Is animal testing still necessary? Episode 48

Is animal testing still necessary to ensure the safety of cosmetics or is it an obsolete idea? Listen to the show to find out the scientific perspective on animal testing of beauty products. 

Show notes

Announcing the winner of the Beauty Brains T-shirt!

On our 44th anniversary show we played the “Name that Noise” game. Hanka from the Czech Republic correctly identified the sound as finger nail clipping (which Perry’s wife hates.)  Congrats Hanka! You win a “Be Brainy About Your Beauty” Tshirt. 

Listen to this week’s show if you’d like to play again. This week’s winner gets a special autographed photo of one of the Beauty Brains doing something unusual. All you have to do is be the first person to leave a comment correctly identifying the beauty-related noise.

Question of the week…Is animal testing still necessary? 

Christina asks… As cosmetic scientists do you feel that animal testing is still relevant to gain data and create safe and effective products for consumers, or is it unneeded and irrelevant?

Is animal testing required?

The only place I could find that definitively required animal testing of cosmetics is China. Russia also requires animal testing but they have recently issued a statement saying they would accept alternative animal testing data. There are a number of countries who have specifically banned animal testing as related to cosmetic products. This includes the EU countries, Norway, Israel, Brazil, and India.

While animal testing is not mandated in countries such as the US, Australia, Canada and Japan, the information is from animal tests are accepted as suitable for demonstrating that a cosmetic meets health and safety standards. And for many aspects of product safety, there are no acceptable alternatives to animal testing. Therefore, although it’s not mandated in some cases manufacturers have no alternative methods of safety testing,

Here is what the FDA says about animal testing of cosmetics….

“The FDA is responsible for assuring that cosmetics are safe and properly labeled. 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. However, the agency has consistently advised cosmetic manufacturers to employ whatever testing is appropriate and effective for substantiating the safety of their products. It remains the responsibility of the manufacturer to substantiate the safety of both ingredients and finished cosmetic products prior to marketing. Animal testing by manufacturers seeking to market new products may be used to establish product safety.”

So in a sense, for some types of cosmetic products animal testing is a de facto requirement in the US.

Why are products tested on animals?

Before the 1930s, Prior to the creation of the FDA, the cosmetic and drug industries were pretty much unregulated in the US. When in the 1930’s there were a number of incidents in which people were blinded or even died due to using a drug or cosmetic, Congress passed the FD&C Act of 1938. This created the regulations for cosmetics that we follow today.

The FDA worked with industry to develop methods which could demonstrate product safety to the satisfaction of both government and industry which lead to the testing of cosmetics on animals. How could this have happened? Two reasons:

1. At that time, animal testing was the best model available for product safety testing. We didn’t have the advanced in vitro testing methods we have today.

2. The majority of society had a different view about the treatment of animals back then. People just didn’t look at the issue the same way.  In the last several decades, Most people’s views on animal rights have changed and scientists are working on creating alternatives to animal testing but the technology is slow to develop. We just haven’t had enough technological development to replace all animal testing.

What kinds of animal are used in the development of cosmetic ?

There are 9 basic types of tests that historically have been done on animals:

  • Skin sensitization – tests for allergic reactions
  • Skin irritation – tests for reversible skin damage
  • Eye irritation – tests for reversible and permanent eye damage
  • Oral toxicity – determines how much of a substance ingested kills test subjects
  • Dermal toxicity – determines how much of a substance applied to skin for 24 hrs kills test subjects
  • Inhalation toxicity – determine the amount of a substance that kills test subjects when inhaled
  • Reproductive toxicity – tests for effects on reproductive health (mutagenicity?)
  • Developmental toxicity – tests for effects on fetus (teratogenicity?)
  • Carcinogencity – determines if an ingredient is likely to cause cancer.
  • There are also a large number of companies that still uses one or more of these tests: Here’s a list that was last updated in Jan of 2014:

Can we completely eliminate animal testing?

People have made the claim that “eliminating animal testing of cosmetics is entirely feasible.” They point to the fact that the US does not specifically require animal testing (they don’t) and the availability of animal testing alternative tests (some do exist). Scientists have developed many advanced alternatives to animal testing—tests that use human cell lines, artificial skin or computer models to test the safety of products. A number of companies employ these methods now reducing the amount of animal testing they do and in many cases eliminating it.

However, there remain types of animal tests which do not have validated animal free alternatives. For example, there are no replacements for inhalation toxicity tests. We haven’t developed an artificial lung yet. There is nothing for repeat dose toxicity. And there are no validated test for carcinogenicity. So, we can’t yet eliminate cosmetic animal testing for those types of factors.

“Cruelty free” claims

How can a company claim a product is “cruelty free” or “not tested on animals? “ Easy – there is no law that defines requirements for these claims so companies are free to make up their own definitions. The simplest way to define cruelty free is something like “Our company does not test our products on any animals.”

But, manufacturers are still required by law to show that a product meets certain safety standards so here’s how they do that:

1. Use animal testing alternatives – in vitro testing has come a long way and can be used to substantiate safety of certain ingredients. That’s a no brainer.

2. Test on humans – Companies can do their safety testing on human volunteers typically patch testing for skin irritation. There are ethical limitations here of course you certainly wouldn’t text toxicity on people.

3. Use ingredients & formulas that have already been tested on animals
Most of the 15,000+ ingredients in the INCI dictionary (the cosmetic ingredient Bible) have been previously tested for safety. Companies
can use ingredients who’s safety was established by someone else. They then point to this data as proof of safety.

Conversely, avoid ingredients that are unknown for safety – Similarly a company can avoid ingredients that haven’t been safety tested or are similar in structure to compounds that are known to have safety issues.

4. Lastly, and most sneaky, is to ask the supplier of the raw material to do the testing for you.
So the problem with these claims is that companies don’t have to disclose HOW they support them. If you’re really concerned, you need to do some digging to understand which of these 4 approaches they’re using.

EU ban on animal testing loophole

I wanted to say something about the EU ban on animal testing which people may not realize. The EU instituted a ban on animal testing for cosmetic products in 2013 so, theoretically, you are not allowed to conduct any animal testing on a cosmetic product. However, companies are allowed to use supporting data that has already been generated to prove safety. And this means that if there was data about an ingredient used in another industry that would be acceptable. So if an ingredient is animal tested for a pharmaceutical application (not banned) that data can be used to prove the safety of it in a cosmetic. Yes, animal testing for cosmetic products is banned but there are ways for companies to get around this ban.

There is at least one organization trying to hold companies accountable to their “no animal testing” positions. The Leaping Bunny program was created by the Coalition for Consumer Information on Cosmetics’ (CCIC). It’s a list of companies that they certify as achieving their cruelty-free standard. If the Leaping Bunny folks deem them worthy of inclusion (after paying money to be certified) then they get to use the Leaping Bunny Logo on their packaging. According to the CCIC, the Leaping Bunny Program provides the best assurance that no new animal testing is used in any phase of product development by the company, its laboratories, or suppliers.

Of course, any company can put a bunny on their packaging and claim that they are “cruelty free.” It’s very difficult for consumers to know who to believe.

Where to learn more

“Safety Evaluation Ultimately Replacing Animal Testing (SEURAT)”

Towards a Cruelty-Free Future: Championing Health without Harm

Review of alternatives to animal testing (EU)

FDA and animal testing

List of animal tests

LIL buy it now button

Buy your copy of It’s OK to Have Lead in Your Lipstick to learn more about:

  • Clever lies that the beauty companies tell you.
  • The straight scoop of which beauty myths are true and which are just urban legends.
  • Which ingredients are really scary and which ones are just scaremongering by the media to incite an irrational fear of chemicals.
  • How to tell the difference between the products that are really green and the ones that are just trying to get more of your hard earned money by labeling them “natural” or “organic.

Click here for all the The Beauty Brains podcasts.