Introduction

[Troy Seidle <TroyS@PETA-online.org>]

My name is Troy Seidle and I represent People for the Ethical 
Treatment of Animals (PETA), a non-profit organization 
representing over 700,000 Americans dedicated to the protection 
of animals and the environment we all share. Our interest in the 
programs and activities of the EPA stems from the fact that the 
EPA requires more chemical toxicity testing on animals than any 
other federal agencyÐÐin fact, the EPA is responsible for 
developing what have become the largest animal-testing programs 
of all time. This clearly makes the animal protection community 
a key stakeholder in EPA decision-making related to the 
evaluation and regulation of chemicals, pesticides, products of 
biotechnology, etc.

Unfortunately, PETA and other animal protection organizations 
have had a dismal experience with public participation at the 
EPA. This experience began in late 1998 when PETA belatedly 
learned of the EPA's high production volume (HPV) 
chemical-testing program. No Federal Register notice had ever 
been published to inform interested stakeholders about the HPV 
program and no solicitation of public input had occurred. In 
clear disregard of the 1981 policy on public participation, the 
HPV program had been developed quietly, behind closed doors, 
between the EPA and only two other organizationsÐÐthe Chemical 
Manufacturers Association and the Environmental Defense Fund. 
When PETA and other animal organizations attempted to meet and 
discuss these issues with EPA officials, we were met with 
complete disinterest and, in some cases, outright hostility.  

We continue to encounter similar situations with other 
EPA-mandated chemical tests and programs even to this date.

In summary, we fully support the goals outlined in the current 
draft policy, but contend that without adequate support, 
commitment and enforcement from the highest levels of the EPA, 
implementation will remain a serious problem. Only when top 
management officials commit themselves to a policy of openness 
and forthrightness and require the same of their staff will the 
American public actually benefit from this important document.