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Safer Chemicals Podcast.

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Sound science on harmful chemicals.

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Hello and welcome to this episode of the Safer Chemicals Podcast.

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I'm Adam,

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working here at the Communications Unit at ECHA,

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and I'm also your host today.

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Now,

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Europe wants to phase out animal testing for chemical safety assessments,

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but how do you actually move from ambition to actual implementation?

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That's what we're going to be looking at in this episode.

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We'll talk about what the Commission's roadmap sets out to do,

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what new approach methodologies can already deliver,

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where the main scientific and regulatory hurdles remain,

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and how ECHA is helping to build the structures needed for the transition.

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And I'm very pleased to say that today we're joined by Tomasz Zabanski from ECHA,

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who comes to this conversation straight from the first meeting of ECHA's

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Collaborative Platform on Alternatives to Animal Testing.

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So Tomasz,

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this is a very timely day to speak with you about how the roadmap can move from

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this kind of policy ambition to practical regulatory progress.

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So thank you very much for taking the time to join and welcome.

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Thank you.

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Yes,

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I'm happy to be here with you.

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So Tomasz,

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before we bring in the wider perspectives,

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maybe we should start with the basics.

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When we talk about these new approach methodologies or NAMs,

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what do we actually mean?

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What kind of methods are we talking about?

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Yes,

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new approach methodologies are a broad set of scientific methods.

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and approaches used to generate information on hazardous properties of the chemicals without relying on traditional observations in animal experiments.

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But then really for a layperson,

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are we talking about computer modeling?

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What are the actual kind of methods that you use?

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Yes,

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so indeed,

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some methods are computer models,

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which are allowing us first to predict certain properties and as well integrate different data streams together.

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There are as well in vitro methods when you are using the cell-based assays to measure some biological responses at cellular or tissue level.

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There are as well those methods which are allowing you to predict how substance will behave in the organism.

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So how it is absorbed and then distributed within the organism.

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We call those methods like toxicokinetics,

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Brody or ADMI.

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Well,

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why are these methods then becoming so important now?

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chemical safety assessment particularly?

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I think we need to look at NAMs from the broader perspective,

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not only from the animal replacement perspective,

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but why they are key.

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They are allowing you to get out from the traditional reliance on traditional toxicology when we've been observing how animals are reacting to the different chemical treatments.

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From one side,

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it's very pragmatic and very efficient because basically you are observing Thank you.

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what's going on.

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But this does not allow you to extrapolate from those observations and learn what was the reason,

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what was the cause for those adversities.

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And so if you want to make more informed decisions,

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move faster,

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you need to better understand what is behind the adverse outcomes.

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And this is what NAMS allows.

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So

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I guess it would be fair to say that NAMS are not kind of one single method,

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but a broad set of approaches that can help us assess chemical safety.

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in new ways that we don't necessarily even know yet are out there.

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And I think this discussion is especially timely because of the commission's roadmap that was just published earlier this month on phasing out animal testing for chemical safety assessments.

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Now,

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from your perspective,

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what is the roadmap trying to actually achieve?

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Is it mainly about reducing animal testing or is it also about changing,

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as you hinted already,

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how chemical safety assessment may work in the future?

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You know,

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for the simpler endpoints,

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when we've been measuring some direct effects of chemicals,

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the process of replacement was relatively straightforward.

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Like skin irritation,

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you measure how different chemicals might irritate your skin.

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That was almost,

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we called it one-to-one replacements.

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Now,

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when you are shifting to more complex endpoints,

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this is not anymore about taking out one element of the system and putting the new one,

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which is animal-free.

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This requires hole.

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redesigning the whole structure,

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how we are regulating chemicals.

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And this redesign needs some policy choices and policy tools.

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And that's why roadmap is very important,

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because it gives us those directions,

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policy ambitions,

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policy directions,

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and some tools how we can implement it in the future.

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So how should listeners kind of understand the ambition here?

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Is this something that can happen quickly?

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I'm guessing I know the answer to this already.

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Or are we talking about a transition with kind of short,

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medium and longer term steps?

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Yes,

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I think in the roadmap you have provisions with the different timelines.

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There are certain things and easy fixes which we can do almost immediately and they call it short-term actions or short-term basket.

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Then for those there is a common kind of belief at least at the commission level that those things can move relatively forward and it's more a matter of implementing it in the legal system.

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So almost all elements scientifically are in place.

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And can you give some examples?

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Yes.

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Just a couple of what those short-term…

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wins would be?

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For example,

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one of our proposals is to replace acute oral toxicity test which is normally the test done on rodents with QSAR predictions for that.

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Okay,

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and QSAR is the...

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QSAR is the computer model which based on the structure of the substance can predict the toxic outcome.

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For this particular case it is predicting the

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acute oral toxicity potential.

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So basically,

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whether the substance will be acutely toxic or not.

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Okay,

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thank you.

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And then the medium term,

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long term?

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Medium term,

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there are a few things which we believe scientifically almost all elements are in place,

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but there are still some fine tuning needed.

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Some test needs to be better validated.

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Maybe we need as well to develop a bit more robust methodology.

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For example,

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toxicokinetics.

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This is one of our proposals,

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which is considered to be midterm because we not yet

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ready for immediate implementation,

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there is still some homework which needs to be done.

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Sounds like a complex workload,

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but good that things are happening.

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Now,

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to set the policy context,

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we actually contacted the European Commission,

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asking them why this roadmap matters and what successful implementation could look like.

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So let's listen to a soundbite from Georg Streck from DG Grow.

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The roadmap towards phasing out animal testing for chemical safety assessment.

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contains 22 policy actions and more than 30 recommendations for specific human health or environmental endpoints.

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The Commission will now start to establish the organizational structures that are mentioned in the roadmap,

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for example,

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the roadmap steering team.

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The roadmap identifies options for animal testing that can be replaced in the short term.

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These should be implemented in the coming years.

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I would consider it

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as a great success if in two or three years you would have consensus among regulators in the EU,

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but hopefully also beyond the EU,

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what are the important elements of such a new regulatory risk assessment?

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So the roadmap is now moving from kind of policy direction again into implementation and identifying kind of the regulatory needs,

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looking at where animal testing can be replaced sooner and also preparing for deeper changes in how safety assessment work.

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is done in the longer term.

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Now,

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what does this mean for ECA in practice?

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For us in practice,

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roadmap gives clearer direction in which commission would like us to go.

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Not only us,

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but as well other important players.

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And this is quite important because already in ECA strategy for 2024-2028,

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we had very strong actions on the promotion of alternatives.

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Those were mainly our initiatives,

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those things which we believed

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are useful and important and needed.

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So now we can better link what we believe is needed to what Commission believes is necessary.

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Most probably will help us to gain coherence with other players in the direction in which we are going,

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and as well will help us prioritize our own activity.

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Okay,

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so on a kind of strategic level,

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I see that,

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and now also the direction setting.

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But then kind of in the day-to-day,

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so what does ECA need to do to help?

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kind of make non-animal approaches more usable in real regulatory decisions?

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What kind of role do we play there?

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We are contributing in three different areas.

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First of all,

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by communicating what we believe is important and what are the biggest stoppers for moving towards alternatives.

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So this is the first,

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just kind of informing and inspiring the research where we believe there is still more long-term research needed.

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So this is the first thing.

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We can as well facilitate and discuss how certain solutions could be implemented in practice in the different regulatory applications.

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So this is the second part.

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And then as well sharing the guidance and the best practices with member states,

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with registrants,

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both at the OECD level and on the different…

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I'm glad that you mentioned the OECD level because this is not just an EU operation.

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This has a lot of impact also internationally.

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Since few years already our strategy was that whenever we decided that something is worth to develop

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As soon as we feel we are ready,

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we wanted to bring it to OECD.

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Of course,

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OECD's QSAR toolbox was the first,

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this kind of development,

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which we are already doing since almost the beginning of ECA since 2008.

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There is no something like European hazard assessment.

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The main players in the chemical market are international players,

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which are not only present on the European market,

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but as well in the other markets.

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So this harmonization of the approaches,

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how we want to move forward with hazard.

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and risk assessment is very important.

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Well,

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maybe we move then a bit more towards the kind of the one important question,

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obviously,

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which is what does this all look like for companies,

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you know,

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who need to generate and submit the safety data that is then used by regulators?

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We did actually ask CEFIC what,

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from an industry perspective,

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would help to accelerate the regulatory uptake of non-animal approaches.

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So we have Katja Lakas from CEFIC with a soundbite.

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So I'll play that now.

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From an industry perspective,

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the biggest accelerator is not simply more data.

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It's about prioritizing the right non-animal methods.

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So we need more data.

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We need methods that are fit for real regulatory decisions,

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that are designed to replace the animal testing over time,

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not just add another layer to today's requirements.

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When it comes to the more complex endpoints,

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these one-to-one replacements are clearly not realistic.

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So where we need here is a more tiered and integrated approach and make sure that we have the stronger exposure and toxicokinetic information available.

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That means clear readiness and acceptance criteria,

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early dialogue with regulators,

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and space to learn from practical use.

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These are the essential requirements.

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So if new methods are only added on top of the existing requirements,

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we risk slowing innovation instead of accelerating the phase out of animal testing.

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So,

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Thomas,

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from ECHA's side,

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what can realistically be clarified in the short term for industry and others?

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And what depends on longer term changes to the full kind of regulatory framework behind?

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I don't know if you remember in our first NAMM workshop,

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we came up with this three-step proposal how to phase out animal testing when our first step was really analyzing the critical gaps,

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what is stopping us from moving forward.

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Second step was,

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okay,

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what we can do already now to gain experience,

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to build confidence.

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And then based on those two,

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how we can redesign the overall system.

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And now

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I think regarding the step one,

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we've been already quite good in indicating.

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many of those critical gaps,

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and they are frequently reported on our report,

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you know,

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these key areas of regulatory challenges,

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and when you have a very extensive chapter on alternatives to animal testing.

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We just published,

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if I'm not wrong,

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the 2026 update.

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Yes,

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new update.

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And now

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I agree with Katia on the thing that the next step now is that we indicated already what we believe are the most critical.

258
00:12:56.387 --> 00:12:57.068
things to cover,

259
00:12:57.468 --> 00:13:04.594
but we've not yet been very explicit on how we would like to see those gaps be covered.

260
00:13:04.654 --> 00:13:06.956
So we have to be more explicit on the criteria.

261
00:13:07.516 --> 00:13:12.440
What we would like to see as an evidence on the table to comfortably conclude that,

262
00:13:12.520 --> 00:13:12.760
okay,

263
00:13:12.821 --> 00:13:13.961
this is not the gap anymore.

264
00:13:14.542 --> 00:13:15.002
And this is,

265
00:13:15.042 --> 00:13:15.343
I guess,

266
00:13:15.483 --> 00:13:20.547
one of the first priority for us to be more explicit what we want to see in the system for the future.

267
00:13:21.119 --> 00:13:21.299
Right.

268
00:13:21.300 --> 00:13:21.559
And this,

269
00:13:21.599 --> 00:13:21.859
I guess,

270
00:13:21.879 --> 00:13:28.802
in turn translates then into the guidance that you were talking about earlier so that the people doing the tests are able to adequately meet these needs.

271
00:13:29.363 --> 00:13:30.183
Not always.

272
00:13:30.243 --> 00:13:36.966
It's only the guidance because sometimes there is still some research needed and we need to set up like objective success criteria.

273
00:13:37.426 --> 00:13:37.606
Right.

274
00:13:38.466 --> 00:13:46.850
And to do it before the solution just to be able to then objectively conclude whether we reach the objectives and we cover the gap or not.

275
00:13:47.750 --> 00:13:48.871
Once we will cover the gap.

276
00:13:49.459 --> 00:13:51.380
Once we conclude that this works well,

277
00:13:51.880 --> 00:13:54.741
then is the time for the guidance to inform registrants,

278
00:13:54.781 --> 00:13:54.981
okay,

279
00:13:55.061 --> 00:14:00.063
how now you can use this new evidence in your regulatory applications.

280
00:14:00.384 --> 00:14:03.225
So the guidance comes later as an outcome.

281
00:14:04.125 --> 00:14:04.245
Now,

282
00:14:04.246 --> 00:14:06.986
you mentioned research there and getting the right research.

283
00:14:07.246 --> 00:14:08.227
Who does this research?

284
00:14:08.747 --> 00:14:10.708
Are we able to commission studies at ECHO?

285
00:14:11.168 --> 00:14:12.148
Is it other players?

286
00:14:13.389 --> 00:14:14.069
Who does the work,

287
00:14:14.089 --> 00:14:16.730
the actual scientific research to help with this?

288
00:14:17.771 --> 00:14:18.011
They are.

289
00:14:19.141 --> 00:14:24.635
different scientific consortia which are taking this on board and the best example is the park.

290
00:14:25.703 --> 00:14:27.905
So this is this partnership between member states,

291
00:14:27.945 --> 00:14:28.886
academia and us,

292
00:14:29.306 --> 00:14:30.347
when we are trying to,

293
00:14:30.507 --> 00:14:33.209
in this collaboration between regulators and scientists,

294
00:14:33.229 --> 00:14:33.990
try to solve this.

295
00:14:34.530 --> 00:14:38.733
Then there is as well a lot of private funding from the industry associations,

296
00:14:39.053 --> 00:14:42.256
other initiatives at the European level,

297
00:14:42.296 --> 00:14:44.918
like this Horizon 2020 or Horizon Europe.

298
00:14:45.518 --> 00:14:46.399
I think we at ECHA,

299
00:14:46.739 --> 00:14:51.443
as an agency who is responsible for implementing different laws,

300
00:14:51.859 --> 00:14:55.903
We are not necessarily those which should drive the research and development,

301
00:14:56.724 --> 00:14:58.586
but we have a responsibility,

302
00:14:58.967 --> 00:15:00.549
and this is already well recognized,

303
00:15:00.769 --> 00:15:02.511
to indicate where are the needs,

304
00:15:02.651 --> 00:15:04.753
especially from the implementation point of view,

305
00:15:04.793 --> 00:15:06.315
where are still the needs to do more.

306
00:15:06.775 --> 00:15:13.603
We can inspire the projects and make sure that they have a good regulatory focus.

307
00:15:14.287 --> 00:15:14.487
Right.

308
00:15:14.587 --> 00:15:14.767
Okay.

309
00:15:14.807 --> 00:15:15.108
Thank you.

310
00:15:15.128 --> 00:15:16.949
Very much appreciate the concrete examples.

311
00:15:16.969 --> 00:15:22.552
I think they help shed a lot of light as to how many players are involved and how much work there is and who is actually taking it on.

312
00:15:22.553 --> 00:15:23.192
So thanks for that.

313
00:15:24.353 --> 00:15:26.314
When people hear about phasing out animal testing,

314
00:15:26.315 --> 00:15:27.775
it can sound like something that sits,

315
00:15:27.875 --> 00:15:28.115
you know,

316
00:15:28.135 --> 00:15:29.195
very far in the future.

317
00:15:29.636 --> 00:15:29.956
But ECHA,

318
00:15:30.036 --> 00:15:31.337
as you've indicated already,

319
00:15:31.457 --> 00:15:38.421
is already kind of working with several tools and approaches that can help reduce or replace animal testing or support regulatory conclusions.

320
00:15:38.441 --> 00:15:42.543
So what are the kind of most tangible examples that you can give?

321
00:15:43.263 --> 00:15:44.865
on progress that Eke can point to today.

322
00:15:44.885 --> 00:15:46.566
I think you've hinted to some already.

323
00:15:47.547 --> 00:15:47.747
Yes,

324
00:15:47.868 --> 00:15:53.232
and this is maybe as well a very good moment to say that actually we have as well some funding possibilities.

325
00:15:54.513 --> 00:15:56.075
We have the NAM framework contract,

326
00:15:56.936 --> 00:16:00.519
which allows us to invest in some specific NAM generation,

327
00:16:00.899 --> 00:16:04.362
which is more filling the gap between research and implementation.

328
00:16:04.763 --> 00:16:05.263
And as well,

329
00:16:05.264 --> 00:16:09.527
we have a framework contract for scientific services.

330
00:16:10.323 --> 00:16:16.085
QSAR toolbox is another example that this constant development of the toolbox is as well financed from our resources.

331
00:16:16.925 --> 00:16:26.868
The other concrete example is we are basically doing the feasibility test study on enhanced fish embryo tests.

332
00:16:26.869 --> 00:16:36.090
So basically test which is using fish embryos and after relatively short exposure with combined with transcriptomics measurements.

333
00:16:36.091 --> 00:16:37.331
So we are measuring how...

334
00:16:38.851 --> 00:16:44.895
fish embryos are response to the toxicants at the transcript level to predict chronic effects,

335
00:16:44.915 --> 00:16:48.838
which normally you would see after a few weeks of chronic exposure on the adult fish.

336
00:16:50.099 --> 00:16:52.560
One aspect is the collaboration also that you've hinted here.

337
00:16:52.580 --> 00:16:54.201
So maybe we could move a little bit towards that.

338
00:16:54.202 --> 00:16:55.843
You mentioned already Cefek and other players.

339
00:16:56.863 --> 00:16:57.123
I mean,

340
00:16:57.143 --> 00:16:58.404
collaboration is essential,

341
00:16:59.025 --> 00:17:00.426
both in Europe and internationally also,

342
00:17:00.466 --> 00:17:01.526
as we've touched upon.

343
00:17:02.407 --> 00:17:03.408
One example is this

344
00:17:03.968 --> 00:17:07.290
European Partnership for Alternative Approaches to Animal Testing,

345
00:17:07.370 --> 00:17:07.891
EPAA.

346
00:17:08.471 --> 00:17:10.032
We asked Gavin Maxwell,

347
00:17:10.532 --> 00:17:11.413
who is the chair,

348
00:17:11.573 --> 00:17:11.973
I believe,

349
00:17:12.433 --> 00:17:13.114
of the platform,

350
00:17:13.914 --> 00:17:21.018
why this kind of cross-sector collaboration matters if Europe wants to move from promising methods to methods that regulators can then actually trust.

351
00:17:21.078 --> 00:17:22.559
So let's listen to Gavin.

352
00:17:24.160 --> 00:17:32.585
The European Partnership for Alternative Approaches to Animal Testing is a collaboration between the European Commission and industry stakeholders to replace,

353
00:17:32.685 --> 00:17:36.887
reduce and refine animal use for meeting regulatory requirements.

354
00:17:37.699 --> 00:17:41.061
ECHA is a very active partner within EPA,

355
00:17:41.421 --> 00:17:47.304
contributing to many of our scientific projects and hosting our annual NAM user forum.

356
00:17:48.165 --> 00:17:56.670
EPA is focused on supporting the Commission roadmaps through helping identify research methods that could address unmet regulatory requirements,

357
00:17:57.310 --> 00:18:03.353
building confidence in non-animal approaches through facilitating scientific dialogue between regulators,

358
00:18:03.914 --> 00:18:06.275
industry safety assessors and NAM experts.

359
00:18:06.823 --> 00:18:14.752
and enabling the transition to a new global regulatory paradigm that uses NAMs to strengthen human health and environmental protection.

360
00:18:15.252 --> 00:18:28.807
I'm hopeful that the collaborative platform and alternatives to animal testing continues to provide this space to open up conversations and how we can build confidence in animal-free safety signs for regulatory decision making.

361
00:18:29.651 --> 00:18:29.771
Now,

362
00:18:30.011 --> 00:18:32.193
that point about confidence building from Gavin,

363
00:18:32.233 --> 00:18:32.473
I think,

364
00:18:32.474 --> 00:18:33.254
is really important.

365
00:18:33.274 --> 00:18:35.516
So it's not only about kind of individual methods.

366
00:18:35.616 --> 00:18:38.899
It's also about creating these conditions so that regulators,

367
00:18:38.959 --> 00:18:43.282
companies and other actors can understand when and how these methods can be used.

368
00:18:43.943 --> 00:18:47.806
And that actually brings us to one of the most concrete implementation tools in this area.

369
00:18:47.886 --> 00:18:52.110
So the new collaborative platform on alternatives to animal testing that ECHA is hosting.

370
00:18:52.130 --> 00:18:52.250
So,

371
00:18:52.890 --> 00:18:53.251
Tomás,

372
00:18:53.451 --> 00:18:56.053
you're joining us just after the first meeting of this new platform.

373
00:18:56.834 --> 00:18:58.375
Maybe we start with why.

374
00:18:58.803 --> 00:19:02.105
Does ECHA need a dedicated platform to begin with?

375
00:19:02.746 --> 00:19:04.727
So to some extent,

376
00:19:04.787 --> 00:19:08.170
we've been doing all those dialogue before already,

377
00:19:09.091 --> 00:19:09.771
like with EPA,

378
00:19:09.911 --> 00:19:10.832
like Gavin mentioned,

379
00:19:10.833 --> 00:19:13.174
we had this long lasting collaboration.

380
00:19:13.494 --> 00:19:19.578
But what we've been missing a bit in all this landscape was direct platform,

381
00:19:19.638 --> 00:19:22.981
which allows us to have this dialogue as well with our member states,

382
00:19:23.021 --> 00:19:25.823
with those experts which are contributing to those decisions.

383
00:19:26.873 --> 00:19:31.254
And it was quite clear when we started to work on the roadmap that they would like to be heard,

384
00:19:31.614 --> 00:19:33.715
that would like to actively contribute,

385
00:19:33.815 --> 00:19:34.835
because at the end,

386
00:19:35.336 --> 00:19:38.917
those are the people which are dealing with practical cases.

387
00:19:39.857 --> 00:19:42.238
They are deciding on risk management measures,

388
00:19:42.278 --> 00:19:43.698
on hazard outcomes,

389
00:19:43.718 --> 00:19:44.098
and so on.

390
00:19:44.099 --> 00:19:46.059
So we need to have them on board.

391
00:19:46.579 --> 00:19:47.679
And that was a bit missing.

392
00:19:47.739 --> 00:19:54.001
And the main idea behind the platform is to bring them on board on those discussions.

393
00:19:54.241 --> 00:20:13.357
maintaining still connection to other important key stakeholders we have still ngos and industry but we want to focus here from on member states as well and just to add you know the building confidence and dialogue is not only important for eca stakeholders we need to as well align with other agencies in europe we

394
00:20:13.397 --> 00:20:23.225
need to align internationally at this ocd level but it's really very complex interaction between many different players and many different levels and

395
00:20:23.665 --> 00:20:27.428
So how to make sure that all contributing actors,

396
00:20:27.708 --> 00:20:28.929
they have their place,

397
00:20:29.209 --> 00:20:29.889
they have their say,

398
00:20:29.970 --> 00:20:32.471
and we are not redoing those things in parallel.

399
00:20:33.332 --> 00:20:33.572
Okay,

400
00:20:34.032 --> 00:20:43.499
so how do you think that this platform can then kind of help move the discussion from general support for NAMs to these specific regulatory use cases?

401
00:20:43.539 --> 00:20:45.280
What concretely can the platform do there?

402
00:20:46.461 --> 00:20:48.923
At least at the beginning to gain momentum,

403
00:20:49.023 --> 00:20:51.985
to build confidence and to have this feel of achievement.

404
00:20:52.473 --> 00:20:57.716
We are starting with things which we've been already investing as ECA and as other stakeholders like EPA,

405
00:20:57.876 --> 00:20:58.216
SEFIC,

406
00:20:58.556 --> 00:21:00.658
already for quite many years.

407
00:21:01.218 --> 00:21:04.540
We believe that many of those elements are already ready.

408
00:21:05.040 --> 00:21:08.962
We want to bring those elements and discuss how it can work in the rich context,

409
00:21:08.963 --> 00:21:10.123
in the biocide context,

410
00:21:10.124 --> 00:21:12.464
in the water drinking directly context,

411
00:21:12.684 --> 00:21:15.906
how we can use them directly in our different regulatory processes.

412
00:21:16.427 --> 00:21:20.369
And we want to discuss it together with our colleagues from the member states.

413
00:21:20.729 --> 00:21:24.772
with the input from industry and NGOs to gain this consensus,

414
00:21:24.892 --> 00:21:26.713
because then at the end,

415
00:21:26.853 --> 00:21:32.137
all the changes in the legal frameworks needs to happen with approval of those players.

416
00:21:32.377 --> 00:21:40.082
And so it's better to build first consensus rather than have never-ending discussions during the policy discussions later on.

417
00:21:41.403 --> 00:21:41.603
Now,

418
00:21:42.704 --> 00:21:43.885
you've had the first meeting.

419
00:21:44.005 --> 00:21:45.706
So I'm curious as to,

420
00:21:46.086 --> 00:21:46.326
you know,

421
00:21:46.327 --> 00:21:48.628
any outcomes from this one that you could already share.

422
00:21:48.728 --> 00:21:48.968
Have you...

423
00:21:50.169 --> 00:21:54.752
I would understand that the first meeting is always about roles and next steps and so on,

424
00:21:54.772 --> 00:21:56.934
and how do we set up the governance and these kinds of things.

425
00:21:56.935 --> 00:22:01.697
But is there anything that you've come up with as a plan other than what you just mentioned?

426
00:22:02.758 --> 00:22:03.498
So first of all,

427
00:22:03.578 --> 00:22:04.319
before the meeting,

428
00:22:04.499 --> 00:22:06.560
after the nomination process was concluded,

429
00:22:06.821 --> 00:22:08.702
we asked all the nominated members,

430
00:22:09.483 --> 00:22:11.944
please give us your ideas about the work items.

431
00:22:12.525 --> 00:22:13.185
And basically,

432
00:22:13.605 --> 00:22:14.646
based on this discussion,

433
00:22:14.686 --> 00:22:18.609
we ended up with four main working topics for the first two years.

434
00:22:19.317 --> 00:22:20.817
in silico methods and QSARs,

435
00:22:21.678 --> 00:22:27.259
refinement of the in vitro toxicokinetic battery in the context of rich information requirements,

436
00:22:27.399 --> 00:22:29.340
but then we can as well use it for other things.

437
00:22:30.300 --> 00:22:35.301
And the third one is use of OMICS for reader cross-and-grouping applications is the first step,

438
00:22:35.621 --> 00:22:36.822
just to make it more concrete.

439
00:22:37.542 --> 00:22:44.664
And then the fourth one is use of NAMs for nanomaterials and other advanced materials.

440
00:22:46.064 --> 00:22:46.324
Okay,

441
00:22:46.444 --> 00:22:46.624
good,

442
00:22:46.725 --> 00:22:47.085
thank you.

443
00:22:48.065 --> 00:22:48.265
Well...

444
00:22:48.545 --> 00:22:53.066
Moving on to the next stakeholder group who are also very active and very needed in this work.

445
00:22:53.086 --> 00:22:58.188
So civil society obviously has an important role in how this transition to NAMS happens.

446
00:22:58.808 --> 00:23:00.949
Maybe we start with the animal welfare perspective.

447
00:23:00.969 --> 00:23:03.949
So we have Julia Baines from PETA and let's play her soundbite.

448
00:23:05.650 --> 00:23:07.830
We really value and welcome the roadmap,

449
00:23:07.930 --> 00:23:13.652
which makes it clear that the future of chemical safety assessment is based on non-animal approaches.

450
00:23:14.252 --> 00:23:16.713
But the question now is one of delivery.

451
00:23:17.369 --> 00:23:20.972
And that's because progress will be measured by what changes in practice.

452
00:23:21.492 --> 00:23:27.376
And that's whether non-animal approaches become the default and if the system evolves to support them.

453
00:23:27.856 --> 00:23:30.939
Because without these types of changes to regulations,

454
00:23:31.299 --> 00:23:33.160
tests on animals will continue.

455
00:23:33.801 --> 00:23:39.905
And that's also why initiatives like ECHA's collaborative platform on alternatives to animal testing is so important,

456
00:23:40.365 --> 00:23:41.626
as it brings regulators,

457
00:23:41.726 --> 00:23:45.609
industry and NGOs together to help build confidence.

458
00:23:46.093 --> 00:23:54.899
So we now look to ECHA to act swiftly and decisively in leading the way to build trust in these methods across the agency and beyond.

459
00:23:56.480 --> 00:24:02.743
There is also the question how to make that transition while keeping the chemical safety decisions protective.

460
00:24:03.564 --> 00:24:04.625
So we also asked HEAL,

461
00:24:05.365 --> 00:24:07.466
this is the Health and Environment Alliance,

462
00:24:07.626 --> 00:24:09.348
for an environmental health perspective.

463
00:24:09.388 --> 00:24:10.168
So this is

464
00:24:10.608 --> 00:24:11.629
Sandra Jen from HEAL.

465
00:24:12.920 --> 00:24:13.320
At HEAL,

466
00:24:13.500 --> 00:24:17.364
we see the implementation of the Commission Roadmap as a crucial opportunity,

467
00:24:17.944 --> 00:24:23.929
both to reduce the dependency on animal testing and to strengthen regulatory management of chemicals in the EU.

468
00:24:24.630 --> 00:24:27.372
It's important to stress the core principle of the roadmap,

469
00:24:27.592 --> 00:24:34.578
that non-animal approaches must deliver a level of protection equivalent to that of currently established methods.

470
00:24:35.278 --> 00:24:36.839
So in line with this core principle,

471
00:24:36.859 --> 00:24:40.683
the protection of health and the environment must always be given priority.

472
00:24:41.503 --> 00:24:41.843
Therefore,

473
00:24:41.844 --> 00:24:42.444
we support the...

474
00:24:42.544 --> 00:24:44.705
cautious transition to new approach methods,

475
00:24:44.706 --> 00:24:45.146
or in short,

476
00:24:45.226 --> 00:24:45.566
NAMs.

477
00:24:46.166 --> 00:24:54.791
These methods are not yet available to fully replace animal tests for the regulatory identification and risk management of the most serious hazards,

478
00:24:55.171 --> 00:24:56.652
such as carcinogenicity,

479
00:24:56.932 --> 00:24:58.213
reproduction toxicity,

480
00:24:58.453 --> 00:25:00.174
and endocrine disrupting properties.

481
00:25:00.795 --> 00:25:07.038
But several promising tools like grouping and read-across are already available to help reducing animal testing.

482
00:25:07.579 --> 00:25:09.840
So let's start making the most of them as well.

483
00:25:11.268 --> 00:25:14.129
So we've heard now two civil society expectations,

484
00:25:14.289 --> 00:25:22.051
faster and more visible progress away from animal testing and still a cautious transition that maintains strong protection for health and the environment.

485
00:25:22.431 --> 00:25:22.771
Tomasz,

486
00:25:23.031 --> 00:25:27.432
how can ECA help bring these expectations together in a practical regulatory setting?

487
00:25:28.413 --> 00:25:29.253
Excellent question.

488
00:25:29.293 --> 00:25:33.754
And I think if you want to have the alternatives to be default option,

489
00:25:34.274 --> 00:25:38.576
you need to first set up what are the performance expectations,

490
00:25:38.816 --> 00:25:39.856
how you can make sure.

491
00:25:40.116 --> 00:25:44.260
that the predictions are as good as the experimental data from animal tests.

492
00:25:45.140 --> 00:25:49.184
This is very important because we don't want to compromise on level of protection.

493
00:25:49.864 --> 00:25:57.891
So the first step is to agree how we will judge the performance of the method against the existing data.

494
00:25:58.572 --> 00:26:02.135
We need to make sure that at least half of the substance can work,

495
00:26:02.195 --> 00:26:02.355
right?

496
00:26:02.375 --> 00:26:08.360
Because otherwise there is no sense to propose as a default option something which can only work for 10 or 5.

497
00:26:08.720 --> 00:26:25.075
percent of cases right then it will create problem for everybody for us for registrants create many confusions and the most important is to be explicit where it can work and when it cannot this is what we are referring as this domain of applicability for those tests now

498
00:26:25.095 --> 00:26:34.664
we've talked about the ambition the tools that already exist and the role of collaboration how important that is but i think it's also important not to make this sound simpler than it actually is

499
00:26:35.600 --> 00:26:38.961
Several of the contributors we've had today have pointed to confidence,

500
00:26:39.001 --> 00:26:41.082
acceptance criteria and protection standards,

501
00:26:41.522 --> 00:26:42.442
as we've just discussed.

502
00:26:43.222 --> 00:26:47.423
What are the kind of biggest misconceptions about how quickly animal tests can be phased out?

503
00:26:48.564 --> 00:26:49.404
To some extent,

504
00:26:49.464 --> 00:26:55.526
it really depends on your regulatory case and your regulatory scenario.

505
00:26:56.426 --> 00:27:01.927
I think those which are more enthusiastic and believe it can move faster are the people where...

506
00:27:04.608 --> 00:27:08.570
from the sector where the exposure context is very well known.

507
00:27:09.130 --> 00:27:11.251
They know exactly how the substance is used,

508
00:27:11.291 --> 00:27:13.272
what are the concentrations you are exposed to,

509
00:27:13.632 --> 00:27:19.494
and basically then it's enough to measure that at this concentration levels which you are exposed to,

510
00:27:19.495 --> 00:27:20.735
you don't see any signs.

511
00:27:20.855 --> 00:27:23.476
Even at the basic molecular level,

512
00:27:23.496 --> 00:27:27.237
you don't see any signs of toxicological response.

513
00:27:27.658 --> 00:27:30.859
And then you can believe that you can conclude on safety.

514
00:27:31.559 --> 00:27:33.460
The problem is that...

515
00:27:33.756 --> 00:27:38.298
A sector like industrial chemicals is a relatively open sector.

516
00:27:38.338 --> 00:27:40.460
It means the way how you can use chemicals.

517
00:27:41.300 --> 00:27:43.561
If you are putting something on the consumer market,

518
00:27:43.621 --> 00:27:45.562
you are losing control how it will be used.

519
00:27:45.582 --> 00:27:50.585
And probably you know that people are very innovative in the way how they can use chemicals.

520
00:27:50.725 --> 00:27:56.388
And they can use it in a completely uncontrolled and not necessarily predicted way.

521
00:27:56.989 --> 00:27:57.229
Plus,

522
00:27:57.249 --> 00:27:59.470
we have to keep in mind that there is co-exposure,

523
00:27:59.490 --> 00:28:02.211
that the fact that you predict that if you are using shampoo,

524
00:28:02.231 --> 00:28:02.972
are getting this

525
00:28:03.460 --> 00:28:10.624
This exposure from the substance does not mean that the same substance is not in the furnitures which we are using every day in your office.

526
00:28:10.644 --> 00:28:11.905
They are not in your textiles.

527
00:28:11.925 --> 00:28:13.345
They are not somewhere else.

528
00:28:13.826 --> 00:28:16.027
So the level of exposure can be actually quite a lot higher.

529
00:28:16.087 --> 00:28:16.627
Exactly.

530
00:28:16.887 --> 00:28:20.409
Chemicals which we believe they are inert and that we shouldn't have any exposure,

531
00:28:20.429 --> 00:28:25.492
we found those chemicals in the bloodstream of the general population everywhere.

532
00:28:25.552 --> 00:28:26.452
So for that,

533
00:28:26.552 --> 00:28:32.956
we need to as well be able to characterize the hazard without this exposure.

534
00:28:34.056 --> 00:28:35.076
context component.

535
00:28:35.577 --> 00:28:44.139
So we would like to know whether certain chemicals are intrinsically dangerous because we don't want to put into the general,

536
00:28:44.359 --> 00:28:48.320
expose general population to the things which are carcinogens,

537
00:28:48.940 --> 00:28:50.141
which are mutagens,

538
00:28:50.241 --> 00:28:50.661
which can,

539
00:28:51.141 --> 00:28:51.421
you know,

540
00:28:51.961 --> 00:28:53.182
affect our reproduction,

541
00:28:54.022 --> 00:28:54.782
health and so on,

542
00:28:54.802 --> 00:28:55.042
right?

543
00:28:55.402 --> 00:28:59.363
So we need to characterize those things before putting chemicals in the market.

544
00:28:59.364 --> 00:29:01.644
And this is the biggest challenge.

545
00:29:02.024 --> 00:29:07.252
And this is the biggest misunderstanding between those different stakeholders groups and ABDs.

546
00:29:07.312 --> 00:29:08.754
Because to change that,

547
00:29:09.275 --> 00:29:09.696
we need to...

548
00:29:10.804 --> 00:29:15.367
rethink how we will do this hazard identification and characterization.

549
00:29:16.088 --> 00:29:16.908
And this is not easy.

550
00:29:18.249 --> 00:29:18.549
Actually,

551
00:29:19.130 --> 00:29:27.796
this idea that you're exposed to potentially the same chemical through different settings or different products leads to this cocktail effect as well.

552
00:29:27.896 --> 00:29:31.638
Is this something that new approach methodologies can somehow help deal with?

553
00:29:31.658 --> 00:29:39.043
The fact that combinations of chemicals and their levels of exposure and building kind of scenarios as to how that affects people in the environment?

554
00:29:39.044 --> 00:29:40.164
Is this something that's considered?

555
00:29:41.468 --> 00:29:41.769
Yes,

556
00:29:41.989 --> 00:29:44.432
and this is one of the promises of the NAMs,

557
00:29:44.492 --> 00:29:46.094
which did not yet materialize,

558
00:29:46.534 --> 00:29:55.164
but I believe it is one of the important tools which can help us break through some of the limitations which we have today.

559
00:29:55.732 --> 00:29:58.253
Because in the classical toxicological testing,

560
00:29:58.553 --> 00:30:03.714
the outcome of the test is the knowledge that chemical X in test

561
00:30:04.295 --> 00:30:08.416
Y cannot give you response Z.

562
00:30:09.936 --> 00:30:10.416
And that's it.

563
00:30:10.437 --> 00:30:13.717
It's very difficult to extrapolate this knowledge to anything else.

564
00:30:13.718 --> 00:30:16.098
You don't know what will happen if you will change the composition.

565
00:30:16.118 --> 00:30:20.300
You don't know what will happen if you add a new component.

566
00:30:20.540 --> 00:30:21.000
With NAMS,

567
00:30:21.020 --> 00:30:21.880
it's a bit different.

568
00:30:21.980 --> 00:30:27.065
because we start to measure the biological responses on the molecular levels,

569
00:30:27.705 --> 00:30:34.431
we can think about it like specific fingerprints for the different type of toxicity caused by different kind of,

570
00:30:34.451 --> 00:30:36.033
let's call them library chemicals.

571
00:30:36.894 --> 00:30:39.816
And then we can deconvolute.

572
00:30:39.856 --> 00:30:44.140
If you have a very complex toxicological response from the mixture effect,

573
00:30:44.360 --> 00:30:48.304
you can try to decompose this for those individual fingerprints.

574
00:30:48.808 --> 00:30:52.850
And then you can try to understand what was the contributing factors to that.

575
00:30:53.250 --> 00:30:54.871
So I think in the future,

576
00:30:54.971 --> 00:30:58.113
once we will learn to build those library of those fingerprints,

577
00:30:58.153 --> 00:31:05.097
it will be much easier to identify which type of components were responsible for this toxic outcome.

578
00:31:05.157 --> 00:31:11.580
And it will be much easier to deconvolute those complex responses to those individual contributing factors.

579
00:31:13.152 --> 00:31:13.272
Now,

580
00:31:13.292 --> 00:31:13.992
before we close,

581
00:31:14.032 --> 00:31:16.573
let me briefly summarize what we've covered today.

582
00:31:16.673 --> 00:31:22.295
So the roadmap gives Europe a clearer direction for moving away from animal testing and chemical safety assessment.

583
00:31:22.715 --> 00:31:23.515
But as we've heard,

584
00:31:23.795 --> 00:31:27.256
implementation will depend on practical and credible steps.

585
00:31:27.856 --> 00:31:30.717
Identifying where non-animal approaches can already be used,

586
00:31:31.217 --> 00:31:33.778
building confidence where more evidence is still needed,

587
00:31:34.238 --> 00:31:36.279
adapting regulatory practice over time,

588
00:31:36.459 --> 00:31:40.460
and keeping the protection of health and the environment at the forefront of this work.

589
00:31:41.020 --> 00:31:41.160
Now,

590
00:31:41.260 --> 00:31:46.542
ECHA's role is to help make this transition workable in real regulatory settings together with the Commission,

591
00:31:46.782 --> 00:31:47.582
member states,

592
00:31:47.842 --> 00:31:48.262
industry,

593
00:31:48.562 --> 00:31:49.963
researchers and civil society.

594
00:31:50.703 --> 00:31:56.725
The Collaborative Platform on Alternatives to Animal Testing is one way to support this by bringing together regulatory needs,

595
00:31:57.045 --> 00:31:59.505
scientific developments and stakeholder expectations.

596
00:32:01.046 --> 00:32:04.167
And ECHA's role is to help turn that ambition into regulatory reality.

597
00:32:05.307 --> 00:32:05.647
Tomás,

598
00:32:05.867 --> 00:32:08.088
thank you so much for joining us today after a...

599
00:32:08.688 --> 00:32:11.209
busy two days and for sharing your insights on this.

600
00:32:11.730 --> 00:32:12.670
Thank you for having me.

601
00:32:14.972 --> 00:32:15.772
And to our listeners,

602
00:32:15.832 --> 00:32:16.693
thank you for listening.

603
00:32:17.013 --> 00:32:19.554
Science is becoming increasingly important in ECHA's work.

604
00:32:19.634 --> 00:32:22.416
And if you want to learn more about our scientific priorities and activities,

605
00:32:22.976 --> 00:32:28.079
visit the science section of our website at eccha.europa.eu forward slash science.

606
00:32:28.639 --> 00:32:30.320
To stay up to date with the latest developments,

607
00:32:30.520 --> 00:32:32.001
you can also subscribe to our news.

608
00:32:34.783 --> 00:32:36.484
Safer Chemicals podcast.

609
00:32:37.201 --> 00:32:39.318
Sound Science on Harmful Chemicals.

