Animals don’t belong in chemical-testing formula

As folk singer Pete Seeger plaintively inquired, “When will they ever learn?”

Off the radar of public attention, the Bush-Cheney Administration is continuing a misguided program begun by the Clinton-Gore Administration, as the Environmental Protection Agency (EPA) moves ahead with yet another massive chemicals testing program using enormous numbers of animals. This one, the Endocrine Disruptor Screening Program, will supposedly identify chemicals that affect human hormones. Anywhere from 5,000 to 87,000 chemicals may be examined, with perhaps 3 million to 104 million animals to be killed.

International scientists have denounced it as “blindly stupid” because the huge doses of chemicals force-fed or injected into animals have virtually no relevance to the low levels of chemical humans might likely encounter. And non-human data poorly predicts human effects.

Scientists agree: humans respond in dramatically different ways than do non-human animals to chemicals that affect hormones. Symptoms vary greatly among species. And major differences exist even within one species. For example, as the journal Science reported in August 1999, one mouse strain is an estimated 100 times more resistant to reproductive effects caused by an endocrine disruptor than are other strains within the same species.

Even within the same strain, factors such as housing and womb position can substantially affect results. A male animal positioned between two other male animals in utero will show different effects from an administered chemical than a male sandwiched between two females. Some endocrine disruptor tests measure the weight of animals’ organs after being killed.

But different laboratories cut out organs slightly differently, compromising results. Says a former chair of EPA’s scientific advisory board, Genevieve Matanoski, M.D., “You can’t go across labs, because each lab tends to be unique — I find that a big problem.”

Why embark on such futility? A 1996 book called “Our Stolen Future” by Theo Colburn suggested that reproductive and developmental abnormalities found in birds and reptiles exposed to high pollution levels might indicate human risk from low levels of those chemicals.

So Congress, in the 1996 Food Quality Protection Act, required EPA to identify chemicals disrupting the human endocrine system. Congress also asked the National Research Council (NRC) of the U.S. National Academy of Sciences to investigate potential threats from such chemicals. Wisely, NRC recommended that meaningful human epidemiological studies assess the problem and identify possible endocrine disruptor-cancer links in people. Reducing production and discharge of suspect chemicals and switching to benign alternatives wherever feasible would also be smart. Incredibly, EPA ignored such approaches and instead launched history’s largest animal-testing program.

EPA also disregarded the congressional requirement to use only “appropriately validated tests.” Although the animal tests that EPA proposes to use have been heavily criticized by scientists, EPA stubbornly considers animal tests reliable and relevant. Furthermore, it hypocritically demands the rigorous scrutiny of a national committee to validate non-animal tests, yet lets an EPA-appointed group review the animal tests.

European Union law at least requires justification before approval of painful animal tests, and use of non-animal tests “wherever possible.” No similar U.S. protections exist, and EPA lacks enthusiasm in pursuing non-animal test methods. EPA even rejected the “high throughput screen,” a rapid, scientific non-animal screening method recommended by its own Endocrine Disruptor Screening and Testing Advisory Committee. EPA’s neglect of $4 million Congress allotted to develop this method will prevent chemicals from being screened out before animal tests begin. Millions of animals will needlessly die in tests that could be eliminated early-on using this humane, scientifically recommended method.

Where’s the logic? EPA admits rushing to meet a congressionally established deadline unrelated to science. Asked why EPA doesn’t try developing a better testing strategy, EPA senior scientist Penelope Fenner-Crisp cited the law’s timetable, lamely offering, “We have to do something that looks like implementation.”

Another government scientist, deeming the program unscientific and ill-conceived, admitted that “due to commitments by laboratories and government agencies, and the availability of funding, the program will proceed — justified or not.”

So, be advised: reams of useless data may be generated at enormous costs in animal lives, taxpayer dollars, and wasted effort. But perhaps EPA can be reeducated in time to avoid this pending tragedy.