In public comments submitted today, People for the Ethical Treatment of Animals (PETA) and the Physicians Committee for Responsible Medicine (PCRM) charged that the National Toxicology Program Interagency Center for the Evaluation of Alternative Toxicological Methods (NICEATM) Interagency Coordinating Committee on the Validation of Alternative Methods (ICCVAM) continues to fail at implementing its Congressional mandate to facilitate the uptake of nonanimal testing methods government-wide. Specifically, the groups charge that ICCVAM's Draft Five-Year Plan (2013-2017):
- inappropriately repeats or retains many of the priorities of the last five-year plan (2008-2012), showing both a lack of progress and an inability on ICCVAM's part to move forward;
- demonstrates a lack of knowledge of some of the key advances in regulatory testing and validation theory that have taken place over the past couple of years, including the Adverse Outcome Pathway concept which is critical to achieving the National Academies' vision for toxicity testing in the 21st century;
- clearly prioritizes refinement over replacement and reduction measures;
- includes statements that undercut the few in vitro methods or approaches ICCVAM has recommended, and
- lacks key details that would allow NICEATM-ICCVAM and stakeholders to track progress and success, especially of NICEATM-ICCVAM's goals to "Promote the Application and Translation of Innovative Science and Technology" and "Facilitate Regulatory Acceptance and Use of Alternative Methods."
With the exception of sponsoring one or two workshops between now and 2017, there are few concrete goals described in the plan and no timeframes set for achieving progress. NICEATM-ICCVAM should be playing a leadership role in bringing about change and achieving the 21st century toxicity testing vision; instead, the plan relegates the entities to a peripheral, minor role at best – and to an obstacle at worst – while member agencies and European counterparts take the lead. In addition, PETA and PCRM call upon NICEATM-ICCVAM to promote – rather than oppose – U.S. adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and allow meaningful representation of experts in nonanimal testing from animal protection organizations on its scientific advisory committee.