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ECEAE estimates a shocking one million animals could be used for first REACH deadline

The European Coalition to End Animal Experiments (ECEAE) has estimated that approximately one million animals could be killed for chemical tests in order to fulfill the testing proposals under the first REACH registration deadline of 1st December (for chemicals produced in quantities of more than 1,000 tonnes) .

According to REACH, animal tests for these substances have to be proposed and not conducted since they are part of the public consultation ‘testing proposal’ system.

The European Chemicals Agency (ECHA) announced on 1st December that 4,300 substances had been registered. These substances include chemicals used in industrial lubricants, coatings, fuels, paints and household products.

According to the ECEAE estimates, 25% of these registrations contain a proposal to animal test. Based on experience of the system to date, the ECEAE, therefore, estimates that this will result in over 1,000 proposals being published as ECHA evaluates the dossiers. Should all these proposals be agreed a total of nearly one million animals could be poisoned and killed (1). These tests include reproductive toxicity on rats and rabbits and long term safety studies on rats and fish. Each test can use between 50 and 2,000 animals.

This estimate does not include the testing on animals that might occur for other chemicals under other deadlines or the animal testing that can be done without a testing proposal.

Given that the number of chemicals registered under the first deadline is 60% more than the estimate given by the Commission in 2003 when REACH was being discussed, the ECEAE now estimates that the total number of animals who could be used overall under REACH is now likely to be at least 13 million (possible range of 13-54 million) (2). This is an appalling prospect.

The ECEAE is committed to try to save as many animals as possible from this appalling fate by helping companies avoid animal testing through commenting on the testing proposals as they are registered.

1. According to ECHA, 24,675 registration dossiers for 4,300 substances, including nearly 3,400 existing substances (phase-in), have been successfully submitted by the deadline of 30 November.
Based on ECEAE experience of the evaluation activities of ECHA as of Sept 2010, 25% of dossiers contain a Testing Proposal. Thus 1,075 Testing Proposals (25% of 4,300) could come out from the deadline of 30 November.
Based on ECEAE calculations of the average number of animals used per testing proposal (based on the first 25 testing proposals an average of 890 animals used- the number of animals varies per endpoint but an average can be calculated since we cannot predict the exact tests proposed yet).
Thus the testing proposals presented under this first REACH registration deadline could lead to the deaths of a total of 956,750 animals (890 animals used in each testing proposal multiplied by 1,075 expected numbers of testing proposals).

2. This range is based on the ‘best case scenario’ estimate for animal use published by ECVAM in 2006 of 8 million animals (Briefing Note On Number Of Animals Expected To Be Used Under Reach: Summary Of Re-Assessment Performed By The JRC, Oct 2006) which was based on the 30,000 total number of chemicals estimated by the Commission in 2003 (Pedersen et al., EUR 20863/2003). This lowest figure was multiplied by 1.6 to bring it in line with current numbers of chemicals. The highest figure is the highest current estimate of 54 million animals which has been well justified but may over estimate the final number of chemicals (Rovida, C and Hartung, T. Re-Evaluation of Animal Numbers and Costs for In Vivo Tests to Accomplish REACH Legislation Requirements for Chemicals – a Report by the Transatlantic Think Tank for Toxicology (t4). Altex 26, 3/09, 1-22, 2009).


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