Platform 3Rs in Regulation

An important objective of EPAA is to improve the implementation of 3Rs in European regulatory testing and decision making. It therefore aims to identify optimised approaches on testing and risk assessment strategies in existing and upcoming legislation and their implementation so as to avoid double and redundant, as well as unnecessary testing. In this respect, EPAA strives to share experience and evaluate consistency across sectors, analyse hot spots and to identify policy drivers for testing.

 

Integrated Testing Strategies

In the framework of its activities on "Integrated Testing Strategies and their impact on the 3Rs", the 2011 EPAA Lead Theme, the EPAA organized a workshop on ITS in Brussels on 26 September 2011.

For EPAA, the term ITS (Integrated Testing Strategies) is meant to cover more than a strategic combination of tests. An ITS might well include non-testing methods (computer based tools such as QSARs, non animal- based ADME-models, etc), and even in vivo models. Essentially, as standalone, the individual components of an ITS cannot provide all information needed for decision making but their strategic combination can.


The objective of the workshop is to explore how industry is already adopting ITS in decision making and to discuss its (potential) use in regulatory compliance procedures. Several EPAA members representatives of different industry sectors will present their general approaches to ITS, setting out their common limits and strengths. They will also address their perceived impact on the 3Rs. In addition, individual companies from these sectors will present case studies of ITS effectively being implemented in their decision making or having past the "proof of concept" phase.

Workshop on ITS and their impact on the 3Rs
26 September 2011, Brussels

Programme PDF

ITS Fact Sheet PDF

Flash report PDF

Presentations

Optimized testing strategies for skin sensitization - LLNA and beyond

The meeting will build upon the findings of the 2010 LRI Workshop on the Local Lymph Node Assay (LLNA). The intention is to share industry sector experience thereby laying the foundations to discuss and recommend future initiatives in skin sensitization testing.

Skin sensitisation training workshop: Moving forward with non-animal testing strategies
A joint workshop from EPAA and Cefic LRI
Helsinki, Finland – 4th February 2013

Press release PDF

EPAA Cross Sector Workshop
19 and 20 September 2011, Brussels

Programme PDF

Flash report PDF

3Rs in acute toxicity testing

A cross-sector review of the drivers for acute systemic toxicity testing and of alternative approaches was carried out by an EPAA Task Force in collaboration with the HSI (Humane Society International) and the NC3Rs (National Centre for the Replacement, Refinement and Reduction of Animals in Research). The review resulted in several recommendations for promoting reduction and refinement in the area of acute toxicity (e.g. deletion of the requirement for acute toxicity testing of active/individual substances by dermal route for classification and labelling, particularly for plant protection products and industrial chemicals). The findings will be published in the Journal Toxicological Sciences and will be discussed with regulators at a workshop planned for 16 September 2010 in Brussels. The publication (Seidle et al., 2010) is already available online via Advance Access ( http://toxsci.oxfordjournals.org/ ).

 

Workshop "Cross-Sector Review of Drivers and Alternative Approaches for Acute Systemic Toxicity Testing"
16 September 2010, Brussels

Final report PDF

ACUTE TOXICITY Round Table, to address the hypothetical situation "How could C&L decisions in the agrochemical and chemical sectors be made if stand-alone acute toxicity testing were prohibited?
28 September 2012, Brussels

Flash report PDF
Full report
PDF

Consistency approach in vaccines testing

The consistency approach is based upon the principle that the quality of a vaccine is the consequence of the strict application of a quality system and of a consistent production of batches. Through the application of this principle, which has been implemented for some novel human vaccines, agreed product characteristics can be tested in vitro during the manufacturing process of a batch and shown to be similar to those of batches demonstrated to be safe and effective in clinical trials. The concept of consistency may therefore be applied to conventional vaccine production in order to replace in vivo tests with in vitro tests indicative of the quality and quantity of the product whilst maintaining the highest quality and safety standards.

 

 

 

The vaccines project team has conducted a survey of 3Rs alternatives to current animal tests that are available for use or under development. We hope that the survey and accompanying presentation will be useful and informative to those working in this field and we welcome comments and contributions to keep the survey accurate and up to date. All contributions should be sent to the Project Coordinator, Dr Ian Ragan.


ECVAM/EPAA Workshop on The Consistency Approach for Quality Control of Vaccines – a 3Rs opportunity
11-12 January 2010, Brussels
More information here PDF

Final report

Workshop on the Application of the Three Rs and the Consistency Approach for Improved Vaccine Quality Control
7 April 2011, Brussels
More information here

Flash report

DTaP vaccines workshop
30 - 31 August 2012, Den Dolder

Flash report PDF

EPAA-EURL ECVAM Workshop on Replacement of In Vivo Human Rabies Vaccine Potency Testing by In Vitro Glycoprotein Quantification Methods: Validation Status and Implementation Strategies
8 - 9 October 2012, Arcachon, France

Flash report PDF

EPAA workshop on implementation strategies of the consistency approach for veterinary inactivated rabies vaccines
5 - 6 November 2012, Brussels, Belgium

Flash report PDF


Vaccines consistency approach workshop: Clostridial Vaccines
19 March 2013, Brussels, Belgium

Flash report PDF

Introduction to the survey PDF

EPAA survey on vaccines consistency approach

Extended one-generation study

This EPAA action focuses on the evaluation of opportunities for the more widespread application of testing strategies being developed as the Agricultural Chemical Safety Assessment (ACSA) approach for reproductive toxicity, e.g., for regulatory testing under REACH.

The extended one-generation reproductive toxicity study design is currently under consideration as an alternative to the current one- and two-generation tests, with potentially widespread applicability and impact on chemical safety assessment across many industry sectors. The EPAA evaluated whether this new approach developed for agrochemicals, could also be applied to other sectors (e.g. industrial chemicals). This will deliver animal welfare benefits with regard to both refinement and a reduction in the number of animals used.

The extended one-generation study as a replacement of the classical two-generation study would lead to a significant reduction in animal numbers used for testing of one substance (1400 instead of 2600 animals, representing a reduction of 45 %). In addition, through more sophisticated measurements and the inclusion of additional endpoints, the extended one-generation study would be a refinement when compared to the classical two-generation study. An OECD expert group was set up end of 2007 to develop a draft guideline and evaluate the validity of the endpoints used. The draft version of the guideline can be downloaded from the OECD homepage.

 

The extended one generation study PDF

Workshop on Triggering and Waiving Criteria for the Extended One-Generation Reproduction
Toxicity Study 14-15 April 2008, Barza d'Ispra
 PDF

 

Investigating regulatory requirements and drivers

In a series of sector specific workshops, the EPAA has mapped the regulatory landscape and identified priority areas and drivers to the implementation of alternative approaches. Participants formulated a series of recommendations that were subject of a specific EPAA follow-up, or are covered by activities by the EPAA or the European Commission otherwise initiated.

 


Sector specific workshops
Implementation and Reporting

 

Supporting validation

EPAA has a great potential to bring new levels of efficiency to the prioritisation and process of validation, by promoting closer collaboration between the European Center for the Validation of Alternative Methods (ECVAM) and industry.

From the first survey among the industry members of EPAA on availability of data for alternative methods, it emerged that most substances and data had already been provided at earlier stages, due to the way that substance selection is implemented. In addition, for certain substances, no data were available, or data were available but for a different set of substances. A fine-tuned framework for collaboration will be used for the next calls for substances.

 


Collaboration framework
Selected method profiles

 

Overcoming barriers to validation

EPAA has identified a number of barriers to validation, some of which are administrative, others of a scientific nature. The following recommendations stemming from current debates are being actioned:
• Systematic application of identical procedures for all submissions for validation;
• Definition and disclosure of criteria for admitting a method for validation;
• Avoidance of proprietary substances and data in selection of materials;
• Complementing the selection of substances by calls at an early stage before the finalization of study protocols, and;
• Optimisation of the peer-review process.

 


Debates
Work in progress

 

Overcoming barriers to regulatory acceptance

EPAA has demonstrated its potential to serve as an inter-sectoral platform and as a catalyst for cross-fertilization. Comparing mechanisms and solutions from different sectors helps to identify the most efficient approaches while respecting sectoral specificities and needs. Currently, the EPAA is following up on the following suggestions made in recent debates and workshops:
• the involvement of regulators at an early stage of method validation;
• better dissemination of information about available alternatives; and
• the inclusion of 3Rs on the agendas of all relevant international regulatory meetings.

 


Debates

Work in progress
  • Ongoing work on regulatory modules

 

Case studies; regulatory compliance

Case studies across sectors have been initiated to verify how 3R approaches can be developed to meet regulatory requirements, taking benefit of the cross-fertilisation potential offered by the EPAA. These include the developing criteria for using possibilities to waive animal testing under REACH, harnessing existing weight-of-evidence approaches and expert judgment across sectors to avoid any additional animal testing for purposes of classification under the GHS, verifying the relevance of current data requirements in different sectors on acute toxicity where only very limited value is obtained, or sharing information on testing requirement stemming from bilateral dialogues between companies and authorities.

  • Acute toxicity  PDF
  • Weighted evidence as a tool for the GHS
  • Waivers of animal testing under REACH