Good afternoon. Thank you for the opportunity to appear before the committee today to discuss this incredibly important bill.
By amending Canada's toxics law, Canada has an exciting opportunity to phase out the unnecessary use of animals in painful toxicity testing and to position Canada as a global leader when it comes to developing non-animal testing methods.
Testing to determine whether a chemical poses health or environmental risks is one of the most harmful types of animal use in Canadian science. Many experiments fall under the highest category of invasiveness, according to the Canadian Council on Animal Care, causing severe pain at near or above the pain tolerance threshold of unanesthetized conscious animals.
In 2019 alone, more than 90,000 animals were used in toxicity tests falling into this most severe category of harm.
The good news is that in Canada and around the world, scientists are rapidly developing non-animal test methods, and many are better than animal studies at predicting human responses to environmental exposures. They are also more rapid and cost-effective.
Ending the unnecessary use of animals in scientific research is also an objective for which there is strong public support across political lines.
For all of these reasons, when the EU and the U.S. modernized their toxics laws, they included strong requirements to avoid and ultimately phase out toxicity testing on animals.
Here in Canada, the Liberal Party made a commitment during the last federal election to eliminate toxicity testing on animals by 2035, and through Bill S-5, this committee can ensure Canada meets this deadline.
Many of the amendments passed by the Senate will help put Canada on track, but further amendments are needed. I have set out details in my brief, but at a high level, Animal Justice would like to see strengthened language to ensure testing on animals is done only as a last resort; the ability to make regulations to protect certain invertebrates such as octopuses in the future, as the need arises; and a greater focus on replacing and reducing the use of animals in toxicity testing, and not merely refining the ways in which they are being used.
Briefly, with respect to part 6 of the act, it's widely expected that an increasing number of genetically modified animals will be developed for varying uses in the coming years. Part 6 treats genetically modified animals in the same way as it treats chemical substances and ignores entirely the welfare of the animals themselves; yet we know that deliberate attempts to influence the genetic makeup of animals can have significant animal welfare implications, including harmful procedures and unanticipated effects such as developmental abnormalities, skeletal abnormalities or enhanced growth of tumours.
I appreciate that the government has committed to conducting a comprehensive review of part 6 at a future date, but in the meantime we propose at the very least enabling the creation of regulations to protect the welfare of genetically modified animals.
Thank you very much.