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iams
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:
- 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.
- Please clarify Iams' research policy with regard to lethal experiments
on animals other that cats and dogs.
- 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.
- 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.
- 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
- Letter from RSPCA to Uncaged Campaigns, 22nd January
2002, Ref: 2499674/chv/cl.
- Marie Woolf, 'Cosmetics company memo reveals plan to
sidestep EU animal testing ban,' The Independent, 04.11.2002.
- 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.
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