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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 chemical “active ingredient”—which does not include the testing that is required for other ingredients in a pesticide formulation or the final formulations themselves. Virtually none of the animal tests required has ever been properly validated to ensure that its 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 designed to manage, destroy, attract, or repel “pests” that are used, sold, or imported into the U.S. The term “pesticide” can include synthetic chemicals, genetically engineered toxins, natural substances such as pheromones and garlic, and even 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

Following PETA’s extensive involvement, OPP is making some effort to move away from animal testing. While OPP recently added developmental neurotoxicity (DNT) testing to its list of data requirements for pesticides, the test is generally required only if there is evidence from previous toxicity tests that a particular pesticide or closely related compound may be toxic to the human nervous system. OPP has also provided a few means by which the DNT test and the required immunotoxicity test may be avoided or animal numbers reduced, including the use of existing data to meet test requirements and performing DNT or immunotoxicity assessments while carrying out other required toxicity tests.  PETA continues to lead a coalition of international animal protection organizations in urging OPP to make greater use of non-animal methods and testing strategies for all required toxicity tests.

A PETA scientist serves as the animal welfare representative on the EPA’s 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. This appointment affords PETA opportunities to network with companies, environmental groups, and other stakeholders, as well as encouraging OPP to reduce its reliance on animal testing. Our involvement with a coalition of consumer product companies and the Institute for In Vitro Sciences to validate and achieve EPA acceptance of a non-animal testing and hazard classification strategy for eye and skin irritation properties of antimicrobial pesticides (i.e., germ-killing household cleaners, such as Mr. Clean, Febreze, Scrubbing Bubbles, etc.)  recently paid off.

In May 2013, the EPA announced that it will accept certain in vitro/ex vivo methods for categorizing the eye irritation potential of antimicrobial products, such as EpiOcular™ and the Bovine Cornea Opacity and Permeability assay. The agency will also consider these approaches for testing conventional pesticides on a case-by-case basis. Use of these methods spares rabbits from use in the notoriously cruel Draize rabbit-eye test for the labeling of pesticide products. Unfortunately, the EPA has yet to adopt validated non-animal methods for categorizing skin irritation and skin corrosion that are already accepted in Europe, instead continuing to require that rabbits be subjected to painful skin tests. PETA is investigating ways in which the EPA could replace these tests with more efficient, cost-effective and humane approaches while still maintaining its hazard classification system, which differs somewhat from Europe’s and has been cited as one of the reasons why the EPA has not adopted certain non-animal tests.

PETA is also focusing on the EPA’s testing requirements for products containing nanosilver, a substance that has appeared increasingly in items such as pool algaecides, athletic clothing, baby bottles, stuffed animals, hospital equipment and wound dressings. Because of its antimicrobial properties, the EPA has treated nanosilver as a pesticide rather than a nanomaterial, yet research has shown that traditional animal-based methods of assessing toxicity are of questionable use for nanomaterials as a whole and have not proved relevant for nanosilver specifically. As each new nanosilver product has been submitted to the EPA for pesticide registration approval, PETA submitted comments arguing for more reasoned approaches and appropriate toxicity test methods for assessing potential nanosilver health effects and less reliance on animal tests that produce results often irrelevant to humans.

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