What is the HPV program?
In 1998, the Environmental Protection Agency's (EPA) High Production
Volume (HPV) Chemicals Challenge Program "challenged" the industry to
make baseline health and environmental effects data available to the public for
nearly 2,800 HPV chemicals produced or imported into the U.S. in quantities of
1 million or more pounds per year. As originally
envisioned, this unprecedented five-year program would have meant that up to
seven different animal tests could have been required for each chemical, killing
more than 1 million mice, rats, rabbits, and guinea pigs and countless birds
and fish. Since negotiating an agreement in 2000 between the U.S. animal
protection community, the White House, and the EPA to reduce the numbers of
animals used, PETA
has commented on every test plan that proposed animal use. Although most of
the program is coming to a close, PETA continues to monitor the remaining
untested chemicals and test plans.
Who is responsible for the HPV program?
The HPV chemical-testing program was initiated in response to intense
government lobbying by the advocacy group Environmental Defense Fund (EDF).
The program was the result of closed-door meetings in 1998 among EDF, the
Chemical Manufacturers Association, and the Clinton-Gore administration. Even
though the program started in November 1998, the EPA only gave public notice of
the HPV program two years later—in December 2000. As a result, the program
bypassed normal governmental procedures of scientific review and public
What tests are being used in the HPV program?
Under the threat of having mandatory testing imposed on them by future EPA
regulation, 469 companies agreed to sponsor 2,155 chemicals in the HPV program.
Faulty tests using animals often work in favor of the chemical industry because
they are frequently inconclusive. Animal tests can actually clear chemicals
already known to be hazardous or delay the regulation or restriction of those
chemicals. Furthermore, recent articles quote industry representatives as
supporting the HPV program in order to avoid a Congressional examination of the
ineffectiveness of the Toxic Substances Control Act, which the EPA has not used
even once in the past decade to ban a dangerous industrial chemical.
Why is the chemical industry participating?
The HPV program called on the chemical industry to collect toxicity information
for each HPV chemical using an arbitrary checklist of animal-poisoning tests.
These tests sometimes involve forcing chemicals down animals' throats or forcing
them to inhale chemicals. Click
here for more information about specific test methods.
Are the results of animal tests relevant to humans?
There is much scientific evidence documenting the failure of animal-based
toxicity tests to accurately predict human reactions to chemicals. Such failures
are not surprising, given the many differences that exist between species in
terms of their anatomy, physiology, biochemistry, and metabolism. These variables
make it impossible to accurately extrapolate test results from one species to
here for more information about scientific
problems with animal tests.
Are there any non-animal methods that could replace animal tests in the
There have been many advances in non-animal testing in recent years, and as a
result, much of the testing required by the HPV program potentially could be
done without poisoning animals. One such method, which uses cell lines to test
for a chemical's ability to damage chromosomes, was incorporated into the
program—but only after a huge effort on PETA's part. There are currently
several additional non-animal tests, including a cell-based test to replace the
crude and cruel lethal-dose tests that are nearing the final stage of
completion. It is also important to note that human experience and occupational
exposure data are ignored in the HPV program even though they could provide a
far more accurate picture of a chemical's true hazard. Click
here for more information about non-animal methods.
Is it true that many HPV chemicals are missing a lot of important
Reports published by EDF, the
American Chemistry Council (ACC), and the EPA greatly underestimate what is
known about HPV chemicals. As a result, the conclusions reached in these
reports are seriously flawed and misleading. For example, EDF's report "Toxic
Ignorance" would have one believe that a lack of animal toxicity testing
for wood shavings is a threat to public health. Similarly, the EPA study
claimed that vinyl chloride has never been studied for its long-term toxic
effects, despite other government documents showing that vinyl chloride has
been the focus of hundreds of human population and animal studies for more than
Research conducted by the Physicians
Committee for Responsible Medicine (PCRM) details
the enormous amount of publicly available information that these reports overlooked.
In fact, since PCRM's study was released, EDF and the EPA
have both publicly acknowledged that their reports should only be considered "scoping
studies" because so much information was overlooked. Far from being
legitimate efforts to determine what is known about HPV chemicals, the EDF and EPA reports were undertaken only to "document"
a predetermined conclusion. The ACC report acknowledges that it was forced to
underestimate existing data because of the "checklist" nature of the
Is it possible that testing was or will continue to be performed on
chemicals already known to be hazardous?
Yes. Although the vast majority of HPV chemicals have been around for decades
and are already very well characterized, they may not have undergone the
specific tests required by this program. So regardless of how much is known
about a chemical's risks, the HPV program still requires all chemicals to
undergo an identical and arbitrary checklist series of animal tests.
But will testing be—or has it already been—performed on chemicals that
have been tested on animals in the past?
Yes, for several reasons: Many animal tests in the past used slightly different
methods than those currently required, which could mean that old test results
will not be accepted under the HPV program. In addition, chemical companies are
unlikely to submit data from previously conducted animal tests that show their
chemicals to be harmful. It is more likely that companies will conduct new
tests with the hope that the results will be more positive this time around.
How is information from the HPV program being used?
Remarkably, the HPV program has nothing to do with taking dangerous chemicals
off the market. In fact, the EPA has stated that it will not even review
chemical information that is submitted but will instead simply put the results
of the tests on its website. Instead of protecting the public from hazardous
chemicals, the EPA will only inform us about the length of time it took mice
and rabbits to die after being force-fed a chemical or how many mouse pups were
stillborn after their mother was force-fed massive quantities of chemicals that
are already known to be toxic. The EPA has not banned a single toxic industrial
chemical in more than 10 years—this dismal track record will not change as a
result of the HPV program.
What is PETA doing about the HPV program?
PETA is actively campaigning in the following ways to bring some common sense
into the HPV program and to save more animals from suffering and death:
here to read more about the HPV chemical-testing program.
Almost all of us grew up eating meat, wearing leather, and going to circuses and zoos. We never considered the impact of these actions on the animals involved. For whatever reason, you are now asking the question: Why should animals have rights? Read more.