Weapons of Rat Destruction
EPA has spent many years and tens of millions of dollars attempting to develop tests that would reliably determine if certain chemicals cause endocrine disrupting effects. They have failed.

Instead of pursuing more promising approaches, the agency has doggedly insisted on complicated, sometimes ambiguous protocols often based on dosing parts removed from lab animals with large quantities of chemicals in hopes of discovering how low doses of the substances would affect living humans. The methodology is akin to lab-coated technicians trying to determine the future by reading chicken entrails.

Even though many of the planned assays have been sharply criticized by peer reviewers, EPA has decided to mandate a mass animal testing program the purpose of which is to set the stage for an additional mass animal testing program that also will not yield meaningful results.

Dr. Theo Coburn, co-author of Our Stolen Future, described EPA's Endocrine Disruption Screening Program (EDSP) as "'archaic' and too narrowly defined to flag many chemicals that disrupt human hormones...." In an interview with Inside EPA she characterized the planned tests as "unnecessary and a waste of money and lab animals." Professor Coburn argues "that one well-designed assay could replace all of the tests in both tiers."

A review of EPA documents obtained under FOIA by the Center for Regulatory Effectiveness revealed that many EPA claims regarding test validation are factually incorrect. For example, with respect to a test called H295R, EPA publicly claimed that it "was completed in June 2008. This assay is ready for use." Meanwhile, an internal EPA document dated "25/02/09" states that the "peer review for the final report will be scheduled within the next several months." EPA has stated that they expected the Estrogen Receptor Binding Test to be validated by March 2009 even though, an internal document lists the expected peer review date as "Spring 2010?" EPA refuses to release many thousands more EDSP documents.

OIRA Administrator-designate Cass Sunstein supports animal testing if the "experiments would ... produce significant medical advances...." He does, however, "suggest that suffering and harm to animals should count, and that any measures that impose suffering and harm should be convincingly justified." The EDSP program cannot be scientifically or morally justified and should not be approved by OMB.