Chemical Companies Plan to Poison 5,000 Animals
Your help is needed to stop dozens of new animals tests under the U.S. Environmental Protection Agency's (EPA) notorious high production volume (HPV) chemical-testing program, which requires the chemical industry to complete an arbitrary checklist of animal-poisoning tests for all chemicals manufactured in or imported into the U.S. in quantities in excess of 1 million pounds.
In 2002, a coalition of chemical companies submitted a test plan for a large group of 20 HPV chemicals called metal carboxylates. These chemicals are used in the manufacture of products such as plastics, paints, and adhesives. PETA’s comments on this original test plan can be seen here. In response to the EPA’s criticism of the test plan, the industry coalition withdrew its original test plan and submitted 12 separate test plans. The original test plan was bad enough, as it would have used approximately 1,000 animals, but the 12 new test plans are far worse. The tests proposed in these new plans will result in the deaths of as many as 5,000 animals. Importantly, since these entirely new test plans have been submitted as "revisions" to the original plan—bypassing the agreed-upon comment period—PETA and other animal protection organizations have had no opportunity to formally comment on these new testing proposals!
The tests that the coalition is proposing include the following:
• LD50 Tests
In these infamous tests, animals are force-fed increasing doses of a chemical until they die. Such acute toxicity tests inflict hideous suffering on animals, who endure severe abdominal pain; diarrhea; bleeding from the nose, mouth, and genitals; convulsions; seizures; and paralysis before they ultimately die. Astonishingly, the chemical companies are proposing four of these cruel tests, even though they themselves admit that the tests are unnecessary!
• In Vivo (Live Animal) Genotoxicity Tests
Genetic toxicity tests are highly stressful and cruel, as mice are subjected to frequent handling, restraint, and inhumane force-feeding in addition to suffering the toxic effects of the chemical that's being investigated. In vitro (non-animal) methods to study genetic toxicity without the use of animals have been accepted by government regulators worldwide as valid alternatives to using animals. Non-animal genetic toxicity testing methods have already been incorporated into the HPV program—after a huge effort on PETA's part. However, four in vivo genetic toxicity tests are proposed in the new test plans.
• Fish Acute Toxicity Tests
These tests are similar to the LD50 test described above, except that chemicals are pumped into the water of tanks holding fish until the animals die. The fish may endure severe pain, as evidenced by visible physical and behavioral abnormalities, before they are ultimately poisoned to death. Two of the proposed fish acute toxicity tests are for chemicals that the EPA’s own program guidelines define as being insoluble in water!
The CEOs of these chemical companies need to hear that you don't want them to poison any more animals under the new metal carboxylate test plans, especially since they have not given the public—including PETA and the rest of the American animal protection community—a fair opportunity to comment on them and suggest humane alternatives.
Please only send polite comments.
George Cornelius, President and CEO
Arkema Inc.
2000 Market St.
Philadelphia, PA 19103-3222
215-419-5494 (fax)
george.cornelius@arkemagroup.com
Diane Milici, Assistant to the President
Arkema Inc.
diane.milici@arkema.com
Robert L. Wood, Chair, President, and CEO
Chemtura Corporation
199 Benson Rd.
Middlebury, CT 06749
203-573-2800 (fax)
robert.wood@chemtura.com
Michelle Formica, Assistant to the President
Chemtura Corporation
mformica@cromptoncorp.com
James F. Kirsch, President and CEO
Ferro Corporation
1000 Lakeside Ave.
Cleveland, OH 44114-7000
216-875-7266 (fax)
kirschj@ferro.com
Julie Wilkens, Assistant to the President
Ferro Corporation
wilkens@ferro.com
Rajiv L. Gupta, Chair, President, and CEO
Rohm & Haas Company
Corporate Headquarters
100 Independence Mall W.
Philadelphia, PA 19106-2399
215-592-3377 (fax)
raj_l_gupta@rohmhaas.com
Daryl D. Smith, Chair, President, and CEO
Troy Corporation
8 Vreeland Rd.
P.O. Box 955
Florham Park, NJ 07932
973-443-4402 (fax)
smithd@troycorp.com
Thomas L. Shepherd, CEO
The Shepherd Chemical Company
4900 Beech St.
Norwood, OH 45212
513-731-1532 (fax)
tshepherd@shepchem.com
Joseph M. Scaminace, President and CEO
OM Group Americas
127 Public Sq.
1500 Key Tower
Cleveland, OH 44114-1221
216-781-1502 (fax)
JM610-586-3975
