PeTA drops 10-year campaign against Gillette

Gillette reports no animal testing on cosmetic products 1994-1996

By Norma Bennett Woolf

After 10 years of demonstrations, fundraising, a letter-writing campaign by children, and a complaint to the Federal Trade Commission, People for the Ethical Treatment of Animals ended its feud with The Gillette Company in December.

PeTA enlisted the help of teachers and children in its effort, offering "Gillette kills" buttons and kits to aid in letter-writing. Even after the company had ceased testing cosmetic products and ingredients on animals, PeTA kept up the assault. The latest demonstration took place at the company's Boston, Massachusetts, headquarters in November. Then, abruptly, in mid-December, the animal rights organization cited a "moratorium" on testing at Gillette and backed off. The company denied that it had declared a moratorium on testing but instead was working towards replacing animal tests with alternatives where possible.

Earlier in 1996, PeTA filed a complaint with the FCC, alleging that Gillette falsely claimed that animal tests are required for certain of its products. Gillette denied the accusations.

Various federal laws covering product testing require animal tests for some ingredients and products and do not require them for others. For example, companies must substantiate the safety of cosmetic products under a rule that does not explicitly require animal tests but does burden the company with the responsibility to make sure that the products are not hazardous to humans. At present, the only tests available to do the job are animal-based tests according to the company and to the US Food and Drug Administration.

Animal testing is required for drug products covered by the FDA. These products include antiperspirants, fluoride toothpastes, hormone creams, sunscreens, and anti-dandruff shampoos.

The Gillette Company has made considerable progress in reducing the use of animals in testing of over-the-counter drugs, has used no animals to test cosmetic ingredients or products for the past two years, and has been active in seeking alternatives to animal tests. The company reports a 90 percent reduction in the use of animals in product safety testing since 1986. That year, 3780 animals were used; in 1991, numbers dropped to 787 and reached 388 in 1995.

"Gillette does fund research to alternatives to animals testing," said company spokesman Danielle Frizzi. "In 1995, this amount was $875,000. In addition, for each dollar Gillette spent during 1995 related to safety testing of personal care and consumer products, approximately 56 cents was for the development of in vitro testing methods, approximately 43 cents was for human clinical testing, and less than one cent of each dollar was spent on animal testing. Since 1991, animal testing has never exceeded six percent of the total safety expenditures for the company."

PeTA persists

In spite of the company's record in reducing animal testing, its efforts in funding development of alternatives, and the specific requirements to test imposed by the federal government, PeTA has continued its high-profile campaign against Gillette.

Frizzi said that the animal rights group has waged "a 10-year campaign of misleading and inaccurate information" against the company. She said that PeTA uses the company's 1987 figures as a base to show that animal use has increased since that time. However, the numbers that year were artificially low as the company was restructuring and did little testing, she said. Thus when PeTA says that numbers have doubled since that time, they are technically correct but they neglect to mention that their foundation numbers are an aberration in the established pattern.

PeTA also uses figures that show the total number of animals used by the company and implies that these animals are all used in product safety testing, Frizzi said. To present a clearer picture of the company's success in reducing the number of animals used in product safety testing, Gillette has begun to separate the figures in its reports.

The Wall Street Journal featured the anti-Gillette effort in a story in September, 1995, that emphasized PeTA's use of school children to pressure the company.

Journal reporter Barbara Carton spoke with children, teachers, and principals and with Gillette officials. She quoted letters from students to Gillette that accused company officials of cruelty and murder and threatened them with dire consequences if the testing did not cease. She also quoted one teacher as saying that she had no intention of presenting Gillette's side of the issue and another who gave a student an A+ for telling Gillette Chairman Alfred Zeien that he is a "cruel, unthinkable vivisector."

Teachers frequently look for projects to relate lessons to life outside the classroom, and PeTA offers them the opportunity to work letters and activism into English and social studies curricula. According to the Journal story, PeTA entices teachers and kids with buttons, slogans ("Gillette Kills"), t-shirts, "maudlin pictures of sad-eyed bunnies," and videotapes of disfigured laboratory animals.

Gillette responds to the letters with information presenting their side of the issue and company officials sometimes call children and teachers to discuss their complaints, but the emotional appeal of PeTA's onslaught is hard to beat with recitations of federal laws and defense of the need for safe products.

FDA regulations

Under FDA definitions, cosmetic products are those intended to be applied to the human body for cleansing, beautifying, or altering appearance without affecting the body's structure or functions. These products include skin cream, lotion, perfume, lipstick, fingernail polish, eye and facial makeup, permanent waves, hair color, non-fluoride toothpaste, and deodorant. Although FDA does not require product safety testing of cosmetics, the agency does urge manufacturers to conduct whatever tests are necessary to assure that the products are indeed safe. Cosmetics that have not been tested must carry a warning statement on the front of packages or labels that reads: "Warning - the safety of this product has not been determined."

FDA is working to develop alternatives to animal testing to assure the safety of cosmetic products, but until new methods are proven to be reliable, the agency considers animal testing to be acceptable.

FDA is charged with the responsibility of protecting consumer health through programs that ensure product safety and effectiveness. Part of that responsibility is to regulate cosmetics after they are marketed and to require tests on all products containing drugs before they are marketed. According to an FDA position paper: "Animal testing by manufacturers seeking to market new products is often necessary to establish product safety. FDA supports and adheres to the provisions of applicable laws, regulations, and policies governing animal testing, including the Animal Welfare Act and the Public Health Service Policy on Humane Care and Use of Laboratory Animals. Moreover, in all cases where animal testing is used, FDA advocates that research and testing derive the maximum amount of scientific information from the minimum number of animals and employ the most humane methods available within the limits of scientific capability."

The animal tests that are acceptable include the Draize eye and skin irritancy tests that have been railed against by activists for many years. FDA considers these tests "among the most reliable methods currently available" for checking the toxicity of substances that come in contact with these body parts. Gillette uses what it calls a modified Draize test to confirm the mildness of test substances. The test uses no more than three rabbits in each study and requires that the animals' eyes be treated with a topical anesthetic before the substance is applied. For skin tests, no more than four animals are used per study.

The FDA does not require an LD50 (lethal dose for 50 percent of test animals) test to establish levels of toxicity in any product.

Gillette tests

Products containing new or reformulated ingredients that fall under the FDA definition of over-the-counter drugs must be retested according to the law. Gillette uses the following tests on these products:

• Acute inhalation test that expose rodents to an aerosol test substance to examine effects on lungs and other major organs.
• Acute toxicity tests use a single dose of the test substance in amounts no more than five grams of substance per kilogram of body weight of rodents
• Anticaries tests that apply a substance to the teeth of rodents to determine if it can prevent decay
• Mucosal tests that apply a test substance to the inside of rodent cheeks to confirm mildness
• Pharmacological tests that use rodents to determine absorption, distribution, biotransformation and excretion of drug compounds, characterization of drug effects and factors modifying those effects.
• Sensitization tests on rodents to determine that substances applied to the skin do not cause allergic responses
• Modified Draize tests to test substances on the skin and in the eyes of rabbits to confirm mildness

Cruelty free products

PeTA and other animal rights groups tout the success of campaigns to force other cosmetic companies to stop animal testing and raise the flag of "cruelty-free" cosmetics to encourage other companies to follow suit. Avon and L'Oreal have fallen victim to the campaign even though there is no definition of just what constitutes a cruelty free product.

According to the FDA, some companies apply the "not tested on animals" claim only to their finished product, not to the ingredients. Others may base the claim on the use of materials that were previously tested on animals or they may rely on the tests of others to substantiate the safety of the products. Some companies may simply shift the tests to an independent laboratory so they can satisfy both the radicals and the law that requires animal tests for some products.

The Body Shop, an early player in the "cruelty free" product business, until recently used ingredients tested on animals as long as the tests were done more than five years earlier. Now the company will no use new ingredients that have been tested on animals.

The National Consumer's League has asked the government to regulate claims of "cruelty-free" product manufacture. The Massachusetts Society for the Prevention of Cruelty to Animals underscored the NCL position in a recent bulletin: "The problem is that 'cruelty free' is not clearly defined by law, so it can mean just about anything a manufacturer wants it to mean."

Back to Gillette

In its 1994 report on research with laboratory animals, Gillette said: "The company takes seriously its moral and legal responsibility to insure that all Gillette products are safe for employees to make and for consumers to use. The company also recognizes its obligation to its stockholders to continue the development and marketing of safe and effective new products."

Gillette no longer does animal testing in-house. The facilities it uses not only comply with federal regulations for humane animal care, but are accredited by the American Association for Accreditation of Laboratory Animal Care, a professional organization that encourages standards of excellence beyond those required by law.

The animal testing that is done uses fewer animals now than ever, and the company is funding research into alternatives that will reduce the use of animals while assuring the safety of the products.

Gillette succumbs to pressure and teams with HSUS to find animal alternatives

"Kind companies say they have better ways of keeping their shampoo and makeup safe. Some use only safe plants to make their shampoo and makeup. Using only safe plants makes the shampoo and makeup safe. There is no need to test the shampoo and makeup on animals."

These words were printed on the front page of Kind News Jr., an education publication of the Humane Society of the US, in November 1989. The article continued: "That's good news for animals like rabbits. Some of the tests other companies use can hurt their eyes or skin. Hurray for kind companies!"

HSUS opposes the use of product testing involving animals, states that such tests are not necessary, and implies that the companies that use animal tests are cruel. Yet, although The Gillette Company fights the PeTA attacks on its product testing program and allocates hundreds of thousands of dollars to development of non-animal tests each year on its own, it recently joined HSUS to seek alternatives to animal testing.

In a program administered by the company and the animal rights organization, two grants of $50,000 each will fund research for alternatives to the skin and eye tests now required by the US Food and Drug Administration for certain products. Researchers Dennis J. DeLuca PhD and Craig A. Elmets MD in the dermatology department at Case Western Reserve University School of Medicine will investigate dermatitis to develop an in vitro test for skin irritancy. James D. Zieske PhD at the Schepens Eye Research Institute, an affiliate of Harvard medical School, will try to develop a model for eye irritancy tests. Neither study will use animals or animal cells.

HSUS is not as visible as PeTA in the battle against the use of animals in product testing, but its campaigns against hunting, dog and cat breeding, trapping, fur, livestock farming, rodeos, circuses, animal acts, and sustainable use of animals are well-known and its catalog and education publications carry items about the cruelty of product testing and, by intimation, those who do the testing.