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The dilemma of lacking data is<br />

a majorhindranceforusing<br />

NOEL‘s and uncertainty factors!<br />

NOVARTIS<br />

In vitro + in vivo genotoxicity assays are hazard identification<br />

tests, and thus do not provide data suitable for use in<br />

quantitative risk assessment<br />

Approach proposed (use of NOEL + UF) is unlikely to be<br />

feasible in most circumstances (no adequate data)!<br />

Pragmatic approach is needed (amount of impurity in µg/day<br />

considered as generally acceptable intake level)<br />

‣ The NOEL / UF approach can be used for toxicologically well<br />

characterized compounds, a condition, which is normally not<br />

met for impurities<br />

L. Müller, Swissmedic, 21-Oct-2003

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