We, the undersigned, are writing to you in response to a letter you received on March 15, 2023, from a group of NGOs requesting that the Environmental Protection Agency (EPA) renounce its objective to prioritize good science while reducing tests on animals. That letter’s request stands in stark opposition to overwhelming public and scientific support for the EPA’s efforts to move away from animal tests. We support the replacement of animals in testing, not only to prevent animal suffering but also because many tests on animals lack reproducibility and relevance to humans and therefore impede regulatory efforts to better protect us and our environment.
We are concerned that exposure to unsafe chemicals is heavily affecting susceptible and vulnerable populations, including pregnant people, communities of color, farmworkers, and children. The animal tests used to make decisions about chemical safety have significant flaws. We want to see our tax dollars put toward a more protective regulatory system, with continued development and implementation of non-animal methods that reliably provide regulators with the information they need.
In 2021, the EPA released a New Approach Methodologies Work Plan to coordinate its efforts to advance non-animal approaches with “the potential to increase the rigor and sophistication of Agency assessments.” The plan highlights the importance of evaluating and applying emerging technology to keep the agency at the forefront of science and poised to best evaluate risks to human health and the environment. We fully support the EPA’s continued advancement of the scientific objectives detailed in it.
Robust non-animal approaches generate reliable information that is relevant to humans. They also allow for more rapid assessment of chemicals, enabling faster removal of dangerous ones from the market and preventing others from ever reaching the market in the future. In this way, non-animal approaches support the administration’s aim to advance environmental justice by protecting susceptible and vulnerable populations most at risk of exposure.
We thank you for your attention to this important issue and for the EPA’s continued work to develop and implement non-animal test methods.