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Chemical test plans

Under the HPV program, chemical companies and consortia submit their proposals to test HPV chemicals, and these proposals are the posted to the EPA's Web site for a 120-day comment period. PETA and other animal protection organizations have been the stakeholders to review and comment on all HPV chemical test plans. What we have found while reviewing the proposed test plans has been shocking.
  • Three out of every four (75 per cent) HPV chemical test plans submitted violate basic, agreed upon animal welfare measures. For example, many companies have submitted poorly researched test plans that make no use of existing information, calling instead for the HPV programs notorious checklist battery of animal tests.

  • The American Chemistry Council planned to kill animals in acute toxicity studies of the already well-characterized substance butadiene. Moreover, the levels to which they proposed to expose animals in these lethal poisoning tests were, literally, explosive.

  • The American Petroleum Institute wanted to subject animals to acute and genetic toxicity tests of such well-characterized substances as butane, propane, and ethane.

  • General Electric planned to test chemicals individually rather than in groupsa violation of the October 1999 moratorium.

  • FMC Corporation planned to subject animals to painful skin toxicity testing, in which chemicals are applied to animals shaved skin to see how much it takes before they die.

  • The Industrial Health Foundation plans to subject 1000 animals to tests with a blinding and corrosive chemical.

A detailed analysis of HPV chemical test plans submitted to date, entitled "Analysis of the High Production Volume Challenge: Industry Violations and EPA Negligence," has been prepared by the Physicians Committee for Responsible Medicine. Click here to download this report. Recent reports that analyze the redundancy and unscientific nature of many of the HPV test plans include an article in the journal Alternatives to Laboratory Animals and PETA's recent HPV rulemaking petition.

You can download our technical comments for each HPV chemical test plan by clicking on the links below or by visiting the EPA's Web site.

Chemical Company or Consortia Chemical Name or Class Animal Protection Community's Comments
Akzo Nobel Functional Chemicals LLC 2-Propanol, 1, 3-dichlorophosphate Click here to view PDF of comments
American Forest and Paper Association Spent Pulping Liquor Click here to view PDF of comments
American Petroleum Institute Petroleum Coke Click here to view PDF of comments
Petroleum Gases Click here to view PDF of comments
Bayer Corporation Cylcohexyl Isocyanate Click here to view PDF of comments
Ciba Specialty Chemicals Corporation Irganox 1076 Click here to view PDF of comments
Irgafos 168 Click here to view PDF of comments
Irganox 1010 Click here to view PDF of comments
Chemical Manufacturers Association (now American Chemistry Council) High Butadiene C4 Click here to view PDF of comments
Alkyl Sulfides Click here to view PDF of comments
C5 Non-Cyclics Category Click here to view PDF of comments
Dioxolane Manufacturers Consortium 1,3-Dioxolane Click here to view PDF of comments
Ethanol HPV Challenge Consortium Ethanol Click here to view PDF of comments
ExxonMobil Alkyl Acetate C6-C13 Category Click here to view PDF of comments
Flavor and Fragrance HPV Consortia Cinnamyl Derivatives Click here to view PDF of comments
Terpenoid Tertiary Alcohols and Related Esters Click here to view PDF of comments
C6-C10 Aliphatic Aldehydes and Carboxylic Acids Click here to view PDF of comments
FMC Corporation 2,3-dihydro-2,2-dimethyl-7-benzofuranol (7OH)and 3- chloro-2-methyl-1-propene Click here to view PDF of comments
General Electric p-Cumylphenol Click here to view PDF of comments
Phosphorous Acid, Cyclic NeoPentanetetrayl Diphenyl Ester Click here to view PDF of comments
Industrial Health Foundation Cyclic Anhydrides Click here to view PDF of comments
Phosphite Producers HPV Consortium Tris (Nonylphenyl) Phosphite Click here to view PDF of comments
Pine Chemicals Association, Inc. Tall Oil Fatty Acids and Related Substances Click here to view PDF of comments
Schenectedy International Alkylphenols Click here to view PDF of comments
Silicones Environmental, Health and Safety Council Aminosalines Click here to view PDF of comments
Silane Trimethoxy Click here to view PDF of comments
Trioxane Manufacturers Consortium 1,3,5-Trioxane Click here to view PDF of comments


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