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Open letter to the Minister of Health, Mr Renato Balduzzi, on the transposition of the EU Directive 2010/63/EU (vivisection):

Rome, 9th January, 2012

 Dear Minister,

The EU Directive 2010/63/EU, which is now in the transposition period in our Country, has been approved in Strasbourg ignoring two important contradictory opinion :

The first
comes from a significant number of physicians and scientists, who claim the scientific invalidity of animal testing and the damage caused by the extrapolation of data from one species to another, particularly from animals to
humans.Such an erroneous method represents:

an obstacle to scientific progress that mainly involves Europe, which cannot keep up with new discoveries, essential for the safeguard of human health and pursued somewhere else with a quite different approach.For example, since 2007, the American National Research Council declared that an 'epochal turning-point' in toxicological tests was necessary to surpass the animal models and, in that direction, it started a five-year research plan, which was signed by the most important USA control agencies;

a huge waste of money.As Robert Weinberg, Biology Professor at MIT said, "every year, pharmaceutical industries waste hundreds of millions dollars using rodents as models in oncology research";

an even more serious waste of human lives.In 2007, 197,000 people died because of adverse reactions to drugs in the EU only; a misleading research method like animal testing certainly contributed to this tragedy.

The second:
comes from the common feeling of the great majority of citizens, who believe in the rights of animals as sentient beings (Treaty of Lisbon, Art. 13).
This is testified by the 120,000 signatures collected in Italy in just two months, in summer 2010, against the Directive, which has been improperly named "Law for the protection of animals used for scientific purposes".As a matter of fact, no protection is granted to animals under this law, which seems to come from the dark centuries of our history.


A law which aims at protecting both animalsand our health cannot but replace in vivo testing with the latest scientific research technologies, to the maximum advantage of:

Reliability of results

Amount of data which can be collected

Speed of response.


It is an error to implement such a law which would lead to persist in a serious scientific error and allow to:

Reuse the same animal several times, even for procedures that induce severe pain, distress and suffering (Art. 16);

Open the chest and carry out other procedures on defenceless animals without using painkillers or anaesthetics (Art. 14, Att. VIII);

Test on stray cats and dogs (Art. 11);

Keep social animals like dogs and primates in total isolation for long periods of time (Att. VIII);

Force animals to swim or to carry out other physical exercises until death (Att. VIII);

Administer electric shocks up to the point of impotence (Att. VIII);

Carry out basic research tests on non-human primates (100,000 of which are captured every year in their natural environment and sold to laboratories all over the world) at the sole discretion of researchers (Art. 5, 8, 55).

Therefore, Honourable Minister, we are requesting the following:
that the transposition process of the
EU Directive 2010/63/EU is suspended and a broad public debate is opened concerning ethical and scientific principles which must inspire a law on medical-toxicological research worthy of being in force in the XXI century,without forgetting that:

Animal testing is the only biomedical research method which has never gone through a validation process; the only method which must not comply, neither preliminarily, nor retrospectively, with protocols attesting its validity and reliability; the only method which relies on the system of 'self-certification' by those who practice it;

A true culture of scientifically based 'replacement methods' which can fully safeguard our health can only be developed if Italian citizens democratically share this process and feel responsible for it.This is not our request,but a requirement of the Aarhus Convention and the European Charter on Environment and Health, according to which citizens must be granted access to the decision-making processes regarding such issues;

The Directive cannot be transposed in secret and in silence!

Even more so in a period of global crisis, this new approach to research can place Italy at the forefront of that kind of innovation which is essential for a proper and advanced economic development based on a democratic and civilized approach.



(translated from Italian by Giuliana Mafirca- Translators against vivisection)

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