April 25, 2006
Stephen L. Johnson, Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Ave. N.W.
Washington, DC 20460
Re: Use of fish in toxicity testing
Dear Mr. Johnson:
Although it remains uncertain whether or not fish are capable of
feeling "pain" in a manner analogous to humans, mounting
scientific evidence indicates that they can indeed experience
physiologically felt discomfort; whether or not this discomfort is
experienced as "pain" per se, it cannot reasonably be
denied as constituting a form of suffering. Researchers at the
Roslin Institute, for instance, have demonstrated that, when fishes
are exposed to noxious stimuli, they exhibit behaviors which extend
beyond that of a mere reflex response and enter the realm of
perceived distress. Moreover, while the "sentience,"
or degree of consciousness, held by fishes is likewise still
considered to be debatable subject, studies have made it clear that they
are capable of learned behaviors, and may thus be considered to have
– in however rudimentary fashion – some capacity for abstraction, and
consequently may also be considered to have some degree of emotive
response to their environmental conditions. In light of all
this, it would seem correct to state that fishes are the possessors
of, at the very least, an experiential consciousness; have a desire to
avoid contact with substances which will cause them harm; and seek
out conditions favorable to their continuance and well-being.
Fishes are, in short, demonstrably capable of expressing all the
prerequisites necessary to make them candidates for protection
against undue cruelty.
The Environmental Protection Agency (EPA) currently requires
companies to subject thousands of fishes each year to deadly
poisoning studies in order to evaluate the potential consequences of
chemical pollution on rivers, lakes, and oceans. In these
studies, groups of fishes are exposed to increasing concentrations of
a test chemical through the water that they live in until a level is
reached at which half of them die. Clearly, the fishes involved
in these studies are subjected to conditions which will cause them suffering.
The European Centre for Validation of Alternative Methods (ECVAM)
recently issued a statement endorsing a "Step-Down"
approach to aquatic toxicity testing; this approach makes use of
algae and daphnia as the first step, or "tier," for
chemical testing, and does so in such a way as to reduce the number
of fishes used from 65.0% to 72.8%. Adoption of such a strategy
by the EPA would significantly reduce the amount of suffering caused
by chemical testing.
It is easy to overlook or ignore the suffering of fishes in our
desire to create a more "chemically safe" environment; and
while the suffering of some may arguably be said to be a reasonable
price to pay in order prevent environmental dangers which, if left
unchecked, would likely bring suffering to many more, when realistic
alternatives to present testing procedures exist, it seems morally
unconscionable not to make use of them. I am, therefore,
writing to urge you to closely consider the possibility of adopting a
new protocol with regard to your chemical toxicity testing program,
one that would bring it in accord with the approach recently outlined
by ECVAM.
Yours sincerely & etc. . . .
|