Image by Katharina N. from Pixabay

On May 28, 2024, ADAV’s Research Director, Nicole Corrado sent a letter to the Government of Canada regarding the continued use of fish and other animals in toxicology testing. Her letter appears below. Beneath that, you will find the response from Canada’s National Program Integration and Coordination Unit (NPIC), Science and Technology Branch of Environment and Climate Change Canada. The response was sent June 11, 2024.

Letter to Government of Canada from Nicole Corrado:

To: Steven.guilbeault@parl.gc.ca; mark.holland@parl.gc.ca; Substances (ECCC) <Substances@ec.gc.ca>
Subject: Canada Gazette, Part I, Volume 158, Number 21: GOVERNMENT NOTICES May 25, 2024 DEPARTMENT OF THE ENVIRONMENT DEPARTMENT OF HEALTH CANADIAN ENVIRONMENTAL PROTECTION ACT, 1999 Publication of final decision after assessment of five substances in the Aldeh…

While biomonitoring studies on humans were done in a cruelty free fashion using urine samples, acute lethality testing/lethal dose testing was done on fish, as well as plenty of other animal experiments to monitor for substances.  Please move away from animal testing and only use cruelty free biomonitoring and non animal methods.  

Federal Environmental Quality Guidelines are based on horrific animal studies in which animals are forced to breathe, be burned by, ingest, and be blinded by chemicals.  They are then killed, or die from the chemicals. Rats were forced to eat and breathe these chemicals until half died; the rest were killed.  Pregnant animals were tested on and the moms and babies were killed.  Plus all sorts of other horrific experiments.  

And under current Canadian policy, the minimum requirement for a type A freshwater guideline include horrific toxicology tests including the LD50 test on 3 fish species (at least one salmonid and one non salmonid), 3 invertbrates including a crusteacean, and one plant.  All sorts of Acute Lethality Testing/LD50 Testing was conducted.  These tests are remarkably cruel and outdated. Other wildlife, like fish, frogs, birds, small mammals, etc, are lethal sampled in the wild, or are tested on and killed in labs.  Even cats, dogs, bunnies, and non human primates are often used in toxicology research. 

Many of these studies were conducted years ago, when this type of research was common. Considering Canada has banned cosmetics testing on animals, and that Canada is phasing out vertebrate toxicity testing by 2035, this testing on animals seems counterproductive.

https://www.canada.ca/en/health-canada/services/cosmetics/animal-testing-ban/guidance-document.html

Please switch to Non Animal Methods for all toxicology research and Federal Environmental Quality Guidelines.  https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fish

Nicole Corrado

Response from Government of Canada:

From: “Substances (ECCC)” <Substances@ec.gc.ca>
Date: June 11, 2024 at 12:08:03 PM EDT
Subject: RE: Canada Gazette, Part I, Volume 158, Number 21: GOVERNMENT NOTICES May 25, 2024 DEPARTMENT OF THE ENVIRONMENT DEPARTMENT OF HEALTH CANADIAN ENVIRONMENTAL PROTECTION ACT, 1999 Publication of final decision after assessment of five substances in the Alde

Dear Nicole Corrado,

Thank you for contacting the Substances Management Information Line.

As indicated in our previous email exchanges, the Government of Canada is committed to advancing efforts to replace, reduce, or refine the use of vertebrate animals in toxicity testing where possible.

Amendments to the Canadian Environmental Protection Act, 1999 (CEPA) under Bill S-5 (Strengthening Environmental Protection for a Healthier Canada Act), which received Royal Assent in June 2023, recognize the need to replace, reduce, or refine the use of vertebrate animal testing when prioritizing and assessing the potential harm that substances may pose to human health and the environment. A strategy is currently being developed by HC and ECCC as part of the Plan of Chemicals Management Priorities to guide a path to replace, reduce, or refine the use of vertebrate animals for toxicity testing and to inform assessments under CEPA.

In June 2023, the Minister of Health announced the ban of cruel and unnecessary testing of cosmetic products on animals in Canada, representing a major step forward in supporting animal welfare by reducing our reliance on animal testing, while ensuring health and safety by making changes to the Food and Drugs Act. Health Canada is also taking action in other areas to reduce the reliance on vertebrate animal testing.

In November 2023, HC and ECCC published a notice of intent on the development of the strategy (https://www.canada.ca/en/health-canada/programs/consultation-strategy-replace-reduce-refine-vertebrate-animal-testing/notice-intent.html), and feedback received on this notice is currently being carefully considered. The draft strategy will be published for public comment prior to the publication of the revised strategy, targeted for June 2025. You are encouraged to participate in the public comment process that will be launched on the draft strategy.

Current efforts are underway at ECCC to modernize and transform toxicity testing to align with recent efforts internationally and federally, to reduce the reliance on vertebrate animals for toxicity testing. For example, ECCC is currently co-leading and providing in-kind support for a Genome Canada-funded project to validate a new approach method for regulatory decision-making (https://genomecanada.ca/project/validation-of-the-use-of-the-ecotoxchip-test-system-for-regulatory-decision-making/).

For further information, please visit: Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act – Summary of Amendments – Canada.ca.

Please note that the Aldehydes Final Assessment mentioned in your most recent email is not associated with a public comment period. This is because it is a final assessment that concluded that the substances are not likely to be causing harm to human health or the environment at current levels of exposure based on criteria set out under section 64 of the Canadian Environmental Protection Act, 1999 (CEPA). Furthermore, the Aldehydes Final Assessment is not a Federal Environmental Quality Guideline publication. However, we still forwarded your comments to the appropriate program areas as general feedback for future consideration.

Kind regards,

National Program Integration and Coordination Unit (NPIC), Science and Technology Branch

Environment and Climate Change Canada / Government of Canada

substances@ec.gc.ca / Tel: (819) 938-3232 or 1 (800) 567-1999 (toll free in Canada)

Fax: (819) 938-5212 or 1 (800) 410-4314 (Toll free in Canada)

Équipe de l’Iintégration et de la coordination des programmes nationaux (ICPN), Direction générale des sciences et de la technologie

Environnement et Changement climatique Canada / Gouvernement du Canada

substances@ec.gc.ca / Tél. : (819) 938-3232 ou 1 (800) 567-1999 (sans frais au Canada)

Téléc. : (819) 938-5212 ou 1 (800) 410-4314 (sans frais au Canada)