No Poisoning of 5,000 Animals for your Chemicals!

george.cornelius@arkemagroup.com, raj_l_gupta@rohmhaas.com, tshepherd@shepchem.com, diane.milici@arkema.com

George Cornelius, President and CEO
Arkema Inc.
Philadelphia, PA 19103-3222

Diane Milici, Assistant to the President
Arkema Inc.

Rajiv L. Gupta, Chair, President, and CEO
Rohm & Haas Company
Corporate Headquarters
Philadelphia, PA 19106-2399

Thomas L. Shepherd, CEO
The Shepherd Chemical Company
Norwood, OH 45212


Dear Madams or Sirs,

A few months ago, the People for the Ethical Treatment of Animals (PETA) wrote to you re: sweeping changes to the testing strategy for a group of chemicals called metal carboxylates in the U.S. Environmental Protection Agency's (EPA) High Production Volume (HPV) chemical-testing program. To date, you have failed to respond in any fashion.

The original test plan was bad enough, as it would have used approximately 1,000 animals, but the 12 new test plans are far worse. The tests proposed in these new plans will result in the deaths of as many as 5,000 animals. Because these entirely new test plans have been submitted as "revisions" to the original plan — by passing the agreed-upon public comment period — PETA and other animal rights organizations have not had any opportunity to formally comment on these new testing proposals or work with you to minimize animal testing.

The tests that your coalition is proposing include the following:

• LD50 Tests
In these infamous tests, animals are force-fed increasing doses of a chemical until they die. Such acute toxicity tests inflict hideous suffering on animals, who endure severe abdominal pain; diarrhea; bleeding from the nose, mouth, and genitals; convulsions; seizures; and paralysis before they ultimately die. Astonishingly, the chemical companies are proposing four of these cruel tests, even though they also argue that the tests are unnecessary because of existing data!

• In Vivo (Live-Animal) Genotoxicity Tests
Genetic toxicity tests are highly stressful and cruel. Mice are subjected to frequent handling and restraint; force-feeding, intubation, or injections into their abdomen; and the toxic effects of the chemicals that are being tested. In vitro (non-animal) methods to study genetic toxicity have been accepted by government regulators worldwide as valid alternatives to animal tests. Non-animal genetic toxicity testing methods have already been incorporated into the HPV program—after a huge effort on PETA's part. However, four in vivo genetic toxicity tests are proposed in the new test plans.

• Fish Acute Toxicity Tests
These tests are similar to the LD50 test described above, except that chemicals are pumped into the water of tanks holding fish until the animals die. The fish may endure severe pain, as evidenced by visible physical and behavioral abnormalities, before they are ultimately poisoned to death. Two of the proposed fish acute toxicity tests are for chemicals that the EPA's own program guidelines define as being insoluble in water!

You as CEOs of chemical companies should know that me and so many other caring people do not want you to poison and torture any more animals under the new metal carboxylate test plans, especially since you have not given the public a fair opportunity to comment on them and suggest humane alternatives!

Sincerely,