I am very disturbed to learn that the Center for Disease Control (CDC) is planning to use animals to study the effects of vitamin E acetate and potentially other toxic compounds to address the health crisis arising from e-cigarette or vaping associated lung injury (EVALI).

 Copious studies spanning decades continue to demonstrate the failure of animal tests to accurately predict human responses. In particular, key differences in the anatomy and physiology of the respiratory tract of humans and animals significantly impact research outcomes of inhalation tests.

Animal testing is so problematic that on January 30, 2018 the U.S. National Toxicology Program released a “Stategic Roadmap” advising regulatory agencies to “provide more human relevant toxicology data while reducing the use of animals.” 

The CDC’s decision to use animals not only flies in the face of scientific recommendations, it is also completely unnecessary.  A broad range of available alternatives exists to replace flawed inhalation studies on animals, including in vitro assays, in silico approaches, computational chemistry, and a range of sophisticated tissue models that include 3D organoids and organs-on-chips.

A growing number of biotech companies offer customizable models that have proven to be highly human-predictive in inhalation testing. VITROCELL® has developed cigarette-smoking machines and robots, including an adaptor for e-cigarettes, that can be used to study the impact of gases, environmental atmospheres, nanoparticles and complex mixtures on the lungs.  MucilAir™ and EpiAirway™ are advanced tissue models, both of which have been validated to model the human airway and assess potential toxicity.

These technologies stand in stark contrast to the shocking brutality of inhalation toxicology experiments done to animals.

Given the severe limitations and cruelty of animal tests, the availability of new technologies that perform better at less cost, and the guidance of the Strategic Roadmap to utilize more relevant human test methods, it is unjustifiable – indeed unconscionable – to allow animals to die in CDC research to explore the threats of EVALI.

I respectfully request that the CDC utilize only non-animal methods to study vaping related lung disease.