On August 17, 1999, Environmental Defense and nine major environmental and health advocacy groups sent the following letter to the Administrator of the Environmental Protection Agency in support of the HPV Initiative and urging EPA to take a leadership role in developing non-animal testing methods for the Initiative.

The Honorable Carol Browner
Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460

August 17, 1999

Dear Administrator Browner:

We are writing to urge that the Agency take advantage of the unique opportunity to validate non-animal alternatives for toxicity testing, particularly the Multicenter Evaluation of In Vitro Cytotoxicity (MEIC) program, in conjunction with the High Production Volume (HPV) Chemical Challenge Initiative.

We strongly support the Initiative's objective of assuring the public's access to basic information on potential health and environmental hazards for chemicals produced in high volumes. For far too long, such information has been unavailable for too many chemicals, thwarting the public's right-to-know about toxics at the very outset – namely, in ascertaining which chemicals are likely to be toxic, and which are not. As a voluntary program backed up by rulemaking, the HPV initiative will greatly accelerate the pace of making basic hazard data on widely used chemicals available to the public, and we applaud the agency for pursuing this approach.

At the same time, we recognize the importance of minimizing the use of animal testing for humanitarian reasons, as animal-welfare organizations have stated. In this regard, we believe it is vital to take advantage of the unique opportunity provided by the HPV Initiative to move forward with development and validation of methods that produce adequate scientific information while reducing or eliminating use of animal testing (which in HPV will occur on laboratory rats and fish). It is our understanding that the MEIC program is now ready for validation as a non-animal alternative for determining acute toxicity. We believe this promising system should undergo validation testing as rapidly as possible as the HPV program moves forward. We strongly encourage EPA to make a specific commitment to sponsoring the MEIC program for validation through the Interagency Coordinating Committee on Validation of Alternative Methods (ICCVAM).

Thank you for considering our views.

Very truly yours,

California Communities Against Toxics
Jane Williams, Executive Director

Childrens Environmental Health Network
Joy E. Carlson, MPH, Executive Director

Environmental Defense
Karen Florini, Senior Attorney

National Environmental Trust
Patricia Kenworthy, Vice President, Government Affairs

David Wallinga, M.D., Senior Scientist

Physicians for Social Responsibility
Robert K. Musil, PhD., Executive Director

Unison Institute
John Chelen, Executive Director

U.S. Public Interest Research Group
Grant Cope, Staff Attorney

cc: Susan Wayland, Deputy Assistant Administrator
Prevention, Pesticides, and Toxic Substances