Public Comments on
Animal Testing
by Mark Langley
|
From Mark Langley
email : langley.ny @
gmail.com
Dr. William S. Stokes NICEATM Director
National Institute of Environmental Health
Sciences
P.O. Box 12233
MD EC—17
Research Triangle Park, NC
27709
919-541-0947 (fax)
I am writing in response to the request for public comments regarding the announcement of an independent scientific peer review meeting on the use of in vitro testing methods for estimating starting doses for acute oral systemic toxicity tests, as listed in the Federal Register at the following website: http://ntp.niehs.nih.gov/files/NICEATM_71_FR_14229.pdf . The use of nonhuman animals in lethal does testing is unjustified, irresponsible, costly, and needless. The federal government convened an international workshop six years ago to review more effective non-animal cell-based methods, yet the announcement for the upcoming workshop doesn't even mention using cell-based methods to replace the use of animals in lethal dose testing. The practice of using nonhuman animals to
mimic or study human disease is often unreliable, and occasionally leads
more scientific investigations astray.
Nonhuman animal studies have not
contributed to either the prevention or treatment of cancer:
Ø Irwin Bross, Ph.D., former director of
biostatistics at the Roswell Institute for Cancer Research, testified
before Congress in 1981 that "[w]hile conflicting [nonhuman] animal
results have often delayed and hampered advances in the war on cancer,
they have never produced a single substantial advance either in the
prevention or treatment of human cancer."
Ø A 1980 editorial in Clinical Oncology
asks why so much attention is devoted to the study of [nonhuman] animal
tumors when "it is ... hard to find a single common solid human neoplasm
[cancer] where management and expectation of cure have been markedly
influenced by the results of laboratory research." D.F.N. Harrison
explains that "most cancers behave differently from the artificially
produced [nonhuman] animal models," and concluded that "it is in the study
of human patients where the relevant answers will be found."
Ø Nonhuman animal tests that attempt to
predict which substances cause human cancers have also been shown to be
unreliable. A 1981 U.S. Congress Office of Technology Assessment Report on
the causes of cancer placed more weight on epidemiological data than on
nonhuman animal experiments because its authors argued that nonhuman
animal tests "cannot provide reliable risk assessments."
Ø According to a 1977 Nature article, of
all the agents known to cause cancer in humans, the vast majority were
first identified by observation of human populations.
Nonhuman animal studies have not
contributed to the study of neurological diseases:
Ø A 1990 editorial in the journal Stroke
noted that of 25 compounds "proven" effective for treating strokes in
nonhuman animal models over the last 10 years, none have proven effective
for use in humans.
Ø Stephen Kaufman, M.D., reviewed nonhuman
animal models of such degenerative neurological diseases as Alzheimer's
and Parkinson's and concluded that "[nonhuman] animal models designed to
improve our understanding and treatment of these conditions have had
little impact, and their future value is highly dubious."
Ø Dennis Maiman, M.D., Ph.D., of the
Department of Neurosurgery at the Medical College of Wisconsin noted in
the Journal of the American Paraplegia Society in 1988, "In the last two
decades at least 22 agents have been found to be therapeutic in
experimental [laboratory] spinal cord injury.... Unfortunately, to date
none of these has been proven effective in clinical spinal cord injury."
Nonhuman animal studies have not
contributed to the study of psychology and addiction:
Ø A review of two clinical psychology
journals, Behavior Therapy and the Journal of Consulting and Clinical
Psychology, showed that only 0.75 percent of the references were to
[nonhuman] animal research studies. Yet in 1986 alone the National
Institute of Mental Health funded 350 animal experiments in psychology at
a cost of more than $30 million.
Ø The Alcohol Studies Center in Scotland
stated in 1985 that "[n]othing of clinical relevance has been achieved to
date for the vast range of experiments in alcoholism" and that "[nonhuman]
animal models of addiction are not relevant to human addiction."
Ø However, in 1995 the National Institute
on Alcohol Abuse and Alcoholism spent $50 million on nearly 300 nonhuman
animal experiments dealing with alcohol abuse. In 1995 the National
Institute on Drug Abuse spent $90 million on nonhuman animal experiments
involving drug abuse. Yet alcohol and drug abuse treatment centers for
human sufferers remain underfunded.
Nonhuman animal studies have proven
unreliable in testing therapeutic drugs:
Ø Penicillin kills guinea pigs and
hamsters, but is very beneficial for humans.
Ø Thalidomide, a tranquilizer formerly
prescribed for pregnant women with morning sickness, caused serious birth
defects in more than 10,000 children but does not cause birth defects in
numerous species of nonhuman animals.
Ø Acetaminophen (Tylenol), a common human
pain reliever, is deadly to cats.
Ø The antibiotic chloramphenicol was
thoroughly tested on nonhuman animals before being released for clinical
use, but was found to cause an often-fatal blood disease in humans.
Ø Of the 198 drugs that were tested on
nonhuman animals in accordance with Food and Drug Administration
guidelines between 1976 and 1985, 51.5 percent caused reactions serious
enough to result in withdrawal from the market or, more commonly,
substantial labeling changes. These reactions included heart failure,
respiratory problems, convulsions, kidney and liver failure, and death. A
consequence of using inaccurate animal tests is that drugs that pass
nonhuman animal trials can be approved for human use and later prove
harmful to people; conversely, drugs that fail nonhuman animal tests but
might actually be beneficial to humans can be wrongly discarded.
Misleading nonhuman animal tests led to
increased risk to humans from delaying our understanding of the effects of
smoking and through misleading results in early polio tests:
Ø Nonhuman animal tests designed to induce
lung cancer through forced inhalation of tobacco smoke were unsuccessful
and cast doubt on human clinical findings, delaying health warnings and
possibly costing thousands of lives.
Ø Albert Sabin, M.D., who discovered one
of the major polio vaccines, testified before Congress that "the work on
the prevention [of polio] was long delayed because of an erroneous
conception of the nature of the human disease based on misleading
experimental models of the disease in monkeys."
The use of nonhuman animals in health care
research can lead to the dangerous transmission of viruses between
species:
Ø Some primate viruses, when transmitted
to humans, can cause disease and even death. Most scientists now believe
that the virus that causes AIDS is a descendent of a virus found in
nonhuman primates.
Nonhuman animal studies are not responsible for the genuine advances in human health: Ø Researchers at Boston and Harvard
Universities found that medical measures (drugs and vaccines) accounted
for at most between 1 and 3.5 percent of the total decline in mortality in
the United States since 1900. The researchers noted that the increase in
life expectancy is primarily attributable to the decline in such killer
epidemics as tuberculosis, scarlet fever, smallpox, and diphtheria, among
others, and that deaths from virtually all of these infectious diseases
were declining before (and in most cases long before) specific therapies
became available. The decline in mortality from these diseases was most
likely due to such factors as improvements in sanitation, hygiene, diet,
and standard of living.
Ø The isolation of the AIDS virus, the
discovery of penicillin and anesthetics, the identification of human blood
types, the need for certain vitamins, and the development of x-rays were
made without nonhuman animal experimentation. The identification of risk
factors for heart disease--probably the most important discovery for
decreasing deaths from heart attacks--was made through human population
studies.
Ø John Marley and Anthony Michael wrote in
the Medical Journal of Australia in 1991, "Our formal knowledge about the
factors that 'cause' disease comes primarily from epidemiological
research, in which systematic comparisons are made between selected groups
of representative individuals."
Nonhuman animal experimentation squanders
precious financial resources:
Ø In 2004, total national health
expenditures rose 7.9 percent -- over three times the rate of inflation.
Total spending was $1.9 trillion in 2004, or $6,280 per person, and is
expected to reach $4 trillion in 2015 according to a 2006 report in Health
Affairs. Total health care spending represented 16 percent of the gross
domestic product (GDP).
Ø The vast majority of federal health care
research funds are channeled through the National Institutes of Health
(NIH), whose 2005 budget was approximately $29 billion, of which about
eighty percent goes to actual research projects. According to the NIH, at
least 40 percent of its grants currently have a nonhuman animal
component. This is an incredible waste of precious financial capital
that could be better spent on human clinical and epidemiological studies,
prevention initiatives, public health programs, and in vitro tests.
Ø The three leading causes of death in
this country today are heart disease, cancer, and stroke--diseases that
can very often be prevented. Heart disease and stroke have similar
risk factors, including high-fat, meat-based diets; cigarette smoking;
high blood pressure; obesity; and sedentary lifestyles. A study presented
at the 1975 meeting of the American Public Health Association found the
heart disease mortality for lacto-ovo-vegetarians to be only one third
that of meat-eaters. Pure vegetarians (vegans) had only one tenth the
heart disease rate of meat-eaters.
Ø Cancer may also have a significant
preventable component. In 1985 the International Agency for Research on
Cancer estimated that as much as 80-90 percent of human cancer is
determined by such things as diet, lifestyle (including smoking), and
environmental carcinogens.
Ø John Bailer and Elaine Smith from the
Harvard School of Public Health and the University of Iowa Medical Center
wrote in the New England Journal of Medicine that "thirty-five years of
intense effort focused largely on improving treatment [of cancer] must be
judged a qualified failure." They further stated that despite progress
against some rare forms of cancer (particularly among patients under 30,
accounting for 1-2 percent of total cancer deaths), the overall
cancer-related death rate has increased since 1950. They recommended a
shift in emphasis from treatment research to prevention research if
substantial progress against cancer is to be forthcoming.
Ø The fourth leading cause of death
(bronchitis, emphysema, and asthma) also has a very large component that
is caused by a preventable factor: cigarette smoking.
Ø In addition, other of the ten leading
causes of death--injuries, suicide, AIDS, and homicide--could be reduced
through prevention. Clearly, prevention should be a priority for health
care funding.
The health of this country could be
substantially improved if health care dollars were more appropriately
distributed. Nonhuman animal experimentation is currently being
inappropriately overfunded at the expense of crucial clinical and
epidemiological studies, preventive medicine, public health programs, and
in vitro studies.
The citizens of this country don't want
any more animals killed in unjustified, irresponsible, costly, needless
and immoral lethal dose testing in this country. It is long past
time to refine and implement non-animal cell-based methods and to stop
poisoning animals to death.
Regards,
Mark Langley |