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Let’s talk about animal testing…

April 13, 2018

When I was around 16 I had to organise work experience in order to complete that phase of my education.  I knew I wanted to be a scientist and, like many teenagers, thought that ‘forensic investigator’ sounded like a job for me, full of fun, problem solving and gruesome intrigue.  I was lucky enough to secure myself a spot doing just that at our city hospital pathology lab and also fortunate to secure a lift from the University Hospital Vet who lived nearby my house.  At the time I had no idea what a vet was doing in a human hospital but I was happy for the lift and the work place opportunity so just got on with it.  As it turned out, the work experience was rather dull, like working in a factory really but ironically (in my eyes) attracting a far lower hourly rate and a requirement for Saturday shifts – no thank you!  Even slicing up the kidney of a knifing victim for analysis wasn’t as thrilling as it looked on the TV and as my 16 year-old-self also wanted to be rich, no amount of science was interesting enough to trump that ambition!  But what was fascinating was in finding out that the hospital vet was in charge of the welfare of the animals in the testing lab.  Yes, I’d found myself slap bang in the guts of the very thing that many of my friends at the time were protesting about and it looked way different to what they had been describing…….

Note, I said ‘different’ not ‘good’, ‘satisfactory’, ‘morally justifiable’ or any other loaded describing word.

In 2014 the NSW Greens Senator Lee Rhiannon put forward a private senators bill to Parliament proposing law changes seeking a ban on animal testing of cosmetics in Australia.  While it was generally agreed that this particular bill required some development, it did serve as a useful entry point into further discussions and investigations into how animal testing  intersects with the cosmetic market here in Australia and that has proved very interesting indeed.

Here is a link to the ABC media report on the introduction of that bill. It also mentions that while the Greens have made this proposal, the Labor party and several Liberal politicians had also expressed support in public for a review of laws in the area of animal testing.

Since this bill in 2014 there have been many responses and movements in terms of progressing this and reforming the way that chemicals are deemed safe here in Australia. Here are some important bits of feedback:

ACCORD (representative body of what is usually the bigger brands and ingredient suppliers/ manufacturers operating here in Australia) 

ASCC (Australian Society of Cosmetic Chemists) response and discussion. 

NICNAS – The body that  implements regulation in terms of chemical safety here in Australia, cosmetic ingredients are covered under NICNAS presently. 

As of today, 13th April 2018, there is still no ban on animal testing for cosmetic ingredients here in Australia but it does appear that we are moving closer towards that direction with this latest round of legal and political wrangling.

But all of this is rather dry for the average member of the public who still doesn’t really know what it means to test a cosmetic on animals.  We imagine all kinds of horrors, shaved bunnies and guinea pigs with stuff oozing out of their eyes and terribly itchy skin,  dogs locked in cages and rodents pinned spread-eagled to a board.  It’s all the stuff of nightmares really and with those views dominating the head space of the un-initiated it is hard to spark a more nuanced discussion.

In Australia, the animal testing of finished cosmetic products is not a thing that happens and it has been this way for decades now, there are no bunnies getting shampoo in their eyes or guinea pigs wearing lipstick in labs here.  As I said, this isn’t the impression that one gets when googling ‘animal testing of cosmetics’ here in Australia as many advocacy groups persist in sharing and promoting these emotive images which upon understanding the facts, seems sadly manipulative to me.

Here in Australia there is animal testing happening but rather than it being on finished products, it is on ingredients. These ingredients could be anything really but in the realm of cosmetics it is most likely to be things that could impact the environment or individuals health in a detrimental way – meaning that these ingredients are most likely sought to be imported in a large way as bulk chemicals.  To make this more relatable some examples of chemicals that might fit this category would include new technology sun filters,  surfactants for conditioning or cleansing the body, film formers that help make-up and sunscreens to work more effectively and stick to the skin  and/or high technology actives where the use in the whole Australian market is likely to exceed the limits of a small volume permit (100Kg).  While it would be disingenuous to conclude that these types of new ingredient are ALWAYS animal tested, it is more likely that they might need to be tested to meet specific Australian regulations.

So, if a brand owner, ingredient supplier or ingredient manufacturer want to access the Australian market with an additive that is not recognised by NICNAS they will be asked to fill out some paperwork to ascertain the potential volume of material that will be entering the country in any given year.  If the level is low, the material might be permitted in as any risks that exist will be contained to a small amount of material.  However, if the ingredient sponsor sees a larger market for their ingredient or the product containing the ingredient they will be required to have the ingredient assessed.  Ingredient assessment may or may not involve animal testing data and that animal testing data may or may not have to be carried out then – sometimes historical data exists for an ingredient and can be submitted and sometimes there is data from similar chemicals, maybe even those tested for another industry such as food or pharmaceuticals, that can be used instead of doing it again.   With regards to that, it has long been the case in the EU cosmetic market that an ingredient manufacturer – the people at the start of the ingredient chain – can’t create a new chemical for cosmetics, say to the regulators it is for pharmaceutical use only and get the animal testing passed off as pharmaceutical industry testing and then sell it as a primarily as a cosmetic ingredient that hasn’t been animal tested.  This would be unethical and misleading and was highlighted as a potential loophole long ago.   However,  new ingredients for cosmetics do come from other industries and sometimes it is legitimate that those ingredients were launched, animal tested and primarily sold into that ‘other’ industry prior to it becoming popular in cosmetics.   This is not illegal but it is most often the case that a time delay, say for example of 5 years post launch/ testing, exists before the ingredient is actively sold as a cosmetic ingredient.  This is part of the reason why some cosmetic brands have a rolling 5-year policy on their ingredient philosophy (won’t buy ingredients that have been animal tested for any purpose in the last five years).   Every brand does this slightly differently with brands who are particularly wanting to simplify and communicate their policy often opting for third-party certification such as found via the leaping bunny group in America or the Choose Cruelty Free here in Oz.

I guess this then begs the question about what types of tests might be carried out on ingredients to meet safety requirements?  

The most likely tests here relate to the big hitters in terms of ingredient and planet safety – your classic ‘safe cosmetics’ type of stuff really.  It’s funny, we all want safer cosmetics yet seem to have little appreciation for what proving safety actually looks like.  I appreciate that some people might then say ‘well we could just use natural ingredients instead of all of these chemicals and then no testing would be needed’ but that is neither practical nor true.  An understanding of safety limits is required for all chemicals be they Oregano Oil,  Shea Butter or Isohexadecane – it’s just that some ‘chemicals’  (or mixtures in the case of essential oils) might have been tested a long, long time ago so don’t need to be tested again now while other ‘chemicals’ are now being used in different ways or have since been found to have impacts that were previously unknown due to them now being used more liberally than before or in combination with different things to before – I’m sure that people have seen the memes that publish the ‘fact’ that ‘the average woman puts 515 synthetic chemicals on their body each day’ – that kind of thing might warrant testing – the combination effect.  In a nutshell the reality is that what is safe is rarely an absolute thing in an applied industry such as ours and as such, when the goalposts move so too must the testing (although this need not all involve animal testing as I have mentioned before).

One type of safety testing often carried out is that on marine pollutants, especially for ingredients that are likely to be shipped in large volumes and may escape into the waterways if drums are punctured – this actually happened to my shipment this week which is a complete bummer, thank goodness it wasn’t hazardous!  The testing might involve establishing LD50 levels for a particular chemical in a waterway and as such is carried out using fish.  The ‘L’ stands for lethal and the ‘D’ for Dose so essentially the test is seeking to find the concentration at which half the fish die and no, that doesn’t sound nice or fun to me and yes, some of this data can be sought via modelling where the chemical is substantially similar to one already tested.  To avoid unnecessary testing and to provide a logically feasible endpoint this type of testing is not just carried on over and above reasonable levels, if it looks like an ingredient, if spilled in a ‘normal’ or even relatively extraordinary way won’t cause harm it would be deemed not toxic to marine organisms, one wouldn’t need to keep upping the dose until fish were swimming in pure surfactant and died anyway.

Other tests that still require animal validation are to establish toxic levels via ingestion.  Again, this type of testing has some logical endpoints that can be applied so that risk can be established without causing excessive discomfort to the animals involved. This type of testing is often but not always carried out on rats and again LD 50 values can be established.

The last big one is reproductive toxicity which is something that people ask me about all of the time but in a round-about way.  Not a week goes by when someone doesn’t ask me about which essential oils are safe to use during pregnancy.  We (the essential oils industry) have some data on that and at least some of that knowledge has been gained through the testing of pregnant animals – usually mice or rats.

The above tests, tests that provide data that is required by law to prove material safety, represent the very worst types of tests that can be carried out on animals and do involve the death of significant proportions of those animals.  It has, to date, provided impossible to completely eliminate animals from the testing of long-term toxicity, carcinogenicity and mutagenicity although the advancement of  computer modelling has made strides in filling the gap and lowering this burden.

But again, do we need more cosmetic chemicals?

Well, ‘need’ is not necessarily a word that I’d use but ‘desire’ or even ‘demand’ might be.  The cosmetic industry is driven by fashion, art, passion, beauty, health, wellbeing, self-expression and so much more than just utilitarianism.  Sure, there are plenty of people out there who will be happy for ever more with just life’s basics but the majority of us still want more than just a clean and moisturised skin, we want to play but to play safely.  What we, as humans have typically struggled with is that this side of our nature, for pushing boundaries and wanting more than just that, does come with some down-sides.  Now I’m not saying that makes animal testing forever inevitable, excusable or even permissible but it does lead us to where we are now.  It is the goal of all of us involved in this industry to move towards a utopian reality where we get all the fun but none of the worry but for people like me, that involves the sober understanding that we are on a journey of an infinite number of steps to get there and that along the way there will be trouble.  So, our job is to try to reduce that trouble, alleviate that burden and lessen our impact as much as possible.

Humans didn’t invent animal testing in the chemical revolution, we have been testing on animals – the first being ourselves – since time began. With clays contaminated by arsenic, mineral oil fresh from the bubbling ponds of North Africa and lead laced iron oxides. We have come a long way and, to be fair, we, as an industry have had that progress hastened by the activism of the people.  It’s not as if scientists want to make animals suffer just so they can tick their boxes, it is more that we all want things to be safe and are required by law to provide evidence of that.

New cosmetic chemicals will keep on coming as we make things safer and create ingredients that solve the problems of today so that we can have better products tomorrow.  Sunscreens that work better;  preservatives that are kinder to our skins natural biome but tougher on the pathogenic microbes we need out of our creams and spritzers and surfactants that can clean more effectively and be flushed more cleanly.  There are always challenges to overcome for those that push boundaries.

So let’s end on this:

This quote is still widely shared. It was first aired in a speech by Charles Magel in 1983, a speech that is available on YouTube actually.  This speech references a group of scientists that were studying language development in primates.   Charles died in 2013 at age 90. He worked as a professor of applied ethics at the Minnesota State University Moorhead and was a passionate animal rights activist.

I got the above picture from here, an article written by PETA in 2016.  

The image of a bunny and the words of Charles from 1983 echo throughout the internet as if the world of science has been suspended in time over the last 35 years.

I am an ‘experimenter’ in as much as I am a scientist but I’ve also experimented on animals according to the definition of the words.

I have had guinea pigs as family pets for years and I have often sat and observed them, looked at how they interact,  seen how different food affects them and generally tried to get to know them a little better.  Sure I haven’t put any cosmetics in their eyes, on their skin or in their bellies but I’ve still experimented.

Personally I find it quite counter-productive when animal testing is not talked about accurately as to me, this inaccurate vision of what science is, what scientists do and how animals are involved is leading to a distrust of science and scientists, that they are somehow inhumane and stuck in a morality time warp where they can’t compute the obvious if it involves even a smattering of human emotion.  This, is simply not true.

What Charles Magel said in 1983 was possibly right for 1983 in as much as it struck a chord and motivated something but in 2018 is it right to still be saying these things as if nothing has changed? As if we as consumers and as people haven’t changed?  As if animal testing hasn’t changed?

So, after that if you are still wondering what is going on here in Australia in terms of animal testing here are some stats from the Humane Research Organisation.

Based on these figures the most frequent animal testing is performed on native mammals . The most common test undertaken is one of observation and the most common reason that animals are used in scientific tests is as part of an environmental study. Just as an aside on that native mammals thing, I don’t exactly know the in’s and out’s of this but I do know that a) Australia has some unique native mammals and that b) some of those are facing very specific and peculiar problems that threaten their existence such as chlamydia in Koalas and Facial Tumours in Tasmanian devils.  Then there are the ways that feral species interfere with native mammals that might be being evaluated. 

The Bottom Line for me.

As a chemist or ‘an experimenter’ as Charles Magel might have called me (hey, he was a scientist too, maybe he was also an experimenter) I acknowledge that animal testing is part of the chemical industry at this time and that animal testing does intersect with the cosmetics industry both here in Australia and in other countries of the world.  I also acknowledge that we, as an industry should seek to ensure that our legal system here in Australia is not placing un-necessary testing burdens on new ingredients, that if we can read across data from other countries to save double-handling we should and that should be expanded as far as reasonably possible.  My only ‘but’ in this is that I feel that the wider public are often mis-led with regards to animal testing and don’t have enough of a grasp of what testing is going on and why, so that they might be better able to affect and influence positive change.  I am especially interested in this now as we are seeing a dramatic rise in the marketing of Vegan cosmetics.  This, I feel, from what I’ve observed in the cosmetic industry at the moment  is almost 80% populism and only 20% substance as, rather like the palm oil issue, most people, including brand owners, have little understanding of what the issues that surround the vegan ethos is beyond the obvious of leaving out honey, beeswax, lanolin and other such animal derivatives.   Our energy and passion are valuable resources and I am most happy when I see people channeling theirs in a way that is most likely to affect change in a positive way rather than milling around in circles and doing what I call ‘busy work’.   What I’d like to see more of is the figures above explained to people,  to have the NICNAS type testing opened up and discussed more transparently with the cosmetics market so that we can all see how many new chemicals are coming in, what testing they have to undertake and what use they will be after all that.  That’s where the real power lies and not in distracting us all with old news, cute or emotionally disturbing animal pictures and emotive headlines.

For me the bottom line is that like most people I’d like to be part of the solution rather than the problem but the only way I’m going to stand a chance of achieving that is if I have some facts instead of fake news.

What do you think?

Amanda  x



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