Office of Pesticide Programs

OPP requires an extensive battery of animal poisoning tests for every pesticide manufactured or sold in the U.S. An estimated 12,000 or more rats, mice, rabbits, birds, fish, and dogs are killed in laboratory poisoning experiments just to satisfy the OPP's data requirements for a single chemical "active ingredient"—which does not include the testing that is required for other ingredients in a pesticide formulation or the final formulations themselves. Less stringent data requirements are applied to natural "biopesticides." Virtually none of the animal tests required by OPP has ever been properly validated to ensure that its results are reliable and relevant to human beings or other species of concern.

To make matters worse, OPP is proposing numerous revisions to its data requirements for chemical pesticides that would raise the animal body count even further. Among these proposed additions is a test for developmental neurotoxicity, which kills upwards of 1,300 animals per chemical tested, despite the conclusion of the EPA's own Scientific Advisory Panel that "the current form of the DNT guideline is not a sensitive indicator of toxicity to the offspring." PETA has led a coalition of international animal protection organizations in challenging these additional testing requirements and in urging OPP to make greater use of non-animal methods and testing strategies.

PETA has also taken advantage of its membership on the EPA's Pesticide Program Dialogue Committee to network with companies, environmental groups, and other stakeholders to pressure OPP to reduce its reliance on animal testing. We are currently working with a coalition of consumer product companies (including Procter & Gamble, SC Johnson, and Clorox) and the Institute for In Vitro Sciences to validate and achieve EPA acceptance of a non-animal testing and hazard classification strategy for eye and skin irritation properties of antimicrobial pesticides (i.e., germ-killing household cleaners, such as Mr. Clean, Febreze, Scrubbing Bubbles, etc.). If successful, this effort will end the use of the notoriously cruel Draize rabbit-eye and skin test for the labeling of these products, replacing it with more efficient, cost-effective, and humane approaches, such as EpiOcular™ and EpiDerm™.

How You Can Help

• OPP is to be commended for its proposal to eliminate the one-year dog study from Part 158.
• In all other respects, OPP's proposed rule fails to reflect the EPA's stated commitments to sound science, the minimization of animal testing, or a realistic assessment and balancing of costs versus benefits and should be revised extensively to reflect more thoughtful testing strategies, such as that proposed by the International Life Sciences Institute.
• Most of the proposed new and newly codified data requirements are politically (versus scientifically) driven, are based on toxicity test methods that have not been formally or adequately validated to demonstrate their reliability and relevance to human beings, and are unlikely to alter the existing risk assessments or the levels of pesticides to which human beings and the environment are exposed.

Please send polite letters to:

The Honorable Lisa Jackson
Administrator
U.S. Environmental Protection Agency
Ariel Rios Bldg. (1101A)
1200 Pennsylvania Ave. N.W.
Washington, DC 20460
202-501-1450 (fax)
Jackson.Lisa@epa.gov

Please send a copy of your letter to the White House Office of Management and Budget, which has the power to force OPP to scale back its proposal:

Dr. John D. Graham
Administrator
Office of Information & Regulatory Affairs
Office of Management and Budget
725 17th St. N.W.
Washington, DC 20503
202-395-3888 (fax)
John_D._Graham@omb.eop.gov

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