Imagine being restrained by your neck in stocks while a person in a white lab coat drips something into one of your eyes, or on to the skin of your back. It burns. You cry out, struggling to break free, but there's no escape, no relief. Once a day, someone comes to your cage to assess the degree of damage to your eye or skin. They offer no comfort or pain relief; they simply write some notes and move on to the next cage. After two weeks you'll be killed and your body examined for toxic signs.
Photo Credit: One Voice
While this procedure is not done on humans, it is commonly done to animals. This procedure is called the Draize test, named after the US Food and Drug Administration scientist who invented it in the 1940s. It's now 2015, and this test is still in widespread use in India -- even a legal requirement in some product sectors. What's worse is that this horrible suffering is completely unnecessary because superior non-animal test methods exist.
Humane Society International is at the forefront of efforts to modernize testing regulations worldwide to see that available animal testing alternatives are used to their fullest potential. Our #BeCrueltyFree campaign, the world's largest campaign to end cosmetics animal testing and trade, was a huge success in India with the Ministry of Health and Family Welfare enacting regulations to end both domestic animal testing for cosmetics as well as the import of cosmetics or ingredients tested on animals anywhere in the world after 14 November 2014.
But that's just the beginning. Obsolete animal tests like the Draize are still a legal requirement in some product sectors in India, such as pesticides. From weed killers and rat poison to insect repellant and cleansers that claim to "kill germs", pesticides are among the most heavily animal-tested products in existence. Indian regulations sometimes require dozens of different animal-poisoning tests to assess the safety of a single new pesticide to market.
Some tests use thousands of animals at a time, while others are repeated two or even three times using different animal species and/or routes of chemical administration (e.g., oral force-feeding, forced inhalation and skin application). This means terrible suffering and death for upwards of 10,000 rabbits, rodents, birds, fish, and even dogs, for every new pesticide chemical. The animals may experience nausea, convulsions and death, all without pain relief.
Photo Credit: HSI
Subjecting animals to such obvious cruelty is inexcusable when proven testing alternatives are readily available -- and there are numerous internationally recognized non-animal tests or strategies that could fully replace the use of rabbits for skin and eye irritation and lethal skin dose studies, the use of guinea pigs and mice in skin allergy studies, the use of rats in skin absorption and genetic toxicity, and reduce animal use by 50 percent or more in many other areas.
Yet regulators in India's Central Insecticides Board and Registration Committee (CIBRC) have been slow to change. Many of our country's testing guidelines were four decades old before they were updated earlier this year, and even now, glaring loopholes remain. Numerous animal tests which have available validated alternatives recommended by the Organization for Economic Cooperation and Development (OECD) have been ignored, and animal data that are not required in any other part of the world are still a mandate in India, despite a legal obligation to use available alternatives under the Prevention of Cruelty to Animals Act, 1960. What is more, the U.S. Environmental Protection Agency is now implementing testing technologies that have the potential to make pesticide safety testing much cheaper, much quicker and close to animal free.
"What's worse is that this horrible suffering is completely unnecessary because superior non-animal test methods exist."
India, being the largest producer of pesticides in Asia, has both a legal and a moral obligation to reduce (and eventually end) its use of animals in pesticide testing by bringing its data requirements in line with international best practices. HSl was successful in leading a similar campaign in the European Union (where test requirements were also 15-20 years out of date with the state of the science in alternative test methods), convincing authorities to recognize alternative approaches with the potential to slash animal test requirements by as much as half -- the largest one-time regulatory animal test reduction ever achieved. HSI is currently in similar negotiations with authorities in Brazil, who recently gave their formal acceptance of 17 OECD alternatives to animal testing.
If Brazil can do it, so can India. The good news is that HSI/India has been working closely with India's pesticide authorities and industry, and CIBRC has begun to implement some of our recommended changes. We still have a long way to go, but together we can seize this exciting opportunity to make India a leader in science and safety risk assessment for pesticides for the benefit of society and animals alike.