The New Zealand Government recently asked for feedback on a range of proposals related to moving New Zealand from its current classification system for hazardous substances to Revision 7 of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
Changes like this affect animals used in research, testing and teaching and it's our job to be their voice and make sure any new regulatory changes don't negatively impact them. In short, we play an important role — defending animals used in science!
We teamed up with the New Zealand Animal Law Association to co-write a submission on this change. This way we could combine our knowledge and energy to do the best job possible for animals.
Hazardous substances in NZ:
Hazardous substances are managed under multiple pieces of legislation with one of the main ones being the Hazardous Substances and New Organisms (HSNO) Act 1996. The purpose of this Act is to protect people and the environment from the harmful effects of hazardous substances.
The GHS is an internationally agreed system developed by the United Nations to classify chemicals and communicate their hazards through labels and safety data sheets. The GHS references multiple different animal tests but classification and labelling schemes don’t have the power to require testing; they’re all about how test results are used to warn consumers about toxic hazards.
The proposed change would be achieved by the issuing of a new EPA Classification Notice and revoking the Minimum Degrees of Hazard Notice (the existing classification framework in the HSNO). This existing framework not only references animal tests but it also requires data from some animal tests.
Read more about the proposed changes here.
Our overall position:
- We support the proposed changes on the basis that any current requirements for animal tests will be removed. While animal tests will be mentioned, they will not be required.
- We understand and agree with the desire to keep up with international standards, but further consider that New Zealand should strive to be at the forefront of scientific and ethical advances.
- On the basis of our scientific and ethical concerns, we submit that industry should be required, or at least encouraged, to use only human-relevant, non-animal based and test methods when determining whether a substance is hazardous to humans.
- Therefore, we recommend that any reference to animal tests in the classification system for hazardous substances be excluded. Alternatively, the classification system could include explicit recognition that animal-based tests should not be used due to their low predictive value, and the poor ethical outcomes of the harm caused to animals in the course of testing.
- We encourage the EPA to review the validity of animal-based methods for measuring the potential of hazardous substances and to promote ethical and human-relevant methods by publishing a clear position statement.
- In summary, we support the proposed changes and encourage any further regulatory changes that will result in the replacement of animal-based test methods.
You can read our full submission here.
A big thank you to Oska Rego from the New Zealand Animal Law Association for co-writing this submission with us!