Cutting-edge science can protect humans, the environment – and animals
We are faced with a once-in-a-generation opportunity to reimagine the way we manage chemicals as a society. By creating a system that fully realises the benefits of non-animal testing, the government can protect us, our environment and animals in laboratories
A letter from the Chair of the Environmental Audit Select Committee, in November 2022, called on new Environment Secretary Thérèse Coffey to get a move on with key Defra policy areas “where progress appears to have stalled”. Among them was the department’s long-anticipated Chemicals Strategy – first announced in 2018 but still yet to be published – which is expected to set out the UK’s vision for managing chemicals for the next 20 years.
This vision is desperately needed to accelerate action on the most hazardous chemicals and strengthen controls on the most harmful chemicals to protect our health and our environment.
Following Brexit, a UK chemicals regulatory regime – centred around the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation – came into force in England, Scotland and Wales. UK REACH, as it stands, effectively replicates EU REACH with a few tweaks.
But what works for 27 EU countries doesn’t necessarily make sense for one, especially if the one aspires to do better. Defra recognises the need to revise UK REACH and associated legislation to make them fit-for-purpose for the UK, but, as with the Chemicals Strategy, Defra remain stuck in the evidence-gathering phase and is yet to produce any concrete proposals.
While inheriting the REACH framework gave us a solid foundation to build on, there is plenty of room for improvement. The European Environmental Bureau’s 2019 report “Chemical Evaluation: Achievements, challenges and recommendations after a decade of REACH” describes how that system’s slow regulatory processes have led to potentially toxic chemicals staying on the market.
For example, the report explains how dossiers for 70% of registered substances were found to lack legally required information, and that, for some 64% of individually evaluated substances, conclusions were delayed by an average of 7-9 years while industry provides further data, including by conducting new animal tests.
Increasing the reliability and efficiency of chemicals regulation under REACH requires a rethink of the way that the data upon which regulatory decisions are made is generated. REACH currently relies heavily on animal tests in an effort to detect and characterise chemicals’ hazardous properties – each year, tens of thousands of tests are conducted in British laboratories alone to satisfy the requirements of international industrial chemicals legislation.
But animal tests are slow, with many methods used today being decades old and never subjected to modern standards of evaluation, meaning that their scientific basis, reliability and relevance to the populations they aim to protect have never been established. Unsurprisingly, animal test data provide a shaky foundation for regulatory decision-making – for example, a discrepancy in the time it takes for humans to eliminate per- and polyfluorinated alkyl substances (PFAS) from the body, as compared to other species, has been implicated in authorities setting unsafe exposure limits.
Capable of being faster and cheaper, non-animal methods can also enable many more chemicals and mixtures to be tested than would be possible with animal tests
A new year brings with it new opportunities for positive change. Modern non-animal methods are recognised as being reliable and relevant, and the ability of non-animal approaches to outperform animal tests is increasingly clear.
Non-animal approaches for evaluating the potential for skin sensitisation, for example, predict human outcomes with up to 84% accuracy, whereas the most widely used animal test is just 58% accurate. Capable of being faster and cheaper, non-animal methods can also enable many more chemicals and mixtures to be tested than would be possible with animal tests.
Scientists and regulators are racing to develop and implement a non-animal approach for identifying developmental neurotoxicants – chemicals that harm the developing nervous system of the foetus or child – recognising that testing thousands of chemicals on animals would cost too much time and money to give rapid and effective protection.
Under the Chemicals Strategy and its plans to revise UK REACH, Defra has a once-in-a-generation chance to build a chemicals regulatory system that provides comprehensive protection for humans and the environment. We envisage that such a system would use non-animal methods to generate new information about chemicals – and, crucially, would be able to rely on this information to classify chemicals as hazardous and take them off the market.
There is also scope to improve the way existing information – including data from academic studies and that generated to meet the requirements of other regulations – is used to underpin regulatory decisions. To avoid the EU situation of toxic chemicals staying on the market for years following their identification, we also need better use of the precautionary principle – that is, making protective regulatory decisions without unnecessary delay instead of attempting to resolve all uncertainties first, including via new animal tests.
Defra’s task is not a straightforward one. Aside from dealing with the weighty question of how we are to regulate chemicals for the next two decades, it is simultaneously trying to come up with an acceptable way of handling chemicals already registered under EU REACH. Demands presented by the Retained EU Law Bill look set to stretch already limited resources even thinner.
But this opportunity for society to reimagine the way we manage chemicals is too great to pass up. Let’s establish ourselves as world-leaders in science, technology and animal welfare by building a system based on modern, reliable and relevant approaches to safety testing that truly protect humans and the environment, while sparing animals from cruel chemicals tests.
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