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IAMS under pressure to come clean over animal testing

An open letter to IAMS...

Mr Gary Cunningham
Director of External Relations
Procter & Gamble
Cobalt 3
Silver Fox Way
Cobalt Business Park
Newcastle-upon-Tyne
NE27 0QN

21st November 2002

Dear Mr Cunningham

IAMS' ANIMAL RESEARCH POLICY

We refer to Iams' most recent statements regarding its "Research Policy" published in information leaflets, the Iams website and in responses to public enquiries (copy enclosed). We also bring to your attention the fact that this letter is open, and a copy will be published on our website.

Credibility of Iams and Procter & Gamble statements

The Iams Company and Procter & Gamble (P&G) have developed a track record of statements regarding policy on animal research that are frequently misleading and/or ambiguous:

• For example, the Royal Society for the Prevention of Cruelty to Animals (RSPCA) complained in January 2002 of the "deficient statement from Procter & Gamble that 'we do not use cats and dogs in research or testing for non-drug products' ". (1)
• The internal P&G memo that appeared in the press recently reveals the deeply cynical approach to public relations held by Procter & Gamble. The memo talks of the need to subvert EU proposals to ban cosmetic testing while maintaining the image of a company 'committed to ending animal testing'. (2)
• Countless reports received by Uncaged Campaigns from consumers given misleading information by Iams customer services regarding its animal research practices.

In the light of P&G's track record of misleading statements in relation to its animal testing practices, and the suspicious circumstances surrounding the sudden development of an Iams research policy following the exposure in the national media of cruel and lethal animal experiments supported by Iams, the company has an ethical and regulatory duty to clarify and substantiate its public statements. The length of this letter is an indication of the suspicious level of ambiguity and confusion in Iams' stated research policy.

We would also like to take this opportunity to draw your attention to relevant codes of the Advertising Standards Authority (ASA):

"...advertisers must hold documentary evidence to prove all claims, whether direct or implied, that are capable of objective substantiation." (3.1)

"Advertisers should not exploit the credulity, lack of knowledge or inexperience of consumers." (6.1)

"No advertisement should mislead by inaccuracy, ambiguity, exaggeration, omission or otherwise." (7.1)

Below we explore the fundamental questions arising from Iams' stated research policy.

1. Lethal experiments on cats and dogs

Since May 27 2001, the date of the publication of the Sunday Express article exposing lethal and painful laboratory experiments on cats and dogs, Iams has made the claim that it made a decision in March 1999 not to commence any further studies on cats and dogs that required the euthanasia of those animals. Iams' recent (November 2002) promotional material contains the statement:

"We will not fund or participate in any study requiring or resulting in the euthanasia of cats or dogs."

However, we have sincere doubts about the validity of this statement, for the following reasons:

• The policy was not referred to in Iams' correspondence to members of the public between the date the policy decision was made (so it is claimed), and the public revelations about Iams' lethal experiments.
• The policy was not disclosed to the journalist from the Sunday Express when she contacted Iams regarding their research practices.
• Iams has failed to disclose documentary evidence to substantiate this claim.
• Iams has failed to show any remorse or regret for the documented suffering and death it has inflicted on innocent cats and dogs.

In order to verify the truth of this statement, please disclose to us relevant documentary evidence (e.g. discussion papers, reports, minutes of meetings, memos, etc.). In the absence of this disclosure we must assume that the statement is not true, and we will communicate this position to the public. You have the opportunity now to respond to this position in advance.

2. Lethal experiments on other animals

Notwithstanding the truth or otherwise of this statement, it is noteworthy that it refers specifically only to cats and dogs. However, Iams' scientists have participated in experiments that have harmed rats (3), and studies using pigs and rats are cited by Iams' scientists in their publications. In the absence of an unequivocal statement from Iams and P&G ruling out all lethal animal experiments, accompanied by substantiating documentation, we deduce that Iams' research policy includes lethal experiments on species of animals apart from dogs and cats. If this is a misapprehension then you now have the opportunity to correct it.

3. Equivalence to research on people

Iams' current policy states:

"We will only conduct research that is equivalent to nutritional or medical studies acceptable on people..."

This appears to be highly misleading. In human medical research, subjects formally consent to undergo research procedures. In medicine, such procedures are carried out for the potential benefit of the subject. In contrast, we are aware that research conducted by Iams includes the exploitation of animals acquired from commercial suppliers of the vivisection industry. Animals used in Iams studies will undergo harmful procedures in a laboratory environment, not for their own medical benefit, but for solely experimental purposes in order to provide Iams with data to assist in the marketing of its products.

The only human medical studies commensurate with Iams' animal studies were those conducted by the Nazis on concentration camp prisoners. Such research cannot be deemed 'acceptable'.

In the face of this clear contradiction, Iams must either:

• Satisfactorily explain how laboratory research on animals, as opposed to clinical research on ill animals with the consent of their guardians, is equivalent to acceptable research using people.
• Withdraw this statement.

We await your comments on this matter.

4. Sources of dogs, cats and other animals used in Iams research

Iams policy states:

"We will test our foods on groups of cats or dogs within the general population who already suffer from target conditions."

There are two confusing aspects of this statement.

• Does the term "general population" refer specifically to companion animals (or 'pets') living with members of the public, or does it have a wider definition? We note that Iams has specifically stated in other correspondence that it will continue to purchase from dealers in animals bred specifically for use in laboratory research.
• This statement gives the impression that the "tests" referred to here account for the entirety of Iams' animal research. However, we are concerned that these tests represent merely the final stages of the entire research process, and that fundamental research to explore underlying biological mechanisms prior to the final testing of finished products continues on dogs, cats and other animals acquired from 'laboratory animal' dealers. We would be grateful for clarification on this matter.

5. Inducing diseases in animals

Iams policy claims:

"... we will not contract for, nor conduct, any study involving surgeries to create or mimic diseases such as diabetes, stroke, heart disease, kidney disease, or intentional damage to other organs..."

• Which animals does this apply to: cats and dogs in "the general population", all cats and dogs, or all animals?
• This statement implies there are certain diseases which will not be deliberately induced by surgical methods in certain animals. The list of diseases is, however, not exhaustive. Please define the nature of the diseases whose surgical induction appears to be ruled out by this statement.

Later, Iams policy statement claims:

"... nor will the company use non-surgical methods to induce or simulate diseases that are not acceptable in nutritional or medical research on humans."

This position appears to be meaningless because it would be entirely unacceptable and illegal to induce disease in humans. The only substantive issue brought up by this statement focuses on the question of the acceptability of the "non-surgical methods". However, it has already been noted that Iams' notion of equivalence between research on people and their experiments on animals appears to be incoherent and misleading, pending a satisfactory explanation. An enormous range of "non-surgical methods" are used in research on humans. However, in the fundamentally different context of harmful and exploitative laboratory research on animals, such methods would harm the animals and have the potential to cause additional suffering. Therefore, we believe the statement above to be deeply misleading.

Please provide a clear explanation of what methods Iams' continues to use to induce diseases or conditions in animals for research purposes.

Finally, in this section, the Iams policy statement says:

"nor will the company fund any university positions that may be involved in such activities [inducement or simulation of diseases] for the study of cat and dog nutrition."

Again, this is ambiguous. Will Iams fund university positions that are involved in the inducement or simulation of diseases in areas of research other than 'cat and dog nutrition', as Iams defines it?

Summary

To recap, these are the questions we have concerning Iams 'research policy' grouped together in sections corresponding to the numbered sections above:

1. Please provide documentary evidence to support the claim that Iams has permanently ceased all support for or participation in lethal experiments on cats and dogs.
2. Please clarify Iams' research policy with regard to lethal experiments on animals other that cats and dogs.
3. Please either: satisfactorily explain how laboratory research on animals, as opposed to clinical research on ill animals with the consent of their guardians, is equivalent to acceptable research using people, or withdraw this statement.
4. Does the term "general population" refer specifically to companion animals (or 'pets') living with members of the public, or does it have a wider definition (specifically, animals purchased from commercial breeders of animals for vivisection)?
   Please clarify whether the statements in this section refer merely to late-stage testing of finished food products, or fundamental research to explore underlying biological mechanisms prior to the final testing of finished products.
5. Which animals does this apply to: cats and dogs in "the general population", all cats and dogs, or all animals?
   Please define the nature of the diseases whose surgical induction appears to be ruled out by this statement.
   Please provide a clear explanation of what methods Iams' continues to use to induce diseases or conditions in animals for research purposes.
   Will Iams fund university positions that are involved in the inducement or simulation of diseases in areas of research other than 'cat and dog nutrition'?

Due to the track record of The Iams Company and Procter & Gamble in general, we must emphasise the need for documentary evidence to substantiate all claims in accordance with ASA Code 3.1.

In the absence of satisfactory clarification of Iams' ambiguous and apparently misleading research policy statement, and disclosure of documentary proof of specific policies, we will have no option but to lodge a complaint with the Advertising Standards Authority in order to establish the facts about Iams' continued abuse of animals in research and to protect the interests of the public.

Please reply within 21 days.

Yours faithfully

Uncaged Campaigns

1. Letter from RSPCA to Uncaged Campaigns, 22nd January 2002, Ref: 2499674/chv/cl.
2. Marie Woolf, 'Cosmetics company memo reveals plan to sidestep EU animal testing ban,' The Independent, 04.11.2002.
3. Muir, HE et al, "Nutrient digestion by ileal cannulated dogs as affected by dietary fibers with various fermentation characteristics," Journal of Animal Sciences 1996, 74:1641-1648 cites experiments on pigs in discussion of canine digestibility of fibre (Li et al, 1994, Canadian Journal of Animal Science, 74:327). Experiments on rats are also cited on several occasions, eg: Beaulieu, Sunvold et al., "Metabolic fuel utilization by canine and murine intestinal cells. FASEB J 1997; 11:A612." In this laboratory study, intestinal tissues were obtained from rats fed on Eukanuba or commercial rat food.

Related links:

• IAMS index
• IAMS exposé
• Global Boycott P&G
• Support for the campaign
• Pet food information sheet

Uncaged Campaigns 25.11.02

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