Imagine yourself sending a message to a loved one using a carrier pigeon instead of WhatsApp, messenger or email. Sounds ridiculous, right? Technology has brought us so far that it seems laughably backward to use anything but the latest cutting-edge technology. This is true in most sectors of life, including product safety testing. So why are most of the tools our government uses for safety assessment more than 60 years old? That's right: despite enormous scientific progress in the development and validation of alternatives to 1940s-era animal tests for product safety, many of our regulators and scientists are choosing to turn a blind eye to the plain inefficiency and obsolescence of animal tests. This is especially true for regulatory testing for pesticides like bug sprays and weed killers.
Countless animals continue to choke -- needlessly -- on pesticide chemicals in horrific laboratory poisoning tests that could be replaced with the stroke of a pen.
At this very moment, animals in laboratories throughout India are being forced to swallow, inhale or absorb toxic pesticide chemicals via the skin, sometimes in a single massive dose, or through repeated daily doses over weeks, or even years. This, in spite of modern non-animal or reduced-animal testing approaches being available, validated and adopted as international guidelines by intergovernmental bodies like the Organization for Economic Cooperation and Development (OECD), and for regulatory use by pesticide authorities in the European Union and elsewhere. Twelve such alternative approaches, if adopted by Indian pesticide authorities, could slash the animal testing burden for new pesticides by nearly half. Therefore, Humane Society International/India has set its sights on replacement of these "dirty dozen" animal tests.
What makes Indian pesticide authorities so averse to updating their safety testing requirements? A look back in history might be helpful. The Dr Gaitonde Committee report first established Indian pesticide data/testing requirements in 1977. The Central Insecticides Board & Registration Committee (CIB-RC) authorized to regulate the manufacture and testing of pesticides under the Insecticides Act of 1968, took more than 35 years to produce an updated document with amended protocols and data requirements which is now known as the "Indian Guidance Document of Toxicology for Registration of Pesticides". This update mainly incorporated newer OECD test guidelines -- again, mostly animal tests -- along with recommendations from the stakeholders, including HSI/India. While a limited number of our inputs were taken up, the revised national guidelines still left much to be desired, as advanced animal testing alternatives were not included.
HSI/India has been meeting regularly with the CIB-RC and pesticide industry for nearly two years, providing detailed proposals for the amendment of regulatory data requirements supported by hard science and regulatory precedent in other countries. We have supplied reams of publications, briefings and in-depth presentations regarding alternative approaches that not only have the potential to reduce costs and animal use, but also have scientific advantages in terms of human relevance that would improve protection of consumers, pesticide factory workers and field applicators.
Our recommendations have met with mixed reaction from industry and CIB-RC. For example, some companies have been resistant to the adoption of alternative approaches in India that are already accepted in the EU (e.g., waiving of the mouse cancer test). CIB-RC has been even more intransigent, refusing to accept anything other than OECD guideline tests and narrowly selected regulatory precedent from other parts of the world (e.g., European "plant protection products" but not "biocides" regulation). We are confronted with what appears to be a pre-determined conclusion to change as little as humanly possible, at the expense of scientific progress, improved human safety, regulatory alignment for international trade and animal welfare.
Indian regulators have chosen to bury their heads in the sand... at the expense of scientific progress, improved human safety, regulatory alignment for international trade and animal welfare.
It is extremely disappointing that while other nations are investing heavily in 21st century testing tools such as "human-on-a-chip" and robot-automated "high-throughput" cell culture platforms for more relevant, efficient and rapid safety risk assessment, Indian regulators have chosen to bury their heads in the sand rather than move ahead with times. This mind-set also comes in sharp contrast to Prime Minister's progressive vision of "Make in India" and "Digital India".
While the Ministry of Health & Family Welfare -- with its landmark decisions to end repeat animal testing for drugs, prohibit animal testing for cosmetics, and phase out the archaic Draize eye and skin test for drugs -- is creating a roadmap for multinational companies, industries and government to invest in advanced scientific technologies in India, pesticide authorities in the CIB-RC are falling farther behind with each passing month. And while the CIB-RC chokes on its own inertia, countless numbers of animals continue to choke -- needlessly -- on pesticide chemicals in horrific laboratory poisoning tests that could be replaced with the stroke of a pen.
Please join us in convincing the CIB-RC to update its data requirements for pesticides by visiting hsi.org/dirtydozen and signing the petition today!