HPV Campaign Action

February 10, 1999
The Honorable Albert Gore, Jr.
Vice President of the United States
The White House
Washington, DC 20502

Vice President Gore:

While we, the undersigned organizations representing more than ten million Americans, support the goal of protecting the public and the environment from hazardous chemicals, we have grave concerns about the current structure of the Environmental Protection Agency (EPA) high production volume (HPV) chemical testing program. We urge a delay in its implementation until the following issues are addressed and resolved:

There has been no Federal Register notification of this program and important stakeholders have been taken by surprise, including the animal protection community. This program has massive ramifications on animal welfare and yet little or no consideration has been given to these concerns. The program must be revised with adequate public and Congressional review and input.

An enormous amount of data, both animal and human, already exist for many of the HPV chemicals. The hurried schedule which you have ordered for this program does not allow for a proper review of these data and the development of a scientifically sound and defensible testing strategy.

The HPV program calls for testing many substances that clearly need no further testing. These include chemicals well documented and regulated as dangerous, substances recognized as safe by the FDA, and substances whose physical properties make certain endpoints irrelevant or impossible to assess. A delay will facilitate a purge of these substances from the list.

The EPA has been slow to consider modern test methods and available data that could prove more accurate and efficient for screening potential hazards. These include in vitro alternatives to the inhumane and unscientific LD-50 test, in vitro alternatives for genetic toxicity tests in animals, wide application of structure-activity relationships, and consideration of existing human exposure data. The “check-the-box” mentality cannot be justified when so much animal suffering is at stake.

There is ample evidence that thousands of chemicals already known to be toxic in both animals and humans remain in common use. The HPV chemical testing program detracts from meaningful and effective programs that have a real chance of protecting the public health and environment. The hurried schedule for this program shows that it is being driven by politics, not science.

Neal D. Barnard, M.D.
Physicians Committee for Responsible Medicine

On behalf of:
American Anti-Vivisection Society
American Fund for Alternatives to Animal Research
Animal Legal Defense Fund
Animal Protection Institute
Animal Welfare Institute
Association of Veterinarians for Animal Rights
Doris Day Animal League
Earth Island Institute
Friends of Animals
Fund for Animals
Humane Society of the United States
In Defense of Animals
Medical Research Modernization Committee
National Anti-Vivisection Society
People for the Ethical Treatment of Animals
Physicians Committee for Responsible Medicine
Society for Animal Protective Legislation


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