategies that include the use of emerging methods and data streams.
While on the surface, this announcement appears to be about protecting the lives of animals, there’s more here than meets the eye. Most of the chemicals we encounter in the environment have never been fully tested for their ability to harm us. This includes chemicals in many of the products we use every day. The law that covers many of these chemicals, the Toxic Substances Control Act (TSCA), created a system in which the government—and our tax dollars—must prove most of the 86,000 chemicals listed in the TSCA inventory harmful after they’ve already been on the market. And it probably goes without saying that the goal of chemical companies is to make sure chemical tests do not reveal harm.
As NRDC explained nearly a decade ago, manufacturers of the chemicals found in our products, homes, and bodies are heavily invested in protecting their products. Whether scientists use animals or emerging data streams to generate data, the chemical industry aims to keep the chemicals they use or manufacture on the market for the longest amount of time possible. The industry uses all of the tools at its disposal to manipulate the regulatory process to hide the harmful nature of their chemicals.
In a chemical testing system that depends heavily on animal testing, the chemical industry’s main goal is to delay. Keeping chemicals in a time-consuming loop of testing and litigation continues or increases revenue streams.
In a system that relies mainly on rapid computer, cell, and protein-based testing, the name of the game is speed.
Emerging methods in chemical evaluations hold a great deal of promise—we support them (see the companion blog post on this topic from my colleague, Dr. Jennifer Sass). They allow scientists to quickly test a lot of chemicals and gather vast amounts of data that we never had access to before. They do have limitations, though. Emerging toxicity tests can be limited, as they show an incomplete picture of biology, the National Academies noted in its 2017 report, Using 21st Century Science to Improve Risk-Related Evaluations.
For example, though a liver cell can give us basic information about what happens in a liver, it is not a liver.
Even with these limitations, these emerging tools can and should be used to help rapidly identify chemicals that could cause people and wildlife harm. That is, if they provide evidence of a harmful effect, a harmful effect should be presumed. They cannot be used, however, to explain away harm. Not finding a needle in a haystack doesn’t mean there isn’t one there.
The chemical industry, though, wants to use these tools to show that there’s no harm. “See? There is no needle!” Even when 25 exist.
So, while Administrator Wheeler’s announcement this week seems a reasonable one on first appearances, it is important to know the context in which this announcement was made. Regardless of the methods used to collect information about chemicals, the public needs an agency that uses its power to fully and adequately protect us, our families, and the places we all live, work, play, and pray. Not just in 2035, but today.