Origins John Draize of the FDA published a procedure for identifying contact allergens, using human volunteers. It became known as the ‘‘repeated insult test’’ and was supposed to be an improvement on the Schwartz-Peck test, also under FDA sponsorship. Though Draize’s method did not have the force of law, it came to be regarded as a quasi-legal regulation which put a manufacturer of a topical drug at risk if the repeated insult test had not been done. To Dr. Kligman’s astonishment, he could not find any published data which validated Draize’s test. He questioned the number of subjects and exposures. Why 200 subjects? Perhaps 100 would suffice? Why ten exposures, instead of 5, or 15 or 100? Subsequently, he learned there was a file in the FDA archives, which on the basis of unpublished experience with many topical agents, justified Draize’s specifications. Dr. Kligman reasoned that the Draize test was ‘‘based not on experimentation but on revelations originating in outer space.’’ Clinical experience had demonstrated that creams containing penicillin were strongly allergenic, forcing them off the market. Also, topical neomycin was known to have an appreciable risk of sensitization. Certain topical bleaching agents, notably monobenzyl ether of hydroquinone, which were effective only when applied daily for many months, could not continue to be used because a substantial percentage of patients became sensitized. The stage was set for the important, and impertinent, question. Would these well-known allergens be detected by the Draize repeated insult test on 200 subjects? Dr. Kligman had available a large population of prisoner volunteers on whom the Draize test could be tested for its validity. The result was stunningly negative. This ‘‘exalted, exaggerated, formidable procedure was incapable of recognizing sensitizers.’’ It almost guaranteed that a formulation would pass with flying colors. In a ‘‘kinky’’ sort of way, this lack of sensitivity may actually have increased the reputation and commercial usefulness of the test. After all, positive results hang a cloud of allergenicity over a product which might be otherwise quite useful. Benzoyl peroxide is an example of a useful drug which is potentially a strong allergen. On the other hand, failure to detect allergenic substances that are used daily can have disastrous effects. For instance, the manufacturers of tetrachlorosalicylanilide claim to have done three separate 200-subject Draize tests in different facilities without discovering that this bacteriostat, incorporated in soaps, was a potent allergen. Had that been known, the calamitous epidemic of photoallergy could have been averted.