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EPA Partners with Organizations to Address Animal Testing in Compliance with TSCA

The EPA announced its partnership with various organizations to address methods for reducing vertebrate animal testing as required under the Toxic Substances Control Act (TSCA).  The webinar took place on April 24, 2019 and brought together People for the Ethical Treatment of Animals (PETA) International Science Consortium, the Physician’s Committee for Responsible Medicine (PCRE) and the EPA.

When TSCA was amended in 2016, various organizations, including PCRE, attempted to ensure that revisions to the Act would not lead to a substantial increase in animal testing. While, in some cases, the EPA continues to require chemical manufacturers to perform animal toxicity tests, the amended TSCA outlines the means toward achieving the objective of reducing and replacing the use of animals in chemical testing. As such, the EPA is required to provide an explanation for its decision to use vertebrate animals in chemical testing processes and perform screening tests without animals to provide information about whether additional tests are required. In addition, the EPA must apply other relevant non-animal methods when conducting tests.

The EPA’s Office of Pollution Prevention and Toxics (OPPT) is obligated to implement the provisions of TSCA including the requirement that the EPA create a Strategic Plan to develop alternative testing methods to vertebrate animal testing. The EPA previously described its Plan to reduce animal testing of chemicals that are evaluated under TSCA by employing new approach methodologies (NAM). NAM refers to any method that can be applied to chemical risk evaluations that eschews the use of animals. The Strategic Plan consists of: (i) identifying and developing NAMs for evaluations under TSCA, (ii) engendering confidence that that NAMS are reliable, and (iii) implementing relevant NAMs.

The goal of finding alternatives to animal testing may have been prompted by reports in Science and other publications that EPA requested or required approximately 10 times the number of animal tests for new chemicals in 2017 as it had in years before. This substantial increase has caused concern among various organizations that oppose the use of animals for chemical testing purposes.

Grimaldi Law Offices has been advising clients for over 20 years on chemical and product law. For knowledgeable advice and in-depth analysis on your chemical regulatory compliance obligations, contact Grimaldi Law Offices at (415) 463-5186 or email us at [email protected].

Ms. Grimaldi maintains a diverse environmental law practice focusing on chemical and product regulation and litigation defense. Her practice areas include Proposition 65, California's Safer Consumer Products Regulations, California's Rigid Plastic Packaging Container Act and the federal Toxic Substances Control Act. Ms. Grimaldi graduated from the University of California Hastings College of the Law magna cum laude and holds a Bachelor of Science Degree in Bacteriology from University of California, Davis. Prior to attending law school, she worked as a research assistant in laboratories at the University of California, San Francisco Cancer Research Institute and at the University of California, San Francisco School of Medicine.