This is Fred Krupp’s reply to letters he received from supporters of PETA, who contacted us by taking part in this action alert.
Thank you for letting us know your concerns about the use of animal testing. We at Environmental Defense Fund respect the work that animal rights and animal welfare organizations have done over the years to support alternatives to animal testing.
Let me clarify that EDF has no knowledge of or association with the laboratory shown in the video distributed by PETA. EDF does not own or operate any laboratories and does not engage in any animal testing of chemicals. EDF is not aware of and would not support the use of any chemical testing protocol that entails testing on dogs.
EDF itself is working to advance a number of efforts aimed at reducing the need for animal testing and enhancing the development and use of non-animal alternatives to chemical testing and assessment.
For example, we are closely following and encouraging progress under the Federal government’s Tox21 initiative. Under this initiative, EPA and several other agencies are working to implement the vision for reducing animal testing that was spelled out in the National Academy of Sciences’ report, Toxicity Testing in the 21st Century.
We also are pressing EPA to enhance its reporting system for chemical use and exposure under the Toxic Substances Control Act (TSCA). Such enhancements will provide more reliable information to allow the agency to better prioritize which chemicals to focus on first in requiring more toxicity data.
EDF also is working to ensure maximum access to chemical information already being developed in Europe under the REACH Regulation, to ensure there is no unnecessary or duplicative testing of chemicals.
Finally, we strongly support provisions for TSCA reform that would allow and facilitate the use of a variety of types of information to determine chemical safety, not just information derived from new chemical testing.
There are two issues that still divide us, I think. The first is whether animal testing continues to be needed. As reflected in recent reports by the U.S. National Academy of Sciences and the European Commission’s Scientific Committee, the state of the science clearly indicates that, unfortunately, testing on a limited number of laboratory animals (rodents, fish, shrimp and earthworms) is still necessary to prevent even greater harm to our ecosystems and the animals and humans that live in them.
EDF does not support animal testing except in those cases where it provides information that is critical to understanding and preventing potential harm to humans, animals and the environment; and where there are not yet alternatives accepted by the scientific community. With these concerns in mind, our scientists are working to develop and implement policies that call for animal testing only where necessary.
The second divide is whether animal testing is ethically acceptable in situations where it is needed. We respect the values that lead some people to oppose animal testing, and recognize the deeply held conviction of some that humans do not have the right to use living creatures for human purposes, however vital those purposes may be. We admire that position, but we do not share it. As long as (and only as long as) current scientific research indicates that limited animal testing is still necessary to avoid greater harm, we believe that it is ethical. DDT, PCBs, asbestos, and leaded gasoline are just a few examples where more up-front testing would have prevented significant ecological, animal, and human harm.
EDF was founded by scientists concerned about animal welfare – specifically the eagles and ospreys that were being harmed by the spraying of the pesticide DDT. Since then, emerging science has only made clearer the fact that animals are among the first and most heavily impacted victims of the large-scale exposure to chemicals that have been allowed to be used without requiring them to be shown to be safe.
Our knowledge of the endocrine-disrupting effects of chemicals originated with studies of animals in the wild. Growing evidence indicates that the widespread and increasing deformations and gender-bending effects seen in wild fish and amphibians are the result of chemical exposures. We now know that wildlife in the remotest parts of the Earth carry dangerous levels of persistent substances in their bodies. All of these impacts of under-assessed chemicals affect untold billions or trillions of animals in the wild.
EDF continues to work to prevent additional harm to the health of all creatures resulting from exposure to dangerous or inadequately studied chemicals. We will continue to support the development of alternatives to animal testing, and will remain indebted to those who are watching closely to make sure that we do.
Environmental Defense Fund