I am commenting to voice my objection to the requirement and reliance on animal research that continue to be present in research procedures required by the EPA.
There is sufficient scientific and empirical data that highlight the dangers and inadequacy of animal research. Countless medical breakthroughs have been later regulated by the FDA for the adverse affects on humans not found in animal testing; medical breakthroughs have been hindered by reliance on animal testing (penicillin comes to mind). To further rely on animal research would undermine the goals of the EPA and the demands of the plaintiff's which required the EPA's proposed amendments: reliable research and ethics.
As previously stated, animal research is not a completely reliable method. By requiring resources to go to such an inefficient model, the EPA is removing the incentive to progress into non-animal models and hampering effective research.
Further, in regards to ethics, by allowing improper research methods to be the preliminary precaution against unsafe test is not an ethical decision. It still allows for humans to be harmed by the negligence of the testing. Additionally, the moral concerns of the animal testing should weigh heavily on the conscience of individuals. To have the millions of animals, such as dogs, rats, and cats suffer needlessly, only to be euthanized, is not something a civilized, scientifically advanced society should require.
Comment submitted by Chris (no surname provided)
This is comment on Proposed Rule
Protections for Subjects in Human Research Involving Pesticides
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