EDMVS Pub Comment (PETA)

Comments presented by People for the Ethical Treatment of Animalsthat the December 10-12 2001 meeting of theEnvironmental Protection Agency’sEndocrine Disruptor Methods Validation SubcommitteeTroy Seidle, B.Sc.Research AssociatePeople for the Ethical Treatment of AnimalsThese comments are submitted on behalf of People for the EthicalTreatment of Animals (PETA) and our over 750,000 members and supporterswho are deeply concerned about the implications to animals of the EnvironmentalProtection Agency (EPA)’s Endocrine Disruptor Screening Program (EDSP).Despite the EPA’s repeated assurances that it is “strongly committed toanimal welfare principles” and to the “development and validation of1scientifically sound tests that reduce, refine and replace existing tests,” there hasbeen little evidence of such a commitment in the agency’s implementation of theEDSP. For example, it appears as though the non-animal assays being consideredfor inclusion in the EDSP are limited to ER/AR binding, steroid hormonesynthesis, and possibly transcriptional activation. There is no evidence that otheravailable and promising in vitro assays have or will be considered for pre-screening or screening purposes in the EDSP.A case in point is the EPA’s treatment of the EDSTAC-recommendedhigh-throughput pre-screening (HTPS) assays. Despite a congressionalappropriation of $4 million to develop and validate assays for use in the EDSP,the EPA abandoned these rapid, in vitro systems as ...