June 19, 2006
Megan Carroll, Chief
Outreach Branch
Office of Pollution and Toxics
U.S. Environmental Protection Agency
Washington, D.C. 20460
Dear Ms. Carroll:
In your response to my letter to Stephen L. Johnson, Administrator,
requesting that EPA consider the "Step-Down Approach" in
aquatic testing procedures involving fishes, you have pointed to
EPA's relationship with the Interagency Coordinating Committee
for the Validation of Alternative Methods and the Organization for
Economic Cooperation and Development as indicators of a commitment on
the part of EPA to reduce the number of animals involved in testing
wherever possible. Given the concerns I expressed on this
matter in my earlier letter, I am, of course, gratified to hear that
this is part of your agenda. However, I note that in your
letter, you also state:
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While we actively
work to develop and adopt alternative methods that will reduce,
optimize, or eliminate animal use, EPA's primary responsibility
continues to be to ensure the protection of human health and the environment.
Until there are reliable, scientifically sound non-animal
alternatives, the Agency must continue to meet its obligations using
the best available information, including animal testing data, when
necessary, to better understand the effects that potentially
hazardous substances can have on living organisms.
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The priority given by EPA to human health, followed by environmental
concerns (both of which appear to rank significantly higher
than concern for the suffering caused to nonhuman animals via testing
procedures) is interesting to note. I believe my interpretation
of the ordering is correct when I say that, by making human health
its primary consideration, EPA operates from a premise which holds
that human exploitation of both the environment and of nonhuman
animals is, so to speak, sacrosanct – a given which is not open to
serious question or doubt. Many of us, however, are
increasingly concerned with the wisdom of this approach.
Without wishing to reduce the emphasis placed on human health, we
believe that equal emphasis should be placed on protecting the
environment for its own sake and on its own merits (i.e. as opposed
to being given a subsidiary function to toxin-producing industries),
and that individual members of nonhuman animal species are deserving,
if not a consideration as great as that bestowed upon humans, then at
least a much greater degree of consideration than is currently given.
Our belief is founded upon the idea that, the human species being but
one part of a larger, intertwining and interdependent whole, to fail
in one area of concern is to fail in all.
It's entirely possible, of course, that I have not fully
appreciated EPA's position; still, I heard neither
acknowledgement nor understanding of the perspective I've
briefly touched upon here. Hence this second letter to you,
which I have given over to an expression of the kind of broader
concerns which premise my desire to see EPA limit or eliminate the
many toxicity tests, involving both fishes and other types of
animals, which it requires to be produced on such a massive scale.
I thank you for your response to my earlier letter, and for your
attention to this one.
Yours sincerely & etc. . . .
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