Select Committee on Science and Technology Written Evidence


Memorandum from the British Union for the Abolition of Vivisection

  1.  The BUAV (British Union for the Abolition of Vivisection) has played a leading role in the REACH debate. We are most grateful to members of the Science and Technology Committee for inviting us to submit evidence to the inquiry on the proposed EU chemicals legislation.

  2.  As requested, in this submission of written evidence we will not attempt to repeat arguments already made through past submissions to the Commission or published documents. We would wish, however, to draw your attention to the following BUAV publications: The Way Forward: Action to End Toxicity Testing on Animals (BUAV 2001); the BUAV's submission to the House of Lords European Union Committee Inquiry on the EU "Strategy for a Future Chemicals Policy" (October 2001) and to the submission made by the BUAV through the European Coalition to End Animal Experiments to the European Commission's consultation on REACH of May 2003. These documents have been submitted to the Committee for information.

  3.  One further publication (Appendix 1): Animal Testing: A Regulatory Smokescreen?, is attached and we wish to point out that this document is, at the time of writing, still in production. We do, however, feel that it will be of use to the Committee in assessing our arguments relating to scientific and practical problems that arise when chemical regulation is based on data obtained from animal testing. As this is a new report, we wish to emphasise its importance: we feel that it brings significant, and previously unpublished, factual information to the testing debate.


  4.  The BUAV is opposed to all animal experiments, and although we seek here to draw your attention to a number of amendments to the current REACH proposal that will reduce the number of animal deaths, our overall objective is to promote an entirely animal free test battery for chemicals.

  5.  We support the aim of protecting human health and the environment through effective chemical regulation based on non-animal test methods. Our document The Way Forward sets out a non-animal test strategy for chemicals, as does our submission to the European Commission's May consultation.

  6.  We believe that animal tests are ethically unacceptable and that there are compelling practical and scientific arguments for avoiding animal use. Furthermore, evidence already presented through our publications The Way Forward and more recently through Animal Testing: A Regulatory Smokescreen?, indicates that as long as animal tests form the basis of chemicals regulation, the process will be flawed and progress on chemicals control will be hindered by irrelevant and inaccurate animal test data.

  7.  We will make every effort to keep within the remit of questions posed by the Committee. In answer to each question, we will divide our comments into two distinct sections: the first being on testing and the second relating to data sharing and the prevention of duplicate animal testing.

  8.  In taking this approach we do not wish to distance ourselves, or our audience, from the reality of animal toxicity testing. It is all too easy to stand back from the central issue we are addressing: the deliberate forced poisoning of millions of animals, over days, months or years. It is a disgrace that animal toxicity testing has continued into the 21st century. REACH, along with the political, economic and ethical debate that it brings, provides all of us with an opportunity to hasten the end of animal poisoning tests, and the introduction of more modern, humane and effective test methods.

Question: What needs to be amended?


  9.  The current Commission proposal to introduce REACH (Registration, Evaluation and Authorisation of Chemicals) contains a requirement that substances produced at 1 tonne or more per year are registered with the proposed EU Chemicals Agency. Because standardised data requirements for so-called "existing chemicals" (those first marketed before 1981) have not previously been required, registration of substances that have been in use for decades will be linked to requirements for the submission of animal test data. There are around 30,000 existing substances, and although data requirements vary according to production volumes of each substance, the overall requirement is for data obtained through many millions of animal tests.

  10.  To test a single high production volume chemical under the current proposal would take thousands of animals. Multiplied over all production volumes and all existing substances it is clear that the level of animal suffering, as well as the cost of testing, is a serious problem that must be addressed.

  11.  The BUAV believes that much of the data needed by regulators already exists, and that by ensuring that data sharing becomes mandatory under REACH, authorities will not only be able to prevent duplicate animal testing being carried out for the purposes of registration and evaluation of substances that are already on the market, but also improve systems of monitoring and co-ordinating test plans for new substances, so that the problem of duplicate animal testing is eliminated entirely. Duplicate animal testing, as discussed here, refers to repetition of animal tests that happens when the company carrying out a test either does not know that the test has already been carried out or does know this but cannot access the results. It does not refer to repetition of animal tests where the repetition is claimed to be for scientific reasons.


  12.  The scientific arguments against the use of animal toxicity tests are set out in The Way Forward (see above). We will not repeat them here but wish our comments to be seen in the context of the inherent deficiencies of animal test methods. The BUAV's recent forthcoming report: Animal Testing: A Regulatory Smokescreen? (Appendix 1 (not printed)) explains how the use of animal tests frequently undermines effective chemical control. The BUAV briefing on carcinogenicity testing (attached as Appendix 2 (not printed)) reports on studies conducted to assess the effectiveness of the animal cancer test. The studies clearly demonstrate the scientific weakness of the test.

  13.  In the most general terms, the scientific arguments against using animal toxicity tests can be summarised as follows:

    1.  The response to a chemical in the animal species/strain/gender used differs from that of humans or another test species.

    2.  The absorption, distribution, metabolism or excretion of a chemical differ between species.

    3.  The tissue effects are not the same at the macroscopic or microscopic level as in humans or are seen in different organs.

    4.  Differences at the anatomical, physiological, cellular, subcellular, or receptor levels cause varying susceptibilities to toxicity.

    5.  The dose required to produce toxic effects in animals may never be reached in humans.

    6.  The target dose in humans cannot be achieved in test animals or the test is not sensitive enough.

    7.  The potential synergy between many chemicals to which humans are exposed cannot be studied in animal tests.

    8.  The test animals (ie inbred, genetically identical rodents) neither represent normal animals of their species nor the human population of concern.

    9.  The experimental conditions may differ from test to test.

    10.  The experimental conditions are inappropriate to the human situation.

  (Based on Table 2 in Gad, SC (1990). Model selection in toxicology: Principles and practice. J Am Coll Toxicol 9:291-302.)

  14.  The BUAV believes that the only ethically and scientifically defensible strategy is an entirely non-animal one. However, for the purposes of this submission, at the very least the current legislative proposal can be amended to reduce animal deaths in the ways listed below.

Annex I

  15.  Paragraph 0.8 of Annex I should be amended to ensure that animal testing stops as soon as findings on a particular toxicological endpoint indicate the need for stringent control measures.

Annex IV and IX

  16.  We have proposed a revised Annex IV that combines the current Annex IV and Annex IX (our "revised Annex IV" is attached as Appendix 3 (not printed)).

  17.  As regards content, the "Guidance note on fulfilling the requirements of Annexes IV to IX" (first part of current Annex IV) is more closely related to Annex IX than to the "Information referred to in Article 9 (1) (a) (i) to (v)" (second part of current Annex IV). The information currently provided in the Guidance note and Annex IX is partly redundant and partly complementary. Therefore the "Guidance note on fulfilling the requirements of Annexes IV to IX" and the current Annex IX should be amended to ensure consistency. This new text should precede Annexes V-VIII in order to ensure that its rules will be put into practice when meeting the information requirements.

  18.  The amendment places more emphasis on steps that can be taken before new animal tests are even considered; calls for a preliminary risk assessment (which may be adequate on its own) to be made before any new tests are undertaken, and mandates the use of in vitro data. All of these measures are necessary in order to meet the Commission's stated aim of ensuring that animal testing is only carried out as a last resort.

  19.  In addition to this re-write, we wish to make the following general points about the current Annex IV:

  20.  We welcome acceptance of the idea that the information requirements of Annexes IV to IX should be fulfilled in stages, so that the outdated "tick-box" approach to toxicity testing is, rightly, abandoned. However, we believe that the staged approach described can be improved in order to meet the Commission's stated aim that animal tests should be used only as a last resort.

Step 1—Gather and share existing information

  21.  This step should not refer to formation of consortia only "where practicable". In order to avoid duplicate animal testing, there should be only one registration per substance as is currently being discussed by the UK government, and this Annex must be amended to reflect that policy.

Step 4—Generate new data/propose testing strategy

  22.  Greater reduction of animal use can be achieved here through text indicating that regardless of tonnage, vertebrate animal testing should not be performed before consultation of experts in the field of non-animal test methods has taken place. Whilst it is welcomed that the Commission has given a clear signal that new non-animal tests should be brought into use at the earliest opportunity through committee procedure, it is felt that the expertise of those with experience in this field should be drawn up on to further examine all test proposals.

  23.  Step 4 should also reflect the need for classification, without further testing, should be made on the basis of relevant exposure and the information requirements for the given production volume. As soon as information gives cause for concern, the substance should be classified accordingly and further testing should not take place.

Annex V

  24.  The in vitro skin penetration test should be added here, not only for assessing skin sensitisation potential (see below) but also to provide enabling data which will assist the risk assessment of chemicals via skin absorption in Annex VI (eg acute and repeat dose toxicity).

  6.3  Skin sensitisation—replace LLNA and Guinea Pig Maximisation Test with a combination of three kinds of non-animal data. These can be used to identify likely sensitisers and non-sensitisers. These are:

    1.  protein binding (eg to human serum albumin) in the test tube;

    2.  skin penetration in vitro (OECD Test Guideline 428); and

    3.  (Q)SARs and computer expert system predictions (eg DEREK, TOPKAT and CASE).

  27.  Three negatives would indicate that the chemical would not cause skin sensitisation, and three positives likewise for sensitisers. For this reason these three methods, although not formally validated for this purpose, should be included in the hierarchical test scenarios for 1-10 t. Contradictory results should be further explored by in vitro methods, and a classification made by use of expert judgement and application of the precautionary principle. When cell-based assays to assess skin sensitisation are developed and available, they will provide sufficient additional information to review the classification. The finalisation of these methods within the foreseen time span of REACH implementation will require priority funding and expertise, via governments, the Commission and the industry. Animal-based skin sensitisation tests should not be required.

  6.4 Mutagenicity

  28.  Under the specific rules for adaptation, the wording is vague as to whether in vivo or in vitro further studies should be done. It should state clearly here that "Further mutagenicity studies in case of a positive result" shall be in vitro studies and not in vivo.

Annex VI

  6.1.1  In-vivo skin irritation

  29.  The specific rule for adaptation ought to reflect that an in vitro method (validation study currently underway) would be able to classify non-irritants as well as irritants; so the wording should say (proposed change in italics):

  30.  "-- the data available from the testing strategy foreseen in Annex V, Section 6.1, is adequate to classify the substance with regard to corrosivity and irritancy."

Annex VI

  6.4  Mutagenicity

  31.  In vivo tests can be avoided here through use of validated alternatives. Classification should be made on the basis of in vitro mutagenicity tests, together with in vitro and computer modelling approaches to absorption and metabolism to predict the whole organism effect.

Annex VI

  6.5  Acute toxicity

  32.  The use of non-animal tests using a stepwise approach requires the inclusion here of in vitro skin absorption data. The in vitro test (OECD 428) is not currently included in Annex X and this omission must be corrected because the rules for adaptation (6.5.3, p 60) state that acute toxicity by the dermal route is appropriate if in vitro tests indicate significant dermal absorption. Since the strategies use this method it must be added to the guidelines.

  33.  Acute toxicity should be determined making use of basal cytotoxicity tests. If necessary, these studies can be complemented by organ-specific in vitro tests to determine organ-specific toxicity.

Annex VI

  6.6  Repeated dose toxicity

  34.  Again, in vitro skin absorption data are referred to (p 61).

Annex VI

  6.7  Reproductive toxicity

  35.  The in vitro embryonic stem cell test should be included here as a non-animal test for direct acting embryotoxins. It has been approved as valid by ECVAM but not adopted by EU regulators because it doesn't include a metabolism step to identify toxic metabolites.

  36.  However this should not stop it being used to identify strong, direct-acting (ie regardless of metabolism) embryotoxins, so it should be listed here and added to Annex X.

Annex VII

  6.4  Mutagenicity

  37.  In vivo tests should not be listed here. Instead classification should proceed on the basis of in vitro mutagenicity tests, together with in vitro and computer modelling approaches to absorption and metabolism to predict the whole organism effect.

Annex VII

  6.6.2  Sub-chronic toxicity study (90 day)

  38.  Again, on p 69 in vitro skin absorption is described so this method must be added to Annex X.

Annex VIII

  6.4  Mutagenicity

  39.  Under the rules for adaptation, further in vivo studies should not be called for in the case of a single positive result in any previous study, if all the other results have been negative.

Annex VIII

  6.9  Carcinogenicity

  40.  Since there is a guideline in Annex X for an in vitro mammalian cell transformation test, this should be mentioned here in the rules for adaptation (p 77-78).


Existing requirements for companies to hold data

  41.  Under existing legislation there are already requirements for companies to hold a significant amount of data, which are in practice obtained from animal tests, so data sharing provisions planned under REACH are of particular importance in reducing animal suffering.

  42.  Commission Directive 91/155/EEC, as amended on 27 July 2001 (the "Safety Data Sheets Directive") requires companies to hold safety data sheets giving information on toxicological and ecotoxicological endpoints. This should include information on "different routes of exposure (inhalation, ingestion, skin and eye contact)" and "known delayed and immediate effects and also chronic effects from short and long-term exposure: for example sensitization, carcinogenicity, mutagenicity and reproductive toxicity including teratogenicity and narcosis."

  43.  Other legislation dealing with health and safety, accidents, and accidental releases, also requires companies to hold data, which will in practice include extensive animal test data.

Duplicate animal testing—a brief outline of the problem

  44.  It is now widely acknowledged that duplicate animal testing is a significant problem, particularly in some sectors. The following are examples only:

    the Commission White Paper on chemicals testing ("Reach") acknowledged that duplicate animal testing is a problem which has to be addressed in the proposed new regime.

  45.  The Environment Council (of Ministers) resolved in June 2001 (in the same context):

    ". . . animal testing should be limited to the level necessary to deliver the objectives of the strategy, including a high level of protection for human health and the environment. Industry should make all existing data available to avoid duplication of testing."

  46.  DG Sanco recently published a report about pesticides regulation (which is outside Reach, although likely to be influenced by it)[44]. It bemoaned the reluctance of companies to form consortia for the purposes of registering substances and said[45]:

    "Ideally, there would have been a single dossier. This would have saved resources both for the various notifiers and for the Rapporteur. It would also have resulted in fewer laboratory animals being sacrificed in duplicated testing. While every effort is still being made to encourage notifiers to create taskforces and to submit a single dossier per substance, it is still not always possible to achieve this. A solution could be to introduce provision in the legislation to avoid duplicate testing eg action point 5[H] in the White Paper on a Chemicals Strategy proposes that any duplicate testing on vertebrate animals will not result in an exemption from the duty to reimburse the party that owns the property rights to the first test."

  It went on to suggest that[46]:

    ". . . there is an inherent conflict of interest between the multinational R&D-based companies and the smaller generic producers. Even within the group of multinationals there is much suspicion and reluctance to share data defined as confidential".

  47.  The OECD recognises that there is a need to "reduce" duplicate animal testing[47], which necessarily presupposes that it occurs.

  48.  The former UK chief inspector, Jon Richmond (also a member of TEWG), recently told a parliamentary committee[48]:

    "What we try to root out is unnecessary duplication—sometimes people do not know they are trying to reproduce the work of others".

  49.  The Animal Procedures Committee ("APC"), the UK Government advisory body, said in its recent report on the cost/benefit test under UK legislation49:

    ". . . avoiding all such duplication [which it describes as `accidental duplication of previous testing'] can be difficult, since the results of many animal studies never make it into the pages of scientific journals—because, for example, they are `negative' (eg they fail to prove a hypothesis), or lead to a `blind alley' (such as occurs when a possible novel drug candidate is found unsuitable and discarded) . . . [49]

    Unnecessary duplication of safety and efficacy tests when adequate data already exist is a particular concern in this context. Commercial competition can be a barrier to data sharing, and data are often classified as confidential within companies, so that test may be duplicated because companies are unaware of and/or cannot gain access to data that other companies and the regulatory authorities hold . . .'

  50.  In an article in Chemistry and Industry on 20 November 2000, Professor James Bridges[50] said this:

    "A vast amount of data on the toxicology and occupational effects of many chemicals (including industrial chemicals, drugs, pesticides, personal care and home products) has been generated over the past 50 years. However, a considerable amount of this information is classified as "in confidence", is very difficult to obtain or cannot be utilised readily because of the form of its presentation. As a result, duplication of effort and initiation of inappropriate tests are not uncommon."

  51.  "Duplication of effort inevitably includes duplication of animal tests. Industry itself is increasingly prepared to acknowledge that it is an issue. There is anecdotal evidence—some of it referred to before the UK parliamentary committee referred to above—that companies sometimes positively want competitors to have to repeat "blind alley" tests in order to gain commercial advantage. For example, in his memorandum to the UK House of Lords select committee on animal procedures in 2001, Robert McCracken, a member of the APC and a lawyer, said this:

    "Unnecessary harm to animals is built in to the system as the absence of any requirement to publicise results leads to duplication. Pharmaceutical companies have a `strong commercial interest' in not publishing blind alley research results [according to a Glaxo Wellcome company representative who expressly agreed that her views could be made public]."

  52.  Indeed, it is not surprising that duplicate animal testing occurs, given that companies are anxious to preserve the confidentiality of data they have spent money in generating.

Solving the duplication problem through REACH

  53.  Since duplicate animal testing is caused by ignorance of, or inability to access, relevant data which has already been generated, it follows that the solution lies in publicising and making available that data. The system must be mandatory. As the Commission recognises, mere encouragement to companies to share data does not work.


  54.  Compensation should, of course, be paid to companies which are required to share animal test data they have generated with other companies. However, there would be nothing new about this. For example, in the US section 3 of the Federal, Insecticide, Fungicide and Rodenticide Act of 1947 ("FIFRA") requires compensation to be paid in some circumstances where data is shared between pesticide companies (with binding arbitration if the companies cannot agree a figure). Similarly, in Germany, Article 14 of the Erstes Gesetz zur Änderung des Pflanzenschutzgesetzes ("Act concerning the protection of crop plants") requires compensation, assessed at 50% of the costs saved by the benefiting company, in certain circumstances. And, in Austria, under section 7(3) of the Chemicals Act 1996, a company holding an approval to market a chemical must share its animal test data with a subsequent applicant, which must then contribute to the cost. Indeed, according to the Commission, Austria, Belgium, Denmark, Finland, Germany, Greece and Spain have taken up the option given by Article 15(4) of EC Directive 67/548 ("the dangerous substances directive") of requiring companies based on their territory to share animal test data, specifically to avoid duplicate animal testing.

True commercial sensitivity not imperilled

  55.  Importantly, the requirement to share animal test data—that which already exists as well as that which is generated in future—would not imperil valuable intellectual property rights. EC legislation already makes a clear distinction between truly sensitive information (colloquially called "trade secrets"), which have to be protected from disclosure, and the results of animal tests, which do not require protection in the same way even though they may have some commercial value.

  56.  For example, under Article 16(6) of the dangerous substances directive, member states and the Commission must not disclose "any information concerning commercial exploitation or manufacturing". However, Article 19(1) then draws a distinction between information which is "commercially sensitive and disclosure of which might harm [a company] industrially or commercially" and other information. The provision goes on to say that "the summary results of the toxicological and ecotoxicological tests"—which will include animal tests—are not "industrially or commercially secret" and can therefore be disclosed. This is, presumably, because their disclosure will not harm the company.

  57.  The same approach is taken in EC Regulation 793/93 (which regulates chemicals which have been on the market since before July 1981), EC Directive 91/414 (the pesticides directive) and EC Directive 98/8 (the biocides directive).

  58.  UK legislation—for example, regulations 19 and 27, respectively, of the Plant Protection Products Regulations 1995 and the Biocidal Products Regulations 2000—makes the same distinction between the commercially sensitive and test data. And so, in the US, does section 10 of FIFRA: test data "shall be available for disclosure to the public".

  59.  Indeed, the fact the chemicals industry has begun to share data on a voluntary basis demonstrates that there are no insuperable intellectual property obstacles to its doing so. For example, European and US companies are engaged in a programme to evaluate the safety of a number of chemicals by 2004. An important component of that programme is the sharing of data, albeit on a voluntary basis. In its oral evidence to subcommittee D of the House of Lords select committee on the European Union on 4 July 2001, the representative of the Chemicals Industry Association ("CIA") stated (para 165):

    ". . . we have already started and made significant progress in addressing and removing many of those barriers to data sharing between members, because people do recognise this is common ground, it is common interest, and we all have a shared goal here. So sharing hazard data between primary manufactures is much less of an issue today than it would have been three years ago. We have made tremendous strides forward and we are keen to build on that . . ."[51].

  60.  We understand that the major global oil companies have also begun to share resources relating to animal testing. In the US, the so-called "October agreement" relating to the High Production Volume ("HPV") programme is designed (inter alia) to avoid duplicate testing and has at its heart the sharing of data, as we shall explain.[52]

  61.  The problem with voluntary schemes, however, is that they only work as well as the companies involved in them want them to work. As we have explained, very often companies do not want to share data because withholding it is perceived to give them a commercial advantage. Compulsion is therefore required if duplicate animal testing is to be avoided.

Co-ordination of test plans

  62.  It is also essential that there is co-ordination of test plans so that duplicate animal testing can be avoided when testing is carried out to meet registration and evaluation requirements of REACH; for testing carried out for the purposes of research and development (currently R&D is exempted from REACH) and testing of non-phase in substances being brought onto the market for the first time.

  63.  The proposal for a central database run by the Agency (Article 73) will help to prevent duplicate animal testing, and measures currently described in Articles 23 to 27 go some way to avoiding duplication for registration of phase in substances. However, these provisions must be strengthened so that data sharing becomes mandatory, either through introduction of a system whereby only one registration per substance is allowed (with a requirement that companies work together on submission of existing data and generation of new data) or through a separate system that would require companies to notify the Agency of the presence of all existing data in a pre-registration package, possibly linked to submission of Chemical Safety Reports. Our preference is the former as it is administratively easier and more likely to eliminate duplicate animal testing.

  64.  The Agency should co-ordinate test plans (for evaluation, R&D and non-phase in substances) through its database, and where these involve exchange of information that could be deemed to be commercially sensitive, exchange of information should be co-ordinated by an independent third party.

  65.  We feel that current proposals for test plan evaluation are too limited (applying, as they do only to animal testing carried out to meet registration requirements to test under Annexes VII and VIII), and could be poorly co-ordinated because test plan evaluation is currently proposed to take place at MS level.

  66.  In addition, we are strongly in favour of a requirement that companies (subject to commercial confidentiality considerations) to publish proposed test plans for a limited period, as happens under the US High Production Volume Program. This enables other companies (and NGOs) to alert the testing company and regulator where the data has already been generated, as well as giving them the opportunity of contending that there may be a better way of generating any required data.



  67.  If Annexes V to IX are not amended to bring new non-animal tests into use, then many millions of animals will suffer and die in testing the backlog of chemicals. Definitive data will be delayed because of the cost of animal tests and the inherent scientific weakness of animal tests.

Data sharing

  68.  Without amendments being made to Articles 23 to 27, loopholes will be built into the REACH data-sharing provisions and duplicate animal testing will continue. This has practical as well as ethical implications, in that testing costs will increase.

The BUAV's view on the role played by the UK Government

  69.  We welcome the UK Government's interest in promoting data sharing and avoidance of duplicate animal testing, in particular through statements published in response to the Commission's May 2003 consultation and in the more recent policy paper on "one registration per substance." We would urge the Government to maintain a strong position on data sharing and avoidance of duplicate animal testing, and to resist calls from industry for a level of "flexibility". On the issue of duplicate animal testing, there must be a simple prohibition backed up by effective data-sharing measures as it is absolutely unacceptable that testing should be carried out simply because companies cannot agree a means by which to share animal test data.

  70.  We would welcome greater support from the UK Government for the funding of development and validation of alternative non-animal tests. Germany has its own state-funded centre for alternative methods, and that centre has played a central role in bringing forward non-animal tests and promoting their use. We believe that the foundation of a UK centre for alternative methods, backed up by significant public resources, is long overdue, and we hope that the UK will see both the scientific and ethical arguments against continued use of animal toxicity tests as good reason for working to introduce alternative non-animal tests.

January 2004

44   Evaluation of the active substances of plant protection products (submitted in accordance with Article 8(2) of Council Directive 91/414/EEC on the placing of plant protection products on the market). Back

45   para 4.6. Back

46   para 9.8 Back

47   See, for example, Council decision concerning the adherence of non-member countries to the council acts related to the mutual acceptance of data in the assessment of chemicals [C(81)30 (Final) and C(89)/87(Final)] adopted on 16 November 1997. Back

48   House of Lords select committee on animals in scientific tests (which reported in July 2002). Back

49   Review of cost-benefit assessment in the use of animals in research (June 2003), pp 50-51. Back

50   Professor of toxicology and environmental health at the University of Surrey, chairman of the EU Scientific Committee of Toxicology, Ecotoxicology and the Environment and chairman of the Working Party on the Harmonisation of Risk Assessment in the EU. Back

51   Ms Judith Hackitt, director business and responsible care, CIA. Back

52   The HPV scheme evaluates the safety of 2,800 industrial chemicals produced or imported into the US in quantities of more than 1 million tons a year. It is broadly equivalent to the European Commission's proposals for chemicals. Back

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