August 19, 1999

Public Information and Records Integrity Branch
Information and Resources Division (7502C)
Office of Pesticide Programs
Environmental Protection Agency
401 Main Street, S. W.
Washington D.C.

Re: Docket Control Number OPP-00610

Dear Agent of the EPA:

I am writing to comment on Docket Control Number OPP-00610, the proposal to add to the battery of animal tests already performed on new pesticides four (4) new toxicity tests. I am opposed to this proposal and would discourage the EPA from adding these redundant tests.

It is my understanding that at a recent meeting on this subject scientists indicated that these new tests would yield no greater information or data than the battery of 19 animal tests already performed to determine toxicity of pesticide chemicals. In other words, these tests are redundant. Further, I understand that each of these new tests would result in thousands of animals suffering terrible pain and discomfort before being killed by the poison pesticides. Considering these tests will yield no additional benefit to consumers and users and will result in the killing of thousands animals, I can only surmise that these tests are financially wasteful, ethically irresponsible, morally reprehensible and downright cruel.

I am asking the EPA:

(1) NOT to add these new tests to the regiment of tests already performed on new pesticide chemicals;
(2) To review the battery of 19 toxicity tests already performed for further redundancy as well as cruelty to animals in accordance with the 1993 NIH Revitalization Act which stipulates that "agencies with regulatory programs should…reduce reliance on animal testing" and should, "periodically review and revise test methods in light of scientific and policy developments"; and
(3) In accordance with the 1996 law which allows it, adopt the "ten-fold factor" to better ensure public safety.

True, the American public wants all products being used in the environment, around our food sources and in close proximity to our family, pets and friends to be safe, but I fail to see how adding tests that reveal no substantially significant, diverse or expansive data on the products will accomplish this goal.

Let me reiterate that I am opposed to the EPA implementing these new tests. We live in what is considered the "modern era." We should be actively seeking better, more accurate, non-lethal and cruelty-free methods for chemical and product testing. Therefore, I find it more than a little disheartening that the EPA is considering the addition of more painful, lethal, and unnecessary tests on laboratory animals when they should be looking to reduce, replace and eliminate those already used.

I thank you for taking the time to read my opinions on this matter, and I hope they will be taken into account when considering this proposal.


Leigh-Anne Dennison

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