Chemicals regulation and non-animal methods: displacing the gold standard

Regulating industrial chemicals in foodstuffs and consumer products is a major aspect of protecting populations against health risks. Non-animal testing methods are an essential part of the radical change to the framework for toxicity testing that is long overdue in global economies. This paper discusses reasons why the drive to reduce animal testing for chemical safety testing is so difficult to achieve, as perceived by those who are closely involved in chemicals regulations in different capacities. Progress is slow, despite the fact that the ethico-legal conditions for a move away from animal testing are largely in place, and despite scientific arguments for a radical change in the paradigm of toxicity testing, away from reliance on animal studies. I present empirical data drawn from two studies in a European Commission context promoting non-animal methods. The aim of the paper is modest. It is to foreground the voices of those who deal with the science and regulation of chemicals on a day-to-day basis, rather than to offer a theoretical framework for what I heard from them. I offer a synthesis of the main challenges faced by non-animal alternatives, as these are perceived by people in different stakeholder groups dealing with chemicals regulation. I show where there are pockets of agreement between different stakeholders, and where the main disagreements lie. In particular there is dispute and disagreement over what counts as validation of these alternative tests, and by implication of the traditional 'gold standard' of animal testing. Finally, I suggest that the shift to non-animal methods in chemicals regulation demonstrates the need for the concept of validation to be broadened from a purely techno-scientific definition, and be more explictly understood as a demand for trust and acceptance, with more attention given to the complex social, institutional and economic settings in which it operates.