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FRAME and the Royal Commission on Environmental Pollution: Common Recommendations for Assessing Risks Posed by Chemicals under the EU REACH System

Robert D. Combes, Jennifer Dandrea and Michael Balls

This document discusses recommendations made by FRAME and the Royal Commission on Environmental Pollution (RCEP) with regard to the current European Commission proposals on the Registration, Evaluation and Authorisation of Chemicals (REACH) system for assessing the risks of chemicals to humans, wildlife and the environment. Of several common aims and recommendations, the two most important are: a) the greater use of non-animal testing methods, especially computational prediction methods (for example, [quantitative] structure–activity relationships, expert systems and biokinetic modelling) for prioritising chemicals for hazard assessment; and b) the greater use of intelligent exposure-based targeted risk assessment, with less emphasis being placed on tonnage-triggers. FRAME has produced a decision-tree testing scheme to illustrate the way in which these approaches could be used, together with in vitro test methods. This scheme has been slightly modified to take account of proposals subsequently made by the RCEP. In addition, FRAME points out that new and improved computational methods are needed through more coordinated research, and that these and existing methods need to be validated. The similarities between the independent publications of FRAME and the RCEP add weight to the recommendations that each have made concerning the implementation of the REACH system.
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FRAME and the Royal Commission on Environmental Pollution: Common Recommendations for Assessing Risks Posed by Chemicals under the EU REACH System

Robert D. Combes, Jennifer Dandrea and Michael Balls

This document discusses recommendations made by FRAME and the Royal Commission on Environmental Pollution (RCEP) with regard to the current European Commission proposals on the Registration, Evaluation and Authorisation of Chemicals (REACH) system for assessing the risks of chemicals to humans, wildlife and the environment. Of several common aims and recommendations, the two most important are: a) the greater use of non-animal testing methods, especially computational prediction methods (for example, [quantitative] structure–ac ivity relationships, expert systems and biokinetic modelling) for prioritising chemicals for hazard assessment; and b) the greater use of intelligent exposure-based targeted risk assessment, with less emphasis being placed on tonnage-triggers. FRAME has produced a decision-tree testing scheme to illustrate the way in which these approaches could be used, together with in vitro test methods. This scheme has been slightly modified to take account of proposals subsequently made by the RCEP. In addition, FRAME points out that new and improved computational methods are needed through more coordinated research, and that these and existing methods need to be validated. The similarities between the independent publications of FRAME and the RCEP add weight to the recommendations that each have made concerning the implementation of the REACH system.
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Working With Other Partners — The Retail Sector

Petrina Fridd

Animal testing to demonstrate the safety of cosmetic and toiletries has been used for many years. However, such testing, now viewed by many consumers as an emotive issue, has been banned within the UK, and is severely restricted in the European Union. Consumer knowledge and understanding have been challenged by the use of focus group studies, which showed that consumers were often confused and potentially misled by claims on labels and in leaflets. Despite the fact that some pressure groups had taken positive action, even holding store demonstrations, in attempts to stop such testing or claims, there was still a legal requirement to demonstrate the safety of products, and this involved the use of animal testing. Nevertheless, there was great pressure to move away from animal testing, clarify marketing and pack claims, and provide general transparency to the consumer. Therefore, the decision was taken to actively seek out and work with organisations which were working toward the validation of alternative testing. A number of potential organisations were approached and, after careful consideration of their respective aims and aspirations, it was decided that, for the retailer in question, FRAME was the most appropriate organisation with which to work.
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Richard Clothier: An Appreciation

Michael Balls

The career of Richard Clothier is reviewed in the light of his long-standing collaboration with Michael Balls and Laurens Ruben at the University of East Anglia (UEA), the University of Nottingham, and Reed College, Portland, Oregon, USA. It began with work at UEA on the aetiology of the lymphosarcoma of Xenopus laevis, followed by studies on the effects of exposure to N-nitroso-N-methylurea on T-cell functions, which led to many contributions to comparative immunology. This was followed by the establishment of the FRAME Research Programme, which led to participation in extensive studies on the development of in vitro cytotoxicity tests and their application in acute and topical toxicity testing. A FRAME Trustee since 1983, Richard Clothier was a co-founder, and subsequently Director, of the FRAME Alternatives Laboratory in the University of Nottingham Medical School, where he led successful collaborations with a number of industrial partners and, in particular, with the European Centre for the Validation of Alternative Methods (ECVAM).
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The MatTek Story — How the Three Rs Principles Led to 3-D Tissue Success!

John Sheasgreen, Mitch Klausner, Helena Kandárová and David Ingalls

MatTek Corporation has been working diligently for over 15 years to replace traditional animal-based toxicity and efficacy tests with alternative test methods based on human-cell derived, three-dimensional (3-D) tissue models. First discussed in detail by W.M.S. Russell and R.L. Burch 50 years ago in their book, The Principles of Humane Experimental Technique, and now fully integrated into forward-looking publications such as Toxicity Testing in the 21st Century: A Vision and a Strategy, the concept of replacing animals in test procedures with human cells and/or human cell-derived in vitro 3-D tissues is being embraced by the world’s research scientists and toxicologists at an ever-increasing rate. 3-D in vitro models are being utilised not only for humanitarian reasons, but also because human 3-D tissues, in particular, produce more-physiologically relevant scientific data. Early on in MatTek’s efforts to develop this alternative test method, senior management sought the assistance of experts within the in vitro testing and animal rights communities, to help define the specific in vitro human 3-D tissue products needed and navigate the regulatory landscape, especially in Europe where the replacement of animal-based testing with non-animal alternative test methods was well underway. MatTek was fortunate to receive that expert assistance on both fronts from Professor Michael Balls, who at that time was the newly-elected first director of ECVAM. In 1997, with the guidance and support of Professor Balls and others in the animal rights community, MatTek began the effort to validate several of its human 3-D tissue-based alternative test methods. Today, two MatTek human cell-derived 3-D tissue-based test methods are validated as full replacements for existing animal-based tests, with more tests in the validation pipeline. In addition, MatTek in vitro tissue models are in use worldwide by chemical, pharmaceutical and consumer product companies, as evidenced by citations in hundreds of patents and scientific articles from these industries. This article concludes with MatTek’s thoughts on the direction that human 3-D tissue-based in vitro testing will take in the future.
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FRAME and the Validation Process

Michael Balls and Richard Clothier

FRAME’s historical involvement in the development of the principles of validation, whereby the reliability and relevance of a procedure are established for a specific purpose, and in the practical application of the process, is summarised, and examples of participation in various validation studies on in vitro tests are reviewed. Emphasis is placed on the need for a parallel invalidation process, and on the role of ATLA as a forum for objective reporting and discussion on all aspects of the validation process.
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FRAME, the Three Rs and the Russell Archive at the University of Nottingham

Michael Balls

The objectives of the Fund for the Replacement of Animals in Medical Experiments (FRAME) are spelled out, as laid down in the Charity’s Trust Deed of 1969, and the support of the Charity’s trustees, consultants, patrons and staff in all that has been achieved during its first 40 years, are recognised. The recent establishment of the W.M.S. and Claire Russell Archive at the University of Nottingham is recognised as a further important link between FRAME and the University.
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“I’m Not Going to Make a Song and Dance about It…”

Jon Richmond

Having been involved with the biomedical sciences and alternatives for 30 of the 50 years since Russell and Burch published The Principles of Humane Experimental Technique, I feel well placed to speak of the contributions made by FRAME over the last 40 years. FRAME has promoted the development and use of alternatives by presenting the “better science” arguments to scientists, promoting informed discussion, changing opinions and changing behaviours. FRAME has also contributed constructively to the political debate, and was instrumental in promoting legislation which incorporated the principles of the Three Rs. Times are changing, and the Three Rs are increasing being politicised: and FRAME is particularly well placed to ensure that good science and good welfare, rather than ideology, remain the basis for interest in and progress with the Three Rs.
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The Role of an Academic Centre

Alan M. Goldberg

On FRAME’s 40th anniversary, I had the opportunity to examine FRAME and CAAT’s missions as closely linked to those of their universities. The roles of education, research and service are key, both to the universities and to our two centres. By examining the current programmes, and identifying the needs of the future, the research activities, policy studies and training, it becomes clear that the Three Rs of alternatives contribute significantly to our respective universities’ missions.
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