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Questions and Answers

What is the HPV program?
The HPV chemical-testing program requires that all chemicals manufactured or imported into the U.S. in excess of 1 million pounds have a complete set of standardized animal tests publicly available. This means that up to seven different animal tests may be required for each of up to 2,800 HPV chemicals. This unprecedented five-year program will kill more than 1 million mice, rats, rabbits, and guinea pigs and countless birds and fish.

Who is responsible for the HPV program?
The HPV chemical-testing program was initiated in response to intense government lobbying by the advocacy group Environmental Defense.

The program is the result of closed-door meetings held in 1998 among Environmental Defense, the Chemical Manufacturers Association, and the Clinton-Gore administration. Even though the program started in November 1998, the EPA only gave public notice of the HPV program two years later-in December 2000. As a result, the program bypassed normal governmental procedures of scientific review and public comment.

What tests are being used in the HPV program?
Under the threat having mandatory testing imposed on them by future EPA regulation, 469 companies agreed to sponsor 2,155 chemicals in the HPV program. Faulty animal tests often work in favor of the chemical industry because they are frequently inconclusive. Animal tests can actually clear chemicals already known to be hazardous or delay the regulation or restriction of those chemicals. Further, recent articles quote industry representatives as supporting the HPV program in order to avoid a congressional examination of the ineffectiveness of the Toxic Substances Control Act, which the EPA has not used even once in the past decade to ban a dangerous industrial chemical.

Why is the chemical industry participating?
The HPV program calls upon the chemical industry to collect toxicity information for each HPV chemical using an arbitrary checklist of animal-poisoning tests. These tests involve injecting chemicals into animals' stomachs, forcing chemicals down their throats, and pouring chemicals into the eyes and onto their skin. Click here for more information about specific test methods.

Are the results of animal tests relevant to humans?
There is much scientific evidence documenting the failure of animal-based toxicity tests to accurately predict human reactions to chemicals. Such errors are not surprising, given the many differences that exist between species in terms of their anatomy, physiology, biochemistry, and metabolism. Such variables make it impossible to accurately extrapolate test results from one species to another. Click here for more information about scientific problems with animal tests.

Are there any non-animal methods that could replace animal tests in the HPV program?
There have been many advances in non-animal testing in recent years, and as a result, much of the testing required by the HPV program could potentially be done without poisoning animals. One such method, which uses cell lines to test for a chemical's ability to damage chromosomes, has already been incorporated into the program-but only after a huge effort on PETA's part. There are currently several additional non-animal tests, including a cell-based test to replace the crude and cruel lethal dose tests, that are nearing the final stage of completion. Importantly, human experience and occupational exposure data are ignored in the HPV program but could provide a far more accurate picture of a chemical's true hazard. Click here for more information about non-animal methods.

Is it true that many HPV chemicals are missing a lot of important information?
Reports published by Environmental Defense, the American Chemistry Council (ACC), and the EPA greatly underestimate what is known about HPV chemicals. As a result, the conclusions reached are seriously flawed and misleading. For example, the Environmental Defense report Toxic Ignorance would have one believe that a lack of animal toxicity testing for wood shavings is a threat to public health. Similarly, the EPA study claimed that vinyl chloride has never been studied for its long-term toxic effects, despite other government documents showing that vinyl chloride has been the focus of hundreds of human population and animal studies for more than 50 years.

Research conducted by the Physicians Committee for Responsible Medicine details the enormous amount of publicly available information overlooked by these reports. In fact, since PCRM's study was released, Environmental Defense and the EPA have both publicly acknowledged that their reports should only be considered "scoping studies" because so much information was overlooked. Far from being legitimate efforts to determine what is known about HPV chemicals, the Environmental Defense and EPA reports were undertaken only to "document" a predetermined conclusion. The ACC report acknowledges it was forced to underestimate existing data because of the "checklist" nature of the information sought.

Is it possible that testing will be performed on chemicals already known to be hazardous?
Yes. Although the vast majority of HPV chemicals have been around for decades and are already very well characterized, they may not have undergone the specific tests required by this program. So regardless of how much is known about a chemical's risks, the HPV program still requires all chemicals to undergo an identical and arbitrary checklist series of animal tests.

But will testing be performed on chemicals that have been tested on animals in the past?
Yes, for several reasons: Many animal tests performed in the past were conducted following slightly different methods than those currently required, which could mean that old test results will not be accepted under the HPV program. In addition, chemical companies are unlikely to submit data from previously conducted animal tests that show their chemicals to be harmful. It is more likely that companies will conduct new tests with the hope that the results will be more positive this time around.

How will information from the HPV program be used?
Remarkably, the HPV program has nothing to do with taking dangerous chemicals off the market. In fact, the EPA has stated that it will not even review chemical information that is submitted but will instead simply put the results of the tests on its Web site. Instead of protecting the public from hazardous chemicals, the EPA will inform us as to how quickly mice and rabbits died when force-fed a chemical or how many mouse pups were stillborn after their mother was force-fed massive quantities of already-known toxic chemicals. The EPA has not banned a single toxic industrial chemical in more than 10 years -this dismal track record will not change as a result of the HPV program.

What is PETA doing about the HPV program?
PETA is actively campaigning to insert some common sense into the HPV program and to save moe animals from suffering and death:

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