The European Coalition to End Animal Experiments (ECEAE) has reacted with disappointment as figures from the European Chemicals Agency released this week show that at least 4,887 new animal tests have now been done for REACH purposes (1).
Although the report claims that the use of non-animal alternatives has increased since the last report in 2011, the number of new animal tests conducted since 2009 has at least doubled from 1,849 to 4,887. As the number of substances registered has nearly doubled since this time, the report in fact shows little change in animal use by the chemical industry.
An analysis by the ECEAE of the minimum number of animals who are typically used in these tests gives a total of at least 700,000. . There has been a threefold increase in the number of reproductive toxicity tests that use hundreds of animals per test.
The ECEAE is pleased to see ECHA acknowledge that more work needs to be done in promoting non-animal alternatives. The report includes sources of information to help companies avoid animal testing, but clearly more needs to be done by companies, the Commission, ECHA and member states to ensure that no company in Europe conducts animal tests that have suitable alternatives.
The ECEAE wants to see:
· The REACH legislation updated to remove the specific requirement to test on rabbits for skin and eye irritation (Annex VIII)
· ECHA and ECVAM to produce a testing strategy for skin sensitisation in time for registrants to use instead of mouse (LLNA) tests for the registrations due 2018
· More active promotion and support of alternatives by ECHA and EU member countries
· Industry clean up its act and stop doing pre-emptive and unnecessary tests
Our key issues in the report:
· Number of animal tests
There has been a doubling of the number of new animal tests done, an increase from 1,849 to 4,887 animal tests, using an estimated minimum of 700,000 animals. There has been a doubling of animal testing in most cases but a trebling (or more) for some of the higher tier animal tests such as reproductive toxicity tests.
· Tests without a proposal
There is still an unacceptably high number of new animal tests that were done without going through the proper consultation process (the testing proposal process in which both third parties and member states have an opportunity to provide input before a decision on the test is made). ECHA found 293 such new animal tests; this is an increase from the last report (107 tests). However we are encouraged to see that ECHA is taking a more proactive role this year to follow these up with the companies and member states.
· Skin and eye irritation tests
Some companies are still conducting new rabbit skin and eye irritation tests. There were 188 new skin irritation tests and 363 new eye irritation tests (135 and 188 in the last report respectively). Although ECHA report that there has been an increase in the number of registrations including in vitro data, the proportion of dossiers using new animal data has not changed. There are alternatives for these two tests so any new animal test is completely unacceptable. We are pleased to see ECHA take steps to promote these alternatives in its report and on its website but more active outreach are needed.
1. The ECHA report, The Use of Alternatives to Testing on Animals for the REACH Regulation, is the second of the reports on this issue that the Agency is obliged to produce every three years under Article 117(3) of REACH. ECHA published the first report late on 30 June 2011, and now this one on 2 June 2014, which can be found here: http://www.echa.europa.eu/documents/10162/13639/alternatives_test_animals_2014_en.pdf and associated press release: http://www.echa.europa.eu/view-article/-/journal_content/title/reach-report-on-alternatives-to-animal-testing-press-release
2. ECHA have published a new web page detailing the skin and eye irritation alternatives here see http://echa.europa.eu/support/oecd-eu-test-guidelines