Emma Miller

Management 302 White Paper

Spring 2015

Spring 2015The Future Decay of Cosmetic Animal Testing

Executive SummaryAnimal testing for cosmetics is a cruel, outdated, and unnecessary process that needs to come to

an end. Cosmetic companies’ methods of animal testing have not changed much since they “were first

devised back in the 1930s, when we had a very basic and crude understanding of how toxicity works in

the body, and we didn’t understand the importance or extent of species differences on test results”

(Humane Society International: About Cosmetics Animal Testing, 2015). I believe animal testing should

be abolished completely, but that will be difficult in critical fields such as medical research. A very

feasible first step would be to bring an end to animal testing for cosmetics, which is the most unnecessary

use of animal testing. Much of the world recognizes cosmetic animal testing is superfluous and barbaric

in today’s scientifically advanced world, and is already illegal in Norway, Israel, India, and the entire

European Union (Kantamneni, 2014).

Urban Decay is a cruelty-free, top-shelf cosmetics company committed to ending animal testing,

and is certified by both PETA and The Leaping Bunny Program (Urban Decay: Commitments, 2015), but

is cruelty-free by simply only using existing ingredients known to be safe. I am writing to Urban Decay’s

founders, Sandy Lerner and Wende Zomnir, to encourage them to set an example for the cosmetics

industry and become advocates for a new type of animal testing alternative: a human in vitro biosubstitute

called EpiSkin. I am proposing Urban Decay take a bold stance and go a step beyond just avoiding

animal tests, and instead support competing methods for testing new substances in cruelty-free ways.

Urban Decay can help pave the road to abolishing animal testing all together.

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Table of Contents

What is Animal Testing?...............................................................................................................................3

Countries, Non-profit Organizations, and Cosmetic Companies against Animal Testing............................5

Why Urban Decay is the Perfect Trailblazer.................................................................................................8

Opposing Views.............................................................................................................................................9

What are the Alternatives to Animal Testing?.............................................................................................12

What Non-Animal Tests are Available?......................................................................................................13

The Future: EpiSkin by SkinEthic...............................................................................................................13

Call to Action...............................................................................................................................................17

Information Sources..................................................................................................................................18

Image Sources...........................................................................................................................................20

Body Text Word Count: 4,471 words

Body Text Page Count: 15 pages

Total Document Count: 5,325 words

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What is Animal Testing?

According to Humane Society International (About Cosmetics Animal Testing, 2015), animal

testing is the use of any non-human animal in procedural animal experimentation, animal research, or in

vivo, and the United States’ reliance on animal testing is staggering.

“An estimated 26 million animals are used every year in the United States for scientific and

commercial testing. Animals are used to develop medical treatments, determine the toxicity of

medications, check the safety of products destined for human use, and other biomedical, commercial, and

health care uses” (Animal Testing ProCon, 2014).

The United States legislation that regulates animal testing is “the federal Animal Welfare Act

(AWA), passed in 1966 and amended in 1970, 1976, and 1985. The AWA defines ‘animal’ as ‘any live

or dead dog, cat, monkey (nonhuman primate mammal), guinea pig, hamster, rabbit, or such other warm

blooded animal.’ The AWA excludes birds, rats and mice bred for research, cold-blooded animals, and

farm animals used for food and other purposes” (Animal Testing ProCon, 2014). Shockingly, this act, the

only one currently addressing animal testing in the United States, does not protect 95 percent of the

animals used in experiments because the act excludes so many species of animals regularly used in testing

(Animal Testing ProCon, 2014).

[The most gruesome photos were omitted for your discretion. There will be no additional animal testing photos.]

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Additionally, “while the AWA regulates the housing and transportation of animals used for

research, it does not regulate the experiments themselves. The US Congress Conference Committee stated

at the time of the bill's passage that it wanted ‘to provide protection for the researcher... by exempting

from regulations all animals during actual research and experimentation... It is not the intention of the

committee to interfere in any way with research or experimentation’” (Animal Testing ProCon, 2014). So

this means that not only are 95 percent of animals excluded from protection in the Animal Welfare Act,

but it also doesn’t protect the animals against the testing itself! The act, as described by Congress, is to

protect the researcher from the animal, not the animal from the research. The Animal Welfare Act isn’t

protecting the welfare of the animals being tested on. Isn’t that ironic.

So where we are right now is that the United States Federal Food, Drug, and Cosmetic Act, by the

Food and Drug Administration, currently allows animal testing but do not mandate it (Humane Society:

Fact Sheet, 2014). “Although they are not required by law, several tests are commonly performed by

exposing mice, rats, rabbits and guinea pigs to cosmetics ingredients. This can include:

Skin and eye irritation tests where chemicals are rubbed onto the shaved skin or dripped into the

eyes of restrained rabbits without any pain relief. (Shown in images on Page 3).

Repeated force-feeding studies lasting weeks or months to look for signs of general illness or

specific health hazards such as cancer or birth defects. 

Widely condemned "lethal dose" tests, in which animals are forced to swallow large amounts of a

test chemical to determine the dose that causes death.

At the end of a test the animals are killed, normally by asphyxiation, neck-breaking, or decapitation. Pain

relief is not provided. In the United States, a large percentage of the animals used in such testing (such as

laboratory-bred rats and mice) are not counted in official statistics and receive no protection under the

Animal Welfare Act” (Humane Society: Fact Sheet, 2014). Those animals are part of the 95 percent

mentioned earlier, and this is a bad place to be.

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Countries, Non-profit Organizations, and Cosmetic Companies against Animal Testing

Luckily, many countries are abolishing animal testing for cosmetics. As of the last few years,

animal testing for cosmetics has been made illegal in Norway, Israel, India, the Brazilian state of Sao

Paulo, and the entire European Union (Kantamneni, 2014), and is on the forefront of the animal rights

agenda.

This has been made possible by the efforts of many non-profit organizations, primarily People for

the Ethical Treatment of Animals (PETA), the Leaping Bunny Program, and, most prominently, the

Humane Society. These animal advocates have made enormous strides in the last two decades to abolish

animal cruelty, including animal testing in the business, government, and social spheres.

The Humane Society International’s “#BeCrueltyFree campaign is the largest and most effective

initiative in the world to end cosmetics animal cruelty” (Humane Society International: About Cosmetics

Animal Testing, 2015). The Humane Society advocates for animals by:

“Changing laws to ban animal testing for cosmetic products and ingredients, and to end the sale

of newly animal tested beauty products from anywhere the world

Promoting modern science, championing the development of new non-animal tests and training

regulators and companies in their use

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Educating consumers, raising awareness about animal testing and how to shop cruelty-free

Working with companies to help them move away from animal testing, and partnering with

cruelty-free companies to lobby for change

Building an unstoppable international campaign backed by the public, top companies, politicians

and our celebrity friends Paul McCartney, Ricky Gervais, Ke$ha and more” (Humane Society

International: About Cosmetics Animal Testing, 2015).

“Animal testing for cosmetics has been banned throughout the 28 countries of the European

Union since 2009. Thanks in large part to Humane Society International’s #BeCrueltyFree campaign, the

EU also banned the sale of cosmetic products or ingredients subject to new animal testing after March

2013. Israel imposed a testing and a sales ban in 2007 and 2013, respectively. And following a vibrant

campaign by our #BeCrueltyFree India team, India also introduced a national test ban in 2013. Most

recently our #BeCrueltyFree Brazil team congratulated the Brazilian state of Sao Paulo for introducing a

complete cosmetics animal testing ban in January 2014, and #BeCrueltyFree New Zealand achieved a

national cosmetics animal testing ban in 2015!” (Humane Society International: About Cosmetics Animal

Testing, 2015).

But I don’t want to fight in the political sphere. In fact, the United States government role in the

cosmetics industry is surprisingly hands-off about regulations. I believe the fastest and most effective

way to create change is by targeting the cosmetics companies themselves. There are three reasons for

this:

First, the government does not regulate what substances go into the cosmetics to begin with.

“Under the law, cosmetic products and ingredients do not need FDA premarket approval” (FDA, 2013).

This, right off the bat, is huge.

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Second, the FDA does not test the safety of the finished cosmetics themselves, and does not

require companies to share safety results with them either. It is entirely up to companies to make sure

their cosmetics are safe—and the companies have the prerogative do that with or without animal testing.

“Companies and individuals who manufacture or market cosmetics have a legal responsibility to ensure

the safety of their products. Neither the law nor FDA regulations require specific tests to demonstrate the

safety of individual products or ingredients. The law also does not require cosmetic companies to share

their safety information with FDA. FDA has consistently advised manufacturers to use whatever testing

is necessary to ensure the safety of their products and ingredients. Firms may substantiate safety in a

number of ways. FDA has stated that ‘the safety of a product can be adequately substantiated through (a)

reliance on already available toxicological test data on individual ingredients and on product formulations

that are similar in composition to the particular cosmetic, and (b) performance of any additional

toxicological and other tests that are appropriate in light of such existing data and information.’ (Federal

Register, March 3, 1975, page 8916)” (FDA, 2013). It is really up to the company whether or not to

prove safety of their cosmetics to the government, and they can do that any way they please, either

through reliance on available test data or performing their own toxicology tests.

Third, the FDA can’t even recall products already on the market. “Recalls of cosmetics are

voluntary actions taken by manufacturers or distributors to remove from the marketplace products that

represent a hazard or gross deception, or that are somehow defective (21 CFR 7.40(a). FDA is not

authorized to order recalls of cosmetics” (FDA, 2013).

These three reasons point to why I chose Urban Decay to fight this battle. The government

doesn’t regulate what ingredients go into the cosmetics, doesn’t test the finished products, doesn’t require

companies to share their testing methods, and isn’t authorized to pull a cosmetic from the shelves. It

seems only logical that if I want to make a change in the industry practices, it should start with the

businesses.

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There are many popular ethical, cruelty-free companies – from LUSH to The Body Shop – but

they are specialty niche cosmetics. They are not mainstream, top-of-the-line brands available at

renowned beauty stores like Sephora or Ulta. These other cruelty-free companies are wonderful, but have

almost a hippy-granola reputation, and don’t compete alongside brands like Too Faced, Stila, Tarte,

Smashbox, or Benefit Cosmetics. Except Urban Decay does compete. That ethical underdog is the

perfect combination of recognizable and revolutionary to take on a mission like this and change the

market for good.

Why Urban Decay is the Perfect Trailblazer

Urban Decay is a top-shelf makeup company that was founded in 1996 by two women who

wanted to shake up the cosmetics industry. The company was started by Sandy Lerner (co-founder of

Cisco Systems) and Wende Zomnir in Laguna Beach, California (Urban Decay: The Ultraviolet Edge,

2015). It was intended to turn the makeup industry on its head, and did so with flying colors – literally.

Since their inception they have upheld the highest values and ethics, with efforts to help empower

women, protect animals, and save the environment (Urban Decay: Commitments, 2015).

Urban Decay has always been on the cutting edge

of beauty (it’s even their slogan, “Beauty with an Edge”!) so

this bold step will be a success for their image, the industry,

and the animals. The company has a strong following, a

powerful reputation, and can use this additional step as an invaluable marketing opportunity.

“Urban Decay is a cruelty-free brand and is committed to ending animal testing. We do not test

our products on animals, nor do we allow others to test on our behalf. Additionally, we require our

suppliers to certify that the raw materials used in the manufacture of our products are not tested on

animals. Our Brand is certified by both PETA and The Leaping Bunny Program (CCIC) as cruelty-free”

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(Urban Decay: Commitments, 2015). The Coalition for Consumer Information on Cosmetics (CCIC),

which runs the Leaping Bunny Program, “requires companies and their ingredient supplies to pledge not

to test on animals at any stage of development and stay open to independent audits” (Graef, 2012), which

means Urban Decay monitors every step of their supply chain to ensure the strictest ethical standards.

But Urban Decay goes even a step further, with a specialty line of vegan

products. “Urban Decay certifies that our products marked vegan do not

contain any animal-derived ingredients” (Urban Decay: Commitments,

2015). The company has just a handful of vegan products, but has an

“ongoing initiative with our laboratories to not only create shades (and

entire product lines) that are vegan from the start, but also to identify

which of our non-vegan products can be converted” (Urban Decay:

Commitments, 2015). A company that makes a specialty line of vegan products for their loyal animal-

rights-advocating customers would definitely be on board to spearhead this movement.

Urban Decay can attribute much of its success to the “loyal customers it built from having an

intrinsic policy of ending animal testing and not conducting animal testing on its own products. Instead

of performing tests on animals, Urban Decay uses alternative methods to test without harming animals”

(Garcia, 2013). This commitment to abolishing animal testing is a big selling point, and very important to

their loyal customers. It is these same customers that will rally around Urban Decay in their efforts to

move beyond simply using cosmetic products known to be safe and shift to being on the cutting edge of

biological innovation.

Opposing Views

In searching for opposing views, I found some defenses on behalf of cosmetic animal testing, but

all the arguments were emotional and subjective, never directly addressing the difficult questions asked

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by animal rights activists. Many answers were along the lines of, “This is how it’s always been done”

and “We’re doing this to protect the consumer.” Cosmetic animal testing advocates gave the vague

argument, “American women use an average of 12 personal care products per day, so product safety is of

great importance” (Campaign for Safe Cosmetics, 2013) to justify testing on animals.

However, there is a strong argument that animal testing is necessary to get preliminary

information on chemicals for cosmetics, and synthetic tests will never be a complete substitute because

they need to be tested on an in vivo animal. “Living systems like human beings and animals are

extremely complex. Studying cell cultures in a petri dish, while sometimes useful, does not provide the

opportunity to study interrelated processes occurring in the central nervous system, endocrine system, and

immune system … Also, conditions such as blindness and high blood pressure cannot be studied in tissue

cultures. Computer models can only be reliable if accurate

information gleaned from animal research is used to build the

models in the first place” (Animal Testing ProCon, 2014). This is

a very strong case for medical animal testing, but doesn’t carry the

same muscle for cosmetic testing. Medical animal testing has a force of advocates, including an

organization called Americans for Medical Progress (AMP) with a slogan, “Because research needs

advocates” (AMP, 2012). It fiercely and thoughtfully defends animal testing for medical advancement,

saying how “animal-based research leads to treatments and cures for both people and animals” (AMP,

2012) and, essentially, that the sacrifice of a few animals helps the greater good of science, health, and

humanity. It strongly and rationally counters every argument PETA throws against medical animal

testing in a very consequentialist way, and I was very impressed. With medical animal testing, sometimes

the ends do justify the means. However, medical testing and cosmetic testing are not the same, as

cosmetic testing doesn’t help find cures for genetic disorders such as Down Syndrome or Parkinson’s

Disease (AMP, 2012). Although, I still argue that we should strive to innovate beyond animal testing so

we never need to test on another animal. For where we are right now, though, medical animal testing has

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the strongest argument I’ve heard. But again, the force behind defending animal testing for medical

research doesn’t carry over into cosmetics because the means don’t justify the ends in the same capacity,

especially when cosmetic testing has far more applicable artificial substitutes available than medical

testing.

Finally, there is the last argument for pro-animal testing, which is that, at the moment, “Cruelty-

Free” companies are riding on the backs of animal-testing companies. They are “using the thousands of

ingredients with a long history of safe use, because these will have existing safety data and require no

further testing (animal or otherwise)” (Humane Society International: About Cosmetics Animal Testing,

2015), but that means they’re not using the newest makeup formulations. “Animal tests continue because

some companies insist on developing and using “new” ingredients. These are ingredients that don’t have

existing safety data—because they’re new! So new safety data has to be generated to satisfy the

regulators before a product can go on sale, and that means new animal testing” (Humane Society

International: About Cosmetics Animal Testing, 2015). The cosmetic industry will become stagnant if

they can no longer test the latest substances, and even mixing safe substances together in a new way can

be dangerous and requires animal testing (Humane Society International: About Cosmetics Animal

Testing, 2015). In order to abolish animal testing for good, we need cruelty-free companies to be able to

test 100 percent of new, unknown substances without animals, and that’s not possible with the current

non-animal testing technology.

But that’s not to say the new biosubstitutes cannot improve research in leaps and bounds without

harming animals. Many medical experiments need animal testing, but not all cosmetics. By Urban

Decay promoting biosubstitutes, the popularity and demand for non-animal tests will grow, and then the

biosubstitute companies will have the income and demand to research and develop new technology every

day.

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What are the Alternatives to Animal Testing?

There are two primary ways for a cosmetics company to achieve cruelty-free status. The first is

to only use cosmetic ingredients known and certified to be safe, and the second is to perform non-animal

tests on new ingredients. “Companies have the option of using existing non-animal tests or investing in

and developing alternative non-animal tests for new ingredients. There are a growing number of non-

animal tests that can be used to assess the short-term safety of previously untested. Non-animal tests for

longer term safety are under development” (Humane Society: Fact Sheet, 2014).

To ensure safety without animal testing, companies can create their products “using the thousands

of ingredients that have a long history of safe use. There are already many products on the market that are

made using such ingredients” (Humane Society: Fact Sheet, 2014). This is what Urban Decay currently

does. They create cosmetics using only ingredients known to be safe, but that circles back to the free-

loading issue mentioned earlier. Theoretically, Urban Decay could wait until Cover Girl tests a chemical

excessively on animals to prove it is safe, and then Urban Decay will take it off the published “safe

substances” list and maintain their cruelty-free status. Obviously the succession isn’t that direct, because

the Leaping Bunny Program checks every step of the company’s supply chain process, from raw material

to the finished product, to ensure no stage of development has any ingredient or product that was tested

on animals (Leaping Bunny, 2015), but the hypothetical chain of offense is the same. Urban Decay

should be on the cutting edge of cosmetics formulas without letting another company do the dirty work.

This is where animal testing substitutes come in.

The Humane Society has a page of non-animal testing alternatives, and they’re fascinating;

ranging from cutting edge science to simple resourcefulness. First, though, the website lists that an

animal testing alternative must achieve one or more of the three R’s (Humane Society: Alternatives to

Animal Tests, 2013):

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1. Replaces a procedure that uses animals with a procedure that doesn't use animals

2. Reduces the number of animals used in a procedure

3. Refines a procedure to alleviate or minimize potential animal pain

What Non-Animal Tests are Available?

There are nearly 50 different alternatives being developed and/or validated today (Humane

Society: Alternatives to Animal Tests, 2013). Here are examples of existing alternatives for cosmetic

purposes (Humane Society: Alternatives to Animal Tests, 2013):

EpiSkin™ and EpiDerm™ —each composed of artificial human skin—can save thousands of

rabbits each year from painful skin corrosion and irritation tests.

The Bovine Corneal Opacity and Permeability Test and Isolated Chicken Eye Test use eyes from

animals slaughtered for the meat industry instead of live rabbits to detect chemicals and products

that are severely irritating to the eyes.

The 3T3 Neutral Red Uptake Phototoxicity Test can replace the use of mice and other animals in

the testing of medicines and other products for their potential to cause sunlight induced "photo-

toxicity."

The Reduced Local Lymph Node Assay for skin allergy testing makes it possible to reduce

animal use by up to 75 percent compared with traditional guinea pig and mouse tests.

The Future: EpiSkin by SkinEthic

The primary one I want to highlight is EpiSkin, by

SkinEthic. “EpiSkin is an in vitro reconstructed human epidermis

from normal human keratinocytes cultured on a collagen matrix

at the air-liquid interface. This model is histologically similar to

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the in vivo human epidermis. The human keratinocytes come from mammary samples obtained from

healthy consenting donors during plastic surgery. HIV 1 & 2, B and C hepatitis tests are carried out on

the donor bloods as well as verification of the bacteriological & fungal sterility of the cells and absence of

mycoplasma” (EpiSkin, 2015).

In simpler language, the process begins with taking

skin cells, or keratinocytes, from healthy adult donors and

growing them in a collagen base, ‘feeding’ them a mixture of

water, amino acids, and sugars. After a few days, the cells will

begin to form a thin sheet of skin cells, and after ten days the

cells grow into layers, replicating a human epidermis (The Beauty Economy, 2014). “Cosmetic products

or ingredients can then be tested for safety and irritancy simply by adding them to the synthesized skin.

Scientists assess their safety by checking the proportion of cells that have been killed off by adding

another chemical which changes color in the presence of living tissue” (The Beauty Economy, 2014).

EpiSkin is worth highlighting for many reasons, but especially because it can measure both safety

and efficacy assays with extremely specific, accurate results. Safety assays including in “vitro skin

corrosion, in vitro skin irritation, acute and chronic skin irritation for topical formulations, and

phototoxicity testing of raw materials or finished products” (EpiSkin, 2015). All of those are tests of

safety that would normally be done on a living animal, and these types of safety measures are the most

harmful, as they test increasing grades of the product until it is visibly harmful and definitely no longer

safe. The EpiSkin will not only protect rabbits from being shaved and their skin abused with chemicals,

but it will show exactly how human skin will react, not how relatively-similar rabbit skin will react. This

addresses the common cry of animal rights activists that animals shouldn’t be used for testing for human

products at all because they’re not humans. “The anatomic, metabolic, and cellular differences between

animals and people make animals poor models for human beings” (Animal Testing ProCon, 2014), and

rabbits only share roughly 85 percent of the same DNA as humans (Animal Testing ProCon, 2014). It

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makes significantly more sense to test on a substitute with 100 percent of the same DNA as the users of

the products. This is why growing skin from the cells of healthy, willing, human donors makes this a

strong biosubstitute.

Additionally, EpiSkin can measure efficacy assays including percutaneous absorption (how

efficiently the product penetrates the skin), effects of UVA and UVB exposure / UVB protection for

measuring cosmetics with sunscreen, pharmacology, toxicology, and colorimetric response to skin dyes

(EpiSkin, 2015). This shows just how versatile the EpiSkin is, and that as technology improves, even

more tests will be able to be performed. The possibilities are endless.

Let me also mention that testing on EpiSkin is significantly less expensive than animal tests. A

standard Draize skin corrosion test done on a rabbit costs $1,800, whereas the same test—with more

accurate results—done on an EpiSkin human skin model only costs $850 (Humane Society International:

Costs of Animal and Non-Animal Testing, 2015). That’s an enormous difference.

Finally, EpiSkin follows all three of the Humane Society’s R’s

1. It replaces the procedure typically done on rabbits and guinea pigs with one done on human

skin cells in a petri dish

2. It reduces the number of animals used in a procedure to zero

3. It refines a procedure to eliminate potential animal pain

Considering the Humane Society asks that alternatives fulfill at least one of these requirements, it’s

astounding that EpiSkin not only fulfills, but excels, at all three.

Then, if all those reasons weren’t enough to get on board with EpiSkin, as of last fall, 2014, it has

taken off in China.

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As a little background on the issue: In February 2012, the China Food and Drug Administration

created mandatory animal testing on all cosmetic products sold in the country. This was a hotly contested

issue, which caused a serious divide in the market: who would turn a blind eye to the cruelty to tap into

the extremely lucrative 110 billion yuan ($17.8 billion) Chinese cosmetics market (Sauer, 2012), and who

would stand firm in their morals and say no? Urban Decay, along with fellow ethical companies LUSH

and The Body Shop, were among the companies to decide not to enter the Chinese market and allow their

products to be tested on animals (Sauer, 2012).

The game changer now is that China has hopped on board with the animal testing substitute,

EpiSkin. In October, 2014, “L’Oréal was granted a Chinese business license for Shanghai Episkin

Biotechnology Ltd., the company it created to market the Asian version of its reconstructed skin model

Episkin” (GCI, 2014). “Chinese authorities have granted a license for Shanghai EpiSkin Biotechnology

Ltd to market its reconstructed human skin model. The development

is hailed by Humane Society International’s China team as an

important step towards enabling domestic cosmetics companies to

replace animal tests with modern in vitro methods, and in so doing,

take advantage of the very latest research technologies in product

safety” (Humane Society International News, 2014).

“Since China’s Food and Drug Administration introduced regulatory reforms in July, Chinese

companies producing ordinary cosmetics no longer need to test finished products on animals, allowing for

a substantial reduction in animal testing. The next step will be to increase the availability, uptake and

acceptance of new in vitro technologies, and the licensing of EpiSkin marks an important step towards

that goal” (Humane Society International News, 2014).

I am encouraged by the range of alternatives. There is clearly a market for these alternative tests

– such as in vitro human skin – that I can see companies investing and paying big bucks for even more

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realistic models. Then, once China has developed the market for in vitro human skin, we all know they

won’t stop at cosmetics testing. If the United States wants to be competitive with China we need to get

on board with biosubstitutes like EpiSkin we need to get on board, and now.

Call to Action

The possibilities are endless for ways in vitro bio-technology can change the face of science and

medicine, and the changes Urban Decay could make in the cosmetic industry could start a ripple effect. I

am writing this paper to encourage Urban Decay to begin using, and publically advocating, an EpiSkin-

type biological substitute for cosmetic testing as a way to start an active discussion in the industry.

L’Oréal has started the conversation, but they have a tainted history of animal testing—and many other

companies are continuing to test on animals right now. Urban Decay has a rare ethical clean slate, and

the opportunity to take its good example and go one step further. The advancements I’m proposing

Urban Decay spearhead can potentially extend to pharmaceuticals and chemical testing, paving a way for

complete abolishment of animal testing in all fields. With your help today we can make animal testing an

evil of the past.

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Information Sources

Americans for Medical Progress (AMP). (2012, August 16). “Animal Research FAQ: The Top 10 Questions.” Americans for Medical Progress. Retrieved 1 May 2015 from http://www.amprogress.org/sites/default/files/Frequently%20Asked%20Questions_Final%202012_0.pdf

Animal Testing ProCon. (2014, January 29). “Should Animals Be Used for Scientific or Commercial Testing?” ProCon.org. Retrieved 5 May 2015 from http://animal-testing.procon.org/#background

Campaign for Safe Cosmetics. (2013). “Nonprofits: Endorse the Campaign.” Campaign for Safe Cosmetics. Retrieved 5 May 2015 from http://www.safecosmetics.org

Cruelty-Free International. (2013). “We Did It! Europe bans animal testing for cosmetics.” Cruelty-Free International. Retrieved 1 May 2015 from http://www.crueltyfreeinternational.org/en/the-solution/animal-testing-for-cosmetics-in-europe-finally-set-to-end

EpiSkin. (2015). “Description, Characterization, Application.” EpiSkin: World leader in tissue engineering for human in vitro skin and epithelial models. Retrieved 5 May 2015 from http://www.episkin.com/pageLibre000100c5.asp

FDA. (2013, August 3). “FDA Authority Over Cosmetics.” U.S. Food & Drug Administration. Retrieved 2 May 2015 from http://www.fda.gov/Cosmetics/GuidanceRegulation/LawsRegulations/ucm074162.htm

Garcia, C. (2013, April 21). “Urban Decay – Expanding to China Requires Animal Testing.” Business Ethics Case Analysis. Retrieved 30 March, 2015 from http://businessethicscases.blogspot.com/2013/04/urban-decay-expanding-to-china-requires.html

GCI. (2014, October 10). “L’Oreal Obtains Business License to Market Chinese Episkin.” GCI Magazine. Retrieved 5 May 2015 from http://www.gcimagazine.com/business/marketers/announcements/278844861.html

Graef, A. (2012, July 7). “Urban Decay Gets Cruelty-Free Status Back.” Care2. Retrieved 29 March, 2015 from http://www.care2.com/causes/urban-decay-gets-cruelty-free-status-back.html

Humane Society. (2014, March 13). “Fact Sheet: Cosmetic Testing.” The Humane Society of the United States. Retrieved 16 April, 2015 from http://www.humanesociety.org/issues/cosmetic_testing/qa/questions_answers.html

Humane Society. (2013, February 8). “Alternatives to Animal Tests.” The Humane Society of the United States. Retrieved 16 April, 2015 from http://www.humanesociety.org/issues/cosmetic_testing/facts/alternatives_animal_tests.html?credit=web_id329654370

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Humane Society International. (2015). “About Cosmetics Animal Testing.” Humane Society International. Retrieved 1 May 2015 from http://www.hsi.org/issues/becrueltyfree/facts/about_cosmetics_animal_testing.html

Humane Society International. (2015). “Costs of Animal and Non-Animal Testing.” Humane Society International. Retrieved 7 May 2015 from http://www.hsi.org/issues/chemical_product_testing/facts/time_and_cost.html

Humane Society International News. (2014). “EpiSkin Biotech License helps China to Advance Cosmetics without Animal Testing.” Humane Society International News. Retrieved 7 May 2015 from http://www.hsi.org/news/press_releases/2014/10/episkin-china-biotech-license-100614.html

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Image Sources

Cover Page Photo: http://www.tomiscolourpavilion.com/wp-content/uploads/2015/03/eyeshadow_by_koco48-d3dcj3c.jpg

Page 3:

Monkey testing: http://media.gotraffic.net/images/ilCKX24ihy8k/v9/628x-1.jpg

Rabbit eye testing: http://upload.wikimedia.org/wikipedia/commons/e/e2/DraizeTest-PETA.jpg

Rabbit skin testing: http://www.peta2.com/wp-content/uploads/2014/04/bunny-cruelty-free-no-text.jpg

Page 5:

PETA logo: http://claytonkroh.com/images/logo_peta.jpg

Leaping Bunny logo: http://www.albabotanica.com/media/wysiwyg/leaping-bunny-logo.jpg

Humane Society logo: http://img1.wikia.nocookie.net/__cb20140330192321/ke-ha/images/e/e2/LOGO_humane.jpg

Page 8:

Urban Decay logo: http://fabulousmecosmetics.com/assets/images/Urban-Decay-logo-1.jpg

Page 9:

Urban Decay vegan palette: http://www.mybeautybunny.com/wp-content/uploads/Urban-Decay-Vegan-Palette.jpg

Page 10:

AMP logo: https://speakingofresearch.files.wordpress.com/2012/10/amp_logo_2011_centered.png

Page 13:

EpiSkin image: http://www.cosmeticsdesign-asia.com/var/plain_site/storage/images/publications/cosmetics/cosmeticsdesign-asia.com/formulation-science/l-oreal-turns-attention-to-testing-alternatives-in-china-as-it-ramps-up-regional-business.png

Page 14:

EpiSkin layers image: http://www.rsc.org/images/NEWS-p12-episkin-250_tcm18-94935.jpg

Page 16:

EpiSkin in China: http://www.episkin.com/iso_album/r-l_oreal-110411-8723_743x570.jpg

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