Blog

Hello. In these ever-changing times, the team here at Safer Medicines Trust felt it may be useful to provide our supporters with some interesting news from all things related to medicines development, hence this new blog page. Latest posts at the top.
Please let us know of any topics you would like us to cover and any feedback you may have on the blogs themselves.

How to make drugs and feel great about everything. First Spark Media. September 2025

The film ‘How to make drugs and feel great about everything’, by director Journey Wade-Hak and co-producer / writer Keegan Kuhn covers what will be familiar ground to many – the translational failure of preclinical animal studies, the adverse effects of approved drugs, the reproducibility crisis, the suffering of animals in laboratories and the new approaches based on human biology that we should be using instead. These are not easy issues to discuss, but this film about the drug development process manages to do so brilliantly. Somehow it succeeds in getting all the important scientific points across, yet with a light touch, while the excellent visuals and one-liners draw in the viewer without diminishing the gravity of what is being considered. (Upon discovering that ‘over 14000 FDA approved drugs have been recalled in the last ten years’, for instance, Journey notes that this is a level of failure not otherwise seen outside of his Tinder profile.)

Continue reading “How to make drugs and feel great about everything. First Spark Media. September 2025”

Misplacement, replacement, displacement

When considering the use of animals in research intended to have relevance for human health, the time may come when we look back and realise that animal experiments have been a huge and costly distraction, a path we might have done better to completely avoid.

If indeed we have taken the wrong turning, our task now is not to replace animal experiments; after all, there is little point in replacing a distraction. No, the task is to get back onto the correct path, which – if we are interested in human health – is research focused on humans and human biology.

Decades of experience show that – at least within academia, where basic and applied animal research is conducted – replacement isn’t working anyway. This is hardly surprising, since replacement requires animal researchers to voluntarily relinquish everything they have been working for and replace it with technologies they may be unfamiliar with and have no incentive to use. Within academia, it is more or less up to individual research teams to choose their own research topics and methodologies, so if the incentives, support or infrastructure for switching from animal to human biology-based approaches are not there, it will not be in their interests to do so. The regulatory sphere, however, is more tightly controlled: here non-animal tests for specific requirements exist, as well as greater economic and political incentives.

When animal researchers working within academia are asked why they don’t substitute their animal experiments with human biology-based approaches, they report that replacement simply isn’t a realistic option, that it is impossible to implement without disturbing the flow of their research. So, what is the ‘flow of research’? In the context of academic animal research at least, it is the flow of securing funding, publications and scientific careers – the flow of scientific capital, in other words. I write about the need to attend to scientific capital in a paper recently published in NAMs journal. In this paper, I also touch upon the concept of displacement, suggesting it is more in tune with an emphasis on phasing out animal research, whereas replacement, with its implication that there is something that needs to be replaced, continues to assert the primacy of animal research. Towards the end of a talk I wish I had come across when writing that paper, Nico Muller suggests that while replacement focuses on substituting existing animal experiments, displacement might focus on preventing more animals from entering the research pipeline in the first place. It’s a helpful distinction.

We erroneously placed our trust in animal experiments – a case of misplacement. But perhaps our trust in replacement is also misplaced. If we want to get firmly onto the path of human relevant research then we need to avoid the distraction of animal experiments and use human biology-based methods to answer questions about humans. That’s not replacing animal experiments, it’s avoiding them because they’re not relevant to human health.

For more discussion on phasing out animal experiments and how this might occur, watch Nico Muller’s talk and/ or read my paper, which provides a sociological perspective on the issue: https://www.sciencedirect.com/science/article/pii/S3050620425000521

 

How can a sociological perspective facilitate the transition from animal research to non-animal, new approach methodologies?

In our new paper, Safer Medicines Trust Research Director, Pandora Pound, explores whether a sociological perspective can help explain why animal research persists within academia despite the availability of scientifically superior, non-animal methodologies (NAMs) – and whether it can expedite a transition away from animal experiments.

Drawing on the theoretical framework of French sociologist Pierre Bourdieu, she explains how animal research maintains its dominance through ‘symbolic capital’ — the rewards and recognition scientists acquire for publishing papers and obtaining funding — and how shifting to NAMs may place this capital at risk. She highlights the relationship between the animal research field and the ‘field of power’ (government, regulators, funders), suggesting this may be delaying the pace of change, and arguing that we need to be alert to the ways in which current power relationships may be perpetuating access to capital for animal researchers and denying it to NAMs scientists.

The paper emphasises that transitioning to NAMs is not just about having the right technologies available, it’s about tackling the academic system of rewards and disincentives, it’s about examining the balance of power and how it works to promote animal research, and it’s about changing what counts as capital within academia, so that scientists are rewarded, not for publishing ‘high-impact’ papers and acquiring prestigious grants, but for conducting scientifically robust, ethical science that will actually make a difference to people’s lives.

An essential read for those working on the transition. Find it here: https://lnkd.in/efXAXJvz

How are US organisations that promote animal research responding to recent developments?

Recent developments in the US have taken us all by surprise, not only because they were unanticipated, but also due to their breadth and ambition. First the Food and Drug Administration (FDA) declared its plans to replace the use of animals with human-based approaches in the development of monoclonal antibody therapies and other drugs,1 then the Environmental Protection Agency (EPA) stated that it planned to reinstate a deadline to eliminate the use of mammals in testing by 2035,2 and the National Institutes of Health (NIH) announced the formation of a new department dedicated to expanding human-based science and reducing animal use3.

This was followed by a statement from the US Navy that it will end its research on cats and dogs.4 The most recent announcement, during a workshop held by the FDA and the NIH, was that all new NIH funding opportunities will henceforth incorporate language encouraging consideration of non-animal, new approach methodologies (NAMs) and that proposals exclusively for animal models will no longer be funded.5So, how are the US organisations that promote and advocate for animal research responding to these developments? Continue reading “How are US organisations that promote animal research responding to recent developments?”

FDA-NIH Workshop: Reducing Animal Testing


A cultural shift

Much has been written about Nicole Kleinstreuer’s announcement in the joint workshop between the FDA and the National Institutes for Health (NIH), namely that all new NIH funding opportunities will henceforth incorporate language encouraging consideration of NAMs and that proposals exclusively for animal models will no longer be funded.

This is wonderful news, but there were even more things to cheer in this workshop, held on July 7th, on the topic of reducing animal testing. For one, Kleinstreuer, who is Acting Deputy Director for Program Coordination, Planning, and Strategic Initiatives at NIH, noted that the first priority of the NIH is to improve population health, but this could not be done using outdated animal-based models. The NIH is investing in NAMs, she said, so that the best science possible is employed to improve public health protection. Second, she spoke inspiringly about the importance of creating long-lasting transformation: ‘We’re not just investing in NAMs’, she said, ‘we’re creating the policy, infrastructure, and partnerships that make that sustainable adoption possible. So, we’re not just shutting down animal labs overnight, we are actually developing long term solutions that ensure there are no new animal labs that open up in their place.’ Third, she noted that NAMs are not ‘side projects’, but ‘foundational’, so that NIH funded research becomes rooted in human relevance. And fourth, referring to plans announced earlier in the year to provide training for reviewers and regulators, she emphasised, ‘These are not just administrative tasks, they are cultural shifts.’ All in all, she described a systems-based approach to transition, focusing on phasing out animal use as well as phasing in NAMs, to ensure lasting cultural, as well as scientific, transformation of the NIH into an institution that prioritises human biology-based research.

And Kleinstreuer was not the only one. I never thought I would hear such enthusiasm about ending animal experiments from an FDA Commissioner, but Commissioner Makary was on fire. He noted that one of his main goals – one of the first he acted on within weeks of gaining office – is to reduce animal testing and said he was struck by how much consensus there was on the topic. Speaking of reducing animal use he said: ‘For one it can help deliver cures and meaningful treatments faster, to the public. Number two it can reduce R&D costs and potentially even translate into lower drug prices, which is an important agenda item for this administration. It can also encourage more innovation. It reduces the capital requirements for new drug development, and finally it’s more humane and more ethical for animals. God did not make animals on planet Earth for us to abuse and torture. And so we have to respect animals and this workshop is aimed at reducing animal testing in every way we can, while safeguarding the public with medications.’

To hear such words issuing from the FDA and NIH is remarkable and signals a clear cultural shift within the US. Imagine similar statements from the UK’s Medicines and Healthcare products Regulatory Agency, or from the UK’s Medical Research Council or Biotechnology and Biological Sciences Research Council. We can only hope that our government is aware of and emboldened by these awe-inspiring developments as it moves forward with its strategy to reduce the use of animals in scientific research.

Watch the inspirational workshop here: https://www.fda.gov/news-events/fda-meetings-conferences-and-workshops/fda-nih-workshop-reducing-animal-testing-07072025

On Clinical Trials Day – May 20 2025

May 20th every year marks Clinical Trials Day, to recognise the day in 1747 when James Lind, a ship’s surgeon in the British Royal Navy initiated what is considered to be one of the first ever clinical trials to study the effects of different treatments on scurvy (vitamin C deficiency) using control groups. Lind made the connection between the benefits of citrus fruits and reduction of scurvy after carrying out a clinical trial in 12 people, only two of whom received the citrus fruits. The principle of using human-relevant data to predict and treat human disease is represented in the pioneering work performed by Lind. Continue reading “On Clinical Trials Day – May 20 2025”

Astonishing April!

It all began on 10th April, when the US Food and Drug Administration (FDA) announced its intention to take ‘a groundbreaking step to advance public health’ by using ‘more effective, human-relevant methods’ to replace the use of animals in the development of monoclonal antibody therapies and other drugs.

Instead of using animals, the FDA will use a range of approaches, including AI-based computational modelling, human organ models and real-world human data. This, the agency says, will speed up and reduce the costs of drug development as well as improve drug safety. FDA Commissioner Martin Makary, who has only been in office since 25th March 2025, says the new approach ‘is a win-win for public health and ethics,’ noting that ‘Thousands of animals, including dogs and primates, could eventually be spared each year as these new methods take root.’ Continue reading “Astonishing April!”

Access to life-saving drugs for seriously ill patients, or easy money for pharmaceutical companies?

We have just had our latest paper published, in JRSM Open. A little different from our usual studies, this one is about the safety of a scheme run by the UK regulator, the Medicines and Healthcare products Regulatory Agency (MHRA). The Early Access to Medicines Scheme (EAMS) was established in 2014 to provide access to medicines that don’t yet have a marketing authorisation for UK patients with life threatening or seriously debilitating conditions. Sounds good? We were interested to see whether, ten years on, it is benefiting patients. Strangely though, we discovered that patients have not been asked for their views, nor have any reviews of the scheme considered the perspective of patients, the people for whom it was ostensibly set up. Instead, we found that reviews focused on the benefits of the scheme to pharmaceutical companies – such as early guidance from the regulator and access to patient populations – and to the UK economy.

Our analysis focuses on 48 submissions to the scheme, relating to 48 indications (mostly cancer) and 32 individual drugs. Unfortunately, we found that the quality of evidence used by pharmaceutical companies to support their submissions was poor, with most studies using surrogate and/or survival outcomes and only 7% using double-blind, placebo controlled randomised trials. Even more worryingly, almost half the expedited drugs had elevated rates of suspected adverse reaction reports according to the pharmacovigilance data we examined. Shockingly, given the paucity and quality of evidence upon which most expedited drugs are approved, the MHRA does not even demand post-approval clinical trials to check whether the promised benefits actually exist.

Perhaps we should not be surprised about this. During her time at the MHRA, Dame June Raine, its Chief Executive Officer, has changed the culture of the agency from one that sees its responsibility as scrutinising pharmaceutical company data on behalf of the public, to one that makes it as easy as possible for companies to market their products. And she is quite open about this. In 2022 she gave a talk at Oxford entitled, ‘From Watchdog to Enabler’ and in 2020 she proclaimed to the House of Commons Science and Technology Committee and the Health and Social Care Committee, ‘The agency, which is an independent regulator, but formerly seen perhaps as a watchdog, should now become an enabler …’. (Q780)

Can a regulator make it as easy as possible for companies to market their products and at the same time protect the public health? Read our paper here: https://journals.sagepub.com/doi/10.1177/20542704251317916

Our new publication in Frontiers in Drug Discovery: How complex in vitro models are addressing the challenges of predicting drug-induced liver injury

We are very pleased to share our recently published paper in Frontiers in Drug Discovery on How complex in vitro models are addressing the challenges of predicting drug-induced liver injury.

Predicting which drugs might have the potential to cause drug-induced liver injury (DILI) is highly complex and the current methods, 2D cell-based models and animal tests, are not sensitive enough to prevent some costly failures in clinical trials or to avoid all patient safety concerns for DILI post-market. Animal-based methods are hampered by important species differences in metabolism and adaptive immunity compared to humans and the standard 2D in vitro approaches have limited metabolic functionality and complexity. The Alliance for Human Relevant Science hosted a workshop at the Royal Society, London entitled Drug-Induced Liver Injury (DILI): Can Human-Focused Testing Improve Clinical Translation? The conclusion was that complex in vitro models (CIVMs) provide a significant step forward in the safety testing paradigm. This perspective article, written by Dr. Katy Taylor and Alliance members representing collaboration across academia and industry, provides a ‘state of play’ on liver CIVMs with recommendations for how to encourage their greater uptake by the pharmaceutical industry.

Full citation: Taylor, K, Ram, R, Ewart, L, Goldring, C, Russomanno, G, Aithal, GP, Kostrezewski, T, Bauch, C, Wilkinson, JM, Modi, S, Kenna, JG, Bailey, J. Perspective: How complex in vitro models are addressing the challenges of predicting drug-induced liver injury.  Front. Drug Discov. 5 – 2025.

Read the full paper here

Two wrongs do not make a right: animal models of physical and sexual abuse

In the move to transition away from animal research and towards New Approach Methodologies (NAMs), the emphasis tends to be on developing and validating NAMs, as if their availability alone will create the necessary momentum for transition.

But transition science tells us that things aren’t that simple and that in fact there needs to be at least equal emphasis on phasing out old technologies. In the case of animal research, one way of doing this might be to call a halt to animal studies that have clearly failed to generate any clinical benefits (stroke, brain injury, Alzheimer’s disease spring to mind). Another might be to immediately cease funding and approving studies that are clearly unnecessary, unscientific and unethical.

It was with the latter in mind that we read Animal Free Science Advocacy’s recent post about an Australian study published last month, which reported on an animal model of non-fatal strangulation (Sun et al 2025). Unbelievably, this model was developed to throw light on the injuries women can suffer at the hands of sexual partners (‘intimate partner violence’). The scientists assigned 6–7-week-old female rats to either control, brain injury, strangulation, or brain injury plus strangulation groups. Brain injuries were inflicted by using pneumatic pressure to propel a 50mg weight against the rats’ heads and strangulation was mimicked by suspending a 680g weight across the rats’ trachea for 90 seconds. Following a period of assessment the animals were killed and their brains examined. The results of this study? Strangulation plus brain injury presents differently to brain injury alone, exacerbating functional deficits, neuropathophysiology, and blood biomarkers.

Continue reading “Two wrongs do not make a right: animal models of physical and sexual abuse”

New report by Lush Prize on the UK as a leader in new approach methods (NAMs) for safety science

A proposal to use the cosmetic animal testing bans as a legislative framework to advance safety standards in other areas, including medicines.

Our Scientific Consultant, Rebecca Ram, is also a Scientific Consultant to the Lush Prize team at the Ethical Consumer Research Association, for whom she has written this new report. It is a comprehensive but concise summary of the progress made in developing non-animal, human-relevant new approach methods (NAMs) for ensuring the safety of cosmetics.

Safer Medicines Trust does not normally comment on cosmetics testing – but this report show how the animal testing bans drove a sea change in innovation of human-relevant methods, and were ‘a unique move that cemented the cosmetics industry’s place as a propeller for innovation in the field of safety testing.’

If you have been confused by the convoluted saga of the on-off bans on cosmetics animal testing – this is a great summary of the whole timeline. Most importantly, it shows how public pressure drove this tremendous change, which could serve as a blueprint for other sectors to follow. The UK could seize this opportunity to become the global leader in animal-free innovation, to the benefit of human and environmental health, as well as the economy.

Lush Prize 2024 Major Science Collaboration Award winner – COLAAB

Safer Medicines Trust is part of the Coalition to Illuminate and Address Animal Methods Bias, otherwise known as COLAAB, so we were delighted when COLAAB was recently recognised for its important work with a Lush Prize in the category of Major Science Collaboration!

COLAAB is an international coalition of researchers and advocates from a range of organisations, charities and universities worldwide. It was formed in 2022 following a workshop to discuss how the bias towards using animal methods plays out within scientific publishing. Workshop attendees from publishing, academia, industry, government, and non-governmental organisations discussed this phenomenon and the impact it could have on scientists’ research and their careers. Two years later, COLAAB held another workshop, this one to explore the issue of bias in reviews of academic funding proposals.

There has long been anecdotal evidence of a bias towards using animals within academia. But what COLAAB has done is two things. First, and importantly, it has named the phenomenon. Being able to talk about ‘animal methods bias’ makes the issue much easier to discuss and helps people recognise it and – crucially – challenge it when it arises. Second, the coalition is collecting empirical evidence about how this bias plays out and how it affects scientists’ ability to get their studies published if they do not use animals. Not content with anecdote, COLAAB has conducted two surveys of scientists’ experiences of animal methods bias in academic publishing. The first was an initial foray into this field and the second, which should be published later this year, is a much larger survey, together with an analysis of biomedical publications. Further research is planned, including a qualitative study of the experiences of PhD students and early career researchers, and – hopefully – an investigation into animal methods bias within biomedical funding.

It’s wonderful that Lush Prize has recognised the importance of this collaboration. Congratulations to everyone involved!

Five key messages from RAT TRAP – shortlisted for a 2024 Lush Prize!

For our first blog of 2024, we summarise five key messages from Safer Medicines Trust’s landmark new book, Rat Trap by Dr. Pandora Pound which we are delighted has been shortlisted for a 2024 Lush Prize in ‘Public Awareness’.

  1. A lack of translation from ‘bench to bedside’ has existed for decades and there are many opportunities that can and must be embraced for change. Better treatments for diseases such as Alzheimer’s, stroke and cancer are long overdue. Knowledge obtained from animal studies cannot be reliably applied to humans.
  2.  Science is at a turning point with the development of more powerful, human-relevant methods to investigate disease and drug discovery; for example in vitro assays , which have advanced from the origins of basic cell cultures through to ‘state of the art’ 3D organoids (‘mini organs’) and microphysiological systems (‘organs on chips’), as well  as advanced in silico models, which have evolved from simpler analyses to advanced deep learning models, incorporating artificial intelligence (A.I.) and the use of ‘big data’.
  3. No single method provides a solution. Instead, new approaches must be combined in different and ‘bespoke’ ways to answer specific research questions and build evidence. These new approaches can be used in tandem with existing clinical approaches and clinical data, which at present are vastly underused.
  4. The regulations governing animal research and pharmaceutical drugs require overhaul to accommodate the transition that is needed towards human-relevant science. Achieving a future with better drug safety and effective treatments depends on it. Regulatory action must be driven by government mandate. There is no specific legal requirement to test on animals, but long-standing guidelines and attitudes maintain a collective expectation that animals must be used.
  5. It is time to break with tradition and embrace the human in disease research and drug discovery. Funding must be diverted away from animal research and towards human biology-based approaches as a matter of priority.  The issue of animal research affects all of us. Our health and safety are at stake. This is not just about animals – the effect on patients has been overlooked for far too long.

See more reviews and information on Rat Trap – the spark for a revolution in science – here
as well as media coverage of the book and interviews with Dr. Pandora Pound

It can be bought direct from the publisher Troubador here
Or from online bookshops, including Amazon here

World Patient Safety Day – Medication Without Harm

 

World Patient Safety Day is grounded in the most fundamental principle of medicine – first do no harm 

“Medication Safety” is the theme for World Patient Safety Day 2022.

Safer Medicines Trust is a patient safety charity whose mission is to improve the safety of medicines, so we very much support calls for “Medication Without Harm”.

The World Health Organisation (WHO) quite rightly wants to reduce medication harm, which accounts for 50% of the overall preventable harm in medical care. US$ 42 billion of global total health expenditure worldwide can be avoided if medication errors are prevented.

However, the WHO does not address the fact that correctly-administered medicines also cause massive and ever-increasing harm, through adverse drug reactions (ADRs) which are not due to any errors or unsafe practices.

Our focus, at Safer Medicines Trust, is on the intrinsic safety of the medicines themselves, rather than on ‘downstream’ factors such as prescribing errors. ADRs kill more than 10,000 people in the UK each year, 100,000 in the US and 200,000 in the EU.

Clearly, our safety tests are failing – but why? A major reason is our reliance on animal tests as the ultimate arbiter of medication safety before proceeding to clinical (human) trials. The evidence is now overwhelming that animals cannot reliably predict drug safety for humans. This is borne out by the fact that 9 out of 10 drugs prove unsafe or ineffective in clinical trials, after appearing to be safe and effective in animal tests.

Thankfully, a wealth of new methods based on human biology is now available and is transforming our ability to understand disease and develop new medicines. Human-relevant tests can predict subtle or rare side effects that even human clinical trials cannot. Human-relevant science offers a golden opportunity to save money, create wealth and improve public health.

So why are we still relying on animal tests? As a new paper entitled A History of Regulatory Animal Testing: What Can We Learn? makes clear, moving away from animal testing is limited not by scientific possibilities, but by historical precedents and persistent beliefs that animal tests will prevent future tragedies. The thalidomide tragedy shocked the world and led to new laws requiring ‘proof of safety’ in animals, despite the irony that it was thalidomide’s near-total safety in animals that helped to cause the tragedy and would not have prevented it. No amount of animal testing can eliminate the risks inherent in introducing new drugs to the market. But regulations based on the state of the art of science and technology 60 years ago have not been updated to reflect the seismic technological advances that now offer a quantum leap forward in our ability to perform meaningful risk assessment.

It is time for governments to insist that medicines are tested by the most up-to-date and relevant methods. Outdated regulations cost lives: patients are being injured and killed because regulations have not kept pace with revolutions in science. Regulatory agencies the world over have been captured (and funded) by the pharmaceutical industry, which they are supposed to regulate, with the net effect that profits take precedence over patients.

In a recent egregious example, both Pfizer-BioNTech and Moderna submitted their omicron-specific covid boosters to the US regulator, the FDA, on the basis of tests in mice – and the FDA approved them, with no human data whatsoever! The US Government has bought 171million doses for $5bn, before seeing any evidence that they will be either safe or effective.

Dr Paul Offit, director of the Vaccine Education Centre at Children’s Hospital of Philadelphia and member of the FDA’s vaccine advisory committee (VRBPAC), says: “Right now they are saying that we should trust mouse data and I don’t think that should ever be true. I don’t think you should ever ask tens of millions of people to get a vaccine based on mouse data.”

This example illustrates the two biggest problems in pharmaceutical medicine: 1) the use of animal data to secure approval for products by claiming they are safe and effective in animals, when their safety and effectiveness in humans is unproven; 2) pervasive conflicts of interest, which prevent regulatory oversight in the interests of the public.

We must move safety testing into the sunlight and into the 21st century, for all our sakes.

The crisis of Alzheimer’s disease research: it’s time to embrace a new approach to help patients

The problem

Alzheimer’s disease (AD) is a leading cause of death in the UK and along with other dementias, is responsible for almost 11% of all deaths in England.1 More than 209,000 new cases are diagnosed each year across the UK.2 It remains a leading cause of death and disability worldwide3, affecting nearly 50 million people. Every three seconds someone develops dementia, equating to 9.9 million new cases annually worldwide.2

Billions have been spent on AD research to date. Since 2008, the US National Institutes of Health (NIH) alone has spent over $32 billion on research grants for AD and other dementias, with projections for 2022 and beyond expected to be much higher. 4 Between 2010 and 2020, UK government investment in dementia research has increased from £28.2m to £75.7m per year.5  Since 1998, the charity Alzheimer’s Research UK has provided £171 million to research projects.6

Despite the scale of funding, finding new treatments for AD has proved virtually impossible and has been described as a ‘graveyard for expensive drug tests.7 Hundreds of drugs have been developed but have an appalling failure rate during clinical (human) trials of over 99%, representing a dismal return on global investment into AD research.8 Failures are due to either a lack of proof that the drug works (efficacy) or safety related side effects (toxicity).9 There are a few drugs available to AD patients, however they too may cause side effects10 and are offered to try to manage day to day symptoms at best. There is no drug available which can slow or stop the worsening of AD.

Controversy and the AD crisis

No new treatments were approved for AD between 2003 and 2021, until the controversial approval of Aduhelm (aducanumab) by the US Food and Drug Administration (FDA) last June.11 The approval was highly criticised by the FDA’s own advisory committee and some staff resigned, allegedly in protest over concerns about Aduhelm’s safety and efficacy and that its approval had been ‘fast tracked’ without appropriate evidence of its benefit to patients.12

Aduhelm’s mechanism of action is to target ‘beta amyloid’, a type of protein which gathers to form sticky clumps or ‘plaques’ between brain cells and is considered to correspond to the decrease in brain function and cognitive decline seen in AD. Most research has focused on blocking this protein to stop plaques accumulating. Another is a protein called ‘tau’ present in the nerve cells of the brain (neurons). In healthy brains, tau proteins are long and straight, to enable transport of nutrients along and between neurons. In patients with AD, these tau proteins are seen to collapse and become tangled, so nutrient transport breaks down and the neurons die. However, research into these proteins and the link to AD is not straightforward, as plaques and/or tangles are known to form long before the onset of AD symptoms.13 Drug failure rates may be compounded by the fact that by the time AD patients enter trials, brain cell damage may be too advanced, leading to some research focus shifting to earlier in the disease process, for example new vaccine trials.14  Furthermore, some patients diagnosed with AD are found to have few or no plaques in the brain15 and plaques can be present in people who never develop AD.16

Following Aduhelm’s approval, AD research has again attracted controversy very recently, with media coverage raising concerns that data from a high-profile study carried out in mice and rats into a particular protein in the brain called ‘amyloid beta *56’ may have been manipulated or exaggerated. Concerns are intensified as the 2006 study was highly influential when published in Nature and has since been cited by well over 2,000 further studies, resulting in multi-million-dollar grants being issued for research on the same theory. 17 For example, as explained in a recent Science article which reported the story, in the last financial year alone the NIH has allocated $1.6 billion (approximately half of its AD funding) to ‘amyloid’ related projects and annual NIH support for similar studies increased from near zero to $287 million by 2021.18 The amyloid theory has dominated AD research to the general exclusion of most other areas of investigation13 and may have potentially misled the field for almost two decades,19 compounded by evidence of a long list of failed treatments.

Why is the failure rate so high?

Prior to being tested in human (clinical) trials, all potential new drugs are assessed in preclinical (also sometimes called ‘nonclinical’) tests for safety and efficacy, the vast majority of which are performed in animals. It’s important to note that animals are not just used at the preclinical stage, but also throughout the entire earlier process of AD research to study human disease mechanisms, identify new therapeutic targets, and develop new drugs before testing them.20 Animal tests are performed either before, or in parallel to several stages of clinical trials in humans. However, nearly all potential new AD treatments have failed somewhere along the clinical trial process, leading to the attrition rate described above. For example, mice often respond to AD drugs, leading to overestimation of performance and subsequent rejection during clinical trials, when humans do not produce the same response. Furthermore, some experimental drugs have even been considered to worsen cognitive decline in patients.21

Animals do not naturally develop AD (and many other diseases) in the same way as humans. This is well known and has led to a dramatic increase in the use of genetically modified (GM) animals to try to artificially create disease symptoms and ‘humanise’ them. However, while GM animals such as mice can be engineered, for example to develop the ‘tau’ protein tangles seen in the brain cells of AD patients, their underlying biology means that results have not translated to patients in the clinic, leading many researchers to conclude that better science is needed. 22

Sadly, research (and those who regulate and approve it) remains entrenched in the use of animal models, despite the known failures. The NIH National Institute of Aging recently said, in reference to AD: “while we have been able to cure the disease in mouse models of the disease, we have not been able to translate these advances to humans”. But instead of this prompting a shift towards more human relevant strategies, the institute is looking for ‘alternative animal models’ such as ‘better mouse models’ and commenting, “the marmoset shows promise”, while looking to recruit “early career investigators interested in expanding the range of animal model paradigms”.23 It’s important to clarify that many species of animals including mice, rats, dogs and monkeys have been used for decades and an animal model termed as ‘new’ usually means trying a different mutation or strain. Old ways and out of date methods – even when they don’t deliver – are clearly hard to escape from, especially when high figure grants are at stake and research infrastructure is firmly embedded in global business supply chains involved in the ongoing breeding, supply and transport of animals. This promises yet another eventual dead end and is astonishing, given how much of the NIH yearly spend is on AD. Animals cannot adequately replicate the disease in humans and so in turn are unable to predict human responses to drugs, due to extensive species differences from macro to micro (molecular) levels. Simply put, they are not human-relevant.

This presents a two-fold problem; firstly, decades of continued reliance on animals keeps leading to failure in human trials and secondly, patients are potentially missing out on many effective treatments that have been rejected, based on a lack of desired response during animal tests. Sadly, this is not a problem confined to AD. The general failure rate for new drugs is between 86-95%. Although several thousand diseases affect humans, only about 500 have any approved treatments.24

Human relevant science is the solution

There is a wide range of human-relevant scientific methods which can be employed in Alzheimer’s Disease research. For example, the pioneering in vitro ‘organ on a chip’ system uses human cells and tissues in microfluidic devices. These mimic a variety of human organs to test new compounds before entering clinical trials. With specific application to AD, this technology has been developed using neurons derived from human stem cells, to provide a model which more closely mimics the development of human AD – and therefore response to treatments – than animals.25

In response to the urgent need to address the lack of effective treatments for AD and the failure of conventionally used (animal) models to date, the Joint Research Centre (JRC) of the European Commission recently published a comprehensive database of 567 biochemical and computational research models (the JRC has also developed similar databases for hundreds of new methods in other disease areas). The publication was a result of the centre’s ongoing work to ‘provide an inventory and scientific evaluation of innovative (human-based) non-animal models/approaches currently in use for basic and applied research in the field of neurodegenerative diseases, more specifically Alzheimer’s and Parkinson’s disease’, and to ‘contribute to the increased adoption and acceptance of alternative methods in neurodegeneration research and related fields. Just a few examples include 3D organoid, ‘brain on a chip’ or in silico (computational screening) methods to investigate protein aggregation or neuroinflammation.26

There is also scope to vastly improve the use of libraries of existing observational, clinical and real-world evidence (RWE) data on AD, given the many hundreds of trials and studies over decades. Retrospective analysis and systematic review of this data can provide opportunities for better diagnosis, treatment and prevention strategies27 as well as human systems biology-based approaches. As proposed in the Journal of Alzheimer’s Disease28, a massive international human genome sequencing effort could help to elucidate the fundamental nature of AD and resolve whether the amyloid hypothesis or other competing hypotheses, such as the innate immunity hypothesis, is correct.

As described earlier, the chronic pathological processes leading to brain cell breakdown may mean that AD is too advanced by the time patients are diagnosed, which has been speculated as a contributing factor to drug failures. For example, some human-relevant models recognise this and are built to address the earlier stages of mild cognitive impairment (MCI) which can precede AD in patients.29

There are other factors in brain physiology and function which may contribute to AD. For example, improvements in cardiovascular health are known to decrease risk of dementia 30 and lifestyle factors such as maintaining good physical and mental activity and a healthy diet remain critical.31 In fact, the US National Plan to address AD and related dementias was updated in 2021 to include actions for promoting healthy aging by reducing risk factors, including physical inactivity, hypertension, smoking or excessive alcohol drinking, unhealthy diet, diabetes, infectious diseases, exposure to toxins, physical brain trauma, depression, and low cognitive/social/educational attainments, among many other damaging factors and conditions associated with aging.32

These are just a few examples of the types of human-relevant approach that can be taken forward in AD research. Many are working in this area, but maintaining funding to prove that this is a better scientific way forward remains challenging. The need for government action, laws and regulatory attitudes to catch up is long overdue.

The opportunities to transform AD research are not limited to just one approach or data source. Instead, all available human-relevant methods can and must be used in combination as ‘new approach methods’ (NAMs) to provide real world solutions, and to end over-reliance on animal models which are failing to deliver the treatments so urgently needed by AD patients. This closing comment by a senior editor of the Journal of Alzheimer’s Disease is aimed at the amyloid hypothesis – but it could equally be applied to the animal model paradigm:

“It is unacceptable, in my judgment, when medical researchers (for whatever reasons) steadfastly hold onto a hypothesis that does not help sick patients in any manner despite being paid to do it. Rationalizing such behavior blocks medical progress resulting in dire consequences for the patients’ clinical outlook. Equally disturbing is the callous effect such conduct has on devaluing the scientific spirit and the search for truth.” 33

References

  1. Monthly mortality analysis, England and Wales – Office for National Statistics (ons.gov.uk)
  2. Incidence in the UK and globally – Dementia Statistics Hub.
  3. 2022 Alzheimer’s disease facts and figures – PubMed (nih.gov)
  4. RePORT (nih.gov)
  5.  Research funding – Dementia Statistics Hub
  6. About our research – Alzheimer’s Research UK (alzheimersresearchuk.org)
  7. Failure Upon Failure For Alzheimer’s Drugs | Inside Science
  8. World Alzheimer’s Day: New approach methodologies are urgently needed – Safer Medicines
  9. Alzheimer’s disease drug-development pipeline: few candidates, frequent failures | Alzheimer’s Research & Therapy | Full Text (biomedcentral.com).
  10. Effects of Alzheimer’s disease drugs | Alzheimer’s Society (alzheimers.org.uk)
  11. New drug for Alzheimer’s – Safer Medicines
  12. Three FDA advisers quit over agency approval of aduhelm (medicalxpress.com)
  13. The amyloid hypothesis on trial (nature.com)
  14. The inside story of the search for an Alzheimer’s vaccine (telegraph.co.uk)
  15. Mild to moderate Alzheimer dementia with insufficient neuropathological changes – PubMed (nih.gov)
  16. Plaques, Tangles in Brain Don’t Always Lead to Alzheimer’s (medicinenet.com)
  17. A specific amyloid-β protein assembly in the brain impairs memory | Nature
  18. https://www.science.org/content/article/potential-fabrication-research-images-threatens-key-theory-alzheimers-disease
  19. ‘Manipulated’ Alzheimer’s data may have misled research for 16 years (telegraph.co.uk)
  20. Alzheimer’s Disease, and Breast and Prostate Cancer Research: Translational Failures and the Importance to Monitor Outputs and Impact of Funded Research – PubMed (nih.gov)
  21. Successful therapies for Alzheimer’s disease: why so many in animal models and none in humans? – PubMed (nih.gov)
  22. Is it Time for Reviewer 3 to Request Human Organ Chip Experiments Instead of Animal Validation Studies? – Ingber – 2020 – Advanced Science – Wiley Online Library
  23. Seeking alternative animal models for Alzheimer’s disease | National Institute on Aging (nih.gov)
  24. White Papers – Human Relevant Science
  25. A human induced pluripotent stem cell‐derived cortical neuron human‐on‐a chip system to study Aβ42 and tau‐induced pathophysiological effects on long‐term potentiation – Caneus – 2020 – Alzheimer’s & Dementia: Translational Research & Clinical Interventions – Wiley Online Library
  26. Dura, Adelaide; Gribaldo, Laura; Deceuninck, Pierre (2021): EURL ECVAM Review of non-animal models in biomedical research – Neurodegenerative Diseases. European Commission, Joint Research Centre (JRC) [Dataset] PID: http://data.europa.eu/89h/a8fd26ef-b113-47ab-92ba-fd2be449c7eb
  27. Advancing Alzheimer’s research: A review of big data promises – ScienceDirect
  28. https://www.j-alz.com/editors-blog/posts/science-based-falsifiability-test-amyloid-hypothesis-ahyp
  29. HESPEROS HUMAN-ON-A-CHIP® SYSTEM MODELS PRECLINICAL STAGES OF ALZHEIMER’S (hesperosinc.com).
  30. Who is most at risk of dementia? – Alzheimer’s Research UK (alzheimersresearchuk.org)
  31. Leroy Hood: The key to treating Alzheimer’s disease may not be a drug – Twin Cities
  32. https://aspe.hhs.gov/reports/national-plan-2021-update
  33. https://www.j-alz.com/editors-blog/posts/what-wrong-alzheimers-disease-clinical-research

New paper discusses  in silico New Approach Methodologies (NAMs) and increasing use of ‘big data’ to advance human relevant research

A new paper by Safer Medicines scientific consultant Rebecca Ram, Dr. Domenico Gadaleta of the Mario Negri Institute, Italy and Dr. Tim Allen of the MRC Toxicology Unit, Cambridge discusses the progress of in-silico methods in New Approach Methodologies (NAMs) as well as the increasing need for use of ‘big data’ and artificial intelligence (AI) approaches in safety testing and biomedical research.

In silico, or computer-based research methods continue to emerge as part of a robust 21st century public health strategy, vital to improving the efficiency of preclinical drug discovery, as well as safety testing in the chemicals industry. They can be used alongside other methods e.g., human-based in vitro (cell or tissue derived) models as components of human-relevant New Approach Methodologies (NAMs).

In generic terms, ‘big data’ describes large quantities of ever-increasing data and the process of extracting and analysing information from them to reveal patterns, predictions or trends. Use of big data is considered vital to science, business, finance and technology. Advances in artificial intelligence continue to provide opportunities to analyse big data available from NAMs, to vastly improve health and medicines research. However, there is still an urgent need for wholescale recognition and investment in these approaches by scientists, governments and regulators.

The paper provides an overview on the progress of in silico methods including evidence of their use in NAMs case studies, as well as discussion of the increasing relevance of ‘big data’. Scientific and legislative drivers for change are also discussed, along with next steps to address challenges in achieving the regulatory acceptance needed to shift the research paradigm and advance human health.

The full paper can be accessed here The role of ‘big data’ and ‘in silico’ New Approach Methodologies (NAMs) in ending animal use – A commentary on progress – ScienceDirect

World Animal Free Research Day

One of our partner charities in the Alliance for Human Relevant Science is Animal Free Research UK. They have initiated an annual World Animal Free Research Day on the anniversary of their founding, 27th May.

Our goals are very complementary: Animal Free Research UK’s vision is “To create a world where human diseases are cured faster without animal suffering”, while Safer Medicines Trust’s mission is to protect patients by speeding a transition to human-focused drug development and testing.

We both agree that outdated animal research is failing patients and that investment in human-relevant science offers a golden opportunity to revitalise medical research, for the benefit of all.

As our Science Adviser, leading cancer researcher Professor Azra Raza tweeted this week: “Take the blinders off and see that using animal models for pre-clinical testing has failed to help develop novel cancer therapies. Invest in Phase 0 Trials. Take therapies directly to humans. Reduce dose by 1/500.”

And as the CEO of Emulate, Jim Corbett writes in Forbes yesterday, “To make the drug development process safer, we have to take a hard look at the models we use. We have to see that the mouse has no clothes and that there are better models out there.”

Exciting activities are coming up: the Animal Free Research UK Conference – Modernising Medical Research – is in Birmingham on Tuesday 28th and Wednesday 29th June 2022. Ticket sales end on 1st June – so hurry!

And the UK’s first Helpathon to accelerate human-relevant science will take place on 11 and 12 October – the deadline for expressions of interest is 30 June 2022.

World Liver Day: Human-relevant research is needed into liver disease and Drug Induced Liver Injury (DILI)

By Rebecca Ram

This month marks World Liver Day (held every year on 19 Apr) to raise awareness about diseases of the second largest organ in the body. After the brain, the liver is the most complex organ and is vital to the efficient control of the gastrointestinal (digestive) system.

Liver diseases account for approximately 2 million deaths per year worldwide, including cirrhosis, viral hepatitis and hepatocellular carcinoma. Cirrhosis and liver cancer are among the global leading causes of fatality, responsible for 3.5% of all deaths worldwide.  According to the British Liver Trust, liver disease is expected to overtake heart disease as the biggest cause of premature death in the next few years and there is an urgent need for new treatments.

In addition to liver disease, specific liver damage as a result of medication continues to be a long-term patient safety problem. The symptoms of Drug Induced Liver Injury, or DILI, can vary from mild to severe, but in the worst cases DILI can lead to permanent liver failure and/ or death. DILI is associated with many drugs currently on the market, accounting for approximately 14 cases per 100,000 patients and is a leading cause of drug failure, both during clinical trials and post-market withdrawal.

‘In vivo’ (animal) models are routinely used to try to replicate characteristics of liver damage, for example the use of carbon tetrachloride is a common procedure to induce liver injury in rodents.  Attempts to artificially recreate human lifestyle factors which can result in liver disease such as chronic alcohol consumption or a high sugar/fat diet are also repeatedly used in animals, which have often been genetically modified (GM).  However, there is widespread concern over the limitations of animals to mimic the complexities of liver conditions in humans.  Despite such concern, animal studies continue to be cited (mainly by those that use them) as ‘essential’ for gaining a better understanding of liver diseases, whilst at the same time scientists acknowledge how little is known despite decades of animal use. Systematic reviews (SR) of animal models of liver disease have also raised questions over the ability of animal models to replicate the human response.

Furthermore, as many liver adverse effects are idiosyncratic in humans, they are not adequately predicted by animal studies, with species differences being described as ‘drastic’, for example when comparing the liver responses of dogs to humans. Again, despite this problem being widely recognised, animal studies are still the conventional approach for testing for potential DILI.

Between January and June 2020, UK research projects related to liver disease were approved which will use over a quarter of a million animals (279,325) in the UK over the following five years. The majority of projects involve mice and rats, as well as many other species, including beagle dogs, rabbits and guinea pigs. Projects range from direct liver disease or DILI projects, to other projects where liver injury is involved or the toxicity testing of new drugs. Just one study for example to investigate DILI will use over 40,000 mice. Of further grave concern is that only 25% of these projects will be independently assessed afterwards to see if they met their scientific objectives. In ‘lay summaries’ describing these projects it is often stated that there is a ‘liver disease crisis’  and that there are ‘urgent unmet clinical needs’, yet these sit alongside claims such as ‘these animal models have been used for years’.

We cannot afford to continue testing unrealistically high experimental doses of drugs or creating artificial diseases in GM animals. New, human-relevant methods are available, including in-vitro approaches using human tissues and cells, e.g. primary human liver cells, or hepatocytes; 3D spheroids (which act as ‘mini-organs’ to predict human responses) and advances in liver on a chip or ‘microphysiological’ systems. These are small but sophisticated devices containing micro-sized channels which are supplied with human liver cells or tissue, to which potential new drugs can be applied to test for human safety, or used as models of human liver diseases. Recent systematic reviews of mechanistic in-vitro assays have shown them to effectively predict DILI for several drugs where preclinical (animal) and other studies previously failed.

Other methods include in-silico (or computational) methods and advanced artificial intelligence ‘deep learning’ models to predict liver toxicity, as well as many other sources of human-derived data. No single method can be used alone, instead different method types can be combined as bespoke, new approach methodologies (or NAMs) to reveal pathways of events right through from a molecular level to physical effects as they manifest in patients.

Due to the enormous expense and time-consuming nature of using animal models, the number of substances that can be effectively tested using in vivo liver toxicity assays is limited. The development of human-based approaches (e.g., in vitro methods to test for liver injury (or hepatotoxicity)  allow many substances to be tested more cheaply and quickly. Indeed, cost reductions of over 90% have been estimated when compared to many typical animal tests.
For further insight, follow this link to see a recent presentation on ‘In vitro models for assessment of DILI’ by Safer Medicines Trust’s Pharmaceutical Director Dr. Gerry Kenna.

 

New Approach Methodologies in COVID-19: systematic review into the neurological effects of SARS-CoV-2 infection presented at SOT (Society of Toxicology) Congress 2022

By Rebecca Ram

Launched nearly two years ago, the CIAO project (Modelling the Pathogenesis of COVID-19 using the Adverse Outcome Pathway Framework) involves the collaboration of scientific experts to identify the chemical and biological events involved in the body’s response to the SARS-CoV-2 virus. Expert working groups are established across a number of areas, for example acute respiratory distress, lung fibrosis, neurological, liver and cardiovascular injury.

At the US Society of Toxicology (SOT) 2022 congress in San Diego last week, research was presented by the project’s literature review working group on the key central nervous system (CNS) events in COVID-19. Using a systematic review (SR) approach, the group, led by the EBTC (Evidence Based Toxicology Collaboration) identified and analysed data relevant to the neurological adverse outcomes of SARS-CoV-2 infection and to further identify potential gaps in knowledge to inform the COVID-19 AOP framework. The results were presented by Donna Macmillan in a poster at the SOT congress, including quantitative analysis and data extraction demonstrated in a systematic evidence map. The SR protocol used has been published as a general approach and guidance to other research areas.

The Adverse Outcome Pathway (AOP) is a game changing pathway-based concept, developed over the last two decades to provide highly mechanistic information on the effects of a ‘stressor’ (for example any chemical or virus – in this case the SARS-CoV-2 spike protein) triggering a  ‘molecular initiating event’ (MIE) and progressing through higher level ‘key events’ (KEs) at cell, organ and tissue level; the relationships between those key events (KERs) through to adverse outcomes observed in the individual and potentially, populations.

The AOP was originally intended to establish toxicity pathways in response to chemicals, but as all diseases, bacteria and viruses act in a similar way to trigger MIEs, AOPs have application across chemical safety, basic and applied/translational disease research. Key events and adverse outcomes are not necessarily unique to one AOP and so can be connected to form almost infinite adverse outcome ‘networks’.

Data resulting from different types of test method can be integrated to map events in AOPs, for example in silico (computational) models for chemical screening (from simpler analysis models through to artificial intelligence, or AI, derived data from machine learning algorithms), in vitro assays (advanced human cell based models such as stem cells or 3D organoids) to assess biological activity, as well as a variety of human based data (e.g. clinical trials, biomonitoring and ‘real world data’ from epidemiological and observational studies). Combinations of these methods are termed ‘New Approach Methodologies’ (NAMs) and they are designed to overcome limitations in the predictive capabilities of conventionally used methods (‘in vivo’ animal models). Case study evidence in NAMs continues to emerge, aiming to provide practical guidance and overcome the bottleneck in achieving regulatory acceptance.

Although the basic AOP is visualised as a linear ‘left to right’ concept, the AOP can be used in any direction or started at any point and all AOPs are ‘dynamic’, as new and updated information can be added to them continuously. In simple terms, AOPs might be very broadly compared to jigsaw puzzles. As pieces (or ‘data gaps’) are filled, they show what is still missing.

Read our previous post on the CIAO project here

The poster above can also be accessed on the CIAO publications page

To find out much more on the successful outcomes of the project to date and how to become involved, visit  https://www.ciao-covid.net/ 

Further information on AOPs, including useful training and educational resources can be found here

 

‘Five For Friday’; Starting 2022 with five examples of human-relevant science using new approach methodologies (NAMs)

By Rebecca Ram

Many research methods which focus on human-relevant biology (NAMs) are in use worldwide.

However, a co-ordinated analysis of all existing methods that could be harmonised for global regulatory approval, as well as diversion of funding to the development of new methods are both long overdue. Encouraging signs were seen in Europe towards the end of 2021, when Parliament voted in favour of an EU wide action plan to accelerate the development of NAMs to improve human safety prediction and phase out animal use, with strong support from scientific stakeholders. Follow up action is now awaited from the European Commission.

As 2022 begins, we continue our ‘Five for Friday’ theme with a summary of some examples of positive progress in human-relevant research…..

  1. There is inevitably a continued focus on COVID-19. A collaborative project using state- of- the- art in silico methods (computer simulations) has recently published its findings on the cause of blood clots in response to the AstraZeneca vaccine.
  2. Researchers at Hebrew University reported a complete elimination of animal use with their ‘organ on a chip’ technology to measure kidney injury (nephrotoxicity). The technology also predicted the effects found in earlier clinical trials of patients who had taken the same drug combinations. Approval of just one new drug takes on average 10 years, uses many thousands of animals and costs £2 billion. In contrast, the Hebrew University technology is reported to provide results ‘ in eight months, without a single animal, and at a fraction of the cost.” and is planned for a submission to the US FDA (Food & Drug Administration).
  3. Advances in artificial intelligence (AI) have been combined with stem cell technology to test thousands of potential new drugs on ‘miniaturized patients-on-a-chip’ devices, to rapidly predict clinical effects and overcome the inaccuracies of animal tests with focus on brain, liver disease and cancer as ‘three areas where safety and efficacy failures of drugs are especially high’. The first ‘AI drug’ is planned to start clinical trials this year, described by the research team at Quris AI as ‘a test case to demonstrate how our system can bring a drug to market in five years with millions of dollars, not 20 years with billions’.
  4. Published within the last few days, a new study has further developed the in vitro−in silico-based NAM safety testing strategy for prediction of human gut metabolism using PBPK modelling (Physiologically Based Pharmacokinetics) The results obtained also highlighted interspecies differences between traditionally used rodents (rats) and humans.
  5. With regard to chemical safety, last month the US Environmental Protection Agency (EPA)  updated its ongoingNew Approach Methods Work Plan’ which includes a number of key objectives including  ‘Establish Scientific Confidence in NAMs and Demonstrate Application to Regulatory Decisions’ and ‘Develop NAMs to Address Scientific Challenges and Fill Important Information Gaps’. This follows on from the earlier 2021 publication of its latest ‘ List of Alternative Test Methods to Animal Testing | ‘ in order to meet requirements of the TSCA (Toxic Substances Control Act) as part of the EPA ‘2035’ directive.

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