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Status and Future Directions of the - US Environmental Protection ...

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Numbers <strong>of</strong> Numbers Published <strong>of</strong> <strong>and</strong> Published Unpublished <strong>and</strong> Unpublished Sources Sources <strong>of</strong> Existing <strong>of</strong> Existing Data, by Endpoint<br />

Data, by (as Endpoint <strong>of</strong> June (as 2004) <strong>of</strong> June 2004)<br />

Discipline Area Specific Endpoint Published Unpublished Total<br />

Health Effects<br />

<strong>Environmental</strong> Effects<br />

<strong>Environmental</strong> Fate<br />

Physicochemical<br />

Properties<br />

As can be seen from <strong>the</strong> numbers <strong>of</strong> studies listed in <strong>the</strong> above table, a significant amount <strong>of</strong><br />

As can be seen from <strong>the</strong> numbers <strong>of</strong> studies listed in sponsors have proposed (as discussed in <strong>the</strong> following<br />

unpublished data has now been made public by <strong>the</strong> sponsors. This indicates that <strong>the</strong> sponsors,<br />

<strong>the</strong> above ei<strong>the</strong>r table, individually a significant or through amount <strong>the</strong> <strong>of</strong> many unpublished consortia participating section). When in <strong>the</strong> isolating Program, <strong>the</strong> have statistics made for aacute<br />

concerted effort to bring forth such existing data <strong>and</strong> represents a major success <strong>of</strong> <strong>the</strong> HPV<br />

data has now been made public by <strong>the</strong> sponsors. endpoints (for both health effects <strong>and</strong> environmental<br />

Challenge Program. It also indicates that many sponsors made significant efforts to evaluate<br />

This indicates that <strong>the</strong> sponsors, ei<strong>the</strong>r individually effects) from <strong>the</strong> table, it is seen that 75% <strong>of</strong> acute<br />

or through <strong>the</strong> many consortia participating in <strong>the</strong><br />

Program, have made a concerted effort to bring forth<br />

such existing data <strong>and</strong> represents a major success <strong>of</strong><br />

<strong>the</strong> HPV Challenge Program. It also indicates that<br />

many sponsors made significant efforts to evaluate<br />

<strong>the</strong> hazards <strong>of</strong> <strong>the</strong>ir chemicals prior to <strong>the</strong> launch <strong>of</strong><br />

<strong>the</strong> HPV Challenge Program, but <strong>of</strong>ten did not make<br />

those underlying data available to <strong>the</strong> public.<br />

The submission <strong>of</strong> existing, unpublished data has had<br />

a significant effect on <strong>the</strong> amount <strong>of</strong> new testing that<br />

Acute-Oral 357 864 1221<br />

Acute-Inhalation 138 346 484<br />

Acute-Dermal 101 472 573<br />

Repeat Dose 556 682 1238<br />

Gene Tox-In-Vitro 901 889 1790<br />

Gene Tox-In-Vivo 303 275 578<br />

Repro/Dev 459 431 890<br />

Subtotal 2815 3959 6774<br />

Acute-Fish 223 639 862<br />

Acute-Daphnid 154 490 644<br />

Acute-Algae 94 312 406<br />

Subtotal 471 1441 1912<br />

Biodegradation 308 590 898<br />

Subtotal 308 590 898<br />

Water Solubility 319 224 543<br />

Vapor Pressure 278 221 499<br />

Partition Coefficient 183 189 372<br />

Boiling Point 426 177 603<br />

Subtotal 1206 811 2017<br />

Totals (41%) 4800 (59%) 6801 (100%) 11601<br />

36<br />

studies were unpublished. The 75% value greatly<br />

<strong>Status</strong> <strong>and</strong> <strong>Future</strong> <strong>Directions</strong> <strong>of</strong> <strong>the</strong> HPV Challenge Program – Final Draft – 10/19/04<br />

contrasts <strong>the</strong> 50% value for unpublished studies for<br />

all o<strong>the</strong>r endpoints <strong>and</strong> can possibly be explained by a<br />

previously lower interest in publishing acute studies.<br />

Data Development Strategies Described in Test<br />

Plans<br />

The following analysis is directly related to <strong>the</strong> above<br />

discussion <strong>and</strong> shows how sponsors have proposed<br />

to address <strong>the</strong> SIDS endpoints. EPA analyzed test<br />

EPA’s High Production Volume Challenge Program<br />

plans for which comments were due through June<br />

2004 to determine how <strong>the</strong> health <strong>and</strong> environmental<br />

effects endpoints were addressed. Three methods were<br />

available to meet <strong>the</strong> minimum data needs for each<br />

SIDS endpoint. Data needs were met by:<br />

■ Using existing scientifically adequate data,<br />

■ Using an estimation technique such as Structure<br />

Activity Relationship (SAR) or “read-across”<br />

categories, or<br />

■ Proposing new testing.<br />

For human health effects, five endpoints (acute,<br />

repeat dose, reproductive, developmental, <strong>and</strong> genetic<br />

toxicity) were considered. For environmental effects,<br />

three acute toxicity endpoints were examined (acute<br />

toxicity to fish, daphnia, <strong>and</strong> algae). The 344 reviewed<br />

test plans address 112 categories <strong>and</strong> 232 single<br />

chemicals.<br />

The figure below illustrates that sponsors have made<br />

maximum use <strong>of</strong> EPA’s guidance concerning <strong>the</strong><br />

Endpoint<br />

<strong>Status</strong> <strong>and</strong> <strong>Future</strong> <strong>Directions</strong><br />

Fate<br />

Phys.chem.<br />

Human Health<br />

Ecotoxicity<br />

use <strong>of</strong> SAR <strong>and</strong> category proposals. Additionally,<br />

<strong>and</strong> in combination with <strong>the</strong> significant amount <strong>of</strong><br />

unpublished data made available through <strong>the</strong> robust<br />

summaries, only a minimal amount <strong>of</strong> new testing<br />

has been proposed. Overall, for physicochemical <strong>and</strong><br />

fate endpoints, as well as health <strong>and</strong> environmental<br />

effects, fewer than 10% <strong>of</strong> <strong>the</strong> endpoints are proposed<br />

to be addressed with new testing. The exact mix <strong>and</strong><br />

number <strong>of</strong> new tests may change as sponsors consider<br />

EPA <strong>and</strong> public comments <strong>and</strong> <strong>the</strong> remainder <strong>of</strong><br />

test plans is submitted; however, <strong>the</strong>re is no reason<br />

to believe that <strong>the</strong> overall conclusions will change<br />

significantly. Comments could lead to some additional<br />

tests being performed, but could also result in fewer<br />

tests. Perhaps <strong>the</strong> most striking conclusion from <strong>the</strong>se<br />

statistics <strong>and</strong> <strong>the</strong> illustration below is that most <strong>of</strong> <strong>the</strong><br />

data existed, but were simply unpublished. Consistent<br />

with that conclusion is how relatively little new testing<br />

is being contemplated.<br />

Endpoint Data Sources (as <strong>of</strong> June 2004)<br />

0 10 20 30 40 50 60 70<br />

Percent<br />

Existing Data<br />

Estimate/SAR/<br />

Read Across<br />

Proposed Testing<br />

44

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