Anonymous public comment

It has recently come to my attention that the EPA and the ATSDR have proposed a chemical testing rule that, at this point, will require testing on animals. Up to 18,000 animals could be used in these experiements, despite the well documented toxicity of the chemicals being tested. I instead would urge the EPA to reevaluate the data needs identified by ATSDR, some of which are nonsensical. For example, testing in which animals are force-fed chloroethane through a tube inserted into their stomachs is required, even though chloroethane is a gas at room temperature. ATSDR has admitted that accidental oral exposure to chloroethane in doses large enough to result in death is highly unlikely, and extensive inhalation data already exist. I also encourage the EPA to use physiologically based pharmacokinetic (PBPK) models to fill ATSDR's data needs by extrapolating from existing data. These sophisticated mathematical models already exist for chloroethane and methylene chloride. This approach would save money and many animal lives! Finally, I strongly reccomend that the EPA accept test protocols that reduce the number of animals used by eliminating duplication and combining multiple tests. Using internationally accepted combination tests can drastically reduce the number of animals killed. Please do not allow the torture ad deaths of these animals. There are option.