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.
http://ec.europa.eu/health/ph_risk/committees/04_sccp/docs/sccp_o_165.pdf
Hi Colin, I feel very strongly about the animal testing for cosmetics issue and I do think this is very different from “eating an animal in a burger” as you say. I choose to buy organic, free-range, high welfare meat from trusted sources and therefore hope and trust that the animals I am eating have led a life which allows them to follow normal behaviour, have been well cared for and have been killed humanely. This I feel is very different to the utter pain and cruelty animals suffer in laboratories by having shampoo dripped in their eyes and all the other horrors inflicted on them so that humans can add to their vast beauty product arsenal. As you say, a matter of opinion.
Ha! I love the way you fearlessly court the Jane B’s of the interworld, Colin!
Another legal aspect is that the REACh regulation actually requires some animal testing to be carried out for toxicological purposes – and REACh registration is the number one reason why animal tests are carried out on new substances like this.
There are scientifically validated non-animal alternatives for most of the required tests, but there are still several that don’t have alternatives (including specific organ effects, and toxicokinetics, i.e. what happens to the substance once it’s ingested.).
The upshot is that in Europe at least, it’s legally impossible to use a material which hasn’t been tested on animals at all – but there are ways around this.
When I worked for a contract manufacturer that supplied to the major supermarkets, “no animal testing” meant that none of the materials had been tested on animals after a certain cutoff date: the Co-Op’s cutoff date (1985) was the earliest, and the cutoff dates for the others varied between 1991 and 2006. This is the most common approach.
Yes that is right Bill. The interpretation of the cosmetic regulations I follow is that the ban is on testing for the purposes of cosmetic development, so REACH requirements don’t count. The use of cut off dates is a reasonable approach to my mind. It means you can use existing data without encouraging further testing. But I can appreciate that some people wouldn’t find it acceptable to benefit from testing whenever it was done. The one that gets me is when firms have rolling cut off dates – that really does sound like a fudge.