United States
Environmental Protection
Agency
Office of Policy,
Planning and Evaluation
Washington, DC 20460
EPA-23Q/12-85-029
April 1985
&EPA
Alternative Methods for
Toxicity Testing:
Regulatory Policy Issues

-------
ALTERNATIVE METHODS FOR TOXICITY TESTING:
REGULATORY POLICY ISSUES
Participating Staff:
Steven M. Lyons
Michael A. Champ
Sandra Panem
Science Group
Chemicals and Statistical Policy Division
Office of Policy, Planning, & Evaluation
U. S. Environmental Protection Agency
Washington, DC 20460
and
James D. Willett
Division of Research Resources
National Institutes of Health
Bethesda, MD 20205
April 1985
Notice: The views and opinions of the authors expressed herein
do not necessarily state or reflect those of the United States
Government, the Environmental Protection Agency, or the National
Institutes of Health.

-------
Table of Contents
Page
Acknowledgements					 Ill
Summary				Iv
I.	Introduction						1
II.	Prevailing Attitudes Toward Alternative Toxicity Test Methods...	10
A.	The Regulatory Community		11
Environmental Protection Agency 				11
Office of Toxic Substances		11
Office of Pesticide Programs		15
Office of Research and Development		17
Food and Drug Administration		18
Department of Transportation		20
Consumer Product Safety Commission		21
B.	The Animal Welfare- Community		22
Ethical Issues and Animal Rights		22
Fund for the Replacement of Animals in
Medical Experiments		24
Coalition to Abolish the LD50 and Draize Tests		25
United Action for Animals		26
The Humane Society of the United States			26
C.	The Chemical, Pharmaceutical, and Cosmetic Industries			28
Pharmaceutical Manufacturers Association		28
Chemical Manufacturers Association......		29
Cosmetic, Toiletry, and Fragrance Association		30
D.	The Not-for-Profit Research Community		31
National Institutes of Health		31
National Center for Toxicological Research		33
National Toxicology Program		34
National Society for Medical Research				35
American Psychological Association		36
Johns Hopkins Center for Alternatives to
Animal Testing		36
Scientists' Center for Animal Welfare		37
III.	Regulatory Policy Issues	 38
IV.	Available Resources for Identification of Alternative Methods
in Toxicology				45
Tables
Table 1 - Terms Employed to Describe Tests Used in Toxicology....	4
Table 2 - Acronyms Used in the Report		47

-------
Bibliography..	 49
General References..	 49
Symposia and Conferences on Animal Alternatives			53
Appendix A: Available Resources for the Identification of
Alternative Methods in Neurotoxicity and Behavioral Toxicity	 56
Meetings on Neurotoxicity and Related Topics			 60
Review Articles and General References	 62
Computer Generated References to Potential Alternative
Methods in Behavioral Toxicity and Neurotoxicity 	 66
Clinical and Epidemiological Studies..	 66
Functional/Behavioral Studies	 66
Electrophysiological and Neuropathological Studies	 69
Biochemical Studies	 70
Tissue Culture Studies	„	.	 71
Non-mammalian Systems	 72
Computer Modelling and SAR Analyses			 73
Miscellaneous Research Proposals		 74
Appendix B				 77
Laws Related to the Use of Animals in Biomedical
Research	 77
Legislation	 77
Congressional Hearings.....		 81
-ii-

-------
Acknowledgements
We thank the following Individuals for critical review of the manuscript,
and for many valuable suggestions and contributions to the final document.
Dr. Irwin Baumel
Director, Health and Environmental Review Division
Office of Pesticides and Toxic Substances
U, S. Environmental Protection Agency
Ms. Marcia Brody
Biological Applications Program
Office of Technology Assessment
Dr. Robert L. Dixon
Director, Office of Health Research
Office of Research and Development
U. S. Environmental Protection Agency
Dr. Alan Goldberg
Director
Johns Hopkins Center for Alternatives to Animal Testing
Dr. Allen Jennings
Director, Chemicals and Statistical Policy Division
Office of Policy, Planning, and Evaluation
U. S. Environmental Protection Agency
Dr. William F. Raub
Deputy Director for Extramural Research and Training
National Institutes of Health
Dr. Walter Rosen
Senior Staff Officer
National Academy of Sciences
Dr. Andrew N. Rowan
Assistant Dean for New Programs
Tufts University School of Veterinary Medicine
Dr. Dennis Stark
Director, Laboratory Animal Research Center
Rockefeller University
-iii-

-------
Summary
Alternative Methods for Toxicity Testing:
Regulatory Policy Issues
Recent progress in the science of toxicology, the high costs of
traditional animal tests, the time requirements for the completion of
tests, and socio-ethical concerns surrounding whole-animal testing have,
resulted in pressures to decrease dependence on animal testing in the
screening and ranking of toxic chemicals, and to substitute alternative
testing methods.
This study surveys attitudes and policies of representative organiza-
tions concerning the issue of alternatives to animal testing. An alterna-
tive test is defined as any procedure that (i) replaces currently used
animal tests with non-animal tests, (ii) reduces the numbers' of animals
in presently used tests, and/or (iii) that refines tests to reduce the
pain and suffering of the animals used. Positions of organizations in
the scientific community, the regulatory community, industry, and the
animal welfare community are examined within the context of growing
pressures to adopt new toxicity testing methodologies. The resulting
issues which effect regulatory development are identified. The report
has also been prepared as an information resource and guide to the
relevant technical literature.
While there is a diversity of opinion in each of the surveyed communi-
ties, some generalizations can be made. Among scientists there is a
consensus that animal testing can provide needed information which is
not provided by non-animal methods, but that, nevertheless, some reductions
and refinements in animal testing can be accomplished. The animal welfare
-iv-

-------
community generally holds that not enough effort has been expended in
searching for alternatives, and is much more optimistic about the
prospects for replacing animal testing than is the scientific community.
The regulatory agencies have begun to-respond to concerns about animal
tests by implementing policies to reduce requirements for some types of
animal toxicity testing and by increasing the flexibility of their guide-
lines. Many chemical, pharmaceutical, and cosmetic manufacturers would
like to see even more flexibility in the regulations, and official accept-
ance of less expensive, short-term testing methodologies. Others in
industry maintain that traditional animal tests are reliable and provide
a great deal of information about toxicity that would be difficult to
obtain in other ways.
Regulatory policy issues concerning the use of alternative toxicity
tests are identified and discussed in the report. These are:
1.	Criteria for the evaluation and adoption of alternative toxicity
testing methods.
2.	Periodic review of toxicity testing methods.
3.	Consistency of policy among federal agencies.
4.	The relationship of federal regulations to international
guidelines on the performance of toxicity testing.
5.	Access to data relevant to alternative test development and dissemi-
nation of information.
6.	Identification of potential alternative testing methods from studies
of environmental effects of toxic chemicals.
7.	The development of incentives for the transfer of technology from
the laboratory to practical application.
8.	Public dialogue about new toxicity testing schemes.
9.	The possible passage of legislation that would require changes
in toxicity testing procedures.

-------
Timely and thoughtful attention to these Issues will enable appropriate
policy development on alternative tests and ensure the protection of
human and environmental health.
-vi-

-------
I. INTRODUCTION
As many as 65,000 to 100,000 chemicals are now in use in American
industry, and approximately 1000 are added each year.^ The U. S. Environ-
mental Protection Agency (EPA) has the major regulatory responsibility
for chemicals under the Toxic Substances Control Act (TSCA) and the
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Formal
data requirements have been established for pesticidal products submitted
for registration under FIFRA, and toxicity data may be requested for
chemical products submitted for Premanufacture Notification (PMN) under
TSCA. The test data are evaluated by EPA to determine the potential
hazards of these products for human, animal, and environmental health.
Animal testing has been heavily relied upon for the assessment of
chemical products. Toxicity testing may begin with acute tests in animals
to establish the degree of toxicity and to identify the organs at greatest
risk. These tests may then be followed by further animal testing for
subchronic and chronic effects. However, recent progress in the science
of toxicology, as well as high costs, excessive time requirements for
completion of tests, and socioethical concerns surrounding whole-animal
testing, have resulted in pressures to decrease dependence on animal
testing. Consequently, there is a growing need to develop faster,
cheaper, and more effective alternative methods of toxicity testing.
For the purposes of this study, alternative test methods can be
defined according to the concept of the "3 Rs" — replacement, reduction,
1 Tilson, H. A., and Mitchell, C. L. 1984. Neurobehavioral Techniques
to Assess the Effects of Chemicals on the Nervous System. Ann. Rev.
Pharmacol. Toxicol. 24^ 425-450. Maugh, T. M. 1978. Chemicals: How
many are there? Science 199: 162.

-------
or refinement.2 That is, alternative methods are any that (i) replace
presently used animal tests with non-animal tests, (ii) that reduce the
numbers of animals in presently used tests, or (iii) that refine tests
to reduce the pain and suffering of the animals used.
The aims of this study are the following:
00 To alert the Office of Policy, Planning, and
Evaluation (OPPE) to changing perceptions in
the scientific community of the acceptability
of alternatives to animal testing, and of the
political pressures to effect change.
°° To survey the policies within EPA, other regulatory
agencies, and representative groups in interested
communities concerning alternative testing.
00 To provide a resource for OPPE risk, managers who
wish to quickly familiarize themselves with the
scientific issues underlying the alternative test
methods debate, and to guide them to the relevant
literature.
00 To test the ease of direct access to the technical
literature for the purpose of identifying new
approaches to alternative tests in toxicology.
For the communities directly affected by the alternative testing
issue, the concerns are not new. Regulators, legislators, scientists,
manufacturers, and animal welfare advocates have been struggling for a
number of years over the appropriate use of alternative test methods in
toxicity testing. Judging by the number of recent news reports, the
level of public interest may also be increasing. There can be no
doubt that concern about animal testing has emerged as an important
issue of popular debate.
Among the pressures to decrease animal toxicity testing are scien-
tific progress in toxicology that has led to the development of promising
2 Russell, W. M. S., and Burch, R. L. 1959. "The Principles of Humane
Experimental Technique." London: Methuen.

-------
new methodologies, the rising cost of animals, limited laboratory space,
the need for speed in obtaining results about potentially toxic chemicals,
legal requirements regarding the use and treatment of animals, and ethical
considerations about the use of live animals. Opposing pressures include
legal and regulatory requirements that specify particular animal tests
for product safety testing, heightened consumer awareness of potential
risks of exposure to toxic chemicals with resulting demands for more
thorough product testing, and scientific uncertainty about the validity
of alternative tests. It should be appreciated that all toxicity testing
methods, including both animal and in vitro tests, share a common problem
— questions about the ability of the test results to be extrapolated
to human health considerations.
Confusion in terminology has often hindered discussion of these
issues. Many terms with ambiguous and overlapping definitions are commonly
used. Table 1 defines some of the terms most commonly used in toxicity
testing.
Alternatives to animal toxicity testing has become a timely issue.
A number of recent legislative proposals have called for the regula-
tion of animal use and experimentation (see Appendix B). If passed,
these proposals would have an immediate impact on the use of animals in
toxicity testing. Also, two major government studies on the issue of
alternative methods to animal tests will soon be released. The Office
of Technology Assessment (OTA) is presently conducting an assessment for
Congress entitled "Alternatives to Animal Use in Testing and Experimenta-
tion." The National Academy of Sciences (NAS) is conducting an evaluation
of the opportunities and limitations in the use of nonmammalian models
in biomedical research for the National Institutes of Health (NIH). A
-3-

-------
Table 1
Terms Employed to Describe Tests Used in Toxicology
Term	Definition
Test, Assay,
Bioassay
Whole—Animal Test,
In Vivo Test
In Vitro Test
Animal
Non-Mammalian
Short-Term
Long-Term
Alternative Test
Acute Toxicity
Subchronic Toxicity
Chronic Toxicity
Effectively synonymous terms which refer to any
laboratory technique or method for measuring a
toxicologic effect.
Tests performed in the intact, living animal.
A test performed in an environment outside of
the living animal, e.g., tissue culture. In
vitro tests may require living animals for their
starting materials
This term has a clear taxononic definition, but as
used in toxicity testing, is often taken to mean only
vertebrate animals. Invertebrates are certainly animals,
but may be acceptable to animal welfare advocates as
alternatives to "animal" tests.
Of or referring to organisms that are not in the taxo-
nomic class Mammalia.
This term has no precise definition, but in toxicology,
usually means a period of days or weeks. Short-term
tests include all acute toxicity tests, virtually all
in vitro tests, and some whole-animal tests. Often
used interchangeably, but is not synonymous, with alter-
native •
In toxicology, a period of months or longer.
A toxicity test that meets the criteria of the 3 Rs
(replacement, reduction, or refinement of whole-animal
methods) as described in the text.
Adverse effects occurring within a short time after a
single administration (e.g., oral, dermal, inhalation),
or multiple doses within 24 hours, of a toxic substance.
Adverse effects occurring from continuous or repeated
doses of a toxic substance over a period of approximately
90 days.
Adverse effects that occur after a long latency period
or that are caused by prolonged and repeated exposure
to a toxic substance. Chronic effects appear approxi-
mately 6 months or longer after first exposure.
_4-

-------
study of short-term testing is also in preparation by the World Health
Organization.
• These studies are likely to receive serious congressional attention
and to focus public debate. Pressure for regulatory reform could therefore
develop rapidly. For example, a proposal to require a battery of short-term
toxicity tests similar to the Minimum Premarket Dataset (MPD) test battery .
of the Organization for Economic and Cooperative Development (OECD) is
under consideration as an amendment to the TSCA reauthorization bill.
An additional example of the type of legislative action which may
be anticipated is provided by the NIH reauthorization bill, that was
passed at the close of the 98th Congress, and then vetoed by the President.
The bill directed NIH to establish a plan to investigate methods of
research which (i) do not require the use of animals; (ii) reduce the
number of animals used in research; or"(iii) produce less pain and distress
in such animals than methods currently in use. (This language is the
same as the "3 Rs" definition of alternative methods cited earlier.) The
bill also called for a plan to validate new methods that are developed,
for the training of scientists in the use of validated methods, and for
the establishment of an Interagency Coordinating Committee to assist
the Director of NIH in the development of the plan.
The objective of all toxicity testing is to identify substances that
are potentially hazardous to human, animal, and/or environmental health.
Current testing protocols for new chemicals generally include tests for
acute and chronic effects that often require the use of a large number
of animals and that may take 1 to 2 years to complete. These are commonly
referred to as "whole—animal" tests, and include both "short-term" and
"long-term" tests.
-5-

-------
A major research effort of modern toxicology is the development and
evaluation of new alternative tests for assessing potentially hazardous
chemicals. Particularly desirable are tests that can be completed
quickly and cheaply. For example, many "in vitro" systems — such as
bacteria, tissue culture, and organ culture — are being investigated
as possible alternative tests. For some types of toxicity, in vitro
tests have become standard components of testing regimes, in addition to
or in place of whole-animal studies.^
Although many alternative methods consistent with the "3 Rs" defini-
tion are short-term and inexpensive, others are not. For example, epidemio-
logical studies are strongly favored by the animal welfare community as
alternatives to animal testing, but are clearly not short-term and are
usually very expensive. It should also be clearly stated that, as reduction
and refinement are defined above, an alternative test may employ whole
animals. The two terms (alternative and short-term) are often inappropri-
ately and interchangeably used. In the following survey, we have tried to
use the same terms that the respective organizations have themselves
used to describe their activities. (Refer to Table 1 for definitions of
these terms).
A distinction is frequently made between "animal research" and
"animal testing." As commonly used, the term "animal testing" refers to
the use of animals to evaluate the toxicity of potentially hazardous
substances and to establish dose levels for pharmaceuticals, while "animal
research" is a broader term including the use of animals in a variety of
^ For example, a number of bacterial mutagenicity assays are now commonly
used, such as the Ames/microsome mutagenicity test which measures the
mutagenic effect of chemicals on the bacterium Salmonella. Another
example is the sex-linked recessive lethal test in Drosophila (fruitfly),
used in the National Toxicology Program's second tier screening protocol.

-------
disciplines in basic biological and medical research — for example,
biochemistry, immunology, pharmacology, etc.
It is probably fair to say there is a consensus among toxicologists
that while particular in vitro tests may become effective substitutes for
whole-animal tests, in vitro testing can never completely replace whole-
animal testing. This is because in vitro tests cannot hope to replicate
the functional and structural complexity of the intact animal nor to
preserve the diversity of mechanisms for toxicity and detoxification
that exists in living organisms. At each succeeding level of biological
organization new properties appear which are not evident or even present
in less complex levels of organisms or systems. While less complex
biological systems or organisms offer models of biological processes which
can sometimes be used to establish priorities for further testing of
chemicals, the pitfalls involved in extrapolating data from such tests are
many. Pharmacokinetic factors which determine how much active chemical
will reach the "receptors" for toxicity differ greatly as do the organisms'
homeostatic, adaptive, and repair mechanisms which influence the expression
of toxic effects. On the other hand, in vitro tests usually have more
precisely defined toxic endpoints than whole-animal tests, and therefore
are superior for the investigation of the basic cellular and molecular
mechanisms of toxicity* As a tool for basic research in toxicology, in
vitro systems have great value.
The problem with in vitro systems for toxicity testing for regulatory
purposes is that each test can generally identify only a narrow range of
toxic effects. It is therefore important to develop test schemata which
build toward humans in both their biological complexity and toxicological
characteristics. This has led to a preference for several tests employed
-7-

-------
in combination as a "battery" of test9.
Although some in vitro tests have been developed that have high
predictive value for particular kinds of toxic effects (e.g., mutagenesis),
there is a risk perceived in some quarters that complete dependence upon
the results of in vitro assays in toxicity testing would lead to an
unacceptably high proportion of false negatives and/or false positives —
chemicals whose actual toxic potential is incorrectly Identified. For
the forseeable future, in vitro tests will perhaps be most effective in
screening protocols rather than as the primary determinant of toxicity.
Unfortunately, there is no perfect alternative test, whether per-
formed singly or in combination with other tests. This is, of course,
also true for whole-animal tests. No toxicity testing protocol can be
100% effective. Extrapolating the information gained from the various
types of toxicity tests to human and environmental health effects is the
critical and most uncertain step in toxicity assessment.
Criteria for measuring the validity of alternative testing methods
have been recently described.^ An alternative test should be easy to
standardize, so that data from different labs are consistent. It must
be able to detect toxicity over a wide range of different chemical struc-
tures and target tissues. Further, the test should be able to provide
information on the toxicity of complex mixtures, and to indicate whether
recovery from toxic insult is possible. These criteria represent a set
of standards that any biosassay, including animal tests and in vitro
tests, ought to satisfy in order to produce useful information concerning
the toxicity of a chemical. A valid test must allow extrapolation of
data from the test to human and/or environmental health, and must be at
^ Dagani, R. 1983. Chemical and Engineering News, Oct. 31, p. 7-13.

-------
least as reliable as existing whole-animal tests.
Changing perceptions surrounding the appropriate use of alternatives
to animal toxicity testing, coupled with social and political factors,
*	argue that regulatory practices may need reexamination with respect to the
use of alternative tests. Consequently, a number of policy issues need
to be addressed, including (1) the codification of a process for the
critical appraisal of alternative tests, (ii) periodic review of toxicity
testing protocols, (iii) the human and environmental health implications
of changes in toxicity testing protocols,' and (iv) the development of a
decision framework for the best regulatory use of alternative toxicity
tests.
-9-

-------
II. PREVAILING ATTITUDES TOWARD ALTERNATIVE TOXICITY TEST METHODS
Numerous groups have interests that are affected by the development
of alternative toxicity tests. Prominent participants in the debate are
the animal welfare community — consisting of antivivisectionists,
animal rights groups, and humane groups; industry — consisting primarily
of chemical, pharmaceutical, and cosmetics manufacturers and their trade
associations; the not-for-profit scientific community — composed of
academic institutions, various professional associations, and government
research institutions; and the legislative and regulatory community at
the federal, state, and local levels. Condensed summaries of the opinions
held by representative groups within these communities are given below.
These summaries were developed following interviews and examination of
publications and meeting transcripts (see Bibliography and Appendices).
Except for specific quotations, the summaries represent the authors'
interpretation of where different groups stand on the alternative testing
issue.
Acute toxicity tests, especially the LD^q and the Draize eye
irritancy tests,^ have been the primary target of animal welfare organiza-
tions that hope to eliminate or reduce animal toxicity testing. Regulatory
agencies and chemical manufacturers have therefore tended to emphasize
their efforts to eliminate or reduce dependence on these tests. The
following survey of attitudes reflects this emphasis on acute toxicity
testing. However, the statements often contain language that can be
interpreted as a general philosophy on alternative toxicity tests.
^ The LDcq (Lethal Dose-50%) is a test that measures the dose, in a
single administration, at which 50% lethality is observed in a test
group of animals. In the Draize test, test materials are placed directly
into the eyes of test animals (rabbits) to measure eye irritancy.
-10-

-------
A. The Regulatory Community
The regulatory community is responsible for protecting human, animal,
and environmenal health from hazardous substances. Different federal
regulatory agencies are responsible for regulating different kinds of
products, and operate through the authority of a variety of statutes.
The agencies have each promulgated a variety of test standards, guidelines,
and rules that affect the conduct of toxicity tests. In addition, state
and local governments may have testing requirements that differ from
federal requirements in significant ways. Some states enforce stricter
requirements than federal law requires. Because federal regulations
have the largest impact on toxicity testing practices, the following
discussion will focus on the activities of the federal government.
Environmental Protection Agency
The relevant offices within EPA, for the purposes of this analysis,
are the Office of Pesticides and Toxic Substances (OPTS) and the Office
of Research and Development (ORD). Within OPTS, the Office of Toxic
Substances (OTS) is responsible for administering TSCA and the Office
of Pesticides Programs (OPP) for administering F1FRA. Both offices have
evolving positions on the use of alternative methods for toxicity testing.
ORD has an extensive research program in toxicology including a major
effort in alternative test methods development. The current positions on
how alternative tests should be employed are summarized for each office-
(a) OTS. New guidelines for determining acute toxicity were
published by OTS in October 1984, covering oral, dermal, and inhalation
toxicity.6 The new guidelines clarify important testing options for
6 Environmental Protection Agency. 1984. Acute exposure guidelines -
notice of availability through NTIS. Fed. Regis. 49^ 39911-39912.
-11-

-------
companies introducing new chemicals and provide more latitude for using
alternative methods. Novel approaches to the determination of acute
toxicity are recommended to encourage a reduction in the use of animals.
The Agency guidelines state that to minimize animal testing, sufficient
information about toxic effects may in some cases be obtained from previously
determined toxicity test results of structurally related chemicals. When
animal tests are requested, EPA identifies the "limit test" as a permissible
substitute for the traditional LD50 test. In the "limit test" a single
group of animals is given an appropriate dose of the test agent, and if
no lethality is observed, then further testing is not pursued for acute
toxicity using the LD5Q. Sometimes a limit test can reduce tenfold
the number of animals used.
To diminish the number of animals used, the Agency also recommends
an estimated lethal dose. This can be calculated by extrapolation or
interpolation of data from a small test group of experimental animals.
However, it has been pointed out that substitution of the estimated
lethal dose for the LD50 test may require larger safety factors to be
applied to account for the greater level of uncertainty in the data.''
Finally, the guidelines stress multiple endpoint evaluation from toxicity
tests. In an acute toxicity study, for example, it is now recommended
that tested animals be examined for subchronic effects, behavioral manifes-
tations, and the identification of target organs, as a means of enhancing
the utility of the data derived from animal toxicity tests.
A policy change which may have the effect of reducing the number of
animals used for toxicity testing under the requirements of TSCA was the
7 Irwin Baumel, personal communication, Office of Toxic Substances.
-12-

-------
recent "Change in Test Standards Policy and Test Rule Development Process."®
This constituted a change in approach to providing test standards for
TSCA Sec. 4 test rules. The new approach involves issuing generic test
methodology "guidelines" rather than generic test methodology "requirements."
Sponsors are allowed to select test protocols listed in TSCA, OECD, or
FIFRA guidelines or to submit test protocols of their own, which EPA must
approve. Increased flexibility in the performance of toxicity tests
is the aim of this change. This should "allow for scientific innovation
and encourage the development of more sophisticated and scientifically
advanced testing methodologies.Another measure that potentially
affects animal usage is the regulatory rule, "Toxic Substances Control
Act Data Reimbursement."^ This rule provides for EPA negotiation of
reimbursement for manufacturers or processors of chemicals that perform
required testing, from the manufacturers or processors who have been
exempted from testing the chemical under Section 4(c) of TSCA. This
provision is designed to prevent duplicative testing, and thus reduce
unnecessary animal testing. The Agency may also use data submitted under
Section 8(e) of TSCA to predict the potential hazard of similar or chemically
related substances submitted for premanufacture notice (PMN). This
section requires the manufacturer or processor to provide to the Agency
any information it obtains on the toxicity of a chemical.
OTS can endorse the use of alternative toxicity tests only when
their scientific basis is sound and allows confidence in the data.
Human health and protection of the environment are the overriding concerns
® Environmental Protection Agency. 1982. Fed. Regis. j£J_i 13012-13014.
9 Ibid., p. 13013.
Ibid., p. 24348.

-------
in toxicity testing. The scientific integrity of toxicity testing cannot
be compromised solely to improve animal welfare. Nevertheless, OTS sees
a significant role for alternative tests. Inclusion of results from
alternative tests with PMN submissions is encouraged, as they enhance
the assessment of potential toxicity of new chemicals.
A formal battery of short-term alternative tests as part of the PMN
process is, however, viewed with some skepticism within OTS. The present
methodologies are considered inadequate to design a static set of tests
that provide useful toxicity data for all chemicals. The MPD of the
OECD is a test battery employed by some European nations for new toxic
chemicals. Ironically, the impetus for its development derived in part
from the passage of TSCA in 1976. Some have suggested that introduction
of such a test battery in the United States would serve as a negative
economic incentive and reduce innovation in chemical research. Alterna-
tively, the MPD may well reduce trade barriers by establishing international
standards for toxicity testing regimens. A rapid and reliable toxicity
screening program may also help innovation by eliminating more unproductive
efforts than good prospects in chemical research.
The OTS has designed a "Retrospective Study of PMN Hazard Predictions,"
which will soon be undertaken. The study will examine the validity of
OTS's use of structure activity relationship (SAR) analyses in the assessment
of the potential hazards posed by PMN chemicals submitted to EPA under
TSCA.I* In brief, a sample of 100 chemicals will be selected from the PMN
current inventory of over 4000 that have been screened by OTS. They
will then be subjected to a battery of toxicity tests, and the results
11 SAR analysis attempts to predict the likelihood of toxic effect by
comparing the chemical structure of a compound to chemically related
compounds of known toxic potential.
-14-

-------
compared to the previous predictions of OTS's structure activity team.
The test battery will include three short-term mutagenicity assays
(Ames Salmonella/microsome test, in vitro sister chromatid exchange
assay in Chinese hamster ovary cells,' and an in vitro mutation assay in
L5178Y mouse lymphoma cells), two general toxicity assays (an acute oral
toxicity test in the mouse, and a 14-day or perhaps 28-day repeated dose
oral toxicity test in the mouse), and a dermal sensitization assay (the
Buehler or "closed patch" test in the guinea pig). This retrospective
study will evaluate the effectiveness of EPA's screening protocols, and
will certainly have an impact upon any decision to require a short-term
test battery for PMN submissions. It will also improve the data base
for the performance of SAR analyses and should lead to greater reliability
in these analyses. For these reasons, the study is an extremely important
effort within EPA to improve the toxicity assessment process.
The OTS has supported an extramural research program on the use of
biological markers for carcinogenicity. The establishment of a correlation
between the presence of such markers at an early stage and the carcinogen-
icity of a compound could lead to a large reduction in the number of animals
used in lifetime bioassay carcinogenicity studies.
(b) OPP. FIFRA requires the registration of all pesticides distri-
buted in the United States, and establishes the authority of the Adminis-
trator to require data in support of the registration. The Data Require-
ments for Pesticides Registration (40 CFR Part 158), recently published
as a Final Rule in the Federal Register,^ specifies the data and
information that must be submitted to EPA to support the registration of
each pesticide. Test standards, guidelines on evaluation and reporting
12 Environmental Protection Agency. 1984. Fed. Regis. 49: 42856-42905.
-15-

-------
of the data, and examples of teat protocols are provided in the various
subdivisions of the "Pesticide Assessment Guidelines.Based upon a
determination of acute toxicity and environmental hazard, pesticides are
classified for "general use," meaning any consumer may use them, or for
"restricted use" by certified users only. The OPP requires acute toxicity
data for oral, dermal, and inhalation effects, and eye and skin irritancy
tests. Acute lethality data are required, although a precise LD5Q is
~ot necessary.
The OPP has the authority to request long-term toxicity data for pesti-
cides that are suspected to remain as residues in foods, or for pesticides
which may present other types of chronic exposure. Over the past five
years, an increasing number of animals have been used in chronic studies
which are performed to comply with the registration and labeling require-
ments of FIFRA.Test guidelines for chronic studies now recommend
50 animals per sex per dose, with three different dose levels in two
species. This has resulted from heightened public concern about the
risks of human exposure to pesticides. Although this policy may appear
to lead to increased utilization of animals, the adequate testing of
pesticides prior to their release for general use may prevent incidents
of large accidental field kills of fish and other wildlife, which may
number to 10,000 birds and mammals or one million fish.
With respect to animal welfare considerations, OPP concurs with
OTS's formulation of test guidelines, and where statutory requirements
allow, the new OTS acute toxicity guidelines will be adopted by OPP.
Environmental Protection Agency, Office of Pesticide Programs. 1982.
Pesticide Assessment Guidelines, Subdivision F, Hazard Evaluation:
Human and Domestic Animals. NTIS-PB83—153916.
William Burnam, personal communication, Office of Pesticides Programs.
-16-

-------
Short-term in vitro tests presently comprise a major part of the test
requirements for pesticides. For example, a battery of tests for the
assessment of mutagenicity is required, with considerable flexibility
afforded the manufacturer in the choice of specific tests.^ ^he
design of the battery depends on the nature of the test substance — it
should.be able to detect point mutations, structural chromosomal aberra-
tions, and other genotoxic effects. Among the tests that may be included
are a variety of in vitro or other alternative tests such as gene mutation
tests in microorganisms, the sex-linked recessive lethal test in Drosophila,
cytogenetic analysis, cell transformation assays, and DNA repair assays.
Several aspects of the Good Laboratory Practices Standards that have
been instituted for TSCA and FIFRA work to reduce unnecessary and wasteful
animal testing.^ Improvement in the quality of the data submitted to
EPA reduces the need for repeated testing and lessens duplicative animal
tests. An Interagency Agreement between FDA and EPA provides for a
coordinated quality assurance program for these agencies' toxicity testing
activities. FDA and EPA perform joint data audits and inspections of
test facilities. These joint audits ensure that data from toxicity
tests are documented and acceptable to the regulatory agencies. In
addition, EPA's GLP Standards incorporate guidelines for the proper care
and handling of laboratory animals.
(c) QRD. The purpose of the environmental and health effects related
research conducted by ORD is to provide information to enable EPA to
make better estimates of morbidity and mortality for a given environ-
15 40 CFR Part 158.135
40 CFR Part 160; 40 CFR Part 772 (Subpart B)
-1.7-

-------
mental exposure to toxicants. Therefore, the research conducted can be
described in three functional categories:^
1.	Dose-Response Research — Studies which directly measure the
health effects of specific toxicants. Animal, human, in vitro
and in vivo studies for a large number of endpoints and toxicants
are conducted.
2.	Test Methods Development Research — Studies to develop improved
means of conducting dose—response research. The results of the
test methods development research are used both by ORD's own
researchers and other research organizations to conduct dose-
response research and testing. This includes alternative test
methods development.
3.	Risk Estimation Methods Development Research — Studies to
develop improved means of making the extrapolations from mouse to
man and from high experimental dose levels to lower environmental
exposure levels. The results of the risk estimation methods
development research are used by other offices to perform health
risk estimates as part of the regulatory process.
Food and Drug Administration (FDA)
The FDA is responsible under the Federal Food, Drug, and Cosmetic Act
and the Public Health Service Act for assuring human safety and for the
protection of animals from the harmful effects of chemicals.18 in recent
years, the FDA has used short-term in vitro tests for several purposes:
to set priorities for the selection of chemicals for further testing, to •
aid in the evaluation of equivocal data from rodent bioassays, and in
the determination of mechanisms of action of toxic chemicals. For example,
approximately 700 chemical food ingredients known as GRAS (generally
recognized as safe) were screened for mutagenicity using short-term in
vitro assays, as an assurance that these traditional food ingredients
17 Robert Dixon, Office of Research and Development, personal communication.
Environmental Protection Agency, Office of Pesticides and Toxic Sub-
stances. 1983. Federal Activities in Toxic Substances. EPA-560/TIIS-83-007.
-18-

-------
were not carcinogenic.19 Very few substances on the GRAS list proved
to be genetically active in the in vitro tests, providing assurance
that they were indeed safe. Another example is the "Threshold Assessment
Guideline,"20 which provides for short-term in vitro tests to help decide
which drugs administered to food-producing animals pose a risk of carcino-
genicity. Flamm and Dunkel^l stated that "short-term tests are used
in other areas as well, and are likely to experience even greater use in
the future in terms of making decisions about substances that are already
on the market, as well as those for which approval is being sought."
A November 1983 Acute Studies Workshop sponsored by the FDA produced
position statements on the use of the LD50 test from several FDA divisions.
A spokesman from the Bureau of Foods stated that his division has
no specific testing requirements for cosmetics, and that range-finding
tests are more appropriate than the LD50 f.or food and color additives.
The Bureau has published guidelines for test procedures that discourage
the use of the LD^q.^
The National Center for Drugs and Biologies of the FDA requires only
a general safety test for biologies. The classical LD50 is not mandated
by the Public Health Service Act. At the Acute Studies Workshop, a
spokesman for the Center said that no suitable alternative methods to
animal tests exist at present for drugs (which fall under the Food,
Flamm, W. G., and Dunkel, V. C. 1983. Impact of short-term tests on
regulatory action. Annals N. Y. Acad. Sci. 406: 395-397.
20	Food and Drug Administration. 1982. Chemical compounds in food-producing
animals: availability of criteria for guidelines. Fed. Regis. 47: 4972-4977.
21	Ibid.
22	Food and Drug Administration. 1983. Toxicological Principles for the
Safety Assessment of Direct Food Additives and Color Additives Used in
Food. NTIS PB-83-170-696.
-19-

-------
Drug, and Cosmetic Act), but that the intent is to use the smallest
possible number of animals. For most new drugs, an estimate of the LD^g
value is all that is required. The LD5Q is specifically required for
batch testing of a few antitumor drugs, and some regulations may possibly
mislead companies into believing the LD^q is required for all drugs.
The FDA is considering eliminating this limited requirement and is rewriting
its other regulations to clarify its position on the LD50'
The Bureau of Veterinary Medicine regulates drugs used to treat
animals, and chemicals used as additives in animal feed. It has no require-
ment for the LDso* and emphasizes low-dose chronic testing of any substance
that can become a component of human food, because it remains as a
residue in animals used as food.
Department of Transportation (DOT)
DOT regulates the shipment of hazardous materials in commerce under
the Hazardous Materials Transportation Act. The Office of Hazardous
Materials Regulation requires some toxicity testing and participated
in the FDA workship on acute studies in November 1983. Test conditions,
types of animals, and minimum number of animals to be used are specified
in its hazardous materials regulations.24 DOT classifies hazardous
materials as either Class A or Class B poisons. Class A poisons are
poisonous gases or volatile liquids, for which exposure to the vapors is
dangerous at very low levels. DOT does not require LD50 data for Class A
poisons. Class B poisons are liquids or solids known to be toxic to
humans or animals, and which may therefore create a potential hazard during
transport. For hazard Class B poisons, acute oral, inhalation, and skin
1
23	Norman, C. 1984. Science 225; 1005.
24	49 CFR 171-179.
-20-

-------
absorption tests are required, but not specifically an LD5q. Some acute
lethality tests are, however, performed to comply with DOT regulations.
Consumer Product Safety Commission (CPSC)
The CPSC regulates toxic chemicals under the Federal Hazardous Sub-
stances .Act (FHSA). Toxicity data are required for labeling purposes and
regulations specify the test conditions-, the animal, and the minimum
number of animals required for testing.25 The CPSC recently published a
statement of policy on animal testing which "is intended to reduce the
number of animals tested to determine hazards associated with household
products and to reduce any pain that might be associated with such testing."
The policy statement further encourages the use of existing alternatives
to animal tests, including "prior human experience, literature sources
which record prior animal testing or limited human tests, and expert
opinion."
When animal testing is found to be necessary, the CPSC has implemented
the following procedures: (1) Acute toxicity is determined by a limit
test rather than a classical LD50 test. This reduces the number of
animals used from 80-100 to 10-20, and is acceptable because the FHSA
and CPSC regulations do not require a precise LD5Q. (ii) Eye irritancy
testing is not performed if a product is known to be a primary skin irritant
since the latter are usually also eye irritants. When eye irritancy testing
is required the animals are treated with an opthalmic anesthetic to reduce
their pain and suffering, (iii) The use of stocks for restraint of animals
during skin irritation testing has been eliminated. This allows free
25	16 CFR 1500-1512.
26	Consumer Product Safety Commission. 1984. Fed. Regis. 49: 22522-22523.

-------
mobility and access to food and water, and has eliminated the stress and
dehydration previously encountered. The CPSC encourages manufacturers of
products subject to the FHSA to adopt similar procedures.
B. The Animal Welfare Community
The animal welfare community consists of diverse groups, including
antivivisectionist organizations, humane groups, and animal rights
advocates. There is a spectrum of positions within the animal welfare
community. Some groups favor complete abolition of all animal testing
and research based on social and ethical concerns. Other groups acknow-
ledge a necessity for animal research and testing, but propose a reduction
of the numbers and suffering of the animals used in toxicity testing.
Numerous animal groups have coordinated their efforts to achieve elimination
of specific tests which they find particularly offensive, such as the
Draize Eye Irritancy Test and LD5Q Acute Toxicity Test. The following
represents a very small sample of the numerous organizations devoted to
protecting the welfare of animals.
Ethical Issues and Animal Rights
Ethical arguments against the use of animals in testing and research
have been based on assertions of basic rights that animals possess and
which are denied in the conduct of animal experimentation. How these
rights are defined depends on philosophical perspective, and varies from
a complete right to life to a less sweeping right to freedom from pain.
There is general agreement, though, that the use of animals in painful
research and testing or for perceived trivial purposes is immoral.
Dr. Thomas Regan, Professor of Philosophy and Religion at North
Carolina State University, articulated the position of those who define
-22-

-------
animal rights very broadly at an NIH-sponsored meeting on "Trends in
Bioassay Methodology" in 1981.^6 He disagreed with scientists who speak
of animals as "models" or "tools," seeing this as a "symptom of our
vanity or our insecurity to suppose that they are here for us as models,
as tools for us, a gift of a thoughtful deity or a beneficent evolutionary
scheme." He argued that animals are like humans in morally relevant
ways. "Their life has a value to them independent of their utility to
us. They can be harmed, not only by being made to suffer, which is an
important consideration, but by being denied various opportunities."
He cited denial of the liberty to move around and the premature ending
of their lives as examples of a notion of harm that is "more extensive
than the notion of suffering."
The central point of his argument is that one cannot justify using
animals for research purposes merely because it benefits humans. The
benefits that derive from harming others is never an adequate justification
of that harm. He also noted that "it is a pernicious prejudice to discrim-
inate against human beings on the basis of their sex or on the basis of
their race." He argued that "if we accept this — if we get to the
point where we say biological differences don't mark moral boundaries —
then we can't rationally hold that belonging to a particular biological
species (Homo sapiens) makes us morally superior. No mere biological
difference, even species membership, marks any moral boundary."
The term "speciesism" has been used by Peter Singer^7 to describe "a
26	Regan, T. 1981. In "Trends in Bioassay Methodology: In Vivo, In Vitro,
and Mathematical Approaches," pp. 115-119. Department of Health and Human
Services, Public Health Service, NIH Pub. #82-2382.
27	Singer, Peter. 1975. "Animal Liberation: A New Ethics for our Treatment
of Animals." New York: New York Review.
-23-

-------
prejudice or attitude of bias toward the interests of members of one's
own species and against those of members of other species," a prejudice
"immoral and indefensible in the same way that discrimination on the basis
of race is immoral and indefensible." Singer argues that the capacity for
suffering and/or enjoyment or happiness is the essential characteristic that
gives a being the right to equal consideration. The limit of sentience
is the only defensible boundary of concern for the interests of others.
In his view, this boundary cannot be drawn so as to include only humans.
Fund for the Replacement of Animals in Medical Experiments (FRAME)
FRAME was established in England in 1969 as an independent charitable
institution to promote the concept of alternatives to animal testing; it
concentrates its efforts on scientific research organizations. FRAME does
not consider itself an antivivisection organization and does not oppose
medical and veterinary research on animals nor animal testing of drugs
and chemicals when essential for continued progress against disease and
for the protection of human safety. FRAME supports research on alterna-
tives in England and in the United States, and has been very influential
in the animal alternatives debate in both countries. The FRAME Toxicity
Committee Report28 Qf November 1982 concluded:
Although animal models are of limited value in predicting
toxic hazards for man, there is as yet little evidence that
it will be possible in the foreseeable future to dispense
entirely with live animal testing... Total abolition of the
need for animal experimentation is a longer term goal, since,
with few exceptions, alternative approaches and methodologies
are not yet developed to the point where they could conceivably
be considered as adequate total replacements.
The Committee recommended maximum scientific use of every animal
28 In "Animals and Alternatives in Toxicity Testing" (eds. Balls, Riddell,
and Worden), pp. 501-540. New York: Academic Press, 1983.
-24-

-------
that has to be used in any form of toxicity testing, and stated that
formal LD50 tests should not be required for most pharmaceuticals and
many other chemicals and "should be replaced by more meaningful acute
toxicity studies involving the use of fewer animals."
Coalition to Abolish the LD50 and Draize Tests
A large number of animal welfare organizations are affiliated with
this coalition, whose primary goal is the abolition of the LD^q Acute
Toxicity Test. With respect to the LD50, this group has an uncompromising
point of views that the LD50 is archaic and should be abolished. The
Coalition asserts that this test, because of its focus on lethality as
the endpoint, provides no information about affected organs, symptoms,
or long-term effects. It urges the substitution of the Approximate
Lethal Dose (ALD) or limit test. The Coalition asserts there is consensus
in the scientific community that the LD50 is useless and should be
replaced by alternative testing methods.29
The Coalition's rhetoric has in general been more aggressive than
its negotiating style. It has been willing to compromise to promote
dialog between scientists and animal activists, and has recognized that
progress will be gradual and dependent upon further advances in the
science of toxicology. For example, in 1980-1981 the Coalition conducted
a campaign against the Draize Eye Irritancy Test. It played a major role
in persuading the Revlon Corporation, the primary target of the campaign,
to award a $750,000 grant to Rockefeller University for a research program
to investigate alternatives to the Draize test. This agreement ended the
29
Open letter from Henry Spira, Director, Coalition to Abolish the LD^q,
September 15, 1983.
-25-

-------
unfavorable publicity that the cosmetic industry had attracted during the
campaign, elevated the awareness of the scientific community to the issue
of animal alternatives, and initiated changes in the use of the Draize
test in industry, such as increased use of anesthesia.
United Action for Animals
This animal welfare organization was founded specifically to promote
alternative methods of testing and research, and has focused on methods
which can ultimately be "replacements" for animal techniques. It
drafted the Research Modernization Act (H. R. 556), which was first
introduced in 1980. If passed, 30-50% of all federal funds for research
and testing that use live animals would have been diverted to create a
National Center for Alternative Research.30 This bill also would have
eliminated or minimized duplication of experiments with live animals.
The Humane Society of the United States
The Humane Society promotes the "3 Rs" interpretation of alternative
testing as the soundest approach to accomplishing a reduction in the
use of animals for toxicity testing. They recognize that "reduction"
and "refinement" are interim steps towards the ideal of total replace-
ment of animal tests. As its principal effort in the area of toxicity
testing, the Society has focused on the elimination of the LD50 and
Draize tests. In a recent Humane Society position paper, their technical
"ii
and ethical criticisms of the LD50 are presented. The LD^q is
30 Zola, J. C., Sechzer, J. A., Sieber, J. E. , Griffin, A. 1984. Animal
Experimentation: Issues for the 1980s. Science, Technology, and Human
Values _9: 40-50.
The Humane Society of the U. S. 1984. Fact Sheet: Classical LD^q
Acute Toxicity Test. Washington, DC.
-26-

-------
described as unnecessary for protecting human health. The Society asserts
that "biological differences between animals and humans severely limit
the usefulness of LD50 data in safety testing." It further criticizes
the LD50 as having little use for medical diagnosis and treatment.
(For example, little or no information is yielded from the LD50 about
poisonous or lethal doses for humans, symptoms of overdoses, long-term
effects, etc.) The LD50 is also seen to be unreliable because of
experimental variables, and test results are consequently often invalid.
The Society's ethical objections to the LD50 can be summarized: (i) It
causes needless pain and suffering, (ii) it wastes animal life, and
(iii) alternatives are available, such as the Approximate Lethal Dose,
the limit test, computer-based predictive systems, and cell culture
methods. The Society suggests that the primary reason for the continued
use of the LD50 is "bureaucratic inertia", and that when regulatory
requirements or guidelines recommending its use are eliminated, the LD^q
will be soon abandoned by the scientific community.
With respect to the Draize test, similar objections are raised by the
Humane Society.32 The technical flaws of the Draize test identified by
the Society include: (i) the results of eye-irritancy testing on rabbits
are of questionable applicability to the human situation, (ii) the test
lacks fine discrimination, and (iii) test results are difficult to reproduce
and, as a result, unreliable. The Society cites the great suffering of
the subject animals and the availability of non—animal alternatives as
ethical objections to the Draize test.
32 The Humane Society of the U. S. 1985. Fact Sheet: Draize Acute Eye-
Irritancy Test. Washington, DC.

-------
C. The Chemical, Pharmaceutical, and Cosmetic Industries
Since the manufacturers of chemicals, drugs, and cosmetics perform
most of the toxicity testing required by law, there are clear economic
incentives for them to replace whole-animal tests with less expensive
short-term in vitro methods. However, there are reasons other than
compliance with the law for these companies to test their products prior
to marketing, which may lead to increased animal testing. First, manufac-
turers want to develop products that consumers will like and buy again.
Second, manufacturers need to establish safety substantiation records to
protect themselves against product liability suits. Evidence of a viola-
tion of a health or safety regulation is tantamount to establishing
liability if the product can be shown to have caused an injury. Therefore,
federal "guidelines" tend to become de facto requirements for certain
kinds of testing, regardless of the good intentions of regulatory agencies
to maintain flexibility. Third, some companies may be hesitant to employ
alternative methods because they wish to avoid risking rejection of
their products by regulatory agencies. Also, many products come under the
jurisdiction of several agencies, and the manufacturer must therefore
comply with the strictest regulations. This kind of risk-averse behavior
is understandable when the massive investment necessary to market a product
is considered. These factors explain the concern about inconsistencies
and ambiguities in regulations which may cause unnecessary, excessive, or
dulicative animal testing. The positions on animal testing of several
trade associations follow.
Pharmaceutical Manufacturers Association (PMA)
PMA's position on the role of the LD50 in drug safety evaluation is
-28-

-------
enunciated as follows
Although there is no adequate substitute for acute toxicity
studies involving the use of laboratory animals, a review
of the utility of the precise LD50 test reveals that neither
the toxicologist nor the clinical pharmacologist needs a
precise LD50 value. In consideration of the final use of
the data, carefully controlled and professionally performed
acute experiments can be conducted which require fewer animals
and yet are more meaningful and relevant to the introduction
of therapeutic agents than the LD50 test. Regulatory require-
ments should accommodate this position.
Chemical Manufacturers Association (CMA)
The CMA represents over 200 companies, which produce more than 90%
of the chemicals manufactured in this country. At the Acute Studies
Workshop sponsored by the FDA in November 1983, a CMA representative
held that traditional tests have provided a great deal of useful informa-
tion to the industry, and that there are no readily available alternatives
to the LD5Q. However, CMA sponsors a number of activities which effec-
tively reduce the number of animals used in toxicity testing. For example,
CMA has developed a comprehensive system for cooperative testing among
its member companies. Any member may suggest a cooperative testing
effort for a particular compound. CMA then informs other manufacturers
of the request, and if there is sufficient interest, CMA decides the feasi-
bility of the proposed project and is responsible for its administration.
Joint testing acts to reduce the number of animals used in testing, and
at the same time saves money for the companies involved. The agreement
allows for some confidential information such as production capacity
and sales volume to be kept secret by participating companies.
U. S. Food and Drug Administration, Office of Science Coordination.
Final Report on Acute Studies Workshop, Nov. 9, 1983, p. 6.
-29-

-------
Cosmetic, Toiletry, and Fragrance Association (CTFA)
The cosmetics industry has been a special target of animal welfare
advocates. They have been especially vocal in opposition to two tests
commonly performed by companies in this industry — the LD50 acute
toxicity and Draize eye irritancy tests. The LD50 test measures the
dose (in a single administration) that kills 50% of a test group of
animals. The Draize test is designed to provide information about eye
irritancy caused by test materials (chiefly ingredients in cosmetic
products) by exposing the eyes of rabbits to the materials. A well-
organized campaign against the Draize eye irritancy test attracted public
attention to the animal testing practices of cosmetic manufacturers.
Consequently, CTFA has been active in the alternative testing debate.
Most prominent among its activities in this area was an award of one
million dollars to the Johns Hopkins Center for Alternatives to Animal
Testing. The following statement made by a CTFA representative during a
symposium on animal alternatives summarizes their position.^
Both as a matter of good business practice and because of
legal requirements, cosmetic manufacturers are concerned to
market safe products. Unfortunately, safety substantiation
sometimes requires the use of animal testing. Cosmetic manu-
facturers would like to avoid such use of animals in the
development of their products. Cosmetic companies share their
customers' concerns for the humane treatment of animals. Our
companies would like to reduce to the irreducible minimum the
use of animals in the testing of cosmetics. Nevertheless,
at present, animal testing is sometimes the only acceptable
means for assuring the safety of consumer products such as
cosmetics.
With respect to the LD50, CTFA's Board of Directors released the
following statement: "All manufacturers of cosmetic, toiletry, and fragrance
34 McNamara, S. H. 1983. Legal Requirements for Safety Testing of Cosmetics.
In "Product Safety Evaluation," (ed. A. M. Goldberg). New York: Mary Ann
Liebert.
-30-

-------
products are encouraged not to use the LD50 test except in those cases
where this specific test is essential to provide appropriate assurance
for consumer safety."35
D. The Not-for-Profit Research Community
Within this community, there is widely varying opinion regarding the
potential of alternative tests. Most members of the research community
express a need for continued use of animals, at least in some areas of
research and testing, for the foreseeable future. The testing of drugs,
for example, is often cited as not amenable to alternative techniques,
because pharmacological activity may be systemic and therefore impossible
to identify in simple in vitro systems. There is, however, considerable
disagreement about the extent to which alternative methods may be appropriate
for particular applications, and there is optimism that in the area of
reduction and refinement of animal testing, progress is possible.
National Institutes of Health (NIH)
Dr. James Wyngaarden, Director of NIH, in a letter to Sen. William
Proxmire,36 described the activities supported by NIH for the reduction
of animal use in toxicity testing. Examples that he cited included the
"International Program to Evaluate Short-Term Tests for Carcinogenicity"
and efforts to apply methods that use a limited number of animals. The
latter is illustrated by the benzidine carcinogenesis testing protocol,
results from which will allow generalization to a whole class of chemicals
and eliminate the need to test the chemicals in this class individually.
35	U.S. FDA, Final Report on Acute Studies Workshop, Nov. 9, 1983, p. 5.
36	in Touch... New Methods in Toxicology. 1982. Vol. 1(2): 7.

-------
In vitro tests are presently being used to screen chemicals for mutagenic
activity in order to establish priorities for 2-year animal studies.
The following practical results from NIH's efforts to reduce animal
testing were outlined by Dr. Wyngaarden:'reduction in reliance on the
LD50 for acute testing data by the National Toxicology Program (NTP);
adoption by the NTP of in vitro tests for genotoxicity; development of
various cell and organ culture systems for testing teratogens at the
National Institute of Environmental Health Science.
Dr. Wyngaarden expressed the opinion that in vitro systems will not
supplant animal tests in the near future. They are more likely to be
useful as screens, which may restrict the use of animals to the confirma-
tion of likely human risk. This will certainly reduce the number of animals
used in testing. He stated further
Animal research has contributed directly to a trend toward decreas-
ing use of animals by leading researchers to non-animal systems
where molecular questions can be answered... Progress in biomedical
research requires that we work within systems which will yield useful
information. As in the area of biological testing, we do not believe
that animals can be totally eliminated from biomedical research - or,
if we remain committed to the fullest benefit from that research, that
they should be.
The NIH has contracted with the National Academy of Sciences for an
evaluation of nonmammalian models in biomedical research. This is an
investigation of the opportunities for and limitations of the use of
lower organisms, in vitro methods, and nonbiological systems as models
for biomedical research. The conclusions of this study will certainly
have important implications for animal toxicity testing. The report
was released in April 1985.
The National Cancer Institute (NCI) has enumerated its activities
37 Ibid.
-32-

-------
encouraging the reduction of animal usage in research.38 Programs investi-
gating the replacement of testing in mice with in vitro tests include: A
$3.2 million evaluation of the clonogenic assay; $500,000 per year for
correlation of in vivo and in vitro screening models; $170,000 per
year to perform biochemical and in vitro tests as adjuncts to animal
tests for screening chemical compounds; assistance projects for in vitro
methods such as $500,000 per year to a Request for Applications for
grants in the area of multi-drug resistant human tumor cell lines, and
5425,000 to screening models for cancer chemotherapy drug development.
The Division of Cancer Cause and Prevention spends $3.1 million per year
on cell culture, bacterial, and other non-animal systems for testing
carcinogens, mutagens, and cancer promoters, and for mechanistic studies.
The Clinical Pharmacology Branch reported at a 1983 FDA Acute Studies
Workshop that it focuses on the maximum tolerated dose (MTD) rather
than the LD50 in tests for anti-cancer drugs. One tenth of the LDjq
(10% lethality) in mice is used to establish the starting dose for
clinical trials.39
National Center for Toxicological Research (NCTR)
This organization is the primary research and testing division of FDA.
Dr. Ronald Hart, Director of NCTR, responding to a letter from Henry Spira
of the Coalition to Abolish the LD50, stated that the NCTR is developing
alternative tests and is trying to reduce the trauma to animals in present
testing protocols.^0 Examples cited were: administration of volatile or
38	Memorandum, April 12, 1983, from J. Paul Van Nevel, Assoc. Dir. Cancer
Communications, NCI, to James Willett, Division of Research Resources, NIH.
39	u. S. FDA. Final Report on Acute Studies Workshop, Nov. 9, 1983, p. 4.
in Touch... New Methods in Toxicology. 1982. Vol. 1(2): 7.
-33-

-------
unstable chemicals by microencapsulation in food rather than by gavage;
statistical methods that allow determination of toxicity values with
fewer animals; in vitro methods for teratogenicity; and cell and organ
culture systems. To quote Dr. Hart, "in the foreseeable future we will
not be able to entirely eliminate the use of animals in the field of
toxicology, but as we understand more about the. mechanisms upon which
toxicity is based, we will be able to better mimic these systems outside
of the animal."
National Toxicology Program (NTP)
The NTP is a Department of Health and Human Services cooperative effort
consisting of the relevant toxicology activities of the National Institute
of Environmental Health Sciences (NIEHS) of NIH, the FDA's NCTR, and the
National Institute for Occupational Safety and Health (NIOSH) of the
Center for Disease Control (CDC). The major part of NTP's budget is
devoted to toxicity testing, with a significant portion spent on methods
development and validation. The Program represents "a leading effort in
the world aimed at developing better, faster, and less expensive methods
for determining whether chemicals may be hazardous.
Through coordination of the toxicology research and testing activities
of its member agencies, NTP improves testing of toxic chemicals and
provides better information for risk estimation. NTP communicates actively
with other federal agencies and the private sector, and thus helps to reduce
duplication of efforts and avoid unnecessary testing. As part of its
function, NTP annually publishes a Review of Current DHHS, DOE, and EPA
Research Related to Toxicology. The EPA research reported in this NTP
National Toxicology Program Annual Plan, Fiscal Year 1984, p. 7.
U.S. Department of Health and Human Services, Public Health Service.
-34-

-------
document is that conducted by the Office of Health Research in ORD.
EPA and NIP cooperate in a number of ways. For example, the NTP/EPA
Clearinghouse on Phthlates is an effort to coordinate information from
research on the toxic effects of these compounds. NTP also tests chemicals
that have been identified by EP,A in priority hazardous waste sites,
under the Comprehensive Environmental Response, Compensation, and Liability
Act (Superfund). Scientists from EPA were involved in the formulation
of the Benzidine Dye Initiative, which is a study of the metabolism and
toxicology of a class of dyes derived from benzidine.
Representatives from EPA and a number of other government agencies
serve on the Chemical Evaluation Committee (CEC) of the NTP. The Committee
evaluates chemicals that have been nominated for testing by federal or
state agencies, industry, labor, or the public, and recommends the types of
testing to be performed. Following opportunities for public comment
and peer review of the CEC's recommendations, the NTP Executive Committee
makes final decisions on whether to test nominated chemicals.
The National Society for Medical Research (NSMR)
The NSMR is a professional association of medical researchers. In a
position paper on animal research,^2 the Society indicates that data
from in vitro tests will always be imperfect because of the complex and
interrelated actions by and on the chemical in the intact animal, and
therefore in vitro tests are inadequate for toxicity testing. They argue
that the possibility of false negatives, due to the simplicity of in vitro
testing models, makes it unwise and scientifically unsound to substitute
in vitro tests for animal test methods. In vitro tests may serve to reduce
42 Adjunct Methods of Testing and Research: An Open Letter. 1982.
Published by the National Society for Medical Research.

-------
animal testing in certain types of simple toxicology testing, for example
in testing for irritancy, butbeyond this, there is difficulty. In vivo
and in vitro testing methods can be complementary; however, the NMSR
believes that the use of in vitro methods alone erroneously assumes a
more complete state of knowledge of structure and function of living
beings than scientists now possess. The NSMR believes "adjuncts" rather
than "alternatives" is a more accurate description of' in vitro tests, as
used by "individuals who believe that it is possible to use laboratory
tests to replace animals in research and testing to improve and protect
human and animal life."^3
American Psychological Association (APA)
APA has advocated a "balanced and deliberative approach" to the
humane treatment of laboratory animals, in which there must be a sound
basis for rejecting current research methods and no risk of jeopardizing
productive research.^ The absence of alternatives reflects the "neces-
sarily slow process of developing such alternatives." APA supports the
NAS study provision of the NIH reauthorization bill which will improve
the data base for policy decisions relating to the use of animals in
research. "Alternative methods for studying behavior for the most part
are not feasible. Studying behavior requires studying live animals."
The Johns Hopkins Center for Alternatives to Animal Testing
The Center was established with a $1 million grant from the Cosmetic,
Toiletry, and Fragrance Association. The role of the Center is to conduct
43 Ibid.
Position Statement on Animal Research Legislation. Published by the
APA Office of National Policy Studies on Animal Research Legislation,
Dec. 1983.
-36-

-------
an "independent, impartial search for alternatives to animal testing"
with a focus on basic research to arrive at a better understanding of the
mechanisms of toxicity.^ The Center's Director, Dr. Alan Goldberg, has
cautioned that "As a practical matter there will be a need to rely
on animal tests for some time to come to protect the public, and to advance
the frontiers of medical knowledge."
Scientists' Center for Animal Welfare
This group was established in 1978 in an attempt to persuade the scien-
tific community to adopt a balanced and nondefemsive attitude regarding
animal welfare. The following excerpts describe the objectives and
functions of the Center.46
The major objective is to help sensitize scientists to the issues
involved in the humane treatment of animals. It stands on the
general principle that all matters of public concern should be
freely discussed, and that scientists themselves should take the
initiative in establishing and maintaining a high credibility and
accountability in matters of public conscience.
The functions of the Center are to foster humane stewardship
of animals by educating scientists and the public about animal
welfare; to promote intelligent and humane decisions in establishing
public policy; to collect and exchange scientific information rele-
vant to animal welfare; and to encourage universities and professional
schools to offer courses on the ethical aspects of our interrelation-
ships with animals and on the technical skills involved in handling
animals.
45	Goldberg, A. M. 1983. The Johns Hopkins Center for Alternatives to
Animal Testing. In "Product Safety Evaluation" (ed. A. M. Goldberg), pp.
3-14. New York: Mary Ann Liebert.
46	Dodds, w«» and	Orlans, eds. 1982. In the Preface to "Scientific
Perspectives in Animal Welfare." New York: Academic Press.
-37-

-------
III. REGULATORY POLICY ISSUES
Regulatory policy Issues emerge as changes occur in the use of
animals in toxicity testing and research. The material assembled in the
previous section provides necessary background for use in developing
solutions to the following problems.
1.	ISSUE: Agency-wide criteria for the evaluation and adoption of
alternative toxicity testing methods
Scientific criteria for establishing the usefulness of an alternative
toxicity test should be based on (1) ability to demonstrate a toxic
effect, (2) sensitivity, (3) reproduclblity, (4) extent of application,
(5) ease of standardization, and (6) cost. A new test should be at
least as good as existing toxicity tests to ensure that human and environ-
mental safety are not compromised. It is important that a formal process
for validation of alternative methods be established that applies specific
criteria for measuring a test's effectiveness.
2.	ISSUE: Periodic review of toxicity testing methods.
Upon validation, an alternative method may be incorporated into
testing protocols utilized for regulatory purposes. It is important
that both new test methods and currently used methods be periodically
reviewed to assess their reliability in predicting human or environmental
hazards. As a new method is used to test chemicals, more reliable infor-
mation about its ability to assess toxicity will be obtained. Some
refinements in the methodology may be needed, or perhaps replacement
with a method that more accurately predicts human and environmental
health effects. Likewise, new technology may make older test methods
-38-

-------
obsolete, either because of technical superiority or lower cost. The
periodic review of testing methods should involve a commitment to modify
or discard tests that are not cost-effective or do not provide good
indications of hazard.
3.	ISSUE: Consistency of policy among federal agencies
Each federal regulatory agency operates under different legislative
mandates. Toxicity testing practices reflect this diversity of responsi-
bilities. There is, however, consensus in the scientific and regulatory
community that precipitous elimination of the use of animals would diminish
the scientific quality of toxicity evaluation, and increase the risk to
humans and to the environment. At the same time, it is generally held
that some reductions, refinements, and, ultimately, replacements of
animal tests are possible. This consensus suggests that despite the
constraints of each regulatory agency's statutory authority, it may be
possible to articulate a general federal policy on alternatives to animal
toxicity testing. At a minimum, it should be possible to formulate
general guidelines on the development and adoption of alternative methods.
4.	ISSUE: The relationship of federal to other governmental regulations
and guidelines on the performance of toxicity testing.
The creation of trade barriers in particular industries is possible
when international toxicity testing practices vary. For example, as a
result of perceived inadequacies in the testing protocols of one country,
a product manufactured in that country may not be approved for sale in
another. A large country with a significant market for a product can
-39-

-------
influence the testing procedures of manufacturers. Manufacturers will
naturally seek the largest market possible for their products, and may
employ stringent testing protocols to ensure the broadest product
approval.
The previously mentioned "Change in Test Standards Policy" (p. 12)
allows manufacturers to employ TSCA, FIFRA, or OECD guidelines for test
protocol development to comply with TSCA testing requirements. FIFRA
testing requirements for pesticide registration are not as flexible,
however, nor are many of the testing requirements of other federal agencies.
Compliance with both federal and international toxicity testing requirements
can therefore be complex and often redundant. Consistent international
guidelines on toxicity testing might alleviate some of these problems.
5. ISSUE: Access to data relevant to alternative test development and the
dissemination of such information.
Numerous agencies require toxicity testing to carry out their legisla-
tive mandates. The existence of a variety of bibliographic computer
data bases greatly facilitates the search for information on alternative
methods. It is possible to rapidly obtain a comprehensive list of journal
articles, conference reports, and research proposals on any subject
(see Appendix A). A number of these data bases are devoted to toxicology,
and many to biomedical research. However, since the emphasis of most
reports is on basic research, more often than not the authors do not
discuss the potential applications of their research results to toxicity
testing. This problem can be circumvented by carefully designing the
search strategy to include a variety of descriptors, 60 that mo6t of the
relevant reports are identified. With practice, and particularly with
-40-

-------
the assistance of information specialists, an extensive literature for
methods that have potential as alternatives can be surveyed.
The primary method of evaluation of new chemicals for regulation
under TSCA is most often SAR analysis. SAR analysis is seriously handi-
capped by the absence of a large data base containing toxicologic test
data, physical chemical property data, and quantitative structure-activity
relationship (QSAR) descriptors. Available substructure and nomenclature
search systems, such as the SANSS data base on the Chemical Information
System (CIS), restrict searchable parameters to chemical names, name
fragments, substructural components, molecular formulae, etc. Although
these systems are invaluable, they do not contain all of the data needed
for SAR analysis. Automated screening to identify analogs of new chemicals
using physical chemical properties is therefore not possible. This makes
the identitication of appropriate analogs to new chemicals, upon which a
subsequent literature search for toxicological data is based, a difficult
and laborious process. An effective system for obtaining this information
would improve confidence in SAR analysis and, because the majority of
decisions requiring further toxicity testing for new chemicals are' based
on SAR analyses, probably reduce the need for animal toxicity tests.
An information system on toxicological methods development would ease
access to data and foster the elimination of duplication in testing.
Also, a specialized quantitative SAR database would improve the quality
of SAR analysis.
6. ISSUE: Identifying alternative testing methods from studies of environ-
mental effects of toxic chemicals.
A great deal of information about toxicity is gained from studies on
-41-

-------
the environmental effects of chemicals. Many of the species studied in
ecotoxicity research (e.g., fish and invertebrates) may be more acceptable
as test species than are mammals. The development of model systems for
studying the mechanisms of toxic effects may be achievable in such species.
Ecotoxicity studies represent a potentially large and promising source
of alternative methods in toxicity testing.
7.	ISSUE: The development of incentives for the transfer of technology
from the laboratory to practical application.
Technology transfer has been defined as the application of basic
research to problems practical in nature.^ The basic research process
of toxicology typically involves devising a model system for use as a
human analog, identification of the toxic endpoint from the model, and
attempts to understand the biochemical mechanism of the toxic effect.
The development of a toxicity test from basic research findings may not
necessarily be the intent of the researcher. Incentives which foster
development of excellent new alternative toxicity tests would be desirable.
8.	ISSUE: Public dialogue about new toxicity testing schemes.
The increase in the number of animals used for toxicity testing
over the last several decades is a direct result of public pressure for
safer consumer products. Many laws designed to protect human and environ-
mental health were passed requiring the manufacturers of new products
to test their products for potential hazard before they reach the market-
^ Brusick, D. 1984. From methodology to assay procedure: the transfer of
technology. Paper presented at the symposium "In Vitro Toxicology," The
Johns Hopkins Center of Alternatives to Animal Testing, Baltimore, MD,
Oct. 23-24, 1984.
-42-

-------
place.
Questions may persist about the reliability of extrapolating data from
alternative tests to human health effects. Unanimity of opinion in the
scientific community about the appropriate use of alternatives is unlikely,
so public debate over the use of alternative methods in regulation may
emerge. As the Agency decides whether or not to approve the use of
particular alternative methods as replacements for currently used test
methods, an effort to engage public discussion of the basis for these
decisions should enable the implementation of testing protocols that
ensure human safety and that minimize the pain and distress of animals.
9. ISSUE: The possible passage of legislation that would require changes
in toxicity testing procedures.
Legislation has been proposed that would limit the use of animals
for toxicity testing and research and would prescribe extensive use of
alternative methods (see Appendix B). In addition, the alternative
testing debate may affect several other pieces of legislation, including
TSCA reauthorization and the research institutions' appropriations. Still
other legislation may require a battery of short-term tests to be conducted
as part of the PMN submission process of TSCA. There are four possible
outcomes with respect to legislative action on alternatives to animal
testing: (i) to eliminate animal use gradually; (ii) to eliminate animal
use precipitously; (iii) to reform the treatment and reduce the numbers
of animals used in research; (iv) or to maintain the status quo.
Although not uniformly favored at present, a "test battery" may be
considered in response to the uncertainties of SAR analysis. A required
-43-

-------
test battery would serve to allow some risk assessment of all new chemicals
based on actual toxicity data. Confidence in the tests included in a
test battery would be broadened as test data accumulated. On the other
hand, the danger of standardization and rigidity is a major disadvantage
of such a test battery. Reduction in flexibility would be unfortunate,
considering the immaturity of development of short-term toxicity tests
and the rapidity of change in this field. It would therefore be critical
to ensure a process for revision and updating of any test battery as the
state-of-the-art improves. Also, a required test battery could quite
possibly lead to more animals being used, since some of the tests utilized
would certainly require the use of animals, and every newly introduced
chemical would need to be tested. An as yet unanswered question is
whether the information derived from a standard battery of tests would
justify the expense of the additional testing.
-44-

-------
IV. CASE STUDY: AVAILABLE RESOURCES FOR THE IDENTIFICATION OF ALTERNATIVE
TOXICITY TESTING METHODS IN NEUROTOXICITY AND BEHAVIORAL TOXICITY
In order to assess the ease of access to information about alternative
techniques in toxicity testing, neurotoxicity and behavioral toxicity
were chosen as the subjects for an extensive literature search, employing
computer bibliographic data bases supplemented with some manual searching.
These areas were selected because they have received less emphasis in
the effort to find testing alternatives than mutagenicity, carcinogenicity,
and reproductive toxicity testing. Also, since fewer assays exist for
neurotoxicity and behavioral toxicity, the search was more manageable
to perform as a case study.
As the expression of extremely complex biochemical and physiological
interactions, behavior is often highly sensitive to toxic chemicals. On
the other hand, many chemicals of known toxicity have no discernible
effect on behavior. Clearly, behavioral tests cannot be solely relied on
to provide information about toxicity. But it is possible that some
behavioral toxicity tests may be better able to detect certain low-level
toxic effects than traditional methods, and would therefore be very
useful as part of a battery of screening tests. Virtually all behavioral
toxicity studies involve the use of live animals. This is not surprising,
since "behavior" requires an intact organism. Many of these studies may
nevertheless be viewed as alternatives, if they lead to reduction or
refinement of animal toxicity tests.
A comprehensive search for data does not, of course, ensure that the
quality of the data is acceptable. After the information is collected,
the next step must be a review by experts to determine which studies have
the greatest potential for the development of alternative tests. Since
-45-

-------
the research is not necessarily directed toward the development of alterna-
tive tests, some mechanism for encouraging investigators to pursue promising
applications to test development should be established.
Appendix A describes the design and performance of the case study,
and specifies the various information resources that identify potential
alternative methods for assessing behavioral toxicity and neurotoxicity.
The opportunities and limitations of the process employed to identify
these resources are discussed. A list of journal reports and research
proposals that were identified in the case study is provided. No attempt
was made to review these studies, other than to verify that they were
relevant to the subject of behavioral toxicity and neurotoxicity. The
task of reviewing this information must be accomplished by experts in
these disciplines.
-46-

-------
Table 2
Acronyms Used in the Report
ALD	Approximate Lethal Dose
APA	American Psychological Association
CDC	Center for Disease Control
CEC	Chemical Evaluation Committee
CERCLA	Comprehensive Environmental Response, Compensation and Liability
Act
CFR	Code of Federal Regulations
CIS	Chemical Information System
CMA	Chemical Manufacturers' Association
CPSC	Consumer Product Safety Commission
CRIS	Current Research Information System
CRISP	Computer Retrieval of Information on Scientific Projects
CSIN	Chemical Substances Information System
CTFA	Cosmetic, Toiletry, and Fragrance Association
DHHS	United States Department of Health and Human Services
DOE	United States Department of Energy
DOT	United States Department of Transportation
EPA	United States Environmental Protection Agency
FDA	Food and Drug Administration
FHSA	Federal Hazardous Substances Act
FIFRA	Federal Insecticide, Fungicide, and Rodenticide Act
FRAME	Fund for the Replacement of Animals in Medical Experiments
GLP	Good Laboratory Practices
GMP	Good Manufacturing Practices
GRAS	Generally Recognized as Safe
LD50	Lethal Dose 50%
-47-

-------
MPD	Minimum Premarket Dataset
MTD	Maximum Tolerated Dose
NCI	National Cancer Institute
NCTR	National Center for Toxicological Research
NIEHS	National Institute for Environmental Health Sciences
NIH	National Institutes of Health
NIOSH	National Institute for Occupational Safety and Health
NSMR	National Society for Medical Research
NTIS	National Technical Information Service
NTP	National Toxicology Program
OECD	Organization for Economic and Cooperative Development
OPP	Office of Pesticides Programs
OPPE	Office of Policy, Planning, and Evaluation
OPTS	Office of Pesticides and Toxic Substances
ORD	Office of Research and Development
OTA	Office of Technology Assessment
OTS	Office of Toxic Substances
PHS	Public Health Service
PMA	Pharmaceutical Manufacturers Association
PMN	Premanufacture Notice
QSAR	Quantitative Structure-Activity Relationship
SAR	Structure-Activity Relationship
SSIE	Smithsonian Science Information Exchange
TSCA	Toxic Substances Control Act
USDA	United States Department of Agriculture
-48-

-------
Bibliography
General References
Ausmus, B. S. , Eddlemon, G. K., Draggan, S. J.f Giddhings, J. M, , Jackson,
D. R. 1980. Microcosms as potential screening tools for evaluating
transport and effects of toxic substances. EPA - 600/3-80-042. ORNL/EPA-4.
Balls, M. , Riddell, R. J., Worden, A. N. , eds. 1983. "Animals and
Alternatives in Toxicity Testing." London: Academic Press.
Best, J. B., Morita, M. 1982. Planarians as a model system for in vitro
teratogenesis Btudies. Teratogenesi9 Carcinog. Mutagen. 2\ 277-291.
Bruslck, D. J. 1983. The use of short-term in vitro and submammalian
tests as alternatives to large scale animal bioassays. Annals NY Acad.
Sciences 406: 68-73.
Caplan, A. L. 1983. Beastly conduct: ethical issues in animal experimen-
tation. Annals NY Acad. Sciences 406: 159-169.
Cohen, B. J. 1984. Pound animals for	research and education. Physiologist
27190-191.
Dagani, R. 1983. Alternative methods	could cut animal use in toxicity
' tests. Chem. & Eng. News, Oct. 31,	v. 61: 7-13.
Diner, J. 1984. A compendium of alternatives to the use of live animals
in research and testing. Brochure of The American Anti-Vivisection
Society and The National Anti-Vivisection Society.
Favre, D. S., Loving, M. 1983. "Animal Law." Westport, CT: Quorom Books.
Flamm, W. G., Dunkel, V. C. 1983. Impact of short-term tests on regulatory
action. Annals NY Acad. Sciences 407: 395-397.
Foundation for Biomedical Research. 1984. The use of animals in biomedical
research. Lab Anim. 13(4): 22-36.
Griffin, A., Sechzer, J. A. 1983. Mandatory versus voluntary regulation of
biomedical research. Annals NY Acad. Sciences 406: 187-200.
Grodsky, P. B. 1983. Public opinion on animal-based research: the unknown
factor in ethical and policy decisions. Annals NY Acad. Sciences 406:
157-158.
Held, J. R. 1983. Appropriate animal models. Annals NY Acad. Sciences
406: 13-19.
Holden, C. 1982. New focus on replacing animals in the lab. Science 215:
35-38.
-49-

-------
Jacobson, E. D. 1984. What the institutional administrator can do to
improve humane animal care. Lab Anim. 13(6): 43-45.
Kaiser, H. E. 1980. "Species-Specific Potential of Invertebrates for Toxico-
logical Research." Baltimore: University Park Press.
Magel, C. R. 1981. "A Bibliography of Animal Rights and Related Matters."
Washington: University Press.
Martin, A. D., Papworth, D. S. 1982. Assessment of mammalian toxicity of
pesticides and other industrial chemicals - flexible guidelines or
rigid protocols? Archives of Toxicology 5: (suppl.) 17-28.
Mattingly, S. F. 1984. Should humane care standards be reviewed? Lab
Anim. 13(6):25-31.
McCarthy, C. R. 1984. What the Public Health Service is doing to improve
humane care. Lab Anim. 13(5): 21-26.
Moor-Jankowski, J., Goldsmith, G. I., Wittrup, L. 1980. Humane method-
ology and conservation of species in maintaining a primate animal labor-
atory for biomedical experimentation: twenty years experience. Dev.
Biol. Stand. 45: 197-202.
Morton, D. M. 1981. Requirements for the toxicological testing of drugs
in the USA, Canada, and Japan. In "Testing for Toxicity" (ed. J. W.
Garrod), pp. 11-19. London: Taylor Francis.
Moss, T. H. 1984. The modern politics of laboratory animal use. Science,
Technology, & Human Values 9j 51-56.
Nardone, R. M., Bradlaw, J. A. 1983. Toxicity testing with in vitro
systems: I. Ocular tissue culture. J. Toxicol., Cutaneous Ocul. Toxicol.
2: 81-98.
National Academy of Sciences. 1984. "Toxicity Testing: Strategies to
Determine Needs and Priorities." Washington, DC: National Academy Press.
National Library of Medicine. 1984. "Laboratory Animal Welfare." Special-
ized Bibliography Series, U. S. Department of Health and Human Services,
Public Health Service, National Institutes of Health. SBS No. 1984-1.
National Library of Medicine. 1985. "Laboratory Animal Welfare — Supple-
ment I." Specialized Bibliography Series, U. S. Department of Health
and Human Services, Public Health Service, National Institutes of Health.
SBS No. 1985-1.
National Toxicology Program. Annual Plans, Fiscal Years 1979-1984, U. S.
Department of Health and Human Services.
National Toxicology Program. Reviews of Current DHHS, DOE, and EPA Research
Related to Toxicology, Fiscal Years 1979-1984, U. S. Department of
Health and Human Services.
-50-

-------
Nethery, L. B., McArdle, J. E. 1985. "Animals in Product Development and
Safety Testing: A Survey." The Institute for the Study of Animal Problems.
Washington, DC.
Obrink, K. J. 1983. Are regulations to protect experimental animals
adequate? Prog. Clin. Biol. Res. 128; 159-166.
Paton, William. 1984. "Man and Mouse: Animals in Medical Research." New
York: Oxford University Press.
Pratt, P. 1976. "Painful experiments on animals." New York: Argus Archives.
Pratt, P. 1980. "Alternatives to pain in experiments on animals." New
York: Argus Archives.
Randall, B. 1984. The use of animals in biomedical research. Issue Brief
no. IB83161, Congressional Research Service.
Regan, T. 1983. "The Case for Animal Rights." Berkeley: University of
California Press.
Rees, K. R. 1980. Cells in culture in toxicity testing: a review. J.
Royal Soc. Med. (London) 73(4): 261-264.
Renner, H. W. 1983. Cell cultures or animal experiment? A comparison and
an evaluation from the genetic-toxicological point of view. Z.
Versuchstierkd 25(1): 1-5.
Ritvo, H. 1984. Plus ca change: antivivisection then and now. Science,
Technology, & Human Values jh 57-66.
Rollin, B. E. 1981. Animal Rights and Human Morality. Buffalo, NY:
Prometheus Books.
Rowan, A. 1977. Animals, alternatives and biomedical research and testing.
World Med. J. 24(4): 55-56.
Rowan, A. 1980. The concept of the three R's: an introduction. Dev.
Biol. Stand. 45: 175-180.
Rowan, A. 1980. Laboratory animals and alternatives in the 80s. Int. J.
Stud. Anim. Prob. _1_(3) : 162-169.
Rowan, A. 1984. "Of Mice Models and Men: A Critical Evaluation of
Animal Research." Albany, NY: SUNY Press.
Rowan, A., Goldberg, A. M. 1985. Perspectives on alternatives to current
animal testing techniques in preclinical toxicology. Ann. Rev. Pharmacol.
Toxicol. 25: 225-247.
Rowan, A. N., Rollin, B. E. 1983. Animal research — for and against: a
philosophical, social, and historical perspective. Perspect. Biol. Med.
27(1): 1-17.
-51-

-------
Rowan, A., Stratmann, C. 1980. "The Use of Alternatives in Drug Research."
London: Macmillan Press.
Sikka, H. C. 1979. Screening methods for toxic substances. ^IS PS
Rep. PS-79, 1029: 83p.
Singer, P. 1975. "Animal Liberation: a New Ethics for our Treatment of
Animals." New York: New York Review.
Smith, A. 1979. Marine Animals in Medical Research. JAMA 242: 2847.
Stewart, W. C. 1984. Legal standards for humane care: the Animal
Welfare Act. Lab Anim. 13(6): 33-41.
Smyth, D. H. 1978. "Alternatives to Animal Experiments." London: Scolar
Press.
Sperlinger, D., ed. 1981. "Animals in Research: New Perspectives in
Animal Experimentation." New York: Wiley.
Stark, D. M. 1983. Developing replacements to whole animal experimental
systems. California Veterinarian 37: 8-90.
Stark, D. M., Shopsis, C. 1983. Developing alternative assay systems for
toxicity testing. Annals NY Acad. Sciences 406: 92-103.
Veith, G. D. 1981. State of the art report on structure-activity methods
development. EPA - 600/3-81-029. NTIS PB81-187239".
Verderbrer, R. F. 1984. Depolarization of humane animal care groups.
Lab Anira. 13(6): 47-51.
Weiss, B., Wood, R. W., Merigan, W. H. 1983. Toxicity evaluation needs
the intact animal. Annals NY Acad. Sciences 406: 82-91.
Zola, J. C., Sechzer, J. A., Sieber, J. E., Griffin, A. 1984. Animal
experimentation: issues for the 1980s. Science, Technology, & Human
Values 9: 40—50.
-52-

-------
Symposia and Conferences on Animal Alternatives
International Conference on Safety Evaluation and Regulation of Chemicals,
Zurich, Nov. 13-16, 1984.	•
Joint American-Swiss Seminar on In Vitro Evaluation of Toxicology and
Teratology, Zurich, Nov. 12, 1984.
Animals and the Scientist: Institutional Responsibilities, Scientists
Center for Animal Welfare, Los Angeles, CA, Nov. 14-15, 1984.
Innovative. Approaches to Biological Testing, Session of Fifth Annual
Meeting, Society of Environmental Toxicology and Chemistry, Arlington, VA,
Nov. 4-7, 1984.
In Vitro Methods in Toxicology, The Johns Hopkins Center for Alternatives
to Animal Testing Third Annual Symposium, Baltimore, MD, Oct. 23-24, 1984.
Third International Workshop on the Application of Tissue Culture in
Toxicology, Urbino, Italy, Sept. 12-15, 1984.
Studies of Development Using Nonmammalian Models, Committee on Models
for Biomedical Research, NAS Workshop, Woods Hole, MA, Aug. 15-17, 1984.
Religious Perspectives on the Use of Animals in Science, American Fund
for Alternatives in Animal Research, London, July 25-27, 1984.
Workshop on Models for the Study of Diseases and Aging, Committee on Models
for Biomedical Research, National Academy of Sciences, Woods Hole, MA,
June 26-27, 1984.
Annual Meeting of the Tissue Culture Association, Joint Sessions with the
Society of Toxicology on "Mechanisms of Toxicity" and "In Vitro Applica-
tions to Toxicity Evaluation," Houston, TX, June 5, 1984.
Workshop on Models for the Investigation of Learning, Committee on Models
for Biomedical Research, NAS, Washington, DC, May 30, 1984.
Model Systems in Cellular Immunology, Committee on Models for Biomedical
Research, NAS Workshop, Washington, DC, April 26-27, 1984.
National Symposium on Imperatives in Research Animal Use: Scientific
Needs and Animal Welfare, National Institutes of Health, Washington, DC,
April 11-12, 1984.
International Workshop on Irritation Testing of Skin and Mucous Membranes,
Kartause Ittigen, Frauenfeld, Switzerland, April 3-5, 1984.
Modeling for Safety and Risk Assessment, Royal College of Physicians,
London, Dec. 4-6, 1984.
Toxicity Testing: Progress Toward Alternative Techniques, London, 1983.
-53-

-------
Alternatives to In Vivo Bioassays for Ri9k Assessment, Forum for Scien-
tific Excellence, Inc., Washington, DC, Nov. 9-11, 1983.
Workshop on Acute Studies: Public Meeting, Food and	Drug Administration,
Washington, DC, Nov. 9, 1983.
Hepatotoxicity - In Vitro Approaches, International	Conference on Safety
Evaluation and Regulation of Chemicals, Boston, MA,	Oct. 24-29, 1983,
In Vitro Applications in Toxicology, Tissue Culture Association, 34th
Annual Meeting, Orlando, FL, June 12—16, 1983.
Animals and Their Alternatives in Research and Testing, Session of the
149th National Meeting of the American Association for the Advancement
of Science, Detroit, MI, May 26-31r 1983.
Acute Toxicity - Purpose and Practice, The Johns Hopkins Center for
Alternatives to Animal Testing, Baltimore, MD, May 24-25, 1983. Proceedings
in "Alternative Methods in Toxicology," vol. 2_, (ed. A. M. Goldberg). New
York: Mary Ann Liebert, 1984.
The Future of Animals in Research and Teaching, Society of Toxicology
Annual Meeting, FASEB, Washington, DC, Dec. 8-10, 1982.
"Animals and Alternatives in Toxicity Testing," (eds. M. Balls, R. J.
Riddell, A. N. Worden). London: Academic Press, 1983. Proceedings of
a Symposium, Fund for the Replacement of Animals in Medical Experiments,
London, Nov. 1-3, 1982.
First CFN Symposium: LD50 and Possible Alternatives. Proceedings in
Acta Pharmacologica et Toxicologica _52, suppl. II, 1983.
In Vitro Alternatives Toxicology Workshop. The Rockefeller University,
New York, Oct. 28-30, 1982.
Cellular Systems for Toxicity Testing, New York Academy of Sciences,
Oct. 1982. Proceedings in Annals of the New York Academy of Sciences,
vol. 407, 1983.
Product Safety Evaluation: Development of New Methodological Approaches,
Johns Hopkins Center for Alternatives to Animal Testing, Baltimore, MD,
May, 1982. Proceedings in "Alternative Methods in Toxicology," vol. _1_,
(ed. A. M. Goldberg). New York: Mary Ann Liebert, 1983.
The Role of Animals in Biomedical Research, New York Academy of Sciences,
Aril, 1982. Proceedings in Annals of the New York Academy of Sciences,
vol. 406, 1983.
Symposium on Trends in Bioassay Methodology: In Vivo, In Vitro and
Mathematical Approaches. U. S. Department of Health and Human Services,
Public Health Service, National Institutes of Health, Dec. 1981.
Proceedings in NIH Pub. No. 82-2382.
-54-

-------
First Conference on Scientific Perspectives in Animal Welfare, Scientists
Center for Animal Welfare, Nov. 1981. Proceedings in "Scientific Perspec-
tives in Animal Welfare," (eds. J. W. Dodds, B. F. Orlans). New York:
Academic Press, 1982.
"Non Animal Research Methodologies." Proceedings of a Symposium, George
Washington University Ethics and Animals Society, Washington, DC, Feb. 18,
1981.
Alternatives to the Use of Laboratory Animals in Biomedical Research and
Testing, Canadian Society for the Prevention of Cruelty to Animals,
April, 1980.
Symposium on the Scientific 3asis of Toxicity Assessment, Gatlinburg, TN,
April 1979. Proceedings in "The Scientific Basis of Toxicity Assessment,"
(ed. H. R. Witschi). Amsterdam: Elsevier/North-Holland Biomedical Press,
1980.
"The Welfare of Laboratory Animals: Legal, Scientific and Humane Require-
ments," Universities Federation for Animal Welfare, 1977. Proceedings
of a Symposium, Potters Bar, England, 1976.
"The Future of Animals, Cells, Models, and Systems in Research, Development,
Education, and Testing," National Research Council - National Academy of
Sciences, 1977. Proceedings of a Symposium, Washington, DC, Oct. 1975.
-55-

-------
Appendix A
Resources for Accessing Information on Alternative Methods -
Neurotoxicity and Behavioral Toxicity
A number of review articles were identified that provide summaries
of available neurotoxicity testing methods. Among the most useful was
the chapter on neurotoxicity in the recent report of the Fund for the
Replacement of Animals in Medical Experiments (FRAME), "Animals and Alter-
natives in Toxicity Testing," (Dewar, 1983). The FRAME report focuses on
alternative techniques and enumerates methods by functional category:
clinical observation and functional/behavioral tests; electrophysiological
methods; neuropathological methods; biochemical methods; tissue culture
methods; and tests in lower vertebrates and invertebrates. Several other
reviews survey testing methods in this field, and include many methods
that can be considered "alternative techniques" (Dewar and Moffett, 1979;
Tilson and Mitchell, 1980; Dewar, 1980; Mitchell and Tilson, 1982; Tilson
and Mitchell, 1984). These articles are authored by recognized experts
who have conducted comprehensive, but not necessarily exhaustive, surveys
of neurotoxicity testing methods.
A search of computerized data bases on the subjects of neurotoxicity
and behavioral toxicity was conducted in order to build an extensive and
current bibliography. The search was limited to the years 1979-1984,
since the review articles thoroughly cover the prior period (as well as
much of the more recent literature), and the goal was to identify all
recent studies that might be useful as alternative methods. The biblio-
graphic data bases searched on the National Library of Medicine and Dialog
vendor systems were: Toxline, Medline, Excerpta Medica, Cancerlit, Life
Sciences Collection, Biosis, Scisearch, NTIS, and Dissertation Abstracts.
-56-

-------
Toxline was the most productive for this subject, and subsequent efforts
were concentrated on this bibliographic data base. Data bases dealing
with research proposals (SSIE and CRIS/USDA) and the Conference Papers
Index were also searched. A truly exhaustive search could include many
other vendors and their component data bases. There are diminishing
returns as the search is extended, however, and computer searching is
expensive. With limited resources, the searcher must decide what consti-
tutes an adequate retrieval of information for the requirements of the
project.
The Chemical Substances Information Network (CSIN) was employed for
the execution of this search. CSIN is not a vendor for databases, but
rather a "data manager". It provides access to a wide variety of vendor
systems and their component data bases through a single source. CSIN is a
particularly useful system for novice data base users, employing an inter-
active "menu" format of commands. It is very "user friendly." However,
its ease of use reduces its flexibility, and limits the applications that
are possible with direct use through individual data base vendors. Never-
theless, CSIN has many useful features available in its "enhanced direct"
mode, which is basically a combination of direct searching with some features
of the CSIN system.
The search strategy was to construct a list of related terms for
each of the following: short-term or alternative assays, neurological
science, and toxic effects, and to retrieve citations that scored at
least one "hit" from each list. A trade-off occurs in the construction
of these lists. The longer the list of terms searched, the more compre-
hensive but less selective the search. Consultation with an information
specialist is recommended to ensure the design of an efficient search,
-57-

-------
sufficiently broad but with a minimum number of "false drops."
The citation lists retrieved were screened manually for reports
describing experiments or tests that have potential as alternative
methods (not necessarily mentioned as such by the authors); reports
whose thrust is the development of alternative toxicity tests; reports
that analyze the validity of alternative tests, or correlate the results
of an alternative toxicity test with standard test results; or reports
of test applications - i.e., the use of existing alternative tests to
assess the toxicity of chemicals.
Once reports had been identified as applicable to alternative testing
for neurotoxicity or behavioral toxicity, they were organized into categories
similar to those described in the FRAME report. These citations are listed
in the bibliography in the following categories: clinical/epidemiological
studies; behavioral/functional observations; electrophysiological or
neuropathological methods; biochemical methods; tissue culture methods;
lower vertebrate and invertebrate studies; and computer models and
structure - activity relationship studies. As can be seen from these lists,
this search retrieved a large number of studies related to behavioral
toxicity, probably reflecting the level of interest in this subject in
the scientific community (but may also be partially due to a bias in the
chosen search strategy).
Several problems were identified that might be commonly encountered
in information access and collection. A few of these have been mentioned
in the preceding discussion, and generic problems were discussed in the
Policy Issues section of the present report. A few specific problems
related to this particular search will be mentioned.
The data bases that were searched provided varyingly useful information.
-58-

-------
Toxline was the best journal literature data base for a survey of toxicity
tests. Medline, Excerpta Medica, Life Sciences Collection, and the others
mentioned earlier did not cover this particular field nearly as well, and
seldom produced information that had not already been retrieved on Toxline.
The Conference Papers Index was difficult to screen because abstracts are
not included in this database. That is unfortunate because conference
reports, although often not peer-reviewed, represent the most current
research results of scientific investigators. The research proposal data
base, SSIE, is completely out-of-date, inasmuch nothing has been added to
it since 1982. CRISP and CRIS/USDA, which contain exclusively grant proposals
supported by NIH and USDA respectively, are useful for identifying the
research goals and directions of investigators, but do not provide actual
research accomplishments. The frequency of updating individual data bases
varies, and they are typically several months behind. To include very
recent information, then, a computer search should be supplemented with a
manual search.
-59-

-------
Meetings on Neurotoxicity and Related Topics
Second International Symposium on Nephrotoxicity, Guilford, England,
Aug. 6-9, 1984.
Federation of American Societies for Experimental Biology, 68th Annual
Meeting, St. Louis, April 1984. Abstracts in Fed. Proc. (Mar. 1 and
Mar. 5, 1984).
American Chemical Society, 187th National Meeting, St. Louis, April,
1984.
Environmental Hazards of Agrochenicals in Developing Countries,
International Conference, United Nations Environment Programme, UNESCO,
Alexandria, Egypt, Nov. 1983.
International Society for Neurochemistry, 9th International Meeting,
Vancouver, BC, July 1983. Abstracts in J. Neurochem. (suppl.).
3rd International Congress on Toxicology, 1983. Abstracts in Toxicology
Letters, 1983.
Federation of European Biochemical Societies, 15th Meeting, Brussels,
July 1983.
Neurotoxicity of Workplace^Chemicals, International Workshop, World
Health Organization and the National Institute of Occupational Safety
and Health, May 1983. Monograph in preparation by the WHO Ad Hoc Group
on Neurobehavioral Toxicology.
Federation of American Societies for Experimental Biology, 67th Annual
Meeting, Chicago, April 1983. Abstracts in Fed. Proc. (Mar. 1983).
12th International Congress of Biochemistry, Perth, Australia, Aug. 1982.
Society for Neuroscience, 12th Annual Meeting, Minneapolis, MN, Oct. 1982
6th European Neuroscience Congress, Malaga-Torremolinos, Spain, Sept. 1982.
Abstracts in Neuroscience Letters, 1982.
5th International Congress of Pesticide Chemistry, Kyoto, Japan, Aug. 1982.
American Academy of Neurology, 34th Annual Meeting, Washington, DC, April
1982. Abstracts in Neurology, April 1982.
Society for Neuroscience, 11th Annual Meeting, Los Angeles, CA, Oct. 1981.
In Society for Neuroscience Abstracts, 1981.
Society of Toxicology of Canada, 13th Annual Symposium, Montreal, Canada,
Dec. 1980.
2nd International Congress on Toxicology, Brussels, July 1980. Abstracts
in Toxicology Letters, July 1980.
-60-

-------
The American Society for Pharmacology and Experimental Therapeutics,
1980 Meeting, Rochester, MN, Aug. 1980. Abstracts in The Pharmacologist
22, July 1980.
6th International Histochemistry and Cytochemistry Congress, Brighton,
England, Aug. 1980.
Society of Toxicology, 19th Annual Meeting, Washington, DC, Mar. 1980.
Society for Neuroscience, 9th Annual Meeting, Atlanta, GA, Nov. 1979.
International Congress of Neurotoxicology. Varese, Italy, Sept. 1979.
Proceedings in "Advances in Neurotoxicology," (ed. L. Manzo). New York:
Pergamon Press, 1980.
11th International Congress of Biochemistry, Toronto, Canada, July 1979.
European Society of Toxicology, 21st Congress, Dresden, GDR, June 1979.
Papers in Archives of Toxicology, suppl. May 1980.
Society of Toxicology, 12th Annual Meeting, New Orleans, LA, Mar. 1979.
Abstracts in Veterinary and Human Toxicology, April 1979.
24th 0H0L0 Biological Conference on Neuroactive Compounds and their
Cell Receptors, Zichron Ya'acov, Israel, April 1979.
Workshop on Test Methods for Definition of Effects of Toxic Substances On
Behavior and Neuromotor Function, April 1979. Proceedings in Neurobehav.
Tox. _1_ (suppl. 1). EPA - 560/11-79-010
Target Organ Toxicity: Nervous System, NIEHS, Raleigh, NC, Oct. 1977.
Proceedings in Environ. Health Persp. 26, Oct. 197 8.
-61-

-------
Review Articles and General References
Bignami, G. 1976. Behavioral pharmacology and toxicology. Ann. Rev.
Pharmacol. Toxicol. ^6: 329-366.
Bondy, S. C. 1982. Neurotransmitter binding interactions as a screen for
neurotoxicity. In "Mechanisms of Action of Neurotoxic Substances" (eds.
K. N. Prasad and A. Vernadakis), pp. 25-50. New York: Raven Press.
Brimblecombe, R. 1979. Behavioral tests in acute and chronic toxicity
studies. Pharmacol. Ther. 5t 413-415.
Brimbleconbe, R. W. , Nicholson, A. N., Wright, C. M. 1979. Adverse central
effects of drugs in man: predictive value of behavioral studies in rodents
and primates. Pharmacol. Ther. J5: 455-460.
Buck, W. B., Hopper, D. L., Cunningham, W. L., Karas, G. G. 1977. Current
experimental considerations and future perspectives in behavioral toxi-
cology. In "Behavioral Toxicology: An Emerging Discilpline" (eds. H.
Zenick and L. W. Reiter). U.S. EPA Report 600/9-77-042.
Buelke—Sam, J., Kimmel, C. A. 1979. Development and standardization
of screening methods for behavioral teratology. Teratology 2£: 17-30.
Butcher, R. E. 1976. Behavioral testing as a method for assessing risk.
Environ. Health Perspect. JU8: 75-78.
Butcher, R. E., Wootten, V., Vorhees, C. V. 1980. Standards in behavioral
teratology testing: test variability and sensitivity. Teratogenesis
Carcinog. Mutagen. 49-61.
Cairncross, K. D., Cox, B., Forster, C., Wren, A. F. 1979. Olfactory
projection systems, drugs and behavior: a review. Psychoneuroendocri-
nology (Oxford) _4: 253-272.
Damstra, T. 1978. Neurochemistry and toxcology: overview. Environ.
Health Perspect. 26: 121-124.
Dayan, A. D. 1979. A morphologist's approach to detection and study of
neurotoxicity. Pharmacol. Ther. 571-577.
Dewar, A. J. 1980. Neurotoxicity testing - with particlar reference to
biochemical methods. In "Testing for Toxicity" (ed. J. W. Garrod), pp.
199-217. London: Taylor Francis.
Dewar, A. J. 1983. Neurotoxicity. In "Animals and Alternatives in Tox-
icity Testing" (eds. M. Balls, R. J. Riddell, and A. N. Worden), pp.
229-284. London: Academic Press.
Dewar, A. J., Moffett, B. J. 1979. Biochemical methods for detecting
neurotoxicity - a short review. Pharmacol. Ther. 5: 545-562.
-62-

-------
Dews, P. B. 1982. Epistomology of screening for behavioral toxicity.
In "Nervous System Toxicology" (ed. C. Mitchell), pp. 229-236. New
York: Raven Press.
Dubner, R. 1983. Pain research in animals. Annals NY Acad. Sciences
406: 128-132.
Evans, H. L. 1978. Behavioral assessment of visual toxicity. Environ.
Health Perspect. lb_\ 53-57.
Evans, H. L., Weiss, B. 1978. Behavioral toxicology. In "Contemporary
Research in Behavioral Pharmacology" (eds. D. E. Blackman and D. J. Sanger),
pp. 449-487. New York: Plenum Press.
Fisher, F. 1980. Neurotoxicology and government regulation of chemicals
in the United States. In "Experimental and Clinical Neurotoxicology"
(eds. P. S. Spencer and H. H. Schaumburg), pp. 874-882. Baltimore:
Williams and Wilkins.
Ho, I. K., Hoskins, B. 1982. Biochemical methods for neurotoxicological
analyses of neuroregulators and cyclic nucleotides. In "Principles
and Methods of Toxicology" (ed. A. W. Hayes), pp. 375-406. New York:
Raven Press.
Hodos, W. 1983. Animal welfare considerations in neuroscience research.
Annals NY Acad. Sciences 406: 119-127.
Hooisma, J. 1982. Tissue culture and neurotoxicology. Neurobehav.
Toxicol. Teratol. 4_: 617-622.
Howard, J. L., Soroko, F. E., Cooper, B. R. 1981. Empirical models of
depression, with emphasis on tertrabenazine antagonism. In "Anti-
depressants: Neurochemical, Behavioral, Clinical Perspectives"
pp. 107-120.
Johnson, B. L. 1980. Electrophysiological methods in neurotoxicity
testing. In "Experimental and Clinical Neurotoxicology" (eds. P. S.
Spencer and H. H. Schaumburg), pp. 726-742. Baltimore: Williams and
Wilkins.
Laties, V. G. 1978. How operant conditioning can contribute to behavioral
toxicology. Environ. Health Perspect. 26: 29-35.
Matthysse, S. 1983. Making animal models relevant to psychiatry. Annals
NY Acad. Sciences 406: 133-139.
Mello, N. K. 1975. Behavioral toxicology: A developing discipline. Fed.
Proc. 34: 1832-1834.
Miller, N. E. 1983. Understanding the use of animals in behavioral research:
some critical issues. Annals NY Acad. Sciences 406: 113-118.
Mitchell, C. L. 1978. Target organ toxicity: nervous system. Environ.
Health Perspect. 26: 3-4.
-63-

-------
Mitchell, G. L., Tilson, H. A. 1982. Behavioral toxicology in risk assess-
ment: problems and research needs. CRC Crit. Rev. Toxicol. 10: 265—274.
Mitchell, C. L., Tilson, H. A., Cabe, P. A. 1982. Screening for neuro-
behavioral toxicity: factors to consider. In "Nervous System Toxicol-
ogy" (ed. C. Mitchell), pp. 229-236. New York: Raven Press.
Nardone, R. M. 1983. Neurotoxicity testing: an in vitro strategy. Annals
NY Acad. Sciences 407: 458-459.
Nelson, P. G. 1978. Neuronal cell cultures as toxicologic test systems.
Environ. Health Perspect. 26: 125-133.
Norton, S. 1977. Observational techniques in behavioral toxicology. In
"Behavioral Toxicology: an Emerging Discipline" (eds. H. Zenick and L.
W. Reiter), pp. 63-72. U.S. EPA Report 600/9-77-042.
Norton, S. 1978. Is behavior or morphology a more sensitive indicator of
central nervous system toxicity? Environ. Health Perspect. 26: 21-27.
Norton, S. 1980. Behavioral toxicology: a critical appraisal. In "The
Scientific Basis of Toxicity Assessment" (ed. H. Witschi), pp. 91-
107. Amsterdam: Elsevier/North Holland Biomedical Press.
Norton, S. 1982. Methods in behavioral toxicology. In "Principles and
Methods of Toxicology" (ed A. Hayes), pp. 353-373. New York: Raven
Press.
Prasad, K. N. 1982. Tissue culture model to study the mechanism of the
effect of heavy metals on nerve tissue. In "Mechanisms of Action of
Neurotoxic Substances" (eds. K. N. Prasad and A. Vernadakis), pp.
67-94. New York: Raven Press.
Reiter, L. 1978. An introduction to neurobehavioral toxicology. Environ.
Health Perspect. 26: 5-7.
Reiter, L. W. 1980. Neurotoxicology - meet the real world. Neurobehav.
Toxicol. 2i 73-74.
Reiter, L. W., MacPhail, R. C., Ruppert, P. H., Eckerman, D. A. 1981.
Animal models of toxicity: some comparative data on the sensitivity of
behavioral tests. In "Behavioral Consequences of Exposure to Occupational
Environments," Proc. 11th Conf. Environ. Toxicol. 11: 11-23.
Reiter, L., MacPhail, R. 1979. Motor activity: a survey of methods with
potential use in toxicity testing. Neurobehav. Toxicol. Teratol. _1
(suppl.): 53-66.
Savolainen, H. 1982. Neurotoxicity of industrial chemicals and contaminants:
aspects of biochemical mechanisms and effects. Arch. Toxicol. (suppl.):
71-83.
-64-

-------
Savolainen, H. 1982. Toxicological mechanisms in acute and chronic
nervous system degeneration. Acta Neurol. Scand. 92(suppl.); 23-35.
Schaumburg, H. H., Spencer, P. 1979. Toxic models of certain disorders
of the nervous system - a teaching monograph. Neurotoxicology 1: 209-
220.
Shanahan, A. J. 1979. Toxicological review team for literature search,
evaluation and organization of currently available toxicological tests.
NTIS - ADA 056311 (vol. 1), ADA 056312 (vol. 2).
Shinkman, P. G., Isley, M. R., Rogers, D. C. 1982. Newer laboratory
approaches for assessing visual'dysfunction. Environ. Health Perspect.
44: 55-62.
Silverman, P. 1974. Behavioral toxicology. New Sci. jjl_: 255-258.
Spencer, P. S., Bischoff, M. C., Schaumburg, H. H. 1980. Neuropatho-
logical methods for the detection of neurotoxic disease. In "Experi-
mental and Clinical Neurotoxicology" (eds. P. S. Spencer and H. H.
Schaumburg), pp. 743-757. Baltimore: Williams and Wilkins.
Stebbins, W. C. 1982. Concerning the need for more sophisticated animal
models in sensory behavioral toxicology. Environ. Health Perspect. 44:
77-85.
Tilson, H. A., Cabe, P. A. 1978. Strategy for the assessment of neuro-
behavioral consequences of environmental factors. Environ. Health
Perspect. 26: 287-299.
Tilson, H. A., Cabe, P. A., Burne, T. A. 1980. Behavioral procedures for
the assessment of neurotoxicity. In "Experimental and Clinical Neuro-
toxicology" (eds. P. S. Spencer and H. H. Schaumburg), pp. 743-757.
Baltimore: Williams and Wilkins.
Tilson, H. A., Mitchell, C. L. 1980. Models for neurotoxicity. Reviews
in Biochemical Toxicology 2^ 265—294.
Tilson, H. A., Mitchell, C. L. 1984. Neurobehavioral techniques to
assess the effects of chemicals on the nervous system. Ann. Rev.
Pharmacol. Toxicol. 24: 425-450.
Tilson, H. A., Mitchell, C. L., Cabe, P. A. 1979. Screening for neuro-
behavioral toxicity: the need for and examples of validation of testing
procedures. Neurobehav. Toxicol. J^Csuppl. 1): 137-148.
Weiss, B., Laties, V. G. 1979. Assays for behavioral toxicity: a strategy
for the Environmental Protection Agency. Neurobehav. Toxicol. j_(suppl. 1:
213-215.
Worms, P., Lloyd, K. G. 1979. Predictability and specificity of behavioral
screening tests for neuroleptics. Pharmacol. Ther. 5: 445-450.
-65-

-------
Computer-Generated Literature References to Potential
Alternative Methods in Behavioral Toxicity and Neurotoxicity
Clinical and Epidemiological Studies
Amiel-Tison, C., Barrier, G., Shnider, S. M., Levinson, G., Hughes, S. C.,
Stefani, S. J. 1982. A new neurologic and adaptive capacity scoring
system for evaluating obstetric medications in full-term newborns.
Anesthesiology 56: 340-350.
Arezzo, J. C., Schaumburg, H. H. 1980, The use of the optacon as a
screening device: A new technique for detecting sensory loss in indivi-
duals exposed to neurotoxins. J. Occup. Med. 22: 461-464.
Barron, S. A., Crohn, T. , Paigen, B. 1981. Peripheral neurotoxicity at
the Love Canal area of Niagara Falls, New York. Toxicology Research
Projects Directory 6_, iss. 10.
Fischbein, A., Thornton, J. C., Sarkozi, L., Kon, S., Levin, S. 1982.
Subjective symptoms in workers with low-level exposure to lead. J.
Appl. Toxicol. 1\ 289-293.
Jones, R. T., Reus, V., Herniag, R. 1. 1981. Drug dependence clinical
research program. Toxicology Research Projects Directory _7» ias. 2.
Mattsoa, R. H., Cramer, J* A., Delgado Escueta, A. V., Smith, D. B.,
Collins, J. F. 1983. A design for the prospective evaluation of the
efficacy and toxicity of antiepileptic drugs in adults. Neurology ^3
(3)(suppl. 1): 14-25.
Functional/Behavioral Studies
Anderson, R. J. 1983. Relative refrac.tory period as a measure of
peripheral nerve neurotoxicity. Toxicol. Appl. Pharmacol. 71: 391-397.
Andronova, L. M., Barkov, N. K. 1981. The effect of neuroleptics,
tranquilizers, narcotics, antidepressants and anticonvulsive drugs on
the alterations of mouse behavior caused by acetaldehyde. Drug Alcohol
Depend. 8^: 85—92.
Anger, K. 1981. Neurobehavioral methods for toxic agents. Toxicology
Research Projects Directory iss. 6.
Annau, Z. 1983. Screening strategies (in toxicology). Appl. Behav.
Pharmacol. Toxicol. (Lect. Workshop), pp. 87-95.
Baird-Lambert, J., Jamieson, D. D. 1983. Possible mediators of the
writhing response induced by acetic acid of phenylbenzoquinone in
mice. Clin. Exp. Pharmacol. Physiol. 10: 15-20.
-66-

-------
Banfi, S., Cornell!, U., Fonio, W., Dorigotti, L. 1982. A screening
method for substances potentially active on learning and memory. J.
Pharmacol. Methods 8_: 255-263.
Betin, C., DeFeudis, F. V. , Blavet, N., Clostre, F. 1982. Further charac-
terization of the behavioral despair test in mice: positive effects of
convulsants. Physiol. Behav, 28: 307-311.
Bhalla, T. N., Bhagava, K. P. 1980. Aconitine-induced writhing as a
method for assessing aspirin-like analgesic activity. J. Pharmacol.
Methods 3^: 9—14.
Bourin, M., Puech, A. J., Chermat, R., Doare, L., Poncelet, M.,.Simon, P.
1981. Psychophannacological profile of new antidepressants compared to
classical antidepressants. Gncephale 7: 235-242.
Buck, W. B. 1981. Behavioral effects of coal conversion products. Toxicology
Research Projects Directory j6, iss. 3.
Butcher, R. E. 1981. An experimental investigation of behavioral teratogenic
effects of exposure to anticonvulsant drugs. Toxicology Research Projects
Directory 6, iss. 3.
Butcher, R. E., Wootten, V. , Vorhees, C. V. 1980. Standards in behavioral
teratology testing: test variability and sensitivity. Teratogenesis
Carcinog. Mutagen. _1^: 49-61.
Consroe, P., Kudray, K., Schmitz, R. 1980. Acute and chronic antiepileptic
drug effects in audiogenic seizure-susceptible rats. Exp. Neurol. 70:
626-637.
Cooper, B. R. , Howard, J. L., Soroko, F. E. 1983. Animal models used in
prediction of antidepressant effects in man. J. Clin. Psychiatry 44(5,
pt. 2): 63-66.
Delini-Stula, A., Radeke, E., Schlicht, G., Hedwall, P. R. 1979. Detection
of CNS-depressant properties of antihypertensives: validity of various
test methods in rodents and estimation of therapeutic margin in hypertensive
rats. Pharmacol. Ther. (B) _5: 431-444.
Dews, P. B. 1982. Epistemology of screening for behavioral toxicity.
Nerv. Syst. Toxicol., pp. 229-236.
Dews, P. B. 1980. Test of environmental toxins on behavior of mice.
Toxicology Research Projects Directory 5^, iss. 11.
Evans, H. L., Palmes, E. K., Daniel, S. A. 1981. New behavioral tests
for occupational solvent risks. Toxicology Research Projects Directory
iss. 6.
Fox, D. A. 1979. Physiological and neurobehavioral alterations during
development in lead exposed rats. Neurobehav. Toxicol. Ksuppl. 1):
193-206.
-67-

-------
Frances, H., Chermat, R., Simon, P. 1980. Oxotremorine behavioral effects
as a screening test in mice. Prog. Neuropsychopharmacol. hi 241-246.
Fung, Y. K., Schwarz, R. D. 1983. An in vivo method for testing drugs
that influence striatal dopaminergic functions. Pharmacol. Biochem.
Behav. 19: 231-234.
Gmerek, D. E., Cowan, A. 1983. An animal model for preclinical screening
of systemic antipruritic agents. J. Pharmacol. Methods 10; 107-112.
Gross-Selbeck, E. 1981. Behavioral screening in lead exposed rats: an
animal model to analyze subtle consequences of low level lead exposure
in children. Z. Versuchstierkund _23_: 195-196.
Herman, Z. S., Felinska, W. 1979. Rapid test for screening of narcotic
analgesics in mice. Pol. J. Pharmacol. Pharm. 31: 605-608.
Holsapple, M. P., Munson, A. E., Freeman, A. S., Martin, B. R. 1982.
Pharmacological activity and toxicity of phencyclidine (PCP) and phenyl-
cyclohexene (PC), a pyrolysis product. Life Sci. _31.: 803-813.
Howard, J. L., Soroko, F. E., Cooper, B. R. 1981. Empirical behavioral
models of depression, with emphasis on tetrabenazine antagonism. Anti-
depressants: Neurochemical, Behavioral, Clinical Perspectives, pp. 107-120.
Jalfre, M., Bucher, B., Coston, A., Mocquet, G., Porsolt, R. D. 1982.
Neuropharmacological profile of MD 780515, a new reversible inhibitor
of type A monoamine oxidase. Arch. Int. Pharmacodyn. Ther. 259: 194-
221.
Jalfre, M., Bucher, B., Dorme, N. , Mocquet, G., Porsolt, R. D. 1983.
Neuropharmacological profile of MD 790501, a new benzamide derivative.
Arch. Int. Pharmacodyn. Ther. 264: 232-256.
Jensh, R. P., Magaziner, A., Vogel, W. H. 1981. Effects of maternal
environment and postnatal multiple testing on adult rat offspring. J.
Toxicol. Environ. Health 7655-663.
Kaneto, H., Kosaka, N. 1983. Drugs liable to cause psychic dependence in
small animal species. III. Selective drinking behavior of mice as a
test for drugs capable of causing psychic dependence. Nippon Yakurigaku
Zassjo 81: 267-274.
Katz, R. J., Sibel, M. 1982. Animal model of depression: tests of three
structurally and pharmacologically novel antidepressant compounds.
Pharmacol. Biochem. Behav. _16^ 973—977.
Kernan, tf. J. 1981. Behavioral effects on coal conversion products.
Toxicology Research Projects Directory 6_, iss. 11.
Schmidt, J., Von Littrow, C. 1979. Neuropharmacological effects of selected
sultones. Pharmazie 34: 296-297.
-68-

-------
Shinkman, P. G. , Isley, M. R., Rogers, D. C. 1982. Newer laboratory
approaches for assessing visual dysfunction. Environ. Health Perspect.
44: 55-62.
Silverman, A. P. 1979. Approach to a behavioral screen in toxicity testing.
Adv. Pharmacol. Ther. 9_: 203-210.
Stebbins, W. C. 1982. Concerning the need for more sophisticated animal
models in sensory behavioral toxicology. Environ. Health Perspect. 44:
77-85.
Tilson, H. A., Cabe, P. A., Squibb, R. E., Burne, T. A. 1981. Acute and
chronic neurobehavioral toxicity of acrylamide in rats. Toxicology
Research Projects Directory 6_t iss. 10.
Unknown. 1981. Assessment of optokinetic nystagmus as an index of neuro-
toxicity. Toxicology Research Projects Directory 6^ iss. 11
Vorhees, C. V. 1983. Behavioral teratogenicity testing as a method of
screening for hazards to human health: a methodological proposal.
Neurobehav. Toxicol. Teratol. 5_: 469-474.
Vorhees, C. V. 1983. Influence of early testing on postweaning performance
in untreated F344 rats, with comparisons to Sprague-Dawley rats, using
a standardized battery of tests for behavioral teratogenesis. Neurobehav.
Toxicol. Teratol. 5_: 587-591.
Vorhees, C. V., Butcher, R. E. , Brunner, R. L. , Sobotka, T. J. 1979. A
developmental test battery for neurobehaviotal toxicity in rats: A
preliminary analysis using monosodium glutamate, calcium carrageenan
and hydroxyurea. Toxicol. Appl. Pharmacol. 50: 267-282.
Electrophysiological and Neuropathological Methods
Adey, W. R., Bawin, S. M., Sheppard, A. R., Sagan, P. M., Lin Liu, S.,
Lawrence, A. F. 1981. Electromagentic radiation and biological systems.
Toxicological Research Projects Directory iss. 12.
Feldman, R. G., Baker, E. L. 1981. Lead exposure - electrophysiologic/
psychologic effects. Toxicology Research Projects Directory 6^ iss.
12.
Gomita, Y., Morii, M., Ichimaru, Y., Moriyama, M., Ueki, S. 1983. Behav-
ioral and electroencephalograph^ study of clobazam. Nippon Yakurigaku
Zasshi JS2: 267-292.
Raybourn, M. S. 1981. In vitro electrophysiology of CNS toxicity. Toxi-
cology Research Projects Directory iss. 6.
Tilson, H. A., Cabe, P. A., Spencer, P. S. 1979. Acrylamide neurotoxicity
in rats: a correlated neurobehavioral and pathological study. Neuro-
toxicology 1: 89-104.
-69-

-------
Biochemical Methods
Binenfeld, Z. , Maksimovic, M., Deljac, V. 1982. New in vitro method for
screening antisoman activity of antidotes. Acta Pharro. Jugosl. 32:
iss. Apr.-Jun., 145-147,
Briggs, C. J., Parreno, N., Campbell, C. G. 1983. Phytochemical assessment
of Lathyrus species for the neurotoxic agent, beta-noxalyl-L-alpha-beta-
diaminopropionic acid. Planta Med. 47(iss. Mar.): 188-190.
Carloldi, S., Lotti, M. 1982. Neurotoxic esterase in peripheral nerve:
assay, inhibition, and rate of resynthesis. Toxicol. Appl. Pharmacol.
62: 498-501.
Chweh, A. Y., Swinyard, E. A., Wolf, H. H., Kupferberg, H. J. 1983.
Correlations among minimal neurotoxic!tyt, anticonvulsant activity,
and displacing potencies in ^H-flunitrazepam binding of benzodiazepines.
Epilepsia (N. Y.) 2Ai 668-677.
Feigenbaum, J. J., Moon, B. H., Cattertan, R., Yanai, J., Klawans, H. L.
1982. Haloperidol-induced plasma prolactin release: sensitivity,
reliability, and comparison to haloperidol antoagonism of dopamine
agonist-induced stereotyped behavior in the rat. Psychopharmacology
(Berlin) 78_: 383-384.
Hayes, S. 1979. Use of ganglioside affinity filters to identify to identify
toxigenic strains of Clostridium botullnum types C and D. Infect.
Immun. 26: 150-156.
Hayes, S. 1981. Genetic basis of botulism phage toxicity. Toxicology
Research Projects Directory l_y iss. 1.
Krueger, B. K. 1981. Biochemistry of excitable membranes. Toxicology
Research Projects Directory 6, iss. 2.
Mailman, R. B., Krigman, M. R., Frye, G. D., Hanin, I. 1983. Effects
of postnatal trimethyltin of triethyltin treatment on central nervous
system catecholamine, gamma-aminobutyric acie and acetylcholine systems
in the rat. J. Neurochem. j+0: 1423-1429.
Ortmann, R., Beschoff, S. , Radeke, E., Buech, 0., Delini-Stula, A. 1982.
Correlations between different measures of antiserotonin activity
of drugs. Study with neuroleptics and serotonin receptor blockers.
Naunyn-Schmiedeberg's Arch. Pharmacol. 321: 265-270.
Racagni, G., Apud, A., Bruno, F., Giordana, M. T., Iuliano, E., Pezzotta,
S., Ferrario, E. 1981. Cyclic nucleotides and specific neurochemical
parameters in brain tumors. Toxicology Research Projects Directory 6^,
iss. 8.
Rose, G. P., Dewar, A. J., Moffett, B. J., Stratford, I, J. 1981. A
biochemical assessment of the neurotoxicity of the radiosensitizing
drug misonidazole in the rat. Clin. Toxicol. 18: 1411-1426.
-70-

-------
Simon, E. J., Hiller, J. M., Giocannini, T. , Groth, H. , Foucaud, B.
1980.	Effects of morphine and analogues on cell metabolism. Toxicol-
ogy Research Projects Directory 5^, iss. 8.
Spencer, P. S., Schaumburg, H. H., Sabri, M. I., Politis, M. J. 1981.
Neurotoxicity and teratology of industrial chemicals. Toxicology
Research Projects Directory 6^ iss. 9.
Whatley, S. A., Hill, B. T. 1983. In vitro neurotoxic assessment of
antitumor drugs. Cancer Lett. (Shannon, Ireland)	75-82.
Wilson, W. E., Bondy, S. C., Hong, J. S. 1981. Development of biochemical
tests for reflecting and predicting neurotoxicology. Toxicology Research
Projects Directory 7t iss. 2.
Tissue Culture Methods
Allen, J. N., Clendonon, N. R., Koestner, A., Hart, R. W., Kartha, M.
1981.	Radiation enhancement in nervous system tumor models. Toxicol-
ogy Research Projects Directory 6_, iss. 4.
Baclar, V. J., Mark, J., Borg, J., Mandel, P. 1979. High-affinity uptake
of gamma-aminobutyric acid in cultured glial and- neuronal cells. Neuro-
chem. Res. _4: 339-354.
Brown, W. J. 1981. Developmental biology in mental retardation. Toxicol-
ogy Research Projects Directory 6_, iss. 3.
Graham, D. G. 1981. Development of an in vitro model for organophosphorus-
induced delayed neurotoxicity. Toxicology Research Projects Directory
6, iss. 9.
Graham, D. G. 1980. Development of an in vitro model for screening organo-
phosphates for neurotoxicity. EPA-600/1-80-016; NTIS no. PB80-169428.
Graham, D. G., Lee, J. S., Ahmed, M. S., Cook, L., Abou-Donia, M. B.
1980. In vivo and in vitro degeneration of the sympathetic nervous
system in organophosphorus-induced delayed neurotoxicity. J. Neuropathol.
Exp. Neurol. 39: 356.
Heath, J. W., Ueda, S., Bornstein, M. B. , Daves, G. D. Jr., Raine, C. S.
1982.	Buckthorn neuropathy in vitro: evidence for a primary neuronal
effect. J. Neuropathol. Exp. Neurol. 41_: 204-220.
Heilbronn, E., Eriksson, H., Haggblad, J. 1982. Neurotoxic effects of
manganese: studies on cell cultures, tissue homogenates and intact
animals. Neurobehav. Toxicol. Teratol. 4^: 655-658.
Herken, H. 1983. Nerve cell clonal lines in culture - models for studying
the molecular basis of neuropharmacological effects. Klin. Wochenschr.
JLL: 1-16.
Hooisma, J. 1982. Tissue culture and neurotoxicology. Neurobehav.
Toxicol. Teratol. 4: 617-622.
-71-

-------
Kaelin, A. C., Cummings, S. J. 1983. A study of monooxygenase activity
in human placental homogenates: in vitro behavior towards a number of
substrates and inhibitors. Biochem. Pharmacol. 32_: 2421-2426.
Kleinschuster, S. J., Yoneyama, M., Sharma, R. P. 1983. A cell aggregation
model for the protective effect of selenium and vitamin E on methyl-
mercury toxicity. Toxicology 26; 1-10.
Kuroda, Y. 1980. Brain slices, assay systems for the neurotoxicity of
environmental pollutants and drugs on mammalian central nervous system.
Dev. Toxicol. Environ. Sci. 59-62.
McKhann, G. M. 1979. The study of isolated oligodendroglia from brain of
patients with non-neurologic disease and from patients with multiple
sclerosis. Toxicology Research Projects Directory 4^ iss. 8.
Nardone, R. M., Spiegel, J., Fedalei, A. , Krause, D., Filipowskl, R. M.
1983. In vitro studies of neurotoxic substances: the effect of organo-
phosphates and acrylamides. Govt. Reports Announcements & Index, iss. 1.
Praminik, A. K., Horn, N., Schwemer, G. 1980. 8402 human cell culture -
a model for evaluating bilirubin-albumin interactions with drug.
Toxicology _17.: 255-259.
Prasad, K. N. 1982. Tissue culture model to study the mechanism of the
effect of heavy metals on nerve tissue. In "Mechanisms of Action of
Neurotoxic Substances" (eds. K. N. Prasad and A. Vernadakis), pp. 67-94.
New York: Raven Press.
Seil, F. J., Vandenbark, A. 1980. Demyelination and synaptic changes
induced by immune sera and cells. Toxicology Research Projects
Directory 5^, iss. 12.
Veronesi, B., Peterson, E. R., Bornstein, M. B., Spencer, P. S. 1983.
Ultrastructural studies of the dying-back process. VI. Examination of
nerve fibers undergoing giant qxonal degeneration in organotypic culture.
J. Neuropathol. Exp. Neurol. 42^ 153-165.
Webster, H., Trapp, B. D., Cullen, M. J. 1980. Xenopus tadpole: a
useful model for studying cellular effects of neurotoxic compounds.
In "Experimental and Clinical Neurotoxicology" (eds. P. S. Spencer and
H. H. Schaumburg), pp. 775-787. Baltimore: Williams and Wilkins.
Vhetsell, W. 0. Jr., Schwarcz, R. 1983. The organotypic tissue culture
model of corticostriatal system used for examining amino acid neurotox-
icity and its antagonism: studies on kainic acid, quinolinic acid and
(-) 2-amino-7-phosphonoheptanoic acid. J. Neural Transm. 19(suppl.):
53-63.
Non-Mammalian Systems
Best, J. B., Morita, M. 1982. Planarians as a model system for in vitro
teratogenesis studies. Teratogenesis Carcinog. Mutagen. 1} 277-291.
-72-

-------
Cabe, P. A., Tilson, H. A., Mitchell, C. L. 1981. Development of the
Japanese quail as an animal model in neurobehavioral toxicology.
Toxicology Research Projects Directory Ji, iss. 11.
Davis, R. E., Schlumpf, B. E., Klinger, P. D. 1984. Systemic colchicine
inhibits goldfish optic nerve regeneration. Toxicol. Appl. Pharmacol.
73: 268-274.
Eanin, I., Fisher, A., Abraham, D. J., Zigmond, M. J., Mantione, C. R.,
Coyle, J. T. 1981. Choline analogs as specific CNS cholinergic
poisons. Toxicology Research Projects Directory^, iss. 8.
Konno, N. , Yamauchi, T., Kinebuchi, H. 1981. Delayed-type neurotoxicity
of an organophosphorus insecticide, cyanofenphos, painted onto cocks-
comb. Nippon Eiseigaku Zasshi (Jpn. J. Hyg.) 36: 447.
Richardson. 1981. Development of an in vitro neurotoxicity assay. Toxicol-
ogy Research Projects Directory 6_t iss. 11.
Segal, S. 1980. Cellular mechanisms in mental retardation. Toxicology
Research Projects Directory j>, iss. 3.
Terada, M., Ishii, A. I., Kino, H., Sano, M. 1982. Studies on chemotherapy
of parasitic helminths. VIII. Effects of some possible neurotransmitters
on the motility of Angiostrongylus cantonensis. Jpn. J. Pharmacol. 32:
643-653.
Wilson, B. W. 1981. Controlled growth and metabolism of avian cells:
pesticides, genes, regulation of muscle and nerve. Toxicology Research
Projects Directory 7, iss. 2.
Computer Modelling and Structure Activity Relationship Analyses
Anderson, R. J. 1981. Detection of neurotoxicity of environmental agents.
Toxicology Research Projects Directory 6_, iss. 3.
Haque, R., Falco, J., Cohen, S., Riodan, C. 1980. Role of transport and
fate studies in the exposure, assessment and screening of toxic chemicals.
In "Dynamics, Exposure and Hazard Assessment of Toxic Chemicals" (ed. R.
Haque), pp. 47-67. Ann Arbor: Ann Arbor Sci. Publ. Inc.
Leksina, L. A., Kabankin, A. S., Lavretskaya, E. F., Landau, M. A.,
Baldenkov, P. N. 1983. Computer-assisted analysis of a group of
compounds with psychotropic activity. V. Relationship of results of
testing in experimental animals and model enzyme systems. Khim.-Farm.
Zh. J7: 956-958.
Miller, D. C. 1981. Computerized video detection of pollutant impact.
Toxicology Research Projects Directory 6, iss. 9.
-73-

-------
Unger, S. H. 1983. Drug Design. Prediction of new leads by multivariate
techniques. Pharmacochem. Libr. 6^ iss. Quant. Approaches Drug Des.,
43-51.
Veith, G. D. 1981. State-of-the-art report on structure activity methods
development. Govt Reports Announcements & Index, iss. 17.
Miscellaneous Research Projects - Methods Development
National Institute of Environmental Health Sciences
Environmental toxicity expressed in visual dysfunction. University of
Rochester, Project No. R01-ES-1885.
Development of monitoring system for effects of chemicals on home cage
behaviors. New York University Medical Center, Project No-l-ES-2-5017.
Food and Drug Administration
Strategies for neurobehavioral toxicity testing. Bureau of Foods, Division
of Toxicology, Project No. 08855.
Neurobehavioral parameters sensitive to changes in membrane permeability.
Bureau of Foods, Division of Toxicology, Project No. 08855.
The effects of chemicals and drugs on intracranial pressure, cerebrospinal
fluid dynamics, brain edema and the blood-brain barrier. National Center
for Drugs and Biologies.
Low-level chemical threat program. National Center for Toxicological
Research, NCTR #6225.
Characterization of catecholaminergically-mediated changes in the swimming
immobilization response in developing rats. National Center for Toxicological
Research, NCTR #6231.
Collaborative study in behavioral teratology. National Center for Toxico-
logical Research, NCTR #255, 285.
Analysis of d-amphetamine sulfate and methylmercury chloride. National
Center for Toxicological REsearch, NCTR #286, 244.
Investigation of neurotoxic effects of drug exposure during development.
National Center for Toxicological Research, NCTR #6115.
Study in behavioral teratology. National Center for Toxicological Research,
NCTR #6127.
-74-

-------
National Institute of Mental Health
Stimulant drug induced psychosis. University of Pittsburgh, Project No.
5-R01-MH24714-08.
Studies of neuroleptic induced tardive dyskinesia. Chicago Medical School,
Project No. R01-MH33991-03.
Studies of neuroleptic induced tardive dyskinesia. New York State Psychiatric
Institute, Project No. R01-MH33946-02.
Studies of dyskinesias produced by antipsychotic drugs. Texas Research
of Institute of Mental Sciences, Project No. R01-MH334692—03.
Mechanisms of tardive dyskinesia. University of Michigan, Project No. R01-
MH36044.
Long-term study of tardive dyskinesia. Medical Research Foundation of Oregon,
Project No. R01-MH36657.
Behavioral toxicity. University of Rochester, Project No. R01-MH31850-04.
Environmental Protection Agency
In vivo short-term response indicators development. Health Effects Research
Laboratory, HERL/A109C0501.
In vivo, in vitro biochemical test systems. Health Effects Research Laboratory,
HERL/E104B0904.
In vivo, in vitro methods to detect neurotoxicity. Health Effects Research
Laboratory, HERL/L104B0711
In vivo evaluation of significance of neurotoxic response indicators. Health
Effects Research Laboratory, HERL/L104G0106.
In vitro, in vivo bioassay prescreening of hazardous wastes. Health Effects
Research Laboratory, HERL/D109A0101.
In vivo, in vitro protocol for toxicological screening of hazardous wastes.
Health Effects Research Laboratory, HERL/D109A0102.
Department of Agriculture
Tiffany, E., Bratton, G« R. Lead toxicity in isolated oligodendrocyte and
astrocyte cultures from rat and bovine brain. Texas A&M University, Project
No. TEX06652.
Bowen, J. M. Mechanisms of viral and environmental toxicant effects in
cell culture. University of Georgia, Project No. GE0V-0161.

-------
Chambers, H. W. Biochemical toxicology of insecticides: selectivity and
resistance. Mississippi State University, Project No. MIS-6303.
Barthalmus, G. T., Tilson, H. A. Behavioral toxicology of herbicides.
North Carolina State University, Project No. NC03668.
-76-

-------
Appendix B^
Existing Laws Related to the Use of Animals in Biomedical Research
Animal Welfare Act
Congress passed the Animal Welfare Act in 1966 (P.L. 89-544) to regulate
interstate trade in dogs and cats procured for research purposes. The Act was
amended in 1970 (P.L. 91-579) to include most warm-blooded animals used in re-
search, exhibitions, and in the wholesale pet trade. A second amendment in
1976 (P.L. 94-279) further extended coverage of the Act to include the trans-
port of live animals. Regulations promulgated pursuant to the Act (as amended)
established minimum standards for the care and treatment of dogs, cats, hamsters,
guinea pigs, rabbits, and non-human primates (monkeys, apes, etc.) held by cer-
tain research facilities. When the Animal Welfare Act was first amended in
1970, the definition of "animal" was broadened to include "such other warm-
blooded animal, as the Secretary may determine is being used, or is intended
for use, for research, testing, experimentation, or exhibition purposes or as
a pet." By regulation [9 CFR 1.1 (n)], some animal species, namely birds,
rats, mice, horses, and other farm animals, are specifically excluded under
the term "animal" and are considered administratively exempt from inclusion in
annual reports that registered research facilities must file with the Department
of Agriculture. At the present time, the Department is requesting laboratories
to voluntarily report their use of rats and mice.
Department of Defense Appropriation Authorization Act of 1975
Title VII of this Act (P.L. 93-365) contains a general provision (sec.
703) placing certain restrictions but not a complete prohibition upon the use
of dogs for chemical and other toxic substance research within the Department
of Defense.
Supplemental Appropriation Act for Fiscal Year 1982
The Supplemental Appropriation Act (Public Law 97—257) was amended to
add an expression of the sense of Congress that certain federal agencies should
be encouraged to develop and validate an alternative to the Draize test. The
Draize test is a controversial eye irritation test performed on laboratory
rabbits.
Legislation
98th Congress
H.Con.Res. 58 (Jacobs et al.)
Expresses the sense of the Congress that when a federal agency utilizes
the Draize rabbit eye irritancy test it should develop and validate
*Most of this appendix was excerpted from: Randall, B. 1984. The use of
animals in biomedical research. Issue Brief no. IB83161, Congressional Research
Service. Two other sources were used: Griffin and Sechzer (1983), and Zola
et al. (1984).
-77-

-------
alternative ophthalmic testing procedures that do not require the use of animal
test subjects. Introduced Feb. 15, 1983; referred to Committee on Energy and
Commerce.
H.Res. 170 (Lantos et al.)
Commends Mobilization for Animals for its effort in protecting animals
used in laboratory experiments. Introduced Apr. 21, 1983; referred to Committee
on Post Office and Civil Service.	(
H.R. 2350 (Waxman)
Health Research Extension Act of 1983. Amends the Public Health Service
Act relating to the National Institutes of Health (NIH) and the national re-
search institutes, and has other purposes.
Three sections of this legislation are important to the issue of using
animals in biomedical research. As proposed, new section 402(e) (1) of the
Act would authorize the director of NIH to establish a plan for research into
experimental methods that would not require the use of animals. This section
also calls for finding new methods that would reduce the numbers of animals
used in research, as well as finding new methods that would produce less pain
and distress in such animals.
Proposed new section 487 of the Act would require the Secretary of the
Department of Health and Human Services to issue guidelines concerning the
care and treatment of animals used in biomedical research. These guidelines
would also require each research entity receiving funding under the Act to
have an animal care committee.
Section 5 of the bill would require the Secretary of DHHS to contract with
the National Academy of Sciences to produce a study on the issue of using
animals in biomedical research.
Introduced as H.R. 1555 Feb. 17, 1983; referred to Committee on Energy and
Commerce. Hearings held by Subcommittee on Health and the Environment Feb. 23,
1983. Subcommittee approved bill with amendments, March 23. Clean bill
(H.R. 2350) forwarded to full Committee in lieu. Committee consideration and
markup held May 3, 5, and 10, 1983. Reported with amendments favorably, May 16,
1983 (H.Rept. 98-191). Considered in House July 25, 1983. Passed House,
amended, Nov. 17, 1983. House incorporated H.R. 2350 as an amendment in the
nature of a substitute to S. 540, June 5, 1984.
H.R. 2633 (Donnelly et al.)
Authorizes the Secretary of Health and Human Services to make grants for
research and development of new methods of research, experimentation, and test-
ing which minimize the use of, and pain and suffering to, live animals. Intro-
duced Apr. 20, 1983; referred to more than one committee.
H.R. 5098 (Torricelli)
Promotes the dissemination of biomedical information through modern
methods of science and technology and prevents the duplication of experiments
-78-

-------
on live animals, and has other purposes. Introduced Mar. 8, 1984; referred to
Committee on Energy and Commerce.
H.R. 5725 (Brown, G.)
Amends the Animal Welfare Act to ensure the proper treatment of labora-
tory animals. Requires that research facilities provide assurances satisfac-
tory to the Secretary of Agriculture that a principal investigator has con-
sidered alternatives to any procedure 'likely to produce pain or distress in an
experimental animal and shall provide details of any procedure likely to pro-
duce pain or distress in any experimental animal. Requires each research
facility to establish an animal research committee which shall be made up of
no less than three members possessing sufficient ability to assess animal care,
treatment, and practices in experimental research. Provides assurances that
members of the animal research committee do not release any confidential in-
formation of the research facility. Directs the Secretary to establish an in-
formation service at the National Agriculture Library to provide information
on improved methods of animal experimentation. Introduced May 24, 1984; re-
ferred to Committee on Agriculture.
S. 657 (Dole et al.)
Amends the Animal Welfare Act to revise the humane standards for animals
transported in commerce. Requires each research facility to establish an in-
stitutional animal studies committee with sufficient expertise to assess the
appropriateness of animal care and treatment in experimental research. Directs
the Secretary of Agriculture to establish an information service at the
National Agricultural Library to provide information on improved methods of
animal experimentation. Introduced Mar. 2, 1983; referred to Committee on
Agriculture, Nutrition and Forestry.
S. 773 (Hatch)
Animal Research Study Act of 1983 requiring an 18-month study of the use
of anijnals in research. Bill added as amendment to NIH renewal authorization.
Introduced Mar. 11, 1983; referred to Committee on Labor and Human Resources.
Reported with amendment (S.Rept. 98-110) May 16, 1983.
H.R. 4185 (Addabbo)
Makes appropriations for the Department of Defense for FY84, and has
other purposes!
As the DOD appropriations bills were being marked up and amended, language
was added that prohibits the purchase of dogs nd cats to be used in training
medical students or other personnel in surgical or other medical treatment of
wounds produced by any type of weapon. The amendment evolved from the dis-
covery that the Department of the Army was proposing to shoot anesthetized,
pound-acquired dogs for medical wound treatment training. The legislation, as
amended, passed the House November 2 and the Senate Nov. 8, 1983; House and
Senate agreed to final language on Nov. 18, 1983. The bill was presented to
the President on Nov. 29, 1983, and became P.L. 98-212 on Dec. 8, 1983.
-79-

-------
97th Congress
H. R. 220 (Ferraro) (identical to H. R. 2210)
The Humane Methods of Research Act. Promoted the development of methods
of research, experimentation, and testing that minimize the use of and pain and
suffering to live animals. Authorized $60 million over a five-year period to
study and utilize alternative methods of research. No action taken.
I
H. R. 556 (Roe, Hollenbeck, and Richmond)
The Research Modernization Act. Sought the establishment of a National
Center for Alternative Research, to develop and coordinate alternative methods
of research and testing which do not involve the use of live animals, to develop
training programs in the use of live animals, to eliminate or minimize the
duplication of experiments on live animals, to disseminate information on such
methods. It would have diverted 30-50% of federal funds for all research and
testing programs that involve the use of live animals to establish the Center.
No action taken.
H. R. 930 (Weiss)
The Protection of Animals in Research Act. Sought to establish an 11-
member commission to study alternative methods to the use of live animals in
laboratory research and testing, using appropriations not to exceed $750,000
per year for five years. No action taken.
H. R. 4406 (Schroeder)
To Amend the Animal Welfare Act to Insure the Humane Treatment of Labora-
tory Animals. Proposed improved standards for the use of live animals in
research facilities, would have expanded the Act to include any vertebrate
animal, and would have mandated procedures for the elimination or reduction of
pain. No action taken.
H. R. 6245 (Walgren).
The Humane Care and Development of Substitutes for Animals in Research
Act. Introduced in April 1982, after hearings on the above bills and combined
several features of these. It sought the development of non-animal methods of
research, experimentation, and testing, and the humane care of animals used in
scientific research, experimentation, and testing. It provided for the accred-
itation of research facilities by a private agency. Its orginal language
provided for the appropriation of $45 million in new funds over three years.
It was later amended to eliminate the provision of new funds for alternative
research, to introduce a threshold number of animals in research facilities
before accreditation was required, and to totally review the law after ten
years. A clean bill reissued as H. R. 6928 on August 4, 1982. A nearly iden-
tical version of the bill was introduced in the Senate by Sen. Dole as S.
2948, the major difference being that in the Senate version an advisory panel
would report on the impact of the legislation three years after enactment. S.
2948 was amended and renumbered to S. 3630. Hearings were held in the House
in December 1982, and changes in H. R. 6928 were made to make it consistent
-80-

-------
with S. 3630, but Subcommitte members could not agree on all the changes, and
no action was taken on either bill by the clo6e of the 97th Congress.
Hearings
98th Congress
U. S. Congress. House Committee on Agriculture. Subcommittee on Department
Operations, Research^ and Foreign Agriculture. Current Enforcement of the
Animal Welfare Act; and H. R. 5725, Improved Standards for Laboratory
Animals Act. Hearings, 98th Congress, 2nd session, Sept. 19, 1984.
U.S. Congress. Senate Committee on Agriculture, Nutrition, and Forestry.
Improved Standards for Laboratory Animals. Hearings, 58th Congress,
1st session, on S. 657. July 20, 1983. Washington, U.S. Govt. Print.
Off. , 1984.
97th Congress
U.S. Congress. House Committee on Energy and Commerce. Subcommittee on
Health and the Environment. Humane Care and Development of Substitutes
for Animals in Research Act. Hearings, 97th Congress, 2d session, on
H.R. 6928. Dec. 9, 1982. Washington, U.S. Govt. Print. Off., 1982.
U.S. Congress. House Committee on Science and Technology. Subcommittee
on Science, Research and Technology. Humane Care and Development of
Substitutes for Animals in Research Act. Hearings, 97th Congress, 2d
session, on H.R. 6245. May 4, 1982. Washington, U.S. Govt. Print. Off.,
1982.
U.S. Congress. House Committee on Science and Technology. Subcommit-
tee on Science, Research and Technology. The use of animals in medical
research and testing. Hearings, 97th Congress, 1st session, on H.R. 556,
H.R. 4406, and related bills. Oct. 13 and 14, 1981. Washington, U.S.
Govt. Print. Off., 1981.
-81-

-------