Open letter to the EPA
September 17, 2019
Open Letter Denouncing EPA Directive That Will Place Lives at Risk
The mission of the Environmental Protection Agency (EPA) is to “protect human health and the environment.” The EPA also “works to ensure that national efforts to reduce environmental risks are based on the best available scientific information.” As members of the scientific community, we believe last week's directive by EPA Administrator Andrew Wheeler to significantly reduce and eventually eliminate animal safety tests by 2035 is in direct conflict with the agency’s mission to protect the health of Americans, animals, and the environment.

Research with animals is undeniably critical to the EPA’s mission. This fact runs contrary to Mr. Wheeler’s claim that “new approach methods” or NAMs “exist today that allow us to better predict potential hazards for risk assessment purposes” than animal models. In fact, there is not a single case of environmental risk assessment where a non-animal alternative or methodology can provide a comprehensive understanding of the risks of new chemical hazards and potential human exposures. To regulate chemicals, the EPA must demonstrate that there are adverse effects in whole living organisms. While the EPA has reduced its reliance on animal testing in certain areas where it is possible to do so (such as testing corrosive chemicals on skin grown in a Petri dish), the EPA has not provided the relevant experimental, peer-reviewed data which demonstrate that “NAMs” are better than animals in assessing the safety of chemicals for other animals, including people, and for the environment.

The EPA’s decision is appalling given that it is not backed by scientific evidence. Nor does it appear that it included input from experts in toxicology, but rather it is informed by personal feelings and campaigns by known absolutist organizations that are staunchly against all animal research. The fact that the EPA’s press release on this directive highlighted and quoted leaders of People for the Ethical Treatment of Animals (PETA), White Coat Waste Project, Physicians Committee for Responsible Medicine, and the Humane Society of the United States, yet did not quote a single scientist, is alarming. The fact that only one set of stakeholders were represented in this decision, and not other stakeholders including experts from relevant disciplines or organizations that represent various health and ethical interests (e.g., bioethicists, the American Heart Association, the American Cancer Society, etc.), raises serious concerns about how policies at the highest level of America’s government are developed and enacted.

We, the undersigned members of America’s scientific community, denounce the EPA’s directive to aggressively reduce animal testing and end research with mammals under arbitrary deadlines. We call on the EPA to withdraw this directive. We understand the important role that research animals have in determining what is safe for humans, for other animals, and for the environment. Any individual or group who purports to value animal lives should support the responsible study of a very limited number of animals to ensure the health of us all – human and animal alike.

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This letter is intended to come from the American scientific community. Therefore, all signatories must be U.S. - based scientists, veterinarians, or other laboratory staff or students from research organizations – public or private – or scientists residing abroad who are U.S. citizens or permanent residents.

Once we obtain more than 200 signatures, we intend to make the letter public, through the news media and other communications channels. We also plan to post the letter on the Speaking of Research website, with the full list of signatories.

It is understood that all signatories are signing in a personal capacity and their views do not necessarily represent those of their institution.

Emails and other information collected here will not be shared with third parties.
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