Why is the EU still testing cosmetic ingredients on animals?
I spent a good part of yesterday reading toxicology reports investigating the safety of Nanoparticulate Titanium Dioxide and Silica. It was an EU sponsored and funded research project spanning 3 years and taking in work from a consortium of laboratories spanning many countries.
It soon became evident that part of this testing was carried out on live animals – injecting them with the particulates (in solution of course) and also passing them into the lungs.
The animals involved were rodents and the testing required sacrifice of the animals to trace the passage of the nano materials.
At that point the fact that I had come to find out about a particular nano material that I was researching fell to the back of my mind. What grabbed me by the throat was the irony of the situation that I was now in. I was reading a paper discussing results of animal testing on ingredients designed for the cosmetics industry. The testing had been authorised and funded in the EU at a time when the big trumpeted fan fair news was a ‘BAN ON ANIMAL TESTING’.
Isn’t that ironic?
To say I had mixed feelings when I read this report would be an understatement. I do not want to see any animal at all put through testing, whatever form that takes and however well-managed (and I do believe that this study was well-managed and that animal welfare was more than just a passing consideration). However, the toxicological data that came back is, on the whole intensely useful from both a materials handling perspective, from the perspective of someone who potentially uses these materials to make consumer goods and from the point of view of ‘where to next’ both in terms of future testing models and to fill in any gaps with these materials.
After all isn’t most of the internet tub thumping about safety?
But it still seemed deceptive to me and made me feel very, very confused and uncomfortable.
I mentioned above that ‘part’ of the testing had been carried out on animals. The animal testing part is called ‘toxicokinetic testing’ or ‘investigating whether the nanoparticles actually reach target cells such as the liver, kidneys, lungs, through normal exposure. The testing looked at two things the first being metabolism. This was to find out if these materials have the potential to bioaccumulate. As you can imagine, bioaccumulation – or being stored in our tissues (possibly the liver or even brain) is not good at all.
The second test – what I will call the ‘breathing in the dust’ test is to see if these ingredients cause damage to the delicate lung tissue and in particular any asbestos type of scenario.
Neither of these tests can be replicated outside of a living body as yet as far as I know.
The other tests which were carried out first (and that detail is important too) were performed on commercially available cell models. These are live cell culture maybe lung tissue cells or gut tissue cells or skin cells – that can be used to rule out any major cellular toxicity. There is no point in feeding a known poison to an animal to ‘see what happens’. We are well beyond that point in terms of the evolution of animal testing (and when I say ‘we’ I mean the scientific world at large). The materials passed this round of testing meaning that as far as the target cells go they should be OK (up to a point and that ‘point’ is carefully calculated based on lots of different details to make sure it is relevant).
So, with that in mind the animal testing part, the last phase of the experiment was looking to compare results between ‘real life’ or in vivo and ‘laboratory cell culture ‘in vitro’, in part this helps validate the cell culture testing but further and more importantly it allows the tracking of the material through the body – an eye into the connected world that is our bodies (or rather a rodents body).
The results from this phase of testing were (to my mind) generally positive in terms of there being little toxicity evident in the animals completing the test but mixed (Some of the animals died before the test finished) which made me more confused than ever for a number of reasons – not least because again, I am wrestling with the ‘is this even legal’ scenario.
My confusion started with the realisation that the particles were entering the animal in ways that were far removed from reality – either by injecting the nanoparticles into a vein or having them literally ‘shoved down your throat’. Neither of these represent how most of us chemists, manufacturers or cosmetic users will be exposed to these ingredients. Also (stating the obvious) we are not rodents – this has been said before but it is true and especially now that we have moved into more subtle territory and are looking for more detailed and delicate responses. I did wonder how these results would stack up and whether there would be anything useful come from them.
Right about now I have to mention that I do understand the method behind the madness of the testing that I read, do appreciate the role of the ‘model’ – the benefits and limitations it presents and the gaps it creates.
But, but, but I just can’t move now – I feel somewhat dirty even using these test results as they stand. I want some questions answered and want to understand the ‘big picture’ behind this set of EU commissioned animal misery.
Let’s start with this:
- Is it ethical (or even legal) to put cosmetic grades of ingredients into an animal test environment given that the EU has made it very clear that animal testing is now banned? I am particularly interested in how this sort of ‘research’ compromises the integrity of the ban, how this testing sits with the decision-making process that went on behind the ban (if the ban was put into force to a) protect animals or b) because we no longer need it or c) because it is not what people want regardless of anything else) and where the line is drawn between ‘allowed’ and ‘prohibited’ animal testing plus how we (the industry) should communicate this to the public.
- Given that toxicokinetics are unlikely to ever be reproducible in complex cell culture isn’t it time we approached toxicity in a different way? By different way I am thinking that rather than trying to track particles (artificially introduced and prepared particles at that) into a body (and not a human body) shouldn’t we be modelling a more real-life scenario using computer models? I am sure this is happening somewhere and am also sure it has limits but am wondering where and what this looks like.
- Given that ‘new materials’ or ‘new risks’ are usually identified in market rather than in the R&D stage (this is a funding issue because people don’t value or invest in science as much as they do a known market reality. That’s politics and beyond politics it is easy to see how this mindset eventuate at an individual level) what variables should be considered in working out a suitable time span for this research?
- Who should be carrying out (and paying for) this research given that people don’t trust businesses (it is all about the money), don’t trust governments (it is all about litigation) and don’t trust themselves (it is all about google)?
- How do we identify a material worth spending this much time and effort on in the first place?
I feel that sums up where my brain is at with animal testing and more specifically the questions in my mind relating to the EU ban. The materials that I mention in this discussion are not novel ‘Frankenstein’ particles that can easily be brushed aside for being too weird or trivial – they are chemicals that act as components in many, many different consumer products – products that are a part of our every-day lives and have been for some time. If I had of picked some weird genetically modified stem cell it would be easier to say ‘just ban the material, save the animals, move on’ but this situation is not that simple.
To summarise, while I feel confident enough in saying that animal testing feels at best wrong and at worst barbaric I am still trying to figure out if the animal part of experiments such as this add to or detract from the results gained from cell culture, if the constraints and compromises necessary to create a solid animal testing protocol invalidate the results and if, given public sentiment over this issue we should not just give it up (for cosmetics) altogether – as that is what people (rightly) assume has happened already in the EU.
I feel that while tests like the one I read have much scientific validity they are undermining image of the scientific process by adding to the general feeling of deception and arrogance that clouds the publics views on science (the playing God scenario), animal testing, experimentation, risk categorisation and management, innovation and progress. I feel saddened that I can’t find much in the way of open and honest discussion about the role that animal testing is, should or shouldn’t play in the EU cosmetics market post ban. I feel slightly angry that my customers are left again to believe that something is black and white when really it is all grey.
Maybe I just have to keep on thinking and pulling this primary research apart in a bid to answer not only my questions but the questions of my ever-concerned customers and peer group and from where I’m sitting it looks like the animal testing ban contains more perforations than my tea bag.