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Introduction

  • Archived: Tue, 10 Jul 2001 11:50:00 -0400 (EDT)
  • Date: Tue, 10 Jul 2001 11:40:23 -0400 (EDT)
  • From: Troy Seidle <TroyS@PETA-online.org>
  • Subject: Introduction
  • X-topic: Introductions/Goals

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.


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