A: Chemicals are among the most thoroughly evaluated and regulated materials in commerce. Chemicals are developed, manufactured, distributed and used under a strict and comprehensive set of government rules. Dow takes very seriously its responsibility to protect people and the environment throughout the life cycle of our products, from manufacturing to disposal/recycle. Commitment to this responsibility is evident in our 2015 Sustainability Goals. That commitment includes conducting research, modeling and laboratory studies to fulfill both product stewardship responsibilities (as outlined in the industry principles of Responsible Care®) as well as voluntary goals and objectives that enhance product safety. The research, modeling and testing conducted by our scientists provides required information for risk assessments to ensure that our chemical products can be used safely. This information is obtained in a manner which complies with international and local regulatory requirements further establishing the reliability and credibility of industry science.
In recent years some have questioned the reliability and credibility of public health and environmental research conducted and/or funded by the chemical industry in general and Dow, specifically. Such opinions, however, fail to recognize that studies conducted and funded by Dow have long been and continue to be recognized as valid and credible by government agencies, non-governmental organizations, and the scientific community at-large. Studies conducted and funded by Dow are necessary and valuable contributions to the understanding of potential public health and environmental effects related to the manufacture and use of its products. Several procedures have been established that authorize independent review of scientific studies, in order to assure that the quality and credibility of studies conducted or funded by Dow meet the highest scientific standards. The practices and procedures by which policymakers and the public can be assured that studies performed by or funded by Dow meet scientific high standards include:
- All studies required by governments are conducted in accordance with Good Laboratory Practice (GLP) regulations which require full availability of the recorded, quality-assured data files1 and which allow for unannounced audits by government authorities, such as the FDA or EPA. Dow also follows GLP requirements voluntarily for many other studies that it conducts.
- An internal Quality Assurance Group reports independently of day to day laboratory management and audits all studies conducted to ensure compliance with GLP regulations. Employees also undergo training to understand the requirements of GLP regulations.
- Studies are conducted according to internationally agreed upon protocols and test guidelines.
- Scientists are encouraged to submit their results in the peer-reviewed scientific literature and to present them in scientific forums.
- All research involving human subjects is reviewed and conducted to comply with generally accepted ethical standards and requirements. This includes the Common Rule, the Nuremberg Code, the Declaration of Helsinki, and any other applicable local government requirements and guidelines which are at least equivalent to those provided by the Common Rule.
- All animal studies are conducted in full compliance with state and federal animal welfare regulations. In addition, Dow is accredited by the Association for Assessment and Accreditation of Laboratory Animal Care International, an achievement recognized as the highest attainable by the animal care profession.
- Studies that demonstrate adverse effects are made publicly available in a timely manner to comply with the U.S. laws of TSCA 8e and FIFRA 6a2 or similar equivalent regulations in other countries.
Dow firmly supports and has full confidence in these processes. Research studies that adhere to GLPs deserve the very highest degree of confidence regarding (1) the specific and detailed experimental protocol design, (2) the measurements taken, and (3) the accuracy of the reported results because all of these elements must meet GLP quality control and quality assurance requirements. Moreover, studies based on regulatory requirements use standardized methods that have been scientifically validated and approved by regulatory bodies. Finally, GLP studies facilitate transparency and the ability of others to reproduce the test results.
Dow is strongly committed to the safe manufacture, use, and disposal of its products. Our scientists have expert knowledge of the chemicals we manufacture, especially as this relates to the development and interpretation of the science needed to comply with the laws and regulations of the chemical industry on a global basis. As members of professional associations, our scientists adhere to both personal and professional commitments to act in accordance with codes of ethics of their professions2. Finally, research should be judged on the basis of scientific merit, without regard for funding source or where the studies are conducted (e.g. academia, government, or industry)3.
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1Furthermore, of the various types of data and information employed in risk assessment, GLP derived data will most readily meet the requirements of the Information Quality Act (USEPA 260/R-02-008. Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Environmental Protection Agency, October, 2002). See http://www.epa.gov/QUALITY/informationguidelines/
2http://www.toxicology.org/MemberServices/AboutSOT/ethics.html
3Conolly, R.B., Beck, B.D., and Goodman, J.I. (1999). Stimulating research to improve the scientific basis of risk assessment. Toxicological Sciences, 49, 1-4.
