Results
(229 Answers)

Answer Explanations 92

2=Do not support
user-578886

We should use alternatives where it makes sense and they are reliable. Some study types measure complex outcomes that cannot be replicated by the currently available alternative methods.

2=Do not support
user-910743

Mammalian models of course are not a good choice to be used for testing but the alternative should be as strong as mammalian models. As far as we don't have such relevant models therefore I would like to stay with animal testing.

2=Do not support
user-136174

Until there is a full proof substitute for animal study, even with all the known flaws or gaps in comparing with human physiology, reducing animal use will only add to hampering the research.

5=Strongly support
user-950121

95% of findings from animal research do not translate into human research. As a scientist, it is difficult to ignore this fact.

4=Support
user-171770

If alternative testing methods are available they should be prioritized instead of animal testing methods.

4=Support
user-480186

The mission to reduce animal in vivo testing is worth its support but the tools are problematic to doubtful.

4=Support
user-515140

I support the motion that the use of animals (mammals in particular) should be reduced. Rationally, the use of microorganisms or AI should be perfectioned to come in as substitutes.

5=Strongly support
user-691043

I strongly support the replacement of animal testing with in vitro methods for two reasons - firstly, ethical and secondly, in vitro testing gives more reliable data than animal testing and reduces significantly the cost of new drugs development.

3=Equivocal
user-388333

I am neutral in this case.

4=Support
user-323940

A lot of the currently conducted animal research is either not necessary or repetitive (due to similar research being conducted in various lab within the same country and around the world); however, certain studies that require a whole functioning organism are unlikely to be replaceable by other means such as in vitro systems in the near future.

4=Support
user-359532

The animal testing can be completely eliminated with an advanced set of in vitro experiments, which mimicing in vivo systems.

5=Strongly support
user-770534

I believe that a more human-centric analysis should be done when dealing with chemical risk assessment and human health. I believe in vitro and in silico methodologies have reached a strong scientifical background that can be applied as an alternative and reduced if not all replace animal testing. While when dealing with environmental and animal health the evolution of these methodologies can be considered also quite satisfactory.

5=Strongly support
user-793797

There is a need to reduce the amount of animal testing and there are cell cultures, tissues cultures and 3D tissue printing alternatives that all help to replace animal experiments.

5=Strongly support
user-377267

There are many ways to reduce animal testing. Reduction is a public and political decision which has been taken already in many countries.

5=Strongly support
user-481228

I strongly support reducing the use of animals for chemical toxicology risks assessment by using computer programs with advanced systems based on large chemical databases or cells-based systems or using animals. Another solution is the use of tests based on a reduced number of animals.

3=Equivocal
user-60755

Although I agree with the memo, it is still impossible to develop reliable living models in the laboratory. Hence, animal models are necessary for reliable real-world outcomes.

3=Equivocal
user-796141

This is in contradiction to current, and I believe all major national and international regulatory agencies that require testing on animals PRIOR to testing on people. All regulatory agencies already heavily rely on non-animal approaches as part of the their toxicology and safety profiling.

5=Strongly support
user-75171

Be aware this is "REDUCE", not completely REPLACE. There are certainly more alternatives of animal testing, especially with the emerging advanced in vitro models like organoids and single or multi-organ microphysiological systems.

4=Support
user-675358

animal testning can be replaced or complmented by toxicokinetic and toxicodynamic modeling see Nirdberg Fowler: Risk assrssment of human metal exposures Academic Press, Elsevier 2019

5=Strongly support
user-900365

The international scientific community is moving toward the 3 Rs, reduce, refine and replace the animal testing. Although I agree with many that the science is not there yet, but a few toxicity endpoints have shown great promises (ski sensitization, irritation). It will take some time until we verify and validate all the NAMs (New approaches methodologies) for all the safety testing, especially when it comes to human consumptions (Food, drugs, etc.).

4=Support
user-819907

Animals are still the closest species we have to humans, their usefulness in experimental research and extrapolation is crucial to science. However, we can reduce their pain and suffering in the process and use in vitro techniques where possible.

5=Strongly support
user-396007

This is better way to identify safety of chemicals in human health. Great to see leadership from EPA.

5=Strongly support
user-670216

the well being and freedom of animal is as important as the one of humans.

5=Strongly support
user-78618

Animals should not be killed

5=Strongly support
user-875539

Animal testing is unethical, expensive, and does not translate well to our species.

2=Do not support
user-927380

It provides great info that ease drug discovery

3=Equivocal
user-999665

Non-Animal Methods are not yet mature, standardized and compared with animal methods in a systematic way.

4=Support
user-676638

Reducing the use of animal testing will be more ethical. Unnecessary violence can be avoided by reducing animal testing. Future is likely to see 3D-printed models capable of replacing animal models.

5=Strongly support
user-338214

The animals have the right to life like human beings. Therefore, animal tests must be rigorous in their approval, execution and supervision. Several Non-Animal Methods should be developed and used to minimize the number of animals needed to validate the proof of concept.

5=Strongly support
user-456699

In vitro and in silico models in addition to the decades of animal toxicity research provides adequate knowledge to inform toxicity decisions without the need for animal testing to be the default choice.

2=Do not support
user-405306

Animal testing has drawbacks and deficiencies, but it is much more informative than in vitro tests

5=Strongly support
user-717150

With the advent of computational tools in toxicology, a methodologies to carry out preliminary screening need to developed and adopted immediately. Cell culture system can come handy as the next immediate step.

4=Support
user-836452

I support the direction of the above-quoted memo of the EPA’s Administrator in 2019 concerning animal study requests, but "completely eliminating...mammal study requests...by 2035" may or may not be justified by 2035. The need for organismic testing for product safety can at the present state of knowledge not yet be rigorously excluded for any precisely defined time point in future. Lets remain modest in order to allow care for human safety and not excusively for animal well-being.

3=Equivocal
user-91797

Am not convinced that we can as yet replace all animal testing and yield predictive, accurate, confident results with alternative methods.

4=Support
user-792945

Careful reduction in animal use as alternatives become available and validated would be a positive development.

5=Strongly support
user-589266

I would like to see a reduction in the number of animals sacrificed to toxicological research. In addition, animal testing in its current form is not necessarily reflective of adverse effects in humans because of overdosing, species specificity, and genetic variation.

4=Support
user-509497

Not a five (5) because in some domains we don't any available, well-recognized models, and the knowledge bas is such that it may take years --- this is especially true in several "orphan" diseases --- e.g., Spinal Muscular Atrophy

4=Support
user-521436

Sometimes animal models cannot be avoided, so need to keep this in perspective

1=Strongly do not support
user-414626

It is too early in the development of in vitro and in silico procedures to emulate whole animal pharmacokinetics

5=Strongly support
user-99229

Drosophila model is much reproducible and better than animal model

4=Support
user-144735

I support the reduction, but not the elimination, of animal testing.

2=Do not support
user-549982

Best way to test/try new biological agents/medicine before being used on humans

5=Strongly support
user-830231

Animal testing shouldn't be necessary in the 21st century, with all the enhanced cell tech and modelling around, and animal alternatives also offer higher performance as well as much better opporunities for development, adaption and improvement.

4=Support
user-759201

I think pathway-based toxicology/nonapical method are very promising, however. Lots of work needs to be done -- and validated. I support the goals, however, as without stretch goals nothing would happen. This was proposed almost 15 years ago in the National Academy's 2007 report, COMMITTEE ON TOXICITY TESTING AND ASSESSMENT OF ENVIRONMENTAL AGENTS, NATIONAL RESEARCH COUNCIL, TOXICITY TESTING IN THE TWENTY-FIRST CENTURY: A VISION AND A STRATEGY (2007).

5=Strongly support
user-90122

Our knowledge and perception of cognition of and in animals is changing and the use of animals as test vessel is outdated. Moreover, the act only as model system and many animals are sufficiently different from humans that they at best model a certain organ or certain system.

3=Equivocal
user-220439

Animal testing is still necessary, but should be managed ethically and reduced to what is absolutely necessary.

5=Strongly support
user-434394

We should go with a more human relevant science

5=Strongly support
user-143038

In 2014 over 11 million animals were used for research. Unfortunately some might be reused for other studies. This could change some strains of the animals and affect subsequent data that may be generated. Findings from the rodents and other mammals do not warrant human application.

5=Strongly support
user-821082

Alternatives to animal testing include sophisticated tests using human cells and tissues (also known as in vitro methods), advanced computer-modeling techniques (often referred to as in silico models), and studies with human volunteers. These and other non-animal methods are not hindered by species differences that make applying animal test results to humans difficult or impossible, and they usually take less time to complete.

2=Do not support
user-665841

As scientists, we aren’t confident yet, the scientific data is not sufficient to compare current processes to new technology and the use of the lowest number of mammals is needed.

1=Strongly do not support
user-414344

While animal models are not humans, they provide an inherently systems-based perspective on how a chemical or drug functions in a biological context. Multiple pathways including repair, pharmacokinetic, and compensatory processes are fully functional to provide a view of biological risk that isolated pathway indicators, no matter how many one can put on a plate can show. Modeling those comptox indicators and adverse outcome pathways remain a primitive science no matter how sophisticated the visual models area. They need much more sophistication and validation to be of any reliable value - in my opinion. If a food additive or drug is excluded with these test methods, there is little lost except perhaps something that might perhaps have been of value - likely not earth shattering. On the other hand, something that gets through has the potential of untoward damage. I believe the comptox approaches can be very valuable used in conjunction with judicious animal testing perhaps one day replacing animal test approaches. I would say dosing regimes including timing, species selection, and assessments have been overly standardized impeding their full interpretive value. Let the science evolve without knee-jerk responses to uninformed sentiments.

1=Strongly do not support
user-481665

very unlikely that we can rely on non-animal approaches for toxicity testing without compromising safety

5=Strongly support
user-125195

It is becoming increasingly clear that the current non-animal tests do not provide sufficiently reliable information about human toxicity compared to alternative tests. And with roughly 70,000 chemicals in commerce and only a thousand or so with sufficient data that provide sufficient, reliable data to inform important regulatory (not screening level priority setting), such as for National Ambient Air Quality and Drinking Water Standards, and Pesticide regulation decisions, it would take far too long and be far too costly to thoroughly evaluate each with the traditional animal based testing strategy. Thus, there is a critical need for the more informative and efficient alternative testing approaches called for in the memo calling for the agency to move to alternative approaches by 2035

1=Strongly do not support
DrAndyDABT

While many non-animal test methods are being developed, it is too early to use them to replace animal testing. There is a limit it what non-animal tests can tell you and much of the complaint about animal testing is that it doesn't model the human well. However, taking a step back into non-animal tests will decrease how well the tests model humans even more. Animal testing is not nice, but it is necessary and can't be fully replaced yet. What should be done is to demand non-animal testing be incorporated into animal tests to see how well they do or more likely do not correlate with results before ever considering eliminating animal testing.

5=Strongly support
user-602956

The scientific community has an ethical responsibility to continue advancing the 3Rs and identify suitable alternatives/NAMs that can provide equivalent information to animal studies.

1=Strongly do not support
user-541702

Scientists need to be free to do research using the best methods we know of. Researchers have had to justify all animal usage for many years, which is appropriate. Arbitrary reductions in animal use, or worse yet, the elimination of research on animals, is bad science.

4=Support
user-43697

While I certainly support the aim of reducing animal testing in the framework of 3R (reduce, refine, replace), I do not support a complete abolishment of animal testing as I do not believe that current in vitro or in silico methods are sufficiently advanced to replace complex biological systems. Of course there are good replacements for some specific types of testing like acute toxicity or irritation; longer-term studies, however, cannot be modelled by alternative systems (yet).

4=Support
user-874787

It is important to reduce the use of animal testing, particularly in certain field research because this leads to the occurring of emergence diseases. In addition, this should be strongly reduce for cosmetic products as this not essential

1=Strongly do not support
user-571430

While I might agree on limiting research using primates or domestic animals or wildlife in general, in general, research on experimental animals is still indispensable in toxicology, pharmacology and oncology. Contrary to public belief, in most instances, this type of research involves selected breeds with well known genetic features, specifically developed for research purposes. There are strict guidelines on protecting animal welfare in the stabulary and during the experiments. Ethics approval for animal experiments is already in place. Introducing further restrictions would limit scientific progress and human wellbeing in perspective.

5=Strongly support
user-232578

Current use of animal test batteries are wasteful and unnecessary. Full use and integration of existing data/knowledge (including chemoinformatics/computational/in vitro approaches) should be used to determine the need for or what specific in vivo tests are necessary.

1=Strongly do not support
user-493638

Unlike pharmaceuticals agro-chemicals,general chemicals and other substaces rely almost totally on experimental toxicology to determine the potential hazard and risk to those occupationally exposed or others through adventitious exposure. At present there is no substitute for the use of integrated organ systems provided by whole animal experiments. If anything there has been a progressive loss in the quality of animal experimentation due to the desire to substitute in vivo studies with in vitro experiments that do nowhere to substitute for relevant in vivo studies. The political rather than science based movement to more in vitro testing has resulted in faster, cheaper and less meaningful results.
If you mandate for poor science you will certainly be successful.

4=Support
user-774962

For some biological effects it is possible to get just as much relevant information to support decision-making with fewer animals. Also, some of the redundancy between in vitro and in vivo tests can be reduced by eliminating the in vivo test.

4=Support
user-740203

Ideally, animal testing wouldn't exist at all.

4=Support
user-200863

Reduction is possible by knowing as much as possible about a chemical using in silico and in vitro methods and conducting only few needed studies to confirm the findings. Eleminating all together is still debatable.

5=Strongly support
dingsli

Due to resource and time intensity, animal testing simply cannot keep up with the growing demand of toxicity data, even the "backlog" can't be cleared in decades.

2=Do not support
user-508906

Reduction of animal testing is linked to the spirit of time but not scientifically justified. Complex interactions are not testable in vitro.

1=Strongly do not support
user-156870

Computational methods or modeling of complex biological systems (e.g. animals) is completely inadequate and is not positioned to replace animal testing by 2035, or at any point in the forseeable future.

2=Do not support
user-805266

Until the EPA and other regulatory agencies begin to accept Non-Animal Methods in place of conventional animal bioassays, I think this directive by the EPA administrator may be short-sighted. I dont disagree with the overall intent here, just the feasibility and timing.

4=Support
user-218578

I support the mission to reduce the use of animal testing but this must be accompanied by other ways to evaluate the safety and efficacy of new drugs and materials.

2=Do not support
user-483397

I do not believe that by 2035 (a mere 13 years from today) the field of toxicology and safety assessment will be in a state to accurately predict all sequela to exposure from any one chemical, let alone any mixture of chemicals.

4=Support
user-477751

Many endpoints in toxicity testing can be adressed by a combination of approaches such as TTC, read-across powered by sophisticated computational chemistry, targeted in vitro testing, and refined exposure assessments. Thus, there is a much reduced need for testing if more science is introduced. Some of the reduced testing may increase uncertainty.

4=Support
RAR53

It is time to move away from AT for non-drug investigations. Instead SAR approaches based on previous AT results that have been compiled in large databases should be used along with in vitro and ex Vivo testing results.

3=Equivocal
user-366413

Reducing animal testing is a good goal. Eliminating it entirely is wishful thinking.

3=Equivocal
user-378617

The assays that replace them have to be as good or (preferably) better.

1=Strongly do not support
user-441980

We need to generate data/ evidence from animal model

5=Strongly support
user-776436

Non-human animals are not humans.

5=Strongly support
sab2x

There has been great progress in reducing the animal based testing in toxicology and having the EPA working against a defined goal will help spur further progress and facilitate this progress by having regulators focused on approval of in vitro/in silico testing.

4=Support
user-802001

Needless mammal testing should be reduced and eliminated, but it isn’t good policy to completely exclude an option that might be necessary.

1=Strongly do not support
user-543876

Incomplete systems (non whole animal systems) do not recapitulate the whole animal, therefore do not provide accurate predictions.

5=Strongly support
user-907789

Animal testing is in most cases cruel and unnecessary

5=Strongly support
user-446092

use of artificially grafted 3D tissues is much more relevant than use of animals

5=Strongly support
user-449763

I support non animal based testing and try to use more modernized molecular pharmacological research

1=Strongly do not support
user-984892

we need to understand that testing in humans is not possible and most early stages are exploratory hence animals fit better. Its is as good as keeping chicken so that they can me slaughtered and eaten by people.

3=Equivocal
user-726821

reduce de number of animals is a good idea but the actual existing substitution methods still have some lacks

4=Support
user-237495

at this moment not feaseble to eliminate, but to use more in vitro models to reduce

2=Do not support
user-271581

In vivo models are necessary to test novel drugs before testing in humans

5=Strongly support
user-343905

Animal testing, besides animal suffering, includes several problems; interaction between animal and exposure conditions, feeding, procedural costs, genetic variability... I have worked in several bioassay projects (more than 15 years) and I finally preferred to use devitalized organisms (such as moss) or artificial materials.

2=Do not support
user-910647

Using animals as test models is requested for some studies and in others can be replaced therefore I don't support the memo for the wellfare of human.

2=Do not support
user-97194

animal studies are needed for research

2=Do not support
user-986831

The depth and breadth of knowledge generated by testing drugs and vaccines in live animals is simply unprecedented and it may be very challenging for any artificial system to compete with this.

3=Equivocal
Sonne72

It’s an noble mission but it’s unrealistic from a medical and pharmaceutical perspective.

1=Strongly do not support
user-598239

The in vitro tests developed to date do not adequately address toxicity assessment for several critical organ systems, especially from gestation through adolescence, or behavior and cognitive function at the whole animal level. There is no wholistic or integrated approach to this in vitro work: just short-term assessment of organs or cells at different steps of development or adulthood using laboratory-derived tissues or cells in culture media that do no adequately represent the whole animal. Moreover, there is no phase 1, 2 or 3 metabolism taken into account or the blood-brain-barrier.

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