Tell the FDA to do more to end animal tests

In November 2018, the Food and Drug Administration (FDA) released a statement claiming efforts to reduce animal testing through a study aimed at eliminating the use of dogs in certain animal drug trials.

The study outlines a protocol for testing an antiparasitic drug in dogs that will examine their blood level while exposed to the drug and then adopt the dogs out to suitable homes when the study is completed. Historically, these tests required infecting animals with parasites in the GI tract, then euthanizing them and studying their tissues in order to evaluate the efficacy of the antiparasitic drugs.

While this is a step in the right direction, this move is simply not enough. The study will apply only to eliminating the use of dogs, and potentially other animals, and only in certain types of similar, future studies involving veterinary drugs.

The proposed FDA study is now open for public comment through January 15, 2019. CAARE is encouraging the public to submit comments urging the FDA to take a more decisive role in reducing and replacing experimentation on all animals. A sample comment is supplied below.

The single most effective action the FDA can take immediately to reduce the massive use of animals is to eliminate the requirement for using animals in safety testing, thereby allowing researchers to submit safety data that uses non-animal methods.


Human-relevant testing platforms exist, such as organs-on-chips and informatics, that can predict human side effects better than animal experiments.

But current FDA regulations require animal testing, even if human-relevant tests are available. This regulation harms animals — and people as well by impairing the safety of clinical trials and drugs released to the public. Now is the time to end it.


The FDA announcement comes at a time when testing on dogs has received a great deal of attention over the past few years. While 2017 U.S. statistics have shown a decrease in the number of dogs used in experiments, the numbers of many other species have increased.

Appallingly, the number of primates has reached an all-time high at just under 76,000.


Clearly there is an urgent need for more comprehensive steps towards reducing and replacing all animal experiments with existing non-animal methods.

The FDA can and should implement broader policies that can have a much greater impact on ending the use of animals is drug testing.

Please take a minute and send your comment to the FDA in support of more comprehensive steps to reduce animal testing.

You can simply copy and paste the text below or personalize and submit your own comments.

Sample comment:

I appreciate the FDA’s recent announcement of the proposed minimally invasive study in dogs that would allow the dogs to be adopted after completion. While this is a positive step towards reducing animals in veterinary drug testing, I believe a much broader effort by the FDA is essential. Current FDA regulations require animal testing, even if human-relevant test methods are available. The single most effective action the FDA can take immediately to reduce the massive numbers of animals used in painful and scientifically flawed tests is eliminating that requirement, as this regulation harms people as well, by impairing the safety of clinical trials and drugs released to the public. Please give serious consideration to ending this requirement and allowing researchers to use human-centric methods that better predict human side effects.

Thank you for taking action to help end the use of animals in painful and deadly experiments.

Citizens for Alternatives to Animal Research (CAARE), is a 501(c)(3) non-profit organization, established to highlight and promote research without animals.


Please donate to support CAARE’s mission to end animal suffering by disseminating information about the power and progress of research without animals.