Monona,

We agree, in silico testing is not ready to replace in-vivo testing, but it must be politically correct if you read today's announcement.

We're replacing lab mice/rats with either unverified computing processes without statistical analysis v. consumers, including children. My questions are: why should we trust a computer program that has not been vetted? Who and how is it determined that the computer models "adequately" replace in-vivo? Once those scientific studies are published, will those making the claims be held accountable scientifically, professionally and liability?

Who will be performing the toxicological testing on those exposed consumers? How relevant will it be? Who will be looking for metabolites of a compound, potential additive or synergistic effects in the consuming population from a compound exposed to when/how? I don't know about you, but I can't remember what I had for lunch/supper two days ago. Now the most important, will we recognize AND correct the mistake in the years to come as a society? When will we return to focus on science, as compared to political correctness?

My observation is that the late =E2=80=9870's started an awareness, the =E2=80=9880's to =E2=80=9890's built on the science, impact and repercussions. Look at significantly the regulations have changed. How successful has OSHA been at updating PEL's or adding new chemicals regulated by OSHA? It's a farce, the original OSHA Act adopted the 1969 list of the ACGIH TLVs and we know significantly more now. How many chemicals have TLVs now compared to the initial '69 list compared to the ACGIH TLVs (the new update was just released)?

We're talking orders of magnitude here, but my question holds, will those who are proven wrong be held accountable? I don't think the process FDA follows would ever enable an FDA official to be held accountable for negligence. I think legally, government officials, e.g., EPA, OSHA, FDA, USDA, etc. "cannot be held liable". Do we have the same luxury? What ethical standards do we need to impose - upon ourselves? I'm thinking of which to apply, PEL, TLV, MAK, etc.? At what level do you enforce - can you justify your choice to management, courts, etc.? We are professional practitioner's and unlike gov't officials, we can be held accountable.

I know I'm asking a lot of questions. I'm only asking for due consideration, research and reflection of the questions for consideration.

Sincerely,

BruceV

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Monona Rossol
Sent: Wednesday, March 7, 2018 8:09 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] EPA Releases Draft Strategy to Reduce Animal Testing

How kind.  I'm especially feisty because our kitchen ceiling fell last Friday and the workmen are here every day tearing up our lives and creating dust.  Hopefully tomorrow they will paint and leave forever!  A couple more days of this and I'd go to some straight bar (hard to find in the Village), walk up to a trucker, and pick a fight.