In the early 1960s, the National Cancer Institute developed procedures to formalize the process for the evaluation of the human risk of cancer from chemical exposure (Boorman, 1994; Weisburger, 1983). This approach was based on decades of research that demonstrated that chemicals that were known to cause cancer in humans could be shown to induce cancer in laboratory animals as well. Despite the fact that this approach by the NCI was envisioned as an initial assessment of carcinogenic activity to identify those chemicals for which further study was needed, the use of two rodent species exposed for 2 years as the primary mechanism to identify potential human hazards was in widespread use by the early 1970s (Boorman, 1994). In 1975, this process was developed into a recommendation that has formed the basis of regulatory guidance (Sontag, 1976). This guidance represented the best thinking of the time about how to accomplish the critical but difficult task of prospectively identifying chemicals that might pose a carcinogenic risk to humans. Despite significant progress in our understanding of the biology of the carcinogenic response in animals and humans in the nearly 30 years since this guideline was published, these recommendations continue to form the foundation of how we do cancer risk assessment today. We have a large and extensive database today from which to develop a more rational, science-based approach to this process. A careful consideration of the available data suggests an alternative approach to this important task. Much of the early work done in this field that led to the use of the 2-year bioassay was done with reactive chemicals, most of which interacted with DNA (Miller, 1978). Ample evidence accumulated that compounds in classes like the polycyclic aromatic hydrocarbons that were known or suspected human carcinogens produced tumors in rodents. It was logical to assume that rodent tumor data could predict the hazard associated with human exposure. The concept of genetic versus epigenetic or alternative mechanisms of carcinogenesis originally proposed in the late 1980s is now well accepted. While much is understood about the mechanism of tumor induction by DNA-reactive carcinogens, assessment of human risk from exposure to nongenotoxic agents is more problematic. Careful and comprehensive evaluation of the modes of action of chemicals that produce tumors in rodents has led to the understanding that positive findings in long-term rodent studies do not necessarily predict human hazard. We now understand, for example, why urinary bladder tumors in rats exposed to high doses of saccharin or melamine do not imply a hazard for humans (Cohen et al., 1991; Rodent Bladder Carcinogenesis Working Group, 1995). Similarly, a broad and very comprehensive array of data on male rat kidney tumors induced by compounds like d-limonene that produce a characteristic male rat hydrocarbon nephropathy do not predict a carcinogenic hazard for humans following exposure to these chemicals (Swenberg and Lehman-McKeeman, 1999). In the pharmaceutical arena, there are numerous similar examples. Rat mammary tumors produced in response to b-adrenergic blocking agents in the 1970s caused significant disruption to drug development programs as concern was raised over the possibility of a similar tumorigenic response in humans. It is now clear that the biology surrounding the tumor promoting activity in rodents (hyperprolactinemia) is dissimilar between the two species and does not predict human hazard (Schyve et al., 1978; Welsch and Nagasawa, 1977). A similar major concern was raised over the appearance of the unusual mesovarial leiomyoma in rats exposed to b-agonists like salbutamol in this same time frame. It is now well accepted that this rodent tumorigenic response is secondary to a unique pharmacodynamic effect in this tissue in the rat and is not an indicator of human risk (Jack et al., 1983). To whom correspondence should be addressed: Schering-Plough Research Institute, 2015 Galloping Hill Rd., Kenilworth, NJ 07033. Fax: (973) 940-4159. E-mail: james.madonald@spcorp.com.
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