Replacing Animal Testing in Canada: A Letter
Image by Michael Mosimann from Pixabay
We are pleased so share the essay below, written to Environment Canada, on the topic of replacing animal testing in favour of sophisticated and viable options. It is by ADAV’s Research Director, Nicole Corrado, partly in response to a notice contained in the Canada Gazette available for viewing by clicking here, but also in response to other ongoing practices in Canada.
Dear Environment Canada,
Regarding these dyes, they were tested on animals.
The only way to modernize CEPA is to eliminate all animal testing in 10 years or less, with clear outlines and deadlines for each test replacement. Environmental monitoring and testing of pollution must involve non animal methods.
There are also no safe uses of pesticides, especially no safe use of rodenticide and other vertebrate poison. A proposed watch list approach may unfortunately increase animal testing and be misused by pest control companies, and other polluting industries to claim (probably through animal testing) that their products are “safe”. Instead, we need to move towards only using traditional natural plant based products we know are safe.
Replacing all animal testing (not just vertebrate testing) by 2035 must be the top priority for Environment Canada. The best way to determine carcinogenic, mutagenic, reproductive, and endocrinological toxicity in humans is biomonitoring and testing on human cells. Bioaccumulation studies can be done with plant cells and that information from additional in vitro testing on animals cells (not live animals) can be added up in a computer simulation, along with in the field harmless bio monitoring studies with humans and non human animals. MIREC (Maternal Infant Research Environmental Chemicals) with human families is one example of a field study that doesn’t harm.
https://www.change.org/p/stop-testing-pollution-and-effluent-on-fish-and-other-animals
Unfortunately, studies like the Great Lakes Fish Monitoring Program involve killing animals for research. These studies could be replaced with water monitoring and bio monitoring fishes.
Sadly, despite Canada requesting that animal research ends in ten years, the Proposed Plan of Priorities may increase animal testing. And animal research grants are being put out for next year. https://science.gc.ca/site/science/en/northern-contaminants-program/call-proposals-2025
While bioethics are clearly mandated for human biomonitoring for contaminants, there is no suggestion for humaneness regarding monitoring contaminants in animals, which involves dissecting the animal to obtain lethal tissue samples. While many of these animals are killed for food and clothing anyway, some animals are killed solely for samples. Ten fishes are killed in sampling from each target species (trout, char, and burbot are the most common victims). It suggests working with the hunting and trapping organizations, but no where does it mention having any animal welfare oversight. Polar bear samples come from trophy hunters. It does mention that non destructive methods be developed, but only for at risk species. There is a need to eliminate the killing of animals for scientific reasons or for sport. Sampling should only be either from animals people are eating (with a goal of reducing animal consumption in favour of more plant consumption), or live biomonitoring methods adapted from human medicine.
Please stop the “acute lethality tests” on rainbow trout, three lined stickleback, and other fish species. These tests involve pumping effluents into fish tanks once a month, and if more than half the fish die, the experiments are repeated twice a month. Sub lethal effect tests are also conducted. Wild fish are killed and their livers analyzed. Canada does not allow Non Animal Alternatives for testing effluent at mines or sewage treatment plants. https://laws-lois.justice.gc.ca/eng/regulations/SOR-2002-222/FullText.html
There are animal free ways to test for pollution. The Physicians Committee for Responsible Medicine suggests using rainbow trout cell lines instead (obtained without harming fish).
https://www.pcrm.org/news/good-science-digest/world-aquatic-animal-day
Any guardians of companion fish will test their tank using paper strips and test tubes. They do not deliberately expose the fish to effluents to see what happens. Bacteria and pollutants in swimming pools are also tested without animals.
Please also end the practice of sublethal toxicity testing of effluent on baby fathead minnows, rainbow trout, and other animals. These animals are killed, dried, weighed, and preserved.
Aquatic Life Referencing Values are created by testing pesticides on laboratory fish. These lethal dose tests/acute lethality tests and chronic toxicity tests are cruel and should be replaced with Non Animal Methods. No new ALRV fish tests should be conducted, and only existing data and new Non Animal Method data be used. https://www.canada.ca/en/health-canada/services/consumer-product-safety/pesticides-pest-management/public/protecting-your-health-environment/programs-initiatives/water-monitoring-pesticides/aquatic-life-reference-values.html
Fish diseases are studied by the Department of Fisheries and Oceans by infecting live fish in a laboratory to see what happens. This is incredibly cruel. https://www.dfo-mpo.gc.ca/science/aah-saa/naahls-slnsas-eng.html
Please stop putting up tree swallow nest boxes in order to kill and dissect the babies to test for toxins in and near the mines, tailing sites, and oil sands. And please stop catching, killing, and dissecting fish and frogs for the same reasons. Please switch to the humane non lethal bio monitoring methods used in humans.
Cruelty free alternatives to toxicity testing involve using plants, phytobacteria, or cell cultures.
And stop working with scientists, trappers, hunters, and anglers to catch, kill, and cut up fish, frogs, mammals, birds, etc to weigh and test their organs for selenium, mercury, other pollutants, and reproductive issues. There are humane non lethal tests to examine if any wild animal is healthy and have not been exposed to toxins. Please also stop the mandate to kill some of the live fish being brought into Canada for disease lethal sampling. https://inspection.canada.ca/animal-health/aquatic-animals/imports/test-selection-and-sampling-requirements/eng/1548710570282/1548710570578
A city that wants to go cruelty free can not if they are mandated to test their sewer water on animals. Sugar refineries must test their wastewater on fish, even if they are a vegan company that only uses non animal methods of sugar refining. Those food producers don’t want to test on animals. Water used to cool nuclear power plants is also tested in fish for any radioactive effects. Pulp and paper mills that want to use only recycled paper and be ethical are forced to test on and kill animals. Mining companies and factories that want to be more ethical are also still forced to conduct harmful animal effluent testing. Environmentalists at Orphaned and Abandoned Mines don’t want to do these tests while restoring the land. Canada is legally mandated to phase out animal toxicity testing, yet many agencies are legally mandated to conduct these cruel tests. Please put an end to all animal toxicity testing and go cruelty free.
Nicole Corrado
