Office of Pesticide Programs
The United States government requires extensive animal poisoning tests for every pesticide manufactured or sold in the U.S. An estimated 7,400 or more rats, mice, rabbits, birds, fish, and dogs are killed in laboratory poisoning experiments just to satisfy government data requirements for a single pesticide “active ingredient.” This does not include animals used in testing that is required for other ingredients in a pesticide formulation or the final formulation itself. Virtually none of the animal tests required have ever been properly validated to ensure that their results are reliable and relevant to human beings or other species of concern.
What Is OPP?
The Environmental Protection Agency (EPA) Office of Pesticide Programs (OPP) regulates all products used, sold, or imported into the U.S that are designed to manage, destroy, attract, or repel “pests.” Pesticides include synthetic chemicals, genetically engineered toxins, natural substances such as pheromones and garlic, and even living organisms such as insects, bacteria, and viruses. OPP’s legislative authority for regulating pesticides comes from the Federal Insecticide, Fungicide, and Rodenticide Act.
OPP and PETA
PETA has long pressured OPP to take measures to move away from animal testing and we are finally seeing some promising results. For years, the adoption of non-animal tests had been hampered by disagreements between regulators and the pesticide industry, but our scientists were successful in breaking the deadlock and bringing both sides to the table to address these issues. As a result, OPP has made significant strides recently in developing ways to use fewer animals in acute toxicity testing. These tests involve feeding a toxic pesticide to animals, applying it to their skin, and forcing them to inhale it. The objective is to determine the amount of pesticide that will kill at least 50% of the animals through the oral, dermal, and inhalation methods of exposure. Other acute toxicity tests involve placing pesticides in the eyes and on the skin of animals to observe the degree of irritation caused and, in the case of skin exposure, if the pesticide causes an allergic reaction. Acute toxicity tests are among the cruelest as they cause pain and suffering and typically end in death.
Another recent success involved a coalition of consumer product companies and the Institute for In Vitro Sciences working with OPP to validate and achieve OPP acceptance of a non-animal eye irritation testing strategy for antimicrobial cleaning products (germ-killing household cleaners, disinfectants, and anti-bacterial soaps). In May 2013, OPP announced that it would accept certain non-animal methods, such as the EpiOcular™ and the Bovine Cornea Opacity and Permeability assays, for categorizing the eye irritation potential of antimicrobial products. Substituting alternative methods such as these for the notoriously cruel Draize test spares rabbits from having harmful chemicals placed in their eyes. While OPP will consider alternative eye irritation methods for use with conventional pesticides (insecticides, herbicides, fungicides, etc.) on a case by case basis only, it is currently working to validate the methods for routine use with these types of pesticides.
PETA also participates in a stakeholder group that is advising and providing feedback to OPP on several other efforts related to acute toxicity. In one effort, OPP is working to adopt validated non-animal methods for categorizing skin irritation, skin corrosion and skin sensitization, which are already accepted in Europe for testing cosmetics and industrial chemicals, instead of continuing to require that animals be used. In another effort, OPP recently evaluated its requirement for conducting both oral and dermal acute toxicity tests on animals when companies apply to register new pesticide formulations. OPP found that in nearly all cases the oral results could be used to predict the dermal results and has issued draft guidance that allows industry to request a waiver for the dermal toxicity test. OPP has other guidance documents that provide criteria staff reviewers can use to waive animal tests where appropriate.
PETA is currently collaborating with OPP on finding additional ways animal tests can be replaced with more efficient, cost-effective, and humane approaches. Transitioning from EPA’s hazard classification system to one more commonly used around the world called the Globally Harmonized System (GHS) is one way increased use of non-animal tests can be achieved because the tests have been designed to work specifically with GHS. OPP is currently exploring what it must do to successfully make this transition. OPP is also investigating the use of an equation that “adds” the known toxicities of the ingredients in new pesticide formulations instead of performing a new animal test. This method has been demonstrated by industry to accurately predict hazard classifications without the use of animals.
Another way PETA interacts with OPP is through its Pesticide Program Dialogue Committee, a federal advisory committee composed of a diverse group of stakeholders who provide feedback to the pesticide program on various regulatory, policy, and program implementation issues. A PETA scientist serves as the animal welfare representative on the committee. This appointment affords us opportunities to network with companies, environmental groups, and other stakeholders, as well as advising OPP on ways to reduce its reliance on animal testing.
While OPP has made good progress in exploring alternatives for some toxicity tests, PETA continues to encourage it to develop and make greater use of non-animal methods and testing strategies for all required toxicity tests.
- Death Toll From Pesticide Testing
- PETA’s Letter to EPA’s Pesticide Office
- EPA’s Response to PETA
- PETA’s Letter to OMB’s Administrator
- Coalition Letter to the OMB
- PETA’s letter to OPP about an alternative for fish acute toxicity testing
- Follow-up letter to PETA’s collaborative meeting with OPP and industry to end acute toxicity animal testing
- The Sum of All EPA Animal Tests
- Animals Used for Experimentation