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Worker and environmental safety assessment of cosmetic ingredients

NC3Rs response to Home Office’s statement on animal testing for cosmetic ingredients

I was pleased to meet with the Home Secretary today along with colleagues from Unilever and the Cosmetic, Toiletry and Perfumery Association. We were able to provide a united voice on the importance of applying robust scientific approaches, that avoid the use of animals, for protecting the safety of workers involved in the manufacture of cosmetics ingredients. These cutting-edge approaches have been used over the last decade to protect the safety of consumers and it is a regulatory contradiction that they are not used for the purposes of worker safety not least because exposure is tightly controlled in UK factories.

This is not a dilution of worker safety nor simply concerns for animal welfare, but a call to apply the latest scientific advances to improve safety assessments. We know that this can be done for cosmetic ingredients for consumers and we need a joined-up and rapid approach across government and its agencies to change the testing requirements under the REACH regulation as it applies to worker safety.

Dr Vicky Robinson, Chief Executive, NC3Rs.

Written Ministerial statement

On 17 May 2023 a written Ministerial statement was published with a regulation update for animal testing for worker and environmental safety of chemicals used exclusively as cosmetic ingredients. 

Background to the NC3Rs position on cosmetic ingredient testing

The testing of cosmetics ingredients to assure worker safety, for the assessment of the effects of chemicals on human health, is conducted to meet the requirements of the UK REACH regulations. There are three scenarios where safety information is needed to assure worker safety under UK REACH:

  1. For chemicals that are used solely as cosmetics ingredients.
  2. For multipurpose chemicals that are used as cosmetics ingredients as well as other uses.
  3. For chemicals that are not used in cosmetics.

For scenario 1: for the past ten years consumers have been protected following safety assessments that do not rely on generating new animal data. The same principles should apply immediately to the safety of workers, with decisions on safety based on non-animal approaches along with extensive exposure assessments carried out by the manufacturers. The latter recognises the UK’s existing state-of-the-art health and safety approaches in modern factories that ensure that workers are protected from exposure. There needs to be rapid action from Government departments and agencies to allow scenario 1 to be put into practice.

For scenarios 2 and 3: animal tests should only take place as a last resort where the chemical is being used for non-cosmetic purposes – after all information from non-animal methods and exposure analysis is reviewed by the regulator and relevant experts in the field, and only where robust safety decisions cannot be reached without recourse to using animals. The interpretation of animal testing as “a last resort” must go further than is the case with EU REACH, where animal data is still often requested despite the existence of this precautionary principle.

Occasions where animal testing has been requested should be monitored and reported with detailed scientific justifications so that trends can be identified and used to guide further research into alternatives such that ultimately all animal testing can be phased out. To support this there will need to be a more coordinated approach across the relevant government departments and agencies and greater engagement of industry stakeholders. This needs to be complemented by training of both industry and regulatory risk assessors so that there is a better understanding of how new approaches can be deployed in practice such that the assessment of worker safety without animal data is expedited.

For the assurance of environmental safety and testing conducted under REACH, the same principle should apply with animal testing being used as a last resort. To minimise the occasions where animal testing is deemed necessary to protect the environment, a greater emphasis on providing detailed environmental exposure information is needed. The field of environmental safety assessment currently lags behind human health regarding acceptance of data from non-traditional approaches and remains an area in need of urgent investment to address this such that the latest science and technology developments are being used.

This response follows on from a previous statement made on Wednesday 10 May.