OPP Progress on Reducing Animal Testing & Adopting Alternative Methods - Update for PPDC

May 20-21, 2020 Pesticide Program Dialogue Committee Meeting

On September 10, 2019, EPA Administrator Andrew Wheeler signed a directive that prioritizes
efforts to reduce animal testing (https://www.epa.gov/sites/production/files/2019-
09/documents/image2019-09-09-231249.pdf). The memorandum calls for the agency to: reduce
its requests for, and funding of, mammal studies by 30 percent by 2025, and eliminate all
mammal study requests and funding by 2035. Any mammal studies requested or funded by EPA
after 2035 will require administrator approval on a case-by-case basis. The directive also calls
for the formation of a working group of agency experts in this field who will develop a work
plan. The work plan is expected to be released in the coming months. EPA's Office of Chemical
Safety and Pollution Prevention (OCSPP) and Office of Research and Development (ORD)
hosted the First Annual Conference on the State of the Science on Development and Use of New
Approach Methods (NAMs) for Chemical Safety Testing in December of 2019
(https://www.epa.gov/chemical-research/first-annual-conference-state-science-development-and-
use-new-approach-methods-O). OPP is participating in the development of the work plan and
helped lead the planning and execution of the conference.

OPP continues to make progress towards reducing laboratory animal use. OPP scientists have
recently published a paper in the open scientific literature that describes the risk-based, weight of
evidence approach used by the Hazard and Science Policy Council for providing waivers for
mammalian studies (https://doi.Org/10.1016/i.vrtph.2019.104481). In February of 2020, OPP
released its Final Guidance for Waiving Sub-Acute Avian Dietary Tests for Pesticide
Registration and Supporting Retrospective Analysis that provides waivers for sub-acute bird
studies. The adoption of this guidance is expected to reduce the number of birds tested by
approximately 720 birds per year. EPA's guidance is based on a retrospective analysis conducted
by EPA and the People for the Ethical Treatment of Animals of avian acute oral and subacute
dietary studies. These studies found that EPA can confidently assess acute risk for birds using
only the acute oral test for most pesticides (https://www.epa.gov/sites/production/files/2020-
02/documents/final-waiver-guidance-avian-sub-acute-dietary.pdf).

OPP continues to work closely with numerous stakeholders on a variety projects such as
retrospective analyses on fish acute studies and dermal absorption data and will continue to
update the PPDC as progress is made. OPP is soliciting comments from external peer reviewers
at two upcoming meetings. In late June, OPP, in collaboration with government, non-
government and industry stakeholders, will be presenting the status of several on-going projects
related to new approach methods and reducing the use of laboratory animals for chronic and
carcinogenicity testing to the Science Advisory Board (SAB). Materials for the June SAB are
expected to be posted on the SAB's website in late May. In September 2020, OPP plans to
convene a meeting of the Federal Insecticide, Fungicide and Rodenticide Act Scientific Advisory
Panel (SAP) on activities related to alternative methods that could inform human health risk
assessment for organophosphate pesticides and reduce animal testing for developmental
neurotoxicity in the future (https://www.epa.gov/pesticides/epa-hold-scientific-advisory-panel-
organophosphates-september).


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