Developing alternative approaches to animal testing
We are at the forefront of research into novel non-animal approaches to replace animal testing for assessing consumer safety.
The vast majority of our products reach consumers without testing any of their ingredients on animals. Our commitment to eliminating animal testing is underpinned by our work since the 1980s in developing and using alternatives to animal tests, including new approaches to risk assessment, biological and computer-based modelling and 'non-animal' methods for data generation.
Since 2004 we have made an additional €3 million a year investment in an innovative research programme on novel non-animal approaches to assure consumer safety. Unilever's conceptual framework for safety assurance is risk-based rather than hazard-based. This means that before experiments to test a new product even begin, all the available data (including levels of exposure and types of ingredients) are analysed to judge the level of risk that can be attributed to each individual ingredient used. At this stage of the process, such procedures can overcome the need for animal testing.
We are making good progress in developing a non-animal approach for assessing skin allergy risk. To encourage acceptance of this new approach we continue to present and publish our results externally, and are working with international research and policy groups to share our experience. For example, in 2011 the risk-based approaches we are developing for assessing consumer safety were discussed with leading scientists, policy makers, regulators and animal welfare organisations at the 8th World Congress on Alternatives and Animal Use in the Life Sciences (Canada), and at key meetings in the EU, US and China.
Unilever is committed to the elimination of animal testing. We are equally committed to consumer health and safety, and to the safety of our workforce and the environment. We do not test finished products on animals unless demanded by the regulatory authorities in the few countries where this is the law. In such cases, we try to convince the local authorities to change the law. Where some testing of ingredients is required by law or currently unavoidable, we aim to minimise the number of animals used.
In pursuit of these goals, Unilever on the one hand applies strict internal control procedures to ensure that animal testing is only carried out when no alternatives are available, and on the other hand, invests in developing and applying alternative approaches to replace animal testing in safety assessments for consumer products.
By adopting this dual approach, we advance the elimination of animal testing and reduce the number of tests to the absolute minimum. We provide transparency both in the use of animals and in the progress made in developing alternative approaches.
How we act
At Unilever, using non-animal approaches is the norm and animal testing is the exception. Before any animal testing is carried out, Unilever's internal control procedures require senior management to certify that there is no other way of proceeding. Unilever does not undertake animal testing, or commission others to do testing on its behalf, unless it is necessary to meet its health, safety and environmental obligations or it is demanded by government regulators or other official bodies.
When there is a need to generate new safety and efficacy data in support of product development, non-animal methods and studies with human volunteers are used to the maximum extent. Unilever develops products which can contribute positively to the health and well-being of consumers. When developing these products, for ethical reasons it is not always possible to carry out tests directly on humans. Therefore, novel ingredients may have to be tested on animals first. Animal studies may need to be performed to establish the mechanism of action underpinning the health benefits of these ingredients as well as to assess their safety.
Unilever's research investment
Scientists at our Safety and Environmental Assurance Centre (SEAC) have played a leading role, in partnership with academic researchers, other companies, industry groups and validation bodies, eg the European Centre for the Validation of Alternative Methods (ECVAM), in the development, validation and subsequent regulatory acceptance of several non-animal methods for use in safety assessment. These include methods for assessing skin penetration, photo-toxicity, skin corrosion and skin irritation. Our research is currently focused on finding alternatives for skin allergy and skin cancer which are associated with the 2013 deadline on cosmetic ingredient testing of the EU Cosmetics Regulation.
We have published more than 250 scientific articles on the development and application of alternative approaches to consumer safety risk assessment and regularly present our ongoing research at scientific conferences. During 2011, SEAC's work on proposed risk assessment approaches for assuring consumer safety without animal testing resulted in seven scientific publications. In August 2011, Dr Julia Fentem, the Head of SEAC, was awarded the prestigious Russell and Birch Award from the Humane Society of the United States for her leadership and outstanding contribution to the advancement of alternative methods.
An example of our scientific partnerships with external organisations in this area is the work that many Unilever staff undertake with Colipa (the European Cosmetics Association) on the cosmetics industry's collaborative approach to replace animal testing. This includes scientific involvement in all Colipa project teams developing non-animal methods for assuring safety (eye irritation, skin sensitisation, genotoxicity and systemic toxicity). As part of this work, in 2009 Colipa initiated research jointly with the European Commission (a total of €50 million in research funding) to help develop the tools that will ultimately make non-animal safety assessments for systemic toxicity possible.
In 2010 SEAC formed a strategic partnership to work with the Hamner Institute in the US to bring together Unilever research in the area of non-animal approaches for risk assessment for cancer, with the implementation of a new pathways-based approach to safety assessment that was suggested in the US National Research Council's report 'Toxicity Testing in the Twenty-First Century: A Vision and a Strategy'. To progress this new approach Unilever is an active member of the Human Toxicology Project Consortium and involved in relevant EU Commission funded research and co-ordination projects.