Federal Issue Brief

 S. 847, Safe Chemicals Act

AVMA Position:



 Introduced by Senator Frank Lautenberg (NJ), S. 847 would amend the Toxic Substances Control Act (TSCA) to ensure that risks from chemicals are adequately understood and managed. Provisions of Section 30 include:

  • Instructs the Administrator of the EPA to take action to minimize the use of animals in testing chemical substances or mixtures. 
  • Encourages funding research and validation studies to reduce, refine, and replace the use of animal tests. 
  • Establishes an ‘Interagency Science Advisory Board on Alternative Testing Methods’ to be composed of members from identified government entities and non-governmental organizations. 
  • Directs the EPA to develop a strategic plan to promote the development and implementation of alternative test methods and testing strategies to reduce the use of animals.
  • Gives Administrator power to adapt or waive certain animal testing requirements.


The Interagency Coordinating Committee on the Validation of Alternative Methods (ICCVAM) was established as a permanent interagency committee in 2000, and is charged with establishing, “wherever feasible, guidelines, recommendations, and regulations that promote the regulatory acceptance of new or revised scientifically valid toxicological tests that protect human and animal health and the environment while reducing, refining, or replacing animal tests and ensuring human safety and product effectiveness.” (ICCVAM Authorization Act of 2000)


  • The AVMA recognizes that the TSCA is a valuable chemical safety law that needs to be strengthened.
  • The AVMA policy on the Use of Animals in Research, Testing, and Education endorses the principles embodied in the “Three R’s” (refinement, reduction, and replacement) and thereby is consistent with the intent of the proposed legislation.  
  • The EPA is already a member of the ICCVAM. Creating another ‘Interagency Science Advisory Board on Alternative Testing Methods’ appears redundant and unnecessary. 
  • Giving the Administrator of the EPA the power to waive certain animal testing requirements without additional information as to how requests for waivers would be evaluated raises safety concerns.

Current Status:

Senate Committee on Environment and Public Works. Legislative hearing held 11/17/2011.

AVMA Contact:

Dr. Whitney Miller, Assistant Director, Governmental Relations Division, 202-289-3211.