UC Irvine
UC Irvine Previously Published Works
Title
Advancing alternatives analysis: The role of predictive toxicology in selecting safer
chemical products and processes.
Permalink
https://escholarship.org/uc/item/695195q3
Journal
Integrated environmental assessment and management, 13(5)
ISSN
1551-3777
Authors
Malloy, Timothy
Zaunbrecher, Virginia
Beryt, Elizabeth
et al.
Publication Date
2017-09-01
DOI
10.1002/ieam.1923
Peer reviewed
eScholarship.org
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University of California
Integrated Environmental Assessment and Management — Volume 13, Number 5—pp. 915–925
Received: 20 July 2016
|
Returned for Revision: 26 September 2016
|
915
Accepted: 7 February 2017
Environmental Policy & Regulation
Advancing Alternatives Analysis: The Role of Predictive
Toxicology in Selecting Safer Chemical Products and Processes
Timothy Malloy,*yz§ Virginia Zaunbrecher,yz Elizabeth Beryt,§ Richard Judson,k Raymond Tice,#
Patrick Allard,zyy Ann Blake,zz Ila Cote,§§ Hilary Godwin,z§ Lauren Heine,kk Patrick Kerzic,##
Jakub Kostal,yyy Gary Marchant,zzz Jennifer McPartland,§§§ Kelly Moran,kkk Andre Nel,§
Oladele Ogunseitan,### Mark Rossi,yyyy Kristina Thayer,# Joel Tickner,zzzz Margaret Whittaker,§§§§
and Ken Zarkerkkkk
ySchool of Law, University of California Los Angeles (UCLA), Los Angeles, California, USA
zFielding School of Public Health, UCLA, Los Angeles, California, USA
§UC Center for the Environmental Implications of Nanotechnology, UCLA, Los Angeles, California, USA
kNational Center for Computational Toxicology, Research Triangle Park, North Carolina, USA
#National Toxicology Program, Durham, North Carolina, USA
yyInstitute for Society & Genetics, UCLA, Los Angeles, California, USA
zzEnvironmental and Public Health Consulting, Alameda, California, USA
§§US Environmental Protection Agency, Washington, DC
kkNorthwest Green Chemistry, Juneau, Alaska, USA
##California Department of Toxic Substances Control, Chatsworth, California, USA
yyyComputational Biology Institute at the George Washington University, Ashburn, Virginia, USA
zzzSandra Day O’Connor School of Law, Arizona State University, Tempe, Arizona, USA
§§§Environmental Defense Fund, Washington, DC, USA
kkkTDC Environmental, San Mateo, California, USA
###School of Public Health, University of California Irvine (UCI), Irvine, California, USA
yyyyClean Production Action, Somerville, Massachusetts, USA
zzzzUniversity of Massachusetts, Lowell, Massachusetts, USA
§§§§ToxServices, Washington, DC, USA
kkkkWashington State Department of Ecology, Olympia, Washington, USA
ABSTRACT
Alternatives analysis (AA) is a method used in regulation and product design to identify, assess, and evaluate the safety and
viability of potential substitutes for hazardous chemicals. It requires toxicological data for the existing chemical and potential
alternatives. Predictive toxicology uses in silico and in vitro approaches, computational models, and other tools to expedite
toxicological data generation in a more cost-effective manner than traditional approaches. The present article briefly reviews
the challenges associated with using predictive toxicology in regulatory AA, then presents 4 recommendations for its
advancement. It recommends using case studies to advance the integration of predictive toxicology into AA, adopting a
stepwise process to employing predictive toxicology in AA beginning with prioritization of chemicals of concern, leveraging
existing resources to advance the integration of predictive toxicology into the practice of AA, and supporting transdisciplinary
efforts. The further incorporation of predictive toxicology into AA would advance the ability of companies and regulators to
select alternatives to harmful ingredients, and potentially increase the use of predictive toxicology in regulation more broadly.
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Keywords: Alternatives analysis
Alternative testing strategies
Alternatives assessment Predictive toxicology
INTRODUCTION
Chemical regulation generally focuses on risk assessment
and risk management. It assumes toxic chemicals will be used
and seeks to mitigate their harmful impact through controls
(Malloy 2014). The last few years have brought increasingly
* Address correspondence to malloy@law.ucla.edu
Published 1 March 2017 on wileyonlinelibrary.com/journal/ieam.
Integr Environ Assess Manag 2017:915–925
Regulation
insistent calls for a “prevention-based” approach to addressing environmental and human exposures to toxic chemicals
(DHHS 2010; NCCELC 2011). Unlike risk management, the
prevention-based approach seeks to minimize the use of
toxic chemicals through adoption of safer, viable alternative
chemicals or processes (Cummings and Kuzma 2017). With
limited exceptions, the preventive approach has lingered in
the periphery of regulatory programs and private environmental management for decades. The US Environmental
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Protection Agency (USEPA) pioneered early efforts in its
rulemaking under Section 6 of the Toxic Substances Control
Act (US Congress 1976) and in its Design for the Environment
(DfE) program (Whittaker 2015). More recently, policymakers
in Europe and individual American states have embraced
mandatory and voluntary prevention-based approaches to
chemical policy. The European Union (EU) adopted this
approach through its Registration, Evaluation, Authorisation,
and Restriction of Chemicals (REACH) regulation (OJEU
2007). California, USA, is employing the approach in its Safer
Consumer Products (SCP) regulations (CCR 2013).
Prevention-based regulations such as REACH and California’s SCP program require manufacturers seeking to use
certain chemicals of concern to evaluate safer, viable
alternatives by performing “alternatives analyses.” In chemical regulation, alternatives analysis (AA), also known as
“alternatives assessment,” is a method used to determine the
relative safety and viability of potential alternatives to existing
products or processes that use hazardous chemicals (Malloy
et al. 2013; NRC 2014). Alternatives may include chemical
substitutes, changes to manufacturing operations, and/or
changes to product design (Sinsheimer et al. 2007). Alternatives analysis is a 2-part process. In the first part, the
methodology identifies potential alternatives and assembles
information regarding the performance of the regulated
chemical and those alternatives across relevant attributes,
typically including public health impacts, environmental
effects, technical performance, and economic impacts on
the manufacturer and the consumer. The second step
identifies and evaluates trade-offs between the original
product and its alternatives (Malloy et al. 2013).
Government agencies, businesses, nongovernmental organizations, and academics have used various AA frameworks and tools in voluntary initiatives for some time
(Edwards et al. 2011; Rossi et al. 2012; ICC 2013), although
their use in mandatory chemical regulation is new. Recent
evaluations of these tools identified gaps in the existing
approaches, including absence of a decision-making framework, lack of sufficient toxicology data regarding alternatives,
and failure of certain approaches to assess exposure (NRC
2014). Although many of these challenges and considerations are also present in conventional risk assessment, they
arise in AA in ways that are unique to the prevention-based
setting.
Alternatives assessment involves assessment of a variety of
hazards associated with human and environmental exposures
to chemicals. There are significant gaps in toxicity information
for the vast majority of chemicals or potential exposure
pathways. Traditional toxicological testing relies heavily
upon in vivo (whole-animal) studies mostly in mammals,
particularly with respect to carcinogenicity, reproductive
toxicity, and other complex endpoints (Ellinger-Ziegelbauer
et al. 2008; Ferreira et al. 2014). It assumes chemicals that
injure animals may have similar impacts on humans. Heavy
reliance upon animal testing has come under increasing
scrutiny. There are scientific concerns regarding the accuracy
of such testing in predicting human outcomes (NRC 2007).
Integr Environ Assess Manag 2017:915–925
Other concerns are based upon its high cost and timeconsuming nature (NRC 2007) and animal welfare issues
(Bakand et al. 2005).
The problem of data gaps is exacerbated in the AA context
in which multiple chemicals contained in various alternatives
must be characterized and compared. Predictive toxicological methods offer the potential for obtaining the necessary
toxicity and exposure estimates in substantially less time and
at significantly less cost conventional methods. Rather than
relying upon conventional in vitro assays and whole-animal
studies, the emerging field of predictive toxicology uses
high-throughput screening (HTS) in vitro and in vivo assays,
knowledge of the mechanisms of toxicity, and advanced
computational methods (“in silico” toxicology) to evaluate
toxicity. This natural complementarity led a recent report on
AA by the National Academy of Sciences to suggest that
incorporating predictive toxicology into future AA frameworks is critical (NRC 2014). Figure 1 illustrates the ways in
which predictive toxicology may be useful in various steps of
the assessment process in a typical AA.
The present article suggests the next steps for integrating
predictive toxicology and AA. First, it provides general
background on the types of predictive toxicological approaches relevant to AA; this is not intended as a thorough
review of predictive toxicology. Second, it identifies the
challenges and benefits presented by predictive toxicological tests in AA. Third, it offers recommendations for next
steps.
OUTLINING PREDICTIVE TOXICOLOGICAL
TECHNOLOGIES
Predictive toxicology encompasses a broad range of
methods that can generate differing levels of information.
Many toxicological methods are predictive. But there have
been recent developments in toxicology, specifically with
regard to in vitro assays and computer models that offer the
opportunity to provide more efficient and less expensive
Figure 1. Uses of predictive toxicology in alternatives analysis.
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ways to evaluate various chemicals or products than do
conventional testing techniques. Generally speaking, predictive toxicology focuses upon the toxicity mechanism,
following it from the initial interaction between a chemical
with a biological target and ultimately leading to a wholeorganism adverse outcome (AO).
There are several conceptual frameworks for defining the
path from the so-called “molecular initiating event” (MIE) to
the AO, of which the one most widely used is the adverse
outcome pathway (AOP) approach (Ankley et al. 2010;
Villaneuve et al. 2014a, 2014b). An AOP always includes an
MIE and an AO, plus one or more intermediate key events
(KEs). The identified MIE and KEs are probed using in vitro or
model organism assays or chemical structure-based computer models. The results of these assays or models can
therefore be predictive of whether that outcome or disease
may develop via the particular injury mechanism defined by
the AOP. Predictive toxicology tools exist for both human
health and environmental endpoints. They stand in contrast
to conventional toxicology methods, which have primarily
focused on detecting the apical AO in in vivo (whole-animal)
studies. Those effects and the doses at which the AOs occur
are then extrapolated to characterize toxicity in humans or
wildlife.
During the last decade, many predictive toxicology tools
were developed for use in traditional risk assessment in the
United States, Canada, and Europe. However, predictive
toxicology tools can also be applied in the AA setting and can
provide hazard or risk information with the possibility of
comparative analysis across materials. There are 4 general
types of predictive technology approaches that could be
used in an AA:
1.
2.
3.
4.
grouping,
high-throughput in vitro assays,
in silico modeling, and
nontraditional in vivo testing.
Grouping
Grouping is the arrangement of chemicals or substances
into groups on the basis of common attributes, such as
human health or ecological endpoints (e.g., carcinogenicity,
aquatic toxicity) or physicochemical features (e.g., the shape
of nanoparticles, existence of a particular functional group)
(OECD 2014). Grouping can include identifying individual
chemical analogues or creating larger chemical categories.
The underlying principle is relatively straightforward: “Similar” chemicals will exhibit “similar” activity such that the
activity of one or more members of a group is predictive of
the activity of other members of the group (Jaworska and
Nikolova-Jeliazkova 2007; Enoch and Roberts 2013). The
USEPA has relied upon chemical grouping in AAs performed
in its DfE program (USEPA 2014). The EU’s REACH program
provides for the use of grouping in its guidance on AA (ECHA
2011a).
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The “gap-filling” methods for estimating properties or
activity for a “data-poor” chemical based on one or more
similar “data-rich” chemicals vary (Cronin 2013). “Read
across” is a qualitative assessment of toxicity that is based
upon expert judgment regarding the similarity with the other
chemical or chemicals and likely activity (OECD 2014).
Examples of read-across approaches include qualitative
structure activity relationships (SARs) analysis, structural
alerts, and expert systems. Trend analysis is a statistical
technique used to determine whether a series of observations (in this case, toxicity or some other activity) form some
pattern such as an upward trend across the group of
chemicals (Dimitrov and Mekenyan 2010).
High-throughput in vitro assays
In vitro focuses on the interactions and effects of chemicals
upon cells, cell lines, or biological molecules (such as
proteins), preferably but not always of human origin, rather
than using whole animals. Recent reports by the National
Academy of Sciences and European authorities envision
increased reliance on mechanistically based in vitro testing
(NRC 2007). Researchers introduce chemicals of interest into
the testing medium and observe changes in biologic
processes that may lead to toxicity to evaluate whether the
tested material is implicated in the initiation or progression of
an AOP. One can design in vitro tests that probe molecular
events in an AOP. This provides the scientific support linking
the results of a simple in vitro test to a potential AO. In vitro
assays can also provide information regarding the relative
potency of materials compared to reference materials or
alternatives. In vivo potency is modulated by toxicokinetics
and/or pharmacokinetics or by administration, distribution,
metabolism, excretion (ADME) processes, which can enhance
or even reverse the relative potency observed in vitro (Rotroff
et al. 2010).
Data from in vitro testing has been used in AA for a range of
hazard endpoints. The USEPA’s DfE program relies upon in
vitro data in assessing mutagenicity and endocrine activity
(USEPA 2011). The REACH program provides that “scientifically validated in vitro tests” may fully or partly replace animal
testing where the information generated in the in vitro assay
is adequate for the regulatory use in question (ECHA 2011a,
2011b).
The value of mechanistically based in vitro assays can be
vastly expanded through HTS; HTS allows researchers to use
advanced robotics and automation to simultaneously test
thousands of materials across a range of concentrations for a
variety of parameters (NRC 2007). The HTS methods
generate a wealth of data that requires specialized tools
and strategies for sorting it, separating relevant information
from noise and artifact, and organizing it to facilitate analysis
(Cohen et al. 2013; Liu et al. 2013). Concentration–response
curves for the tested materials allow for comparison of the
relative potency of the materials in AA (Parham et al. 2009).
High-throughput screening data can be employed for rapid
response assessment. For example, in 2010, USEPA’s Office
of Research and Development used HTS data regarding
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endocrine disruption and other biological activity to compare
8 oil spill dispersants in connection with the Deepwater
Horizon oil spill (Judson, Martin et al. 2010). High-throughput
screening data can be used to generate quantitative
structure-activity relationship (QSAR) models, discussed
immediately below.
In silico modeling
In silico alternatives rely upon computational techniques
that use the structure or other features of a chemical to assess
its toxicity or fate (Madden 2010). These approaches include
computer-assisted expert systems, modeling approaches
such as QSAR, toxicokinetic models, fate and transport
models, and the creation of virtual cells, tissues, and organs
(Hartung and Hoffman 2009; Shah and Wambaugh 2010).
The most prominent in silico approach is QSAR analysis,
which uses mathematical models to relate the activity or
potency of a set of chemicals to their physicochemical
properties or other descriptors so as to generate predictions
of toxicological data for a target chemical (Shah and
Wambaugh 2010; Patlewicz et al. 2013). Development of a
robust QSAR requires rich physicochemical and toxicological
data for a large enough set of chemicals. For some endpoints,
such as bacterial mutagenicity, aquatic toxicity, and skin or
eye irritation, sufficient information exists, and QSARs are
well established for many chemical classes (Patlewicz et al.
2013). Well-accepted QSARs are lacking for many other
endpoints such as carcinogenicity, repeated dose toxicity,
and developmental toxicity (Cronin 2010).
Quantitative structure-activity relationships are used in
existing AA frameworks. For example, USEPA’s DfE program
relies upon USEPA’s ECOlogical Structure–Activity Relationship Model (ECOSAR) model to predict aquatic toxicity in the
absence of data on the chemical (Mayo-Bean et al. 2012).
That program also contemplates the use of QSARs with
respect to predicting endocrine activity (ECHA 2011b). The
REACH program allows for the use of QSARs in lieu of testing
data in AA where certain conditions are met (ECHA 2011a; Liu
et al. 2013).
Nontraditional in vivo testing
Unlike in vitro and in silico approaches, in vivo testing
provides an understanding of how the organism as a whole
will respond to a chemical and its metabolites over time.
Nontraditional in vivo approaches can combine the
integrative benefits of whole-animal testing with the speed
and reduced costs of in vitro and in silico approaches
(Mesens 2014). Some types of short-term rodent studies fall
within the nontraditional category, for example, short-term
or accelerated cancer bioassays using rodents that have
been genetically modified to exhibit high sensitivity to
chemically induced cancers (Eastmond et al. 2013). Other
approaches involve the use of smaller animals as surrogates
for higher, more complex ones. Model organisms such as
the vertebrate zebrafish (Danio rerio) and invertebrate
nematode (Caenorhabditis elegans) have been used in
Integr Environ Assess Manag 2017:915–925
assessing complex endpoints such as reproductive and
developmental toxicity (Balls 1995; Ferreira et al. 2014).
Given the size and availability of zebrafish embryos and
C. elegans, these animals can be used in medium-throughput
high-content screening (HCS), a variant of HTS in which the
readout of the assay captures more complex data than in an
HTS screen (Taylor 2006). A typical HCS readout may be a
microscopic image from which quantitative information may
be drawn regarding observable physical or biochemical
characteristics of the cell or organism. For example, HCS of
the effects of a material on zebrafish embryos would generate
quantitative data regarding hatching, developmental abnormalities, and mortality using high-content imaging software.
ASSESSING THE CHALLENGES AND BENEFITS OF
APPLYING PREDICTIVE TOXICOLOGY TO AA
Using these predictive toxicology methodologies in AA
has advantages and limitations, which are summarized in
Tables 1 to 4. The tables are not exhaustive. They capture the
most salient advantages and limitations when comparing the
potential use of these technologies in AA.
While each of the approaches raises its own benefits and
limitations, there are 5 common challenges, which are
enumerated in the following sections.
Validating methods and achieving acceptance by all
stakeholders
Validation requires an objective demonstration that a test
method measures the attribute that it is intended to detect in
a reliable manner. Publications on formal validation outline
the following major criteria: 1) reliability of the assay, 2)
relevance to the scientific question being addressed, 3)
fitness for purpose, 4) providing an adequate definition of the
test, 5) demonstration of within-laboratory reproducibility, 6)
demonstration of the ability to transfer the test to other
laboratories, and 7) demonstration of the accuracy of the test
(Balls 1995; ICH 1996; DHHS 1997; Hartung et al. 2004;
Stokes et al. 2006; Hartung 2007; Stokes and Schechtman
2008; Stokes and Wind 2010; Judson et al. 2013). Formal
validation, such as that performed by the Organisation for
Economic Co-operation and Development (OECD) or other
governmental bodies, is generally required for acceptance of
data from predictive toxicology tests in a regulatory context.
The validation required to use toxicology data in the AA
context varies depending on the purpose of the AA. If a test is
being used to guide development of a new chemical or
product, then the developers will need scientific confidence
in the results of the test but will not require full regulatory
approval. If data are being used to make a safety case to
regulators as part of a required AA, then more formal
validation may be needed. A higher level of validation is
desired for a method that provides the only data around a
particular aspect of safety (e.g., skin sensitization). With
different levels of validation available for different tests, AA
practitioners need a clearer understanding of what level of
validation is required for regulatory AA.
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Table 1. Major advantages and limitations of grouping in AA
Advantages
Limitations
Fast, even in comparison to other alternative
testing strategies
Requires particular data and analysis capacity
Least expensive
Chemical similarity sometimes does not translate into mechanistic similarity
Can rely on established categories or groupings
Acceptance by regulators as basis for regulatory response may be low
Does not require a chemical sample for testing
Potential legal challenges
AA ¼ alternatives analysis.
Properly interpreting the results from predictive toxicology
tests
Predictive toxicology tests produce data that are used to
predict the potential for an AO. Though potential of adversity
is not the same as an observed adverse effect, such
information is increasingly being used to make regulatory
decisions. Similar to any in vivo test method, properly
interpreting predictive toxicology tests requires a comprehensive understanding of the validation status and limitations
of each assay, which requires the interpreter to answer such
questions as these:
Is the test method reliable and relevant?
Does the assay test the parent compound only?
What is the chemical domain of applicability?
How are the data analyzed statistically, and is there
potential bias?
Does the test battery exclude key AOPs?
Can the data be extrapolated to in vivo doses?
Are the methods properly described?
There are no appropriate in vitro model systems for a
number of priority areas in toxicology, including hepatotoxicity,
cancer prediction, and developmental or reproductive toxicity
(Knudsen et al. 2015), although efforts in those areas are
ongoing (Liu et al. 2015).
Integrating data from different methods
Integrating toxicological data obtained using different
experimental platforms is a major challenge for the following
reasons:
The types of endpoints evaluated, whether in vitro or in
vivo, can vary greatly, ranging from mechanistic ones (e.g.,
changes in gene expression in target cell populations) to
apical ones (e.g., cell death, developmental deficits).
Even when there is a common endpoint (e.g., alteration of
the function of the estrogen receptor using a reporter
gene assay), different data analysis methods are often
used, which can result in different conclusions about the
activity or potency of the same compound tested under
seemingly identical experimental conditions (Shockley
2015).
Table 2. Major advantages and limitations of high-throughput in vitro assays in AA
Advantages
Limitations
Concerns regarding the relevance of results to effects that may
Provides fast screening, particularly for potential alternatives for
occur in the whole organism
which there often are no data. Screening can also address large
numbers of chemicals and help target additional research.
Can easily test a range of concentrations
For some assays, higher likelihood of false positives and false
negatives
More quantitative than descriptive methods
Can be difficult to link to exposure data
Less expensive than traditional approaches
The data generated can be difficult to interpret and communicate,
making it difficult for the public and third parties to understand
how conclusions regarding toxicity were developed
Often provides mechanistic information that can facilitate
translation to predictions of human health impacts
Some assays are proprietary, limiting access
Can compare active ingredient to complete product formulation
Mechanistic basis results in selection bias for known mechanisms
and against unknown or difficult-to-predict pathways
Opportunity to evaluate mixtures
Investment in robotics can be expensive
Opportunity to examine genetic variability
Difficult to assess temporal patterns and longer-term effects
Ability to simulate different windows of exposure
May be difficult to assess important ecological effects such as
persistence and bioaccumulation
AA ¼ alternatives analysis.
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Table 3. Major advantages and limitations of in silico modeling in AA
Advantages
Limitations
Offers a cost-effective way either to prioritize chemicals of
concern or to assess potential alternatives for which there
often are no data
Variable predictive ability of models
Allows for modeling of initiating events
No institution to monitor validation
Can inform the design of safer chemicals
Some models are proprietary, which limits access and impairs
transparency
Fast
Because many models are based upon experimental results
regarding a set of structurally similar data-rich chemicals,
model applicability is limited to data-poor chemicals with
similar structure
Does not require chemical sample for testing
Can be more difficult to develop if the mechanistic basis is
unknown
Computational predictions of environmental fate and degradation allow Model quality varies considerably and model performance
can be manipulated by choosing particular chemicals
exposure to be estimated without expensive monitoring and can
predict bio-persistence and concentrations in the environment
—
For some chemicals there may be a lack of quality data to
develop and use models
AA ¼ alternatives analysis.
Generally, only study summary data are available,
whereas the more useful, detailed experimental data
are maintained in unconnected data silos, making it
difficult if not impossible to evaluate all data using a
standardized data analysis method.
federal frameworks for assessing human and experimental
animal data are currently available, and a similar approach
for mechanistic data is under development (Judson et al.
2012).
In addition to developing databases in which all relevant
publications and electronic data can be archived, there is a
critical need for a set of commonly accepted methods for
comparing results across different test method platforms.
Efforts at systematic review may fill this gap, for example,
A decision is only as good as the data it is based on.
Addressing data quality issues is ultimately critical and
unfortunately in toxicology has been given little attention
until recently (Przybylak et al. 2012; Matevia 2015).
Recent implementation of systematic review methods in
Assessing and addressing data quality issues
Table 4. Major advantages and limitations of nontraditional in vivo testing in AA
Advantages
Limitations
Tissue and organ specific
Increased difficultly in determining mechanism by which the
chemical may be causing toxicity
Response more accurately represents how the organism will respond
Does not necessarily translate across species
Integrative, can show systematic impact including impacts on behavior Longer and more expensive than grouping, HTS, and in silico
Provides confidence that you are testing the metabolites, although not In some jurisdictions, it is legally limited or prohibited
necessarily the human metabolites
Faster than traditional full-rodent studies
In some cases, better at assessing short-term impacts than
long-term impacts
Need for fewer animals
—
Can be paired with mechanistic information to shorten study length
—
Can study exposure-specific impacts
—
Easier to integrate into AA
—
Applicable to mixtures
—
AA ¼ alternatives analysis; HTS ¼ high-throughput screening.
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environmental health should help. Although systematic
review methods are most developed for epidemiological
and traditional in vivo evidence, there is great interest in
extending the methods to the type of evidence used in
alternative testing strategies (Murray and Thayer 2014;
Thayer et al. 2014; DHHS 2015; Mandrioli and Silbergeld
2016). Increased concern about the quality of shared data
should also lead to increased attention to the development
of standardized tools and approaches, which in turn can be
incorporated to compare alternatives as part of the AA
process.
Standardizing and sharing data
In order to perform the hazard assessment of an AA, one
needs either data on the chemicals of interest or models that
can be used to predict the chemicals’ toxicology profiles. To
build such models requires relatively large databases of
chemical toxicology data. Several efforts have been gathering
such data and publishing it online to make direct evaluation
or model building possible, including the following:
the USEPA’s ACToR system, a data warehouse that
aggregates toxicology and other relevant data from
thousands of sources, including ToxCast (Judson et al.
2008, 2012; USEPA 2015);
the National Institutes of Health’s PubChem (NIH 2016)
that collects data on chemical bioactivity (mainly from in
vitro experiments);
ChEMBL similar to PubChem, but with a focus on
extracting data from the open literature (Gaulton et al.
2012; EBI 2016);
the National Toxicology Program’s Chemical Effects in
Biological Systems (CEBS) project (NIEHS 2016); and
the National Library of Medicine’s toxicology data
network (TOXNET) (USNLM 2016).
All of these systems allow browsing by chemical and largescale downloads for modeling efforts (Judson et al. 2005;
Richard et al. 2008; Judson 2010). The advent of this kind of
database advances access to the information needed for AA,
but publicly available information is still lacking for many
chemical–endpoint combinations and transformation
products.
Despite these challenges, the possible benefits that the
methods could have if applied in regulatory AA are
significant. The present paper now turns to developing a
road map for assimilating predictive toxicology methods into
AA.
A roadmap for incorporating predictive toxicology into AA
The speed and low expense of many of these methods
make them particularly attractive for use in AA. However,
predictive toxicology is still an emerging field, as is regulatory
AA. In the short term, a measured introduction of predictive
toxicology into AA is appropriate, at first focusing on more
established methodologies for limited applications. For
example, existing and emerging QSARs and nontraditional
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in vivo testing could be used in the near term to fill data gaps
for certain endpoints. Likewise, mechanistically based in vitro
approaches may be used for screening alternatives, or for
identifying endpoints for which additional testing may be
needed.
These recommendations mirror suggestions made in a
recent report by the National Academy of Sciences on
selecting chemical alternatives (NRC 2014). Given AA’s more
expansive need for toxicology data on multiple chemicals
compared to traditional one-at-a-time chemical risk assessment, AA could act as a test case to drive the use of predictive
toxicology in traditional regulatory decision making. The
application of predictive toxicology in these situations should
be transparent, allowing for ex post assessment that could
inform and refine the use of predictive toxicology in AA and in
other regulatory applications, allowing it to increase its
robustness and reliability over time.
Such limited uses would not capture the full potential value
of predictive toxicology. In the long term, the discipline
should move toward broader use of these approaches.
Systematic and broader application of individual approaches
will be important to the growth of effective AA methods, and
will help build confidence in the use of these approaches for
other applications. Such application presents 2 challenges: 1)
how to combine data from alternative testing approaches
with conventional data and 2) how to meld together the
different types of alternative testing approaches.
Analysts are often faced with a range of data, including
epidemiological data, human studies, animal studies, and
conventional in vitro data. Much of the data may relate to a
common issue of concern (such as acute toxicity or
developmental toxicity), but the form, nature, and quality
of the data can vary. This issue can be exacerbated when
emerging testing approaches providing mechanistic information about impacts at the cellular level are included with
conventional animal studies, or when data from different
studies or assays give incongruent results. Tools and
methods available to integrate multiple streams of data
include qualitative weight-of-evidence approaches, structured forms of systematic review, and quantitative, probabilistic methods (Woodruff and Sutton 2011; Park et al. 2013;
Rooney et al. 2014; NanoInfo 2016).
Integration of alternative testing strategies includes the
development of a cohesive suite of mechanistically based
assays that could provide an extensive data set for chemical
formulations and mixtures. Alternatively, integration could be
the systematic use of several predictive approaches, including “tiered approaches,” “integrated testing strategies,” and
“intelligent testing strategies” (Bradbury et al. 2004; Nel
et al. 2013). Each of these integration approaches aims to
meld the various methods in an efficient, well-grounded
manner and are beyond the scope of the present paper.
To successfully deploy predictive toxicology into AA,
resources will need to be invested in research, policy
development, capacity building, and education. This includes short-, medium-, and long-term steps that could be
taken to develop the field of predictive toxicology and to
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encourage its acceptance and use in AA. To do that, the
present paper offers the 4 recommendations, spelled out in
the sections that follow.
Recommendation 1: Use case studies to advance the
integration of predictive toxicology in AA. Systematic case
studies can answer specific questions about how to integrate
predictive toxicology into AA, including these:
How well do HTS approaches work for screening potential
alternatives about which there is little to no available
conventional toxicological data?
How should predictive toxicology data be normalized
and weighted in AA?
How should entities conducting AA determine what
predictive toxicology data should be included or
excluded?
How can predictive toxicology advance the consideration
of ecotoxicity in AA?
How can predictive toxicology advance the consideration
of interactive effects in AA?
Case studies should be specifically designed to address
these questions, possibly running multiple scenarios with
different approaches to data inclusion and weighting to
assess the impact of various uses of toxicological data. Case
study topics that have the potential to address one or more of
the specific questions listed above include marine antifouling
paint, chemicals used in fracking, flame retardant alternatives, C nanotubes, and bisphenol A (BPA) alternatives. It is
important to follow up these case studies over time as new
data become available to evaluate how well the AA methods
worked in improving overall safety.
Recommendation 2: Employ predictive toxicology approaches to screen chemicals of concern for AA. A large
number of chemicals used in commerce have been identified
as chemicals of concern by entities such as the USEPA, the
National Toxicology Program, the European Commission, and
the International Agency for Research on Cancer. Regulators
and companies face the task of prioritizing chemicals for AA
and subsequent substitution or regulation. Predictive toxicology approaches—including in silico modeling and creation of
new data through HTS—could be used to prioritize these
chemicals of concern along with other relevant toxicological
data. For example, prioritization of the approximately 300
chemicals on Washington State’s list of Chemicals of High
Concern to Children presents a useful opportunity to use
predictive toxicology methods (WAC 2017).
Various government entities are already testing a number
of compounds using predictive methods (Judson, Houck
et al. 2010) and are making much of the data public. Most
recently, the USEPA’s Endocrine Disruptor Screening Program identified an integrated testing approach using
predictive methods as an acceptable alternative to several
Tier 1 assays used to screen for estrogen activity (Browne
et al. 2015). However, such efforts can be complicated by
Integr Environ Assess Manag 2017:915–925
difficulty acquiring a reasonable amount of a compound for
testing, and securing resources to support the efforts,
particularly when undertaken by state agencies or private
entities. Academics often are willing to run some tests at cost
and share cell lines and protocols.
Recommendation 3: Use existing resources to advance the
integration of predictive toxicology in AA . A number of
existing predictive toxicology and AA resources could be
leveraged or modified to advance the integration of
predictive toxicology into AA, including these:
Having existing AA frameworks agree that predictive
toxicology has a place in AA and should be used. The
frameworks could uniformly accept certain tests and
tools. Ideally, this would include a tools clearinghouse to
assist decision makers in the selection and use of
predictive toxicology methods that recommended methods by chemical class and endpoint.
Assessing the toxicology data available on PubChem
from different endpoints generated using a common set
of chemicals in grants. This would allow the comparison of
the same chemical sets across different assays and
approaches, which would facilitate validation.
Looking at nonregulatory validation options or validation
from other jurisdictions. This includes investigating
whether existing OECD-approved tests for alternatives
to animal testing or a forthcoming EU ranking system for
data quality could facilitate the use of predictive
toxicology in AA.
New predictive toxicology methods should be considered
for integration into AA as they are developed. Funding and
interdisciplinary education and training for students and
professionals are important to increasing the capacity to
perform AAs.
Recommendation 4: Support trans-sector and transdisciplinary efforts to integrate predictive toxicology in AA. Though
there is interest in incorporating predictive toxicology
methods into regulatory AA, the relevant disciplines (toxicologists, decision analysts, regulatory and legal experts,
and policy makers) and sectors (government, industry, civil
society, and academia) often work in silos, inhibiting the
integration of predictive toxicology into AA. Specific
suggestions to expand transdisciplinary work include these:
Develop a research coordination network to provide the
necessary vehicle for systematic collaboration across
disciplines and institutions.
Use existing efforts to bring together regulators, industry,
civil society, and academics to agree on testing protocols
for nanotechnologies as a model.
Facilitate the creation of a safe harbor from litigation or
regulatory action for data provided to regulators during
an AA to encourage the sharing of industry data as part of
a collaborative learning process.
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Encourage acceptance of data across and within sectors.
For instance, state government agencies could use HTS
screening data generated by the federal government in
their prioritization processes.
Although some of these actions are partially underway,
there is still much to be gained from interaction between
professionals from diverse sectors and industries.
CONCLUSION
Predictive toxicology has an important role to play in AA.
Although many of the challenges associated with using
predictive toxicology in other realms will also exist in AA, it
also offers some promising opportunities to advance the use
of predictive toxicology for regulatory purposes. Continued
collaboration among toxicologists, decision analysts, regulators, and engineers on case studies and other projects is the
next step to advancing AA and predictive toxicology.
Acknowledgment—This manuscript is the product of a
workshop hosted by the UCLA Sustainable Technology and
Policy Program, a joint collaboration of the UCLA School of
Law and the Center for Occupational and Environmental
Health in the UCLA Fielding School of Public Health in
partnership with the UC Center for Environmental Implications of Nanotechnology (UC CEIN). UC CEIN is funded by a
cooperative agreement from the National Science Foundation and the EPA (NSF DBI-0830117; NSF DBI-1266377). The
Institute of the Environmental and Sustainability and the
Emmett Institute on Climate Change and the Environment,
both at UCLA, also provided support.
Data Accessibility—No data were generated for this article.
All data used are publicly available through the references cited.
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