Office of Pesticide Programs
All products designed to manage, destroy, attract, or repel “pests” that are used, sold, or imported into the United States are regulated by the EPA’s Office of Pesticide Programs (OPP). 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 (FIFRA).
OPP requires an extensive battery of animal poisoning tests for every pesticide manufactured or sold in the U.S. An estimated 12,000 or more rats, mice, rabbits, birds, fish, and dogs are killed in laboratory poisoning experiments just to satisfy the OPP’s 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. Less stringent data requirements are applied to natural “biopesticides.” Virtually none of the animal tests required by OPP has ever been properly validated to ensure that its results are reliable and relevant to human beings or other species of concern.
To make matters worse, OPP is proposing numerous revisions to its data requirements for chemical pesticides that would raise the animal body count even further. Among these proposed additions is a test for developmental neurotoxicity, which kills upwards of 1,300 animals per chemical tested, despite the conclusion of the EPA’s own Scientific Advisory Panel that “the current form of the DNT guideline is not a sensitive indicator of toxicity to the offspring.” PETA has led a coalition of international animal protection organizations in challenging these additional testing requirements and in urging OPP to make greater use of non-animal methods and testing strategies.
PETA has also taken advantage of its membership on the EPA’s Pesticide Program Dialogue Committee to network with companies, environmental groups, and other stakeholders to pressure OPP to reduce its reliance on animal testing. We are currently working with a coalition of consumer product companies (including Procter & Gamble, SC Johnson, and Clorox) 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.). If successful, this effort will end the use of the notoriously cruel Draize rabbit-eye and skin test for the labeling of these products, replacing it with more efficient, cost-effective, and humane approaches, such as EpiOcular™ and EpiDerm™.