Letters on Canada’s Strategy to Phase Out Animal Testing Submitted by ADAV Members & Supporters

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As Canada moves to end toxicity testing on animals, ADAV members and supporters were inspired by a call from Animal Justice and by following the Canada Gazette to submit letters including those below to the Government of Canada to ensure the change is truly implemented. The first letter was ADAV’s official submission.

On Strategy to Phase Out Animal Testing

In 2009, Health Canada signed on to the International Cooperation on
Alternative Test Methods, yet to date no federal funding has been nor is
projected to be applied toward fulfilling this commitment.

Alternative testing methods that preclude the use of animals are quickly
becoming the touchstone of 21st century biomedical research and toxicity
testing. Non-animal testing methods offer more reliability and cost efficiency, and funding is needed if Canada is going to become a leader in the development, validation and implementation of these alternative methods.

If, for example, through the use of human cell cultures we can test in one
afternoon a compound at 20 different exposure levels – which would take 30
years using traditional animal testing methods – why would we not focus our
collective energies there?

Please ensure funding for the Canadian Centre for Alternatives to Animal
Methods at the University of Windsor, and even found new such centres of
excellence throughout Canada.

The Animal Defence and Anti-Vivisection Society


Re Strategy to replace, reduce or refine vertebrate animal testing

Dear Environment and Health Canada,

Thank you for this new legislation.  Animal testing is outdated, cruel, and inaccurate.  Animals do not respond the same way as humans, and various species of animals do not respond the same way from each other.  Non animal methods are far more accurate, as they look at the cell cultures and computer simulations of the target species.  Refining is not enough, as there is no way to adequately reduce suffering in toxicology tests.  

Please stop toxicology testing on animals.  These tests involve force feeding animals chemicals, putting chemicals in their eyes and on their skin, and making animals inhale chemicals.  Animals are given high doses of these chemicals until half of them die. Animals do not respond to chemicals the same way humans do, so the research is inaccurate.

Acute Lethality Testing is a type of LD50 testing that is done frequently by mines, municipal sanitation sewers, pulp and paper mills, and oil sands.  These horrible tests, along with other laboratory testing done on fish, are mandated under many laws not covered by Bill S-5.  More testing, not less, is being brought in to “modernize” pulp and paper mills.  


These tests should also be stopped.  Please enforce and bring in new laws to prevent pollution.  But please do not use animal testing to detect pollution, like Acute Lethality Testing, other laboratory animal tests, or lethal sampling of wildlife and fish.  Please only use Non Animal Methods.  Please amend all legislation to stop testing on fish.

Please stop Acute Lethality Testing and other animal testing of effluent and other pollutants.  https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fish

Please stop testing pesticides on animals.  These tests are as bad as the now banned cosmetics tests.  https://www.change.org/p/stop-testing-pesticides-on-animals

Please also stop genetically modifying animals, and lethal sampling of animals.  


NAMs should mean Non Animal Methods, not New Approach Methods.  Switching to zebrafish, or using less rodents for a shorter time, is not much better.  Those animals still suffer.  https://www.canada.ca/en/health-canada/services/chemical-substances/fact-sheets/use-new-approach-methods-risk-assessment.html

Please mandate that all animal testing, species, number of animals, where they got the animals, type of test, reason for test, institution, and what they are doing to replace aninal testing, be made very clear on one single easy to read public website.

Bill S-5 does not give a clear deadline as to when animal testing will be ended.  A clear deadline of January 1, 2035 must be put into law.  

Canada should phase out vertebrate animal testing no later than 2035.  But switching to invertebrate testing is not the answer.  Many invertebrates, like octopus and squid, are really smart. And all invertebrates, including insects, feel pain.  Please go further by stopping ALL animal testing.  https://www.canada.ca/en/health-canada/programs/consultation-strategy-replace-reduce-refine-vertebrate-animal-testing.html

There is a Non Animal Method alternative for every single animal method.  We just need to put the money, time, and effort into discovering them!  Please support a Canada Made Solution!  https://www.uwindsor.ca/ccaam/


Nicole Corrado


Note: Nicole Corrado has recently become ADAV’s Research Director


Phasing Out Animal Testing in Canada with Bill S-5: Comment on Strategy

Thank you for passing Bill S-5 which will phase out painful toxicity tests on animals.

As you know, many toxicity tests fall into “Category E” – the most severe category of harm that animals can experience according to the Canadian Council on Animal Care (CCAC). These tests can involve forced ingestion followed by vomiting, forced inhalation causing throat and lung irritation and burning to animals restrained in inhalation chambers, and skin or eye irritation causing painful and itchy sores and rashes. 

Once an experiment is done, the animals involved are generally killed. In 2022 alone, more than 105,000+ animals were used in Category E toxicity tests. Animals commonly used include rabbits, guinea pigs, mice, and birds.

I hope that in moving away from toxicity testing on animals more funding will go toward non-animal methods (NAMS). These are often more predictive of human health and environmental outcomes than traditional animal testing. Methods include cell and tissue tests, computer models and other sophisticated methods which are becoming increasingly available. Non-animal methods are often more reliable than tests using animals in terms of predicting human and environmental health outcomes as well as being more time and cost-effective. This will further support CEPA’s environmental and health protection objectives.

Canada needs to make a funding commitment to support the new legislation that includes dedicated funding for continuing to develop and validate non-animal methods. This includes specifically establishing a formal Canadian centre for validation through the Canadian Centre for Alternatives to Animal Methods at the University of Windsor. The centre hasn’t been given public funding, unlike similar centres around the world, putting its long-term sustainability in serious jeopardy.

Thank you for your work on this issue.



To Whom it may concern,

Bill S-5 is very important to me personally. The phasing out of toxicity testing on animals needs to be an absolute priority! I thank you for taking steps!

I ask that enough funding is directed to non animal toxicity testing to make the change quickly. I understand that Canada is gathering and sharing information with other countries which is excellent.

An important factor to me is that progress will be shared with the public. That concerned Canadians will be able to access this information. Information about the types of testing and the NAM’s replacing the outdated animal method.

I am looking forward to seeing the numbers of animals used steadily and quickly decline until no longer used.

Any comments on my letter will be greatly appreciated.

Thank you.


Lori Fitzgerald


Bill S-5 Funding


The Minister of Health

The Minister of the Environment and Climate Change

Now that Bill S – 5 has passed it makes sense to have funding directed to a lab already using  modern science for testing/research.

The Canadian Centre for Alternatives to Animal Methods at the University of Windsor.

The funding should be sufficient for the work to progress quickly. The horrendous suffering of animals in toxicity testing should end as soon as possible.

Thank you for your attention to this vitally important issue.

Curtis Clyne

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