66 TESTING
Driving positive change in ecotoxicity testing
Kirsty-Jo Muddiman, Dr Carol Treasure – XCellR8, UK
The obligations of EU REACH regulations have brought the animal testing debate back into the cosmetics industry to the frustration of both industry and the consumer. We thought we had this nailed; consumers do not want cosmetics or their ingredients to be tested on animals and the EU had decided to support this through legislation. We thought that ingredients used in cosmetic products would be exempt from the animal testing obligations of REACH but it turns out that we were wrong on two counts: Worker Exposure Assessment and Environmental Assessment.1
While industry seeks to take action
and make progress in developing alternatives to animal testing for the worker exposure assessment, can we make any progress in reducing the number of animals used for the environmental assessment and are the ethical considerations even the same for environmental testing?
The cosmetic perspective Cosmetic ingredient suppliers understood the need to develop alternatives to animal tests and progress has been made on tests designed for human safety assessment; reducing, refining and replacing the use of animals in scientific procedures. However, the demand for animal- free products cannot be defined by the 3 Rs alone since the very definition of the 3 Rs relies upon the legislative definition of what an animal in a scientific procedure is.2
It does
not cover the use of animal products in testing and its definition of an animal is restricted to vertebrates and the “higher sentient” organisms, cephalopods.3
vegan products is increasing,4
At a time when the demand for we cannot rely on
EU legislation to define the needs of the market globally. Historical definitions of animals in scientific
procedures were based on the assumed sentience of commonly used animals and whether their use was considered a scientific procedure. A lack of clarity existed, owing to the exclusion of animal products and consideration of how they were harvested. A new definition for the use of animals in testing was needed; one which addressed the demands of the market in a wider field of vision, considering the sliding scale of animal products used in testing completely; whether they were legally considered as an animal in a scientific procedure or not. The XCellR8 scale for animal- free testing brings transparency to an industry in need of clarity based on market demands rather
PERSONAL CARE January 2021 Figure 1: The XCellR8 Scale for animal free testing.
than legislative legacy (Fig 1). With this scale, we can begin to benchmark
progress and understand that progress should not be halted simply because we move from in vivo to in vitro; the goal for current market demand in attaining a truly animal-free test for human safety endpoints for cosmetics and their ingredients has not yet been fully achieved.
Environmental testing How we address the needs for safety testing for environmental assessment without the use of animals is more challenging. The industries which have walked this path before us may have been satisfied that invertebrates were not “animals” in the eyes of the law but in the cosmetics industry, where truly animal-free products are in high demand, we look further than legislation to qualify our claims. Invertebrate testing, such as testing on
earthworms, holds a different dilemma for cosmetics companies than perhaps the agrochemical or biocide industry have traditionally considered and of course the vertebrate fish study brings a moral dilemma of a higher degree. Using the XCellR8 scale of animal-free testing (Fig 1), invertebrate studies would be classed as in vivo but it is also true that the scientific justification for environmental protection is not quite the same as we are used
to considering in the general argument for the abolition of animal testing for cosmetics and their ingredients. When industry assessed eye irritation on live
rabbits, this was done to predict what effects we could expect in the human eye. Tests on daphnia predict what will happen to daphnia and similar organisms in the environment. Where the objectors have called for in vitro testing instead of the use of rabbits for human safety testing, this same argument holds no water when we consider environmental testing. Environmental safety is of paramount
interest to the cosmetics industry, driven by the growing market for products which are safe to use environmentally.5
There is a
need to demonstrate environmental safety of ingredients and products, often to the same customers demanding animal-free products. Therein lies the dilemma, how can we demonstrate environmental safety without using animals or their products?
Current environmental testing strategy The first tier of environmental testing, for REACH and other regulations, is the acute base set of algae, daphnia and fish. Taking algae as a plant and daphnia as invertebrates, only the fish test remains a legal “animal in scientific
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