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