Katherine Lloyd-Hughes - Comments

Document ID: PHMSA-2009-0126-0038
Document Type: Public Submission
Agency: Pipeline And Hazardous Materials Safety Administration
Received Date: October 13 2010, at 12:00 AM Eastern Daylight Time
Date Posted: October 14 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: August 24 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: October 25 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b6dfbf
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Even as far abroad as the UK it is well-known that in order to test corrosive chemicals before they are transported the DOT still allows rabbits' backs to be shaved and corrosive chemicals applied to their raw skin and left there for up to two weeks. These chemicals often burn the skin, leading to tissue damage. Rabbits are given no pain relief during this excruciating test, and after the test is finished, the animals are killed. That this continues in the 21st century is disgraceful and diminishes the USA in the eyes of the international community. We are aware that almost 18 years ago, the DOT agreed to let companies start using the non-animal test Corrositex®. Although Corrositex® provides accurate information, the agency is still telling companies to use the rabbit test! We in the UK & around the world would strongly argue that in order to maintain any international credibility DOT should: 1) Adopt internationally approved non-animal skin corrosion tests 2) Update its website immediately and simplify procedures for companies to use the non-animal corrosion tests

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