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skin corrosion Skin Corrosion
skin absorption Skin Absorption
skin irritation Skin Irritation
phototoxicity Phototoxicity
pyrogenicity Pyrogenicity

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Shareholder Campaign
> 3M

3M (Minnesota Mining and Manufacturing Co.) markets a diverse range of industrial and consumer products, including Post-it® notes, Scotch® tape, bandages, pharmaceuticals, and medical supplies. Animal testing conducted by 3M may be expressly required by government regulations (e.g., FDA testing requirements for pharmaceuticals), or it may be a voluntary activity on the company’s part to establish the safety of its products (e.g., skin irritation testing of adhesives used in bandages or tape).

2005 Resolution: Give the Animals 5

PETA’s “Give the Animals 5” Campaign calls on companies to abandon five crude and cruel animal tests, replacing them with state-of-the-art and scientifically valid non-animal methods that are already in use in other countries. With the help of PETA supporters who hold stock in 3M, a resolution was filed in the fall of 2004, calling on the company to do the following:

  • Commit specifically to using only non-animal methods for assessing skin corrosion, skin irritation, skin absorption, phototoxicity, and pyrogenicity

  • Confirm that it is in the company’s best interests to commit to replacing animal-based tests with non-animal methods

  • Petition the relevant regulatory agencies requiring safety testing for the company’s products to accept as total replacements for animal-based methods those approved non-animal methods described above, along with any others currently used and accepted by the Organization for Economic Cooperation and Development (OECD) and other developed countries

Despite assurances that “3M acknowledges and encourages the use of alternatives to animals and subscribes to the recognized principles of replacement, reduction, and refinement,” the company took a position in opposition to our shareholder resolution. Furthermore, 3M sought permission from the Securities and Exchange Commission (SEC)—the agency responsible for administering federal securities laws in the U.S.—to exclude our resolution from its proxy statement, arguing that it dealt with ordinary business matters that are not subject to a vote by stockholders. The SEC staff did not concur with any of the company’s arguments and ordered 3M to publish the PETA-sponsored resolution in its shareholder proxy materials.

PETA’s resolution was brought to a vote at 3M’s annual meeting in St. Paul, Minnesota, on May 10, 2005. Almost 14 million shares (2.9 percent) were voted in favor of the resolution. Although shareholder resolutions almost never win the required number of votes the first time that they are proposed, they do provide an opportunity to educate management, boards, and other shareholders about important issues, leading to change over the long term.

2006 Resolution: Animal Welfare Policy

In 2006, PETA submitted another resolution to 3M, calling on the company to develop and make publicly accessible an animal welfare policy that would include reducing the numbers of animals used, provide social and behavioral enrichment measures to the animals used, and apply to any outside laboratories used.

The resolution was largely the result of the horrors uncovered in the independent contract testing laboratory Covance Inc., whose officials boast that they have every major company as a client.

3M again challenged our resolution at the SEC, partly on the grounds that the company would be unable to evaluate the animals’ needs. Again, the SEC ruled in PETA’s favor and ordered 3M to publish the PETA-sponsored resolution in its shareholder proxy materials. 3M published our resolution along with its opposition statement advising shareholders to vote against it.

Negotiations with 3M prior to the annual meeting resulted in withdrawal of the resolution when the company agreed to implement the proposal.

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