Blinded for Beauty

Rabbits Used in Product Testing


By Vicki Katrinak, AAVS Policy Analyst
The image of a rabbit has become the logo of choice for the cruelty-free product industry. This is due in part to the work of animal advocates who displayed pictures of rabbits with eye injuries and shaved sides to reveal the horrors of the product testing industry to consumers. Many companies responded to consumer concerns by banning product testing or working to develop appropriate non-animal alternatives; however, thousands of rabbits continue to suffer and die each year to put consumer products such as shampoo, lipstick, and laundry detergent on store shelves.

The Draize Tests

The test most often associated with rabbits in laboratories is the Draize Eye Irritancy Test; however, other animals including dogs and nonhuman primates are also used for this procedure. John H. Draize, Ph.D., a scientist at the United States Food and Drug Administration (FDA), developed the Draize eye test in 1944 to assess eye irritation caused by various chemicals. In the test, a substance is placed in one eye, with the other eye serving as a control. The rabbits are restrained, preventing them from responding naturally to the irritation, and their eyes are evaluated after one hour and then at 24-hour intervals for up to 14 days. Some continue to be evaluated up to 3 weeks later. The level of irritation to the eyes is scored numerically by observation of the three major tissues of the eye (cornea, conjunctiva, and iris).[1] Rabbits suffer from redness, bleeding, ulcers, and even blindness, and are likely killed upon completion of the experiment.

Similar to the eye test, Draize also developed a skin irritancy test that measures the level of irritation caused by test substances on the skin. Rabbits, as well as rats and mice, are often used for the Draize skin irritancy test in which one patch of skin is shaved and a high concentration of a test substance is applied while another shaved area is used as a control. The skin is then observed for signs of irritation such as swelling, itching, soreness, and inflammation.[2]

Flawed Science

Using rabbits and other animals to assess the safety of cosmetic and household products is not only unjustified cruelty, but also flawed science. As reported by Nature, toxicology tests “are stuck in a time warp, and are largely based on wasteful and often poorly predictive animal experiments.”[3] Different species and even different animals within the same species can change test results due to differences in absorption, distribution, metabolism, and excretion of chemicals. Test conditions are often unrealistic, with extremely high doses administered by abnormal routes, and “test results have to be ‘scaled up’ to humans but the mathematical formulae used have not been proved accurate.”[4] All of these factors lead to highly unreliable safety data.

The Draize eye test has been criticized for several reasons. The structure of the cornea of the eye of a rabbit differs significantly from that of a human. Rabbits also produce a smaller volume of tears than humans, allowing chemicals and other irritants placed in rabbit eyes to linger longer and cause more irritation.[5] Not only does this make the Draize eye test unreliable, but it also adds to the immense suffering caused by this test. In addition, “the subjective nature of the gross observations made during the scoring of the test, plus normal animal-to-animal variability, make it virtually impossible to routinely reproduce the final Draize score, especially for midrange irritants.”[6] Similarly, the reliability of the Draize skin irritancy test has been questioned since different species have very different types of skin, “so a simple extrapolation to likely human responses is rather dubious.”[7] Clearly, animals are not sufficient models for product testing, yet their use remains entrenched in modern science.

Cosmetic Testing and the Law

It was not until the early twentieth century that cosmetic and household products were tested on animals. In 1933, a product called Lash Lure blinded over a dozen women, and one woman died after an ulcer caused by the product became infected. This incident and others like it led the United States Congress to pass the Food, Drug, and Cosmetic (FD&C) Act of 1938.[8] This law gave the FDA regulatory authority over cosmetic products, and companies began to test products and ingredients on animals in an effort to ensure safety for consumers. While many companies still use animal testing to assess the safety of their products, "the FD&C Act does not specifically require the use of animals in testing cosmetics for safety, nor does the Act subject cosmetics to FDA premarket approval.”[9] In addition, the U.S. Consumer Product Safety Commission, which ensures the safety of household chemicals, does not require the testing of household products on animals. There are sufficient existing safety data as well as in vitro alternatives to make animal testing for cosmetic and household products obsolete. Unfortunately, many companies remain resistant to changing their testing techniques, and U.S. agencies like the FDA continue to endorse animal testing methods as the gold standard.

While product testing on animals has declined in the U.S., efforts to stop the testing of cosmetic products on animals have been more successful in Europe. In 2003, animal advocates in the European Union (EU) successfully pushed for passage of a ban on cosmetic testing on animals. The seventh amendment to the Cosmetics Directive (76/768/EEC) sets a series of deadlines for animal testing bans and marketing bans of cosmetics containing animal tested ingredients. Most of these deadlines are tied to the availability of non-animal testing methods. In 1998, the United Kingdom banned testing cosmetic products and ingredients on animals, and testing bans or partial bans are also in place in Austria, Belgium, Germany, and The Netherlands. Unfortunately, until the EU sales ban is in place, most cosmetic products sold in these countries will have been tested on animals in other countries.[10]

Labeling

While many animal tests have been replaced by suitable alternatives, saving countless lives, many animals continue to suffer and die to manufacture personal care and household products. At the same time, companies have learned that making “cruelty free” claims can lead to big profits. Compassionate consumers purchase products with labels claiming to be “cruelty free” or “not tested on animals,” but this claim often refers only to the finished product. Most animal testing of products does not occur at the final stage but rather through the supply chain. So, a product may claim that its products are not tested on animals, while all its ingredients have been tested on animals. Similarly, some companies state that "we" do not test on animals, when in fact the testing is merely contracted out to another company. These kinds of labels and claims are often confusing and misleading to consumers.

Concerned about the number of different animal testing claims that companies use with no accountability, several animal protection organizations, including the American Anti-Vivisection Society, joined forces in 1996 to create the Coalition for Consumer Information on Cosmetics (CCIC).[11] CCIC, which licenses the leaping bunny logo, requires companies to follow the Corporate Standard of Compassion for Animals, a voluntary pledge whereby companies state that they will not conduct or commission animal tests for any of their finished products, ingredients, or formulations after a fixed cut-off date. Unlike other lists, the CCIC requires companies to renew their pledges annually and obtain verifiable assurances from their ingredient suppliers that no new animal testing has or will take place after the fixed cut off date. These assurances make CCIC the only reliable list of cosmetic and household products that are 100 percent cruelty-free.

Hope for the Future

Unlike so many other animal abuses, the issue of using animals in product testing is one that ultimately rests with consumers. Reliance on animal testing methods for cosmetic and household products will continue unless concerned citizens speak out with their purchasing power. By making informed humane choices and encouraging others to do the same, individuals can push for an end to product testing and stop the needless suffering of millions of rabbits and other animals each year.

Sources Cited

[1] Curren, Rodger D., & Harbell, John W. (1998). In vitro alternatives for ocular irritation. Environmental Health Perspectives, 109, 486.
[2] Langley, Gill, Ph.D., & Langley, Chris, Ph.D. (2005). Safety without suffering: Ensuring the safety of cosmetics without tests on animals, p.21. Retrieved September 22, 2006, from http://usa.lush.com/terms/animaltest.html
[3] Abbott, Alison. (2005, November 10). More than a cosmetic change. Nature, 438, 144.
[4] Langley, Gill, Ph.D., & Langley, Chris, Ph.D. (2005). Safety without suffering: Ensuring the safety of cosmetics without tests on animals, p.13-14. Retrieved September 22, 2006, from http://usa.lush.com/terms/animaltest.html
[5] Langley, Gill, Ph.D., & Langley, Chris, Ph.D. (2005). Safety without suffering: Ensuring the safety of cosmetics without tests on animals, p.23. Retrieved September 22, 2006, from http://usa.lush.com/terms/animaltest.html
[6] Curren, Rodger D., & Harbell, John W. (1998). In vitro alternatives for ocular irritation. Environmental Health Perspectives, 109, 487.
[7] Langley, Gill, Ph.D., & Langley, Chris, Ph.D. (2005). Safety without suffering: Ensuring the safety of cosmetics without tests on animals, p.21. Retrieved September 22, 2006, from http://usa.lush.com/terms/animaltest.html
[8] Institute for Laboratory Animal Research (2004). Safety Testing. In Science, Medicine, and Animals. (p. 21-28). Retrieved November 27, 2006, from http://newton.nap.edu/books/0309088941/html/21.html
[9] United States Food and Drug Administration. (2006, April 5). Animal Testing. Retrieved November 30, 2006, from http://www.cfsan.fda.gov/~dms/cos-205.html
[10] British Union for the Abolition of Vivisection. (n.d.). Cosmetic Testing Around the World. Retrieved November 30, 2006, from http://www.buav.org/campaigns/cosmetics/testing.html
[11] CCIC is comprised of the American Anti-Vivisection Society, American Humane Association, Animal Protection Institute, Beauty Without Cruelty, USA, Doris Day Animal League, Humane Society of the U.S., New England Anti-Vivisection Society. Please visit the CCIC website at www.leapingbunny.org.


AV Magazine | Winter 2007
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