I don’t think that animal testing works the way some people commentating on the internet appear to think it works. This was brought home to me when I was asked a question about a new preservative material called silver citrate. It is one that might appeal to the lovers of natural because both silver and citrate sound safe and natural. We all know what silver is and so assume it is safe. Citric acid sounds like it comes from oranges so that sounds pretty safe too. But the person who was interested in it had read the material safety data sheet that came with it, and concluded that it had been tested on animals. For them this was a no no.
I am not sure that they are right to draw that conclusion though.
Toxicological data appearing on a material safety data sheet aren’t necessarily, or even very often, generated by the company producing the data sheet. The figures and the studies quoted on this sheet aren’t referenced – data on MSDS sheets never are. They appear to have been based on work reported in 1999 which was used to register this product for different applications. It wasn’t commercialised as a cosmetic preservative until much later, and the approval in 2009 was accompanied by an SCCS opinion explaining its reasoning. The animal data was referred to in this opinion but it doesn’t look like the animal work was done to justify its use in cosmetics. This raises an interesting philosophical question for those who are interested in this issue. If the idea of using this material in cosmetics was purely an afterthought then this material has not been tested on animals for the purpose of cosmetic development.
This is what the timescale suggests. But it doesn’t preclude the possibility that the whole thing was actually a cunning plan. The other data might have been generated with a view to its later value in getting the product onto the cosmetic preservative market.
This also comes up from a legal point of view as well, since the cosmetic regulations forbid testing for cosmetic purposes. The legal test seems to have been passed given that the material is well on its way to being approved. If the people assessing it had concluded that the testing was done for the purpose of getting it onto the cosmetic market then presumably they wouldn’t have approved it.
But legal decisions aren’t the same as moral ones, so it might still not be acceptable to your personal values. You might be prepared to accept that the company has acted in good faith on this one, or you might feel you can’t risk being complicit in what is clearly a potential loophole. I find the ten year gap between the testing and the cosmetic application pretty strong evidence that the cosmetic use is an afterthought – but without mindscans of the participants it is impossible to know.
Speaking personally I can’t see any difference between carrying out tests on animals for the purpose of cosmetic safety and any other use of domesticated animals. I don’t see how harming an animal to make sure my shampoo is safe is worse than eating one in a burger. But this is a matter of opinion, and the kind of opinion that is often deeply held. My personal objection to animal testing for cosmetic purposes is that it is pretty much always a waste of time and money, and so the cruelty issue doesn’t really arise.
But if you can get over the animal testing this does look like a valuable addition to the cosmetic chemist’s tool kit. There might be a few issues though. Silver salts are light sensitive as any old school photographer will tell you. You’d need to make sure that wasn’t an issue with your product. And I imagine that silver in its ionic form might well have some interactions with some cosmetic ingredients that would render it ineffective. The obvious example is EDTA, but anything charged and polymeric like say carbomer could conceivably be a problem.
So it will need to be thoroughly evaluated. But frankly we ought to be grateful for anything. Every current preservative has some kind of downside and one more choice has to be a good thing.