In February, the US Food and Drug Administration (FDA) issued a sunscreen testing proposal requesting additional data on 12 ingredients commonly used in sunscreen and much of that data would be generated by new animal tests. Shockingly most of the ingredients for which new animal testing has been requested have already been tested on animals and have long histories of safe use. Moreover, new animal tests won’t make sunscreens safer because animals tests poorly predict human response.

For example, the carcinogenicity test, which involves the use of about 400 animals per test, is notoriously unreliable with an estimated prediction of human cancers of only 42%. Earlier this year at a colloquium cosponsored by the FDA there was strong consensus that these tests are inaccurate and should be phased out with urgency. Yet this is one of the tests the FDA has requested for the sunscreen ingredients.

Moreover, most of the ingredients for which new animal tests have been requested have already been tested and determined safe in Europe and that data is available to the FDA. Ordering more tests would be redundant, wasteful and pointless. There is simply no justification to subject thousands more animals to suffering for sunscreens.

We have urged the FDA to instead review the existing data and revaluate the scientific need for additional studies which will cause significant suffering to many animals, are highly time-consuming and expensive and are of questionable value in terms of human relevance.

You can help.

If you live in the US, you have until June 27th to ask the FDA to rethink its request for additional animal tests for sunscreens. Comment here: Click on the “Comment Now” button on the top right side of the FDA Sunscreen Rule comment page: https://www.regulations.gov/document?D=FDA-1978-N-0018-1648

You can simply write: “I am opposed to new animal tests for sunscreens. Existing safety data is available and should be utilized. New animal tests will be redundant, wasteful, will cause animal suffering and will not guarantee human safety.”