From: mhulsey@hestia.fcs.uga.edu (Martin Hulsey)
Subject: Animals in testing
Followup-To: talk.politics.animals
Organization: Dept. Foods & Nutrition, Univ. of GA
Distribution: usa
Date: Mon, 23 Nov 1992 20:59:33 GMT

In <BxxoyG.1nI@wpg.com>, russ@wpg.com (Russell Lawrence) writes...

>rl> Avon and Revlon are among the many dozens of companies that no longer 
>rl> do animal testing.  Are they "unscrupulous"?  If so, please explain why.
>
>From article <mhulsey-181192105351@fatrat.fcs.uga.edu>, by mhulsey@hestia.fcs.uga.edu (Martin Hulsey):
>mh> I have no proof, but I understand that they contract such work out 
>mh> to other firms now.  
>
>How did this wee bit of "understanding" happen to come your way,
>Martin?  Please specify your sources.  

I probably deserve your sarcasm here.  I recalled reading this in a NABR
newsletter, but I cannot find my reference.  Therefore, I withdraw my claim
for the moment.

Anyway, you need to understand the possibility of deception here.  A
company's signing an affidavit that they will do no animal testing, and
claiming that their products are "cruelty-free" are two entirely different
matters.

>mh> I would be appreciative if you could clairify this.  How do you 
>mh> verify that companies aren't really surreptitiously testing their 
>mh> products or ingredients elsewhere?  
>
>How could we prove that you've never, ever, committed some truly 
>heinous criminal act?  Answer: We can't.  However, the logical burden 
>of proof falls on the accuser, rather than the accused.  

No, the burden of proof falls on any company making the claim that their
products are "cruelty-free."

>Are you claiming that Revlon and Avon are involved in such chicanery?
>If so, let's see your evidence.  

At my last trip to the drug store, I saw no "cruelty-free" claims on Revlon
products, so I withdraw my claim of "unscrupulousness" with respect to that
company.  I haven't yet determined whether Avon truly claims that its
products are cruelty-free, or whether they merely claim to do no animal
testing themselves.  A friend of mine who sells Avon promises to
investigate.

Why do you imagine that companies would have such an "official policy," yet
not proclaim it on their packaging?  Why do you presume that companies like
Paul Mitchell would run two different versions of TV commercials in
different markets?  Could it be that the consumer demand for "cruelty-free"
products is not as great as some would suggest?  Could it be that a
majority of humans have more concern for their own eyes that those of
rabbits?  I hope that these questions will not ultimately have to be added
to "the list."

>mh> Do you disagree that there are no existing standards for applying 
>mh> the label "cruelty-free?"
>
>No.  On the other hand, if company officials sign an affadavit stating
>their position on animal testing, it seems to me we should take them
>at their word unless there's proof to the contrary.

The problem with this position is that, in order for a product to be truly
"cruelty-free," the manufacturer AND its all of its suppliers must give the
same assurances.  Isn't a "cruelty-free" product what you folks are after?

Do you have a statement from Revlon and Avon (or any other company)
verifying that NONE of the raw materials employed in the manufacture of
their products are elsewhere tested on animals?

>mh> According to "Partners in Discovery," a propaganda organ of the 
>mh> NIH, "...federal regulations generally require information that 
>mh> can only be obtained from animals, to determine the safety and 
>mh> efficacy of a new medicine, medical procedure, or consumer 
>mh> product...  It is important to recognize that most products 
>mh> advertised as 'not tested on animals' contain ingredients that in 
>mh> fact _have_ (emphasis theirs) been tested on animals-or a company 
>mh> could not label a product as safe for human use." 
>
>From Vogue magazine (November, 1990):
>
>"Though neither the FDA nor the Consumer Product Safety 
>Commission requires animal testing before a consumer product or 
>cosmetic goes on the market, both agencies have historically used 
>animal toxicity data as their standard for evaluating safety.  
>While publicly stating that it doesn't think any single 
>alternative test is developed sufficiently, for example, to 
>replace the Draize eye irritancy test, the FDA has offered 
>passive approval to companies such as Avon, Revlon, and Estee 
>Lauder, which have conducted investigations of various 
>alternatives and found them to be at least as accurate as the 
>animal tests for their product lines." 

Your "rebuttal" from the popular press is self-contradictory.  If the FDA
and CPSC do not *require* safety data from animals, why would any company
need "passive approval" or any form of approval to instead employ the
"alternatives?"

Also, how did the above-mentioned companies determine that the
"alternatives" are "at least as accurate" as the Draize test without
themselves performing the Draize test?

>[...]
>
>I think you should furnish the source of your allegation concerning
>Revlon and Avon.   After you post it, I'm going to fax copies to
>both companies and ask them for a reply.

Hell hath no fury like Russell's fax.  Why don't you instead ask them to
verify that their suppliers also perform no animal testing?  If I can find
my above-mentioned reference, rest assured that you will see it.

If a manufacturer produces a product is composed of materials that are
animal-tested by the manufacturer's supplier or previously shown to be safe
using animals (i.e., GRAS), would you regard the final product as
"cruelty-free?"

Let me remind you that the fate of animal testing does not hinge upon
safety testing of cosmetics and other non-medical products.

I fully support the development of alternatives to procedures such as the
Draize test.  Animal activists, in their zeal to save animals, would push
for forced employment of these "alternative" tests *before* their efficacy
is accepted by leading authorities.  In fact, legislation outlawing the
Draize test, sponsored by animal advocates such as Barbara Boxer (D-Cal.),
have already been rejected in Congress, and in several state legislatures. 
Yet, efforts to ban the Draize test continue.

Please be aware that when satisfactory alternatives are ultimately found
for procedures such as the Draize test, they won't foretell the end of
animal testing in other areas.  Safety testing of pharmaceuticals will be
likely to continue for some time afterward.

--
mhulsey@hestia.fcs.uga.edu                      Society for Neuroscience
Martin G. Hulsey                              National Rifle Association
Dept. Foods & Nutrition      Society for the Study of Ingestive Behavior
University of Ga.    North American Association for the Study of Obesity
Newsgroups: talk.politics.animals