An Evaluation of the US High Production Volume (HPV) Chemical-testing Programme: A Study in (Ir)Relevance, Redundancy and Retro Thinking
Andrew Nicholson, Jessica Sandler and Troy Seidle
Under the US Environmental Protection Agency (EPA) High Production Volume (HPV) Challenge Programme, chemical companies have volunteered to conduct screening-level toxicity tests on approximately 2800 widely-used industrial chemicals. Participating companies are committed to providing available toxicity information to the EPA and presenting testing proposals for review by the EPA and posting on the EPA Web site as public information. People for the Ethical Treatment of Animals (PETA) and a coalition of animal protection organisations have reviewed all the test plans submitted by the participating chemical companies for compliance with the original HPV framework, as well as with animal welfare guidelines issued by the EPA in October 1999. Our review found major and recurring flaws in the programme’s execution, as well as in its fundamental design. Approximately 75% of the test plans reviewed violated fundamental terms of the programme. Many participating companies failed to conduct comprehensive analyses of available data and instead proposed superfluous and meaningless tests. The US HPV programme’s exclusion of human health and exposure data has led to numerous examples of irrelevant experiments that will not affect how a chemical substance is used or handled. Contrary to claims by both the EPA and Environmental Defense that few new animal tests are being performed, an estimated 100,000 animals have already died in this US Government-sponsored animal-testing programme.