I want to discuss with you a problem which arose recently and should be of interest to everyone here. There is a bill before Congress-the Toxic Substances Control Act-which might see action in the near future. The reason for concern is the difficulty in seeing it function efficiently once it is activated. To be sure, I am not a spokesman for HEW. The point is that many toxic substances reach the environment, which have not been tested for their toxicity. There may not be enough mice or rats or even investigators around to do the job. But there are other difficulties which became apparent in the last decade and which bring this issue closer to tissue culture research. Some bioassay systems which were developed over the last 50 years have slowly been questioned with regard to their usefulness. As recent as 20 years ago no one took issue, however the results of a test for carcinogenicity turned out, positive or negative, with regard to the interpretation of the data and application of the knowledge gained by regulatory agencies. Recently it has been admitted that a negative test result does not give absolute assurance of complete inactivity and a positive test does not mean that under appropriate conditions of human exposure to the chemical the same results should be expected. In the 40's investigators tackled carcinogenesis testing in whichever way appeared most useful, mostly on mice. Many of these tests are now considered inadequate for extrapolation to man. Today, feeding rats the test chemical is generally accepted but not considered conclusive, so that feeding tests on a second rodent species is recommended before taking action. In this complex situation Congress is looking into the requirements for testing if and when the Toxic Substances Control Act becomes law and how to distribute the cost between the industrial sector and the taxpayer. Not only a staggering expense is involved, but, worse, a lot of time is required. With it comes the question whether industry will have to stop using "questionable" chemicals, now in large-scale production, until convincing "safety data" are available or their use can be continued until definitive decisions regarding safety can be made. If these chemicals are to be tested in animals in ways similar to the human contact, cost estimates may be enormous. For most extensive testing of one chemical, a total of $800,000 was projected; for a chemical requiring less complete testing, $200,000 was the estimate. The question of which tests are necessary for a completely "satisfactory" answer on safety for mankind cannot be answered and therefore should not be asked. Conditions of the bioassay are different from human exposure even if they are mimicked as closely as possible. If an air pollutant is to be inhaled by the test species exactly as by man, we realize that we do not have a proper species at 676
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