Australia has new legislation on cosmetics testing, and it’s good news

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Source: Flickr/ Marco Verch

From 1 July 2020, Australia will have a de facto ban on new animal testing for chemicals solely used in cosmetics.

Whilst the ban does not actually apply to animal testing as such, it targets the use of data from animal testing to prove that chemicals manufactured in or imported to Australia are safe to humans and the environment and is therefore, for all intents and purposes, a ban. Under the new legislation, industrial chemicals for sole use in cosmetics can be imported or manufactured only if they provide safety data that do not rely on new animal testing. This provides a disincentive for companies to conduct toxicity (safety) testing on animals, because such data will not be acceptable under the new legislation.

The new legislation

The Industrial Chemicals Act 2019 became legislation on 12 March 2019. It is part of a package of Acts and establishes a legislative framework for the Australian Industrial Chemicals Introduction Scheme (AICIS). It replaces the previous scheme, the Australian Government’s National Industrial Chemicals Notification and Assessment Scheme (NICNAS). From 1 July 2020, AICIS will regulate the introduction (importation and manufacture) of industrial chemicals. This will ensure that chemicals used in consumer products are safe for consumers and the environment.

Under the new Act, industrial chemicals do not include chemicals used for agricultural, veterinary or therapeutic purposes, or in food or feed. These are regulated by other legislation. Cosmetic products are considered industrial chemicals, and they will be regulated under AICIS.

The new legislation does not apply to historical animal test data. The restrictions only apply to data obtained by a test on animals conducted after 1 July 2020.

Ministerial Rules

The Act gives power to the Minister to make rules that guide the implementation of the Act. The Act provides an overarching framework, and Ministerial Rules will add much of the detail of how the scheme will operate. This is where Minister McKenzie’s 11 commitments made to Humane Society International (HSI) and the #BeCrueltyFree Australia Campaign will come into play.

The Minister’s commitments

Despite the fact that most ingredients for cosmetics have multiple end uses, we are encouraged that the Government has promised to look at the possibility of extending the ban to include multi-use cosmetics ingredients.

This promise is one of Minister McKenzie’s 11 commitments to HSI, which had lobbied for additional measures to strengthen the ban.

The 11 commitments, if adopted as Ministerial Rules, will reduce animal testing of cosmetics ingredients further, and will perhaps signpost the way towards a broader ban on animal testing of chemicals and drugs.

Animal testing can and must be banned when better, cruelty-free methods are available. Such  human-relevant, non-animal test methods are already available and are being used in other countries, for example in the European Union. But we need more of these methods, and government support is essential for further progress in this area.

So it is reassuring that Minister McKenzie has made a commitment to explore whether it is possible to make a portion of existing funding available to support the development and uptake of new animal-free testing methods that will be acceptable under the new legislation.

Other Ministerial commitments refer to encouraging the cosmetics industry not to use animal test data even if the legislation allows them to do so, to publish statistics on the use of animal test data, and generally consult with all stakeholders. For example, she committed to “Include representatives from HSI and other relevant stakeholders, in a governance arrangement to guide the implementation of its policy to ban cosmetic testing on animals”.

The new legislation is indeed good news. Although no animal testing of cosmetics has occurred in Australia for years, the new Act will ensure that we don’t slip backwards. The Minister has acknowledged the “general international trend away from reliance on the use of animals to determine the hazards and risks associated with the use of industrial chemicals”. Together with the Minister’s  11 commitments, this gives us hope for further progress on the slow road towards phasing out all animal research and testing, which will be replaced with better methods that are relevant to humans.

Our colleagues at HSI have worked tirelessly to negotiate and achieve commitments in addition to the Act, and we commend them on their hard work.

 

This article was first published on the website of Humane Research Australia on 16 March 2019.

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Ethical investing and animal welfare

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Source: Flickr/ chenjack

Today, I received an email from Bank Australia announcing its clean money campaign. Bank Australia informed me that it does not invest in fossil fuels, live animal exports, weapons, tobacco and gambling. Instead, “to help create positive impact for people, their communities and the planet”, the bank lends money to individual customers, housing for people with disability, affordable housing, renewable energy projects and not-for-profit organisations.

For those of us who want to invest our money ethically, it’s great to have such a bank in Australia. But “ethical investing” doesn’t mean the same to everybody. Most ethical investment considers environmental and social factors in addition to financial return. Consideration for the welfare of non-human animals is rare. So it’s wonderful that Bank Australia doesn’t do business with companies involved in live animal export.

Cruelty Free Super goes further. This superannuation fund screens out investment in companies that engage in animal cruelty, such as animal testing, fish farming, animal racing or breeding, the production of fur and animal skins, food retailers and processors who use or sell animal-based foods, and companies who produce equipment for fishing and hunting.

Australian Ethical is another company that applies ethical screening in regard to animal welfare. For example, it does not invest in companies which raise animals for live export for food. While its website declares that “We avoid investments that harm: People, animals, society, environment”, the harm done in animal experimentation is not recognised. Australian Ethical’s Ethical Charter acknowledges “the dignity and well being of non-human animals”, but that does not appear to include laboratory animals. Companies that are known to conduct or commission animal testing are included in its list of investments (for example, Ansell Limited, Cochlear Limited, Fisher & Paykel Healthcare Corporation Limited).

For my self-managed superfund, I have been looking for managed funds that screen out animal testing. I have not been able to find such a fund in Australia, but have noticed one in the UK: Kames Capital’s ethical investment screening excludes companies based on the following criteria: animal welfare, the military, nuclear power, the environment, political donations, genetic engineering, gambling, alcohol, tobacco, pornography, banks with exposure to large corporate or Third World debt, and oppressive regimes. What a collection of unethical business pursuits!

Kames’ animal welfare exclusion criteria apply to companies that

  • Provide animal testing services or manufacture or sell animal-tested cosmetics, household products or pharmaceuticals
  • Have any involvement in intensive farming
  • Operate abattoirs or slaughterhouse facilities
  • Are producers or retailers of meat, poultry, fish or dairy products or slaughterhouse bi-products

Both Kames and Australian Ethical are included as case studies in a recent report by FAIRR (Farm Animal Investment Risk & Return): FAIRR in action: How leading global investors are factoring intensive farming issues into their investment processes.

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Source: Flickr/ peapod labs

As it’s the end of the year: Thank you for reading my blogs throughout 2018. I wish you joyful, safe and cruelty-free holidays!

The new NHMRC Corporate Plan – a missed opportunity

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Source: Flickr/ Igor Spasic

As more and more researchers point to the inadequacy of using animal models to study human conditions, Australia’s National Health and Medical Research Council (NHMRC) – the major funder of biomedical research – still does not seem to make any moves towards encouraging more human-relevant research.

The NHMRC’s Corporate Plan 2018-2019 has just been published. From the NHMRC website:

The NHMRC Corporate Plan 2018–2019 covers the period 2018–19 to 2021–22. It identifies the major health issues for this period, how we will deal with these issues and a strategy for medical research and public health research, in line with the requirements of the NHMRC Act. It also describes NHMRC’s purposes, planned activities and performance measures for the period and addresses our capability, environment and risk oversight and management.

The Plan does not touch on the transition from outdated animal research to human-relevant research. While “advances in technology” and “engagement with industry and support of innovation” are mentioned in the section on “NHMRC’s environment”, the strategy to dealing with this “risk” is limited to “timely and effective leveraging of advanced technology to reduce the burden on applicants and assessors and enable reporting on the return on investment in health and medical research.”

Animal studies do not predict adequately what will happen in humans. Many research “breakthroughs” observed in animals do not translate to clinical trials with humans and into medical practice. However, this is not acknowledged in the Plan, which includes a section on research translation. (The NHMRC does fund several research and translation centres)

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Source: Flickr/ National Center for Advancing Translational Sciences. Neurovascular Unit-on-a-chip

The value of animal experiments for predicting the effectiveness of treatment strategies in clinical trials has remained controversial, mainly because of a recurrent failure of interventions apparently promising in animal models to translate to the clinic. (van der Worp et al., 2010)

Following target discovery, as much as 90% of novel medications fail to make their way through the different phases of clinical trial to approval. The majority fail to pass at phase II – the transition through proof of concept to large scale trial at Phase III (Cook et al., 2014; Perrin, 2014; DiMasi et al., 2016). Many critics attribute this high rate of attrition to the models on which the targets are discovered – usually laboratory rodents; the argument being that the differences between animal models and human disease are too great to be able to draw valid conclusions between them. In other words, targets derived from animal models are not suitable for use in clinical populations, and hence fail at trial. (Perry & Lawrence 2017)

The lack of leadership is disappointing. Other countries’ government agencies are more proactive. For example:

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Source: Flickr/ National Center for Advancing Translational Sciences. Growing mini-brains in a dish.

Indeed, in the past few years, a substantial number of research grants have been invested in organ-on-a-chip projects from the National Institute of Health (NIH), the Food and Drug Administration (FDA), and the Defense Advanced Research Projects Agency (DARPA) in the USA, from Framework Program 7 (FP7) in the EU, and from Japan Agency for Medical Research and Development (AMED) in Japan. This investment also shows the magnitude of expectations for research related to organ-on-a-chip technology. (Kimura, 2018)

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Source: Flickr/ National Center for Advancing Translational Sciences. This illustration highlights some of the tissue and organ systems that scientists in NCATS’ Tissue Chip for Drug Screening program are working on.

It’s disappointing that we are not pulling our weight in contributing to innovative biomedical research, that Australia is lagging behind comparable countries. It’s disappointing that a good proportion of public funds are wasted on ineffective research. It’s disappointing that, as a consequence, patients are not seeing the treatments and cures that are missed because our scientists study the wrong species. Actually, the latter is more than disappointing. It’s infuriating.

Good news from Brussels for cats, dogs and primates of all kinds

The Netherlands were first with their plan for a transition to non- animal research. Now the Brussels-Capital Region, one of three regions in Belgium, has announced a ban on experiments on dogs, cats and non-human primates:

From 1st January 2020, experiments involving dogs, cats and primates will be forbidden in the Brussels-Capital Region. Not only will tests on dogs, cats and primates no longer be allowed, from 1st January 2025 animal experiments will also be prohibited in education and in safety tests except in cases where no alternatives are available and the tests are deemed absolutely necessary.

This is great news, and it shows it’s possible to phase out animal research. Of course, animal testing on cosmetics has already been banned in the 28 European Union countries, as well as in Norway, India and Israel. Several other countries are considering a ban.

Phasing out animal experimentation is not only possible, it is also necessary because the results vary for different species, strains and sexes. Transferability from animal to human studies can’t be assumed.

A recent news item illustrates this: 11 babies died after their mothers were given a Viagra-like drug during pregnancy. The women were part of a drug trial in the Netherlands that tested whether the drug sildenafil citrate could help boost the growth of the baby. Sildenafil had been tested on several animal species, including mice, rats, rabbits and dogs, and the authors of a systematic review concluded that:

… no teratogenic or fetotoxic effects of sildenafil have been reported in experimental animal models at dose levels much higher than those used in humans.

The review also included reports about a small number of pregnant women who were treated with sildenafil as a treatment for premature delivery. The efficacy of sildenafil was reported as “limited” and “conflicting”.

Meanwhile, a Queensland study using sildenafil on pregnant women has been temporarily halted. The Queensland study is different to the study in the Netherlands, and so far has no negative outcomes.

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Leo, a former “tool for research”. Source: Humane Research Australia

But back to the “good” news. Phasing out animal research depends on the availability of non-animal, human-relevant methods and technologies.

This month, researchers from the Johns Hopkins University demonstrated that artificial intelligence is more accurate than animal testing in spotting toxic chemicals. Professor Thomas Hartung, one the researchers, wrote:

… we have now developed a computer method of testing chemicals that could save more than a US$1 billion annually and more than 2 million animals. Especially in times where the government is rolling back regulations on the chemical industry, new methods to identify dangerous substances are critical for human and environmental health.

Hartung’s research group found that chemicals that are known to be toxic in humans are only proven so in about 70 % of repeated animal tests. The new computer software, however, identified toxic substances in 89% of 48,000 (toxic) chemicals that were tested.

Another area where fast progress is being made is organs-on-chips. The organs-on-chips market is expected to grow rapidly: from US $9.6 million in 2017 to US $45.6 million by 2022. (see also previous blog post from 25/04/2017)

Animal research is an inaccurate “science”, and better, human-relevant methods and technologies have been and are being developed. Which country or jurisdiction will be next to start phasing out animal research?

 

 

Change, slow but steady

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How can we tell whether public opinions are changing? How can we tell whether views on particular issues have changed compared to some time ago? As animal advocates, our aim is to achieve change to policies, regulation and legislation that improves the lives of animals. Changing public opinion alone can make a difference to the lives of animals – when, for example, consumers stop buying the eggs of caged hens -, and it is essential to achieve regulatory and legal change.

Surveys and polls are a common way of gauging public views on political and social issues. They are important tools to monitor and evaluate animal advocacy, and provide direction for future strategies.

So what do we know about awareness of and views on animal experimentation, and whether they are changing?

Overseas surveys tell us that the public’s views on animal experimentation are changing:

  • a Pew Research Center survey from 2015 in the U.S. informed us that approximately equal numbers of people favour and oppose the use of animals in scientific research (47% vs 50% respectively), while the vast majority of scientists (89%) favour animal research, a difference of 42 percentage points.
  • a Gallup poll in 2015 found that a third of Americans want animals to have same rights as people (compared to 25% in 2008), while 62% said animals deserve some protection but can still be used for the benefit of humans.
  • A 2017 Gallup poll in the U.S. found a 51% acceptance of medical testing on animals, a decreased acceptance rate compared to polls in previous years.
  • In an Ipsos MORI 2016 poll in the UK, 65% (compared to 68% in 2014) of people said they could accept the use of animals in research as long as it is for medical purposes, and there is no alternative.
  • In Germany in 2017, a Forsa poll found 71% of respondents in favour of a ban on painful animal experiments, while 23% did not consider such a ban necessary.

In Australia, the results from a survey commissioned by Humane Research Australia (HRA) have just come in: Nexus Research surveyed 1,006 people in April 2018. The sample was quota controlled by age and gender, and selected in proportion to the population aged 16+ years in each State/Territory. A survey of this size is considered sufficient as a representative sample of the Australian population, with an error margin of around ±3%. More information about the survey can be found on the HRA website.

Taking small samples from large populations is a valid statistical technique for getting accurate information about the wider population, for a fraction of the time and cost.

HRA commissioned similar surveys in 2008 and 2013. Below are some of the findings, comparing how people’s awareness and views changed over the 10 years since the first survey.

Awareness

Awareness of animal research has changed over the years. While in 2013 only 57% of people were aware of animals being used in research, this increased to 71% in 2018. In the latest survey, people under the age of 30 and those with an income between $80,000-$120,000 had the highest awareness of animal research (both 79%).

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In 2013 and 2018, people were asked whether they were aware that monkeys and other non-human primates are used in medical research in Australia. The vast majority of respondents were not aware of this (91% in 2013, 82% in 2018). On the other hand, over the last five years the number of people who know that non-human primates are used in laboratories has doubled from 9% to 18%.

In the last survey, a new question was added: ‘Do you consider that our governments provide sufficient information to understand the extent of animal experimentation in Australia?’ About the same proportion as those who were not aware of primate research answered this question with ‘no’ (81%).

Positions against animal experimentation are typically based on two arguments: ethical considerations that deem inflicting suffering on sentient beings as morally wrong, and/or scepticism about the scientific validity of animal experimentation. Both were explored in the surveys.

Ethical concerns

Do humans have the moral right to experiment on animals? In all three surveys, more than half of the respondents did not believe this, and a significant proportion was unsure. More men than women (31% vs 15%) and more people aged 70+ than people under 30 years (34% vs 21%) believed that humans have the right to experiment on animals. People living in households with pets expressed a much stronger view against animal experiments than those who did not live with pets (64% vs 53%), while the latter expressed greater indecision (13% vs 22%).

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To gain more nuanced views, questions were asked about the purpose of research and the species of animals used. About three in four people opposed the use of animals for developing household products and cosmetics testing in all three surveys. Interestingly, this proportion decreased slightly over the 10-year period, while the proportion of those opposed to basic/scientific research, teaching/educational purposes and developing pharmaceuticals for people (medicines/tablets) rose slightly. A question about environmental research was only asked in 2018.

oppose use for of AR

People do not feel as strongly for rodents (mice and rats) and rabbits as they do for dogs and non-human primates. While concern for all four species increased slightly over the years, half as many people opposed research on rodents compared to dogs.

oppose by species

The level of discomfort and pain inflicted on animals also influenced people’s views: the more painful the procedures, the greater the opposition to animal research (2018: from 33% to 72%).

oppose by level of pain

Overall, more women than men expressed ethical concerns, as did younger people (<30) compared to older people (>70), and people who live in households with pets compared to those who do not.

Transferability

All three surveys asked respondents about their views on the transferability of results from animals to humans. However, the wording of the question changed in the 2018 survey:

‘Do you believe or not believe that it is always safe to transfer results from animal research (e.g. from rabbits, mice, rats and dogs) to apply to humans?’ (2008 and 2013)

‘Do you believe that it is safe to transfer results from animal research (e.g. from rabbits, mice, rats and dogs) to apply to humans?’ (2018)

The change in wording might explain the significant increase in the number of people who believed that results from animals apply to humans (2008: 14%, 2013: 13%, 2018: 35%). About a third of respondents were unsure. In 2018, significantly more men than women (42% vs 29%) and older people aged 70+ compared to those aged under 30 years (50% vs 31%) believed that it is safe to transfer results from animal research to apply to humans.

transferability

Alternatives

In 2018, people were asked whether they were ‘aware of any current alternatives instead of using animals in research for human medicines. Only 20% responded that they were aware of such alternatives.

It is no surprise then, that the vast majority of respondents favoured ‘allocating a proportion of medical research grants to finding scientific alternatives to animal experiments’, although this support decreased over the years from 79% to 67%. I have no explanation for this trend.

Change, more change

To my knowledge, this Nexus survey is the only of its kind in Australia. How sure can we be that it describes accurately Australians’ opinions about animal experimentation? Nexus Research recruited survey participants from a panel. While there have been concerns expressed about this type of recruitment, ‘the quality of the answers obtained from online panels does not seem to be worse than that from more traditional methods of data collection and, in some cases, may be better.’ So, for the time being, this is the best we have.

As the president of Humane Research Australia I’d like to think that our work has contributed to greater awareness of animal research and increasing compassion with the animals used in laboratories. It is clear that the public wants accurate and comprehensive information about animal research. It is also clear that the public needs to be better informed about alternatives to animal research. Without such knowledge, how can people develop informed views and considered moral judgment about animal research?

 

World Week for Animals in Labs

This week is World Week for Animals in Laboratories when we commemorate the suffering of millions of animals in laboratories around the world and raise awareness of better, human-relevant research methods that do not involve inflicting pain on animals.

Animal research is still a mostly secret industry. Although research institutions are required to collect data about animal research, this information is not made publicly available in full. Here in Australia, Humane Research Australia (HRA) collects available data and makes them available on its website. The latest available statistics  indicate that during 2015 approximately 9.9 million animals were used in Australia (although this includes studies that involve observation only). HRA also publishes case studies of horrific procedures that are being carried out on animals in this country.

Over the last decades, increasingly evidence has come to light showing the pitfalls of animal research. For example, scientist have been able to cure different types of cancer in mice, but a cure in humans is still elusive.

The development of penicillin was delayed because the researcher Dr. Alexander Fleming thought it was ineffective in a rabbit model of systemic infection. In fact, Fleming later stated “How fortunate we didn’t have these animal tests in the 1940s, for penicillin would probably never have been granted a license, and possibly the whole field of antibiotics might never have been realised. (Kramer & Greek 2018)

While animals have been used in experiments for decades, animal models have not been validated; they have not been tested to see whether they are fit for purpose. And yet, most regulatory testing still requires that new drugs and treatments be tested on animals before they are evaluated for safety and efficacy in clinical trials with humans. On the other hand, any new testing method that does not involve animals has to go through a rigorous validation process.

The vast resources dedicated to animal experimentation have an opportunity cost for humans: new drugs that fail in animals but would benefit humans do not become available. We know that one in ten new drugs that are safe and effective in animals fail in humans. We do not know how many new drugs that would be safe and effective in humans never made it to drug trials in humans. And we do not know how many patients have suffered or died prematurely due to this opportunity cost.

 Even for two individuals within the same species, small differences in DNA can mean the difference between life and death. A tiny difference of one amino acid within the human chromosome is all that separates a patient with life‐threatening sickle cell anemia from those of us who do not suffer from that condition. Dramatic differences can exist across species even without changes in amino acid sequences. Genes are regulated—turned on and off—by other genes. For example, mice and humans share the gene that allows mice to grow a tail. The reasons humans do not normally grow a tail during development is that the gene is never turned on (i.e., expressed). Differences in gene regulation and expression vary within and between species and account for differences in response to drugs and disease. (Kramer & Greek 2018)

Even supporters of the practice point to numerous flaws in animal research. The National Health and Medical Research Council (NHMRC) is the major funder of biomedical research in Australia. In 2017, it published a report  with the title Best practice methodology in the use of animals for scientific purposes. This report includes a long list of flaws in animal research: flaws in the quality of experimental design, flaws in the quality of experimental statistics, flaws in the quality of techniques and procedures, and flaws in reporting (pp. 10-13).

Animal experimentation is cruel, ineffective and a waste of our taxes. It supports an industry that is outdated and needs to change. This change has started, but it is very slow. I have written about this in previous posts, for example here. Unfortunately, Australia is not at the forefront of innovation.

So what can we do to get a move on the end of animal experimentation and replace the use of animals with advanced science? Some ideas: Share your views on outdated animal research with friends and family, politicians and on social media. Make a donation to a charity that works towards ending animal experimentation. Organise a fund-raising event. Don’t buy cosmetics and household products that have been tested on animals.

Thoughts and prayers on World Day for Laboratory Animals on 24 April and during the week are not enough.

Toxicity testing without animals

When I mention that I am against animal experimentation, the reaction is often: “Would you prefer these tests were done on humans?” In the discussion that follows it turns out that most people don’t know that there are better and less cruel ways of doing biomedical research. Some people suggest that these alternatives, such as computer-based methods, can never be as adequate as a living animal.

However, over the last decade science has made much progress in developing non-animal methods and tools to use in basic and applied research, and for regulatory testing such as the testing of new drugs and chemicals. Governments are now encouraging and mandating researchers to use these new methods instead of live animals. For example, earlier this year 16 federal agencies in the US developed a Roadmap to guide progress toward replacing animal use in toxicity testing.

The roadmap was developed to guide the application of new technologies, such as high-throughput screening, tissue chips, and computational models, to toxicity testing of chemicals and medical products.

What exactly are these new technologies? An open access article published last year by Mary T. McBride – Future platforms for toxicity testing – provides a good summary of current and future methods for toxicity testing without animals:

  • In vitro model systems, using cells and cell cultures, such as stem cells, tissue engineering and organs-on-chips, with a human-on-a-chip being under development.

 

  • In vitro pathway-based assays and quantitative high-throughput screening (HTS). The latter employs liquid robotics handling systems and computerised data processing, to screen a single compound against a large number of assays to identify toxicity pathways or to test a large number of compounds using a single assay.

 

  • Cell-based imaging technologies and high-content screening, using imaging tools such as innovative microscopy methods, ultrasound, Computed Tomography (CT), Magnetic Resonance Imaging (MRI), and Positron Emission Tomography (PET).

 

  • Omics approaches, such as genomics, transcriptomics (a microarray technology to establish human genome-wide gene expression profiles by measuring all of the approximately 100,000 mRNA molecules or ‘transcripts’ produced in a cell or a population of cells), proteomics (the comprehensive study of the entire complement of proteins and their modifications of an organism to understand cellular processes) and metabolomics (the study of metabolites, such as lipids and proteins, and used to identify all of the metabolites present in a given cell or organism at a specific time).

 

  • Data integration analysis and interpretation: bioinformatics and visualisation tools. This involves combining data from different platforms and assays across multiple experiments.

 

  • Computational toxicology, which includes the integration of mathematical and computer models to map, model and understand the biological circuitry of toxicity pathways to predict the toxicity of environmental chemicals and pharmaceuticals and their dose-response relationships.

 

Tissue engineering has made tremendous advancement in the field of tissue-engineered preclinical models. Such models now exist for many whole tissues including skin, muscle, cartilage, blood vessels, bone, bladder, liver, cornea, reproductive tissues, adipose, small intestine, neural tissues, kidney and cardiopulmonary systems.

McBride suggested that “the new approach may significantly reduce costs and time required to conduct chemical safety assessments and could markedly diminish and potentially eliminate animal testing.” She pointed out that this is not an exhaustive list, and that rapid advances in biology and biotechnology are continuously emerging.

Various databases listing resources for non-animal research are available to researchers and the general public, for example ALTBIB (Resources for Alternatives to the Use of Live Vertebrates in Biomedical Research and Testing) and EURL ECVAM (European Union Reference Laboratory for alternatives to animal testing).

So no, the often cruel and painful experiments currently conducted on live animals don’t need to be done on humans. Nor do they need to be done on animals.