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An approach to systematically describe the uncertainties and complexity of the standard animal testing and assessment approach for carcinogenicity is explored by using a OECD Guidance Document that was originally developed for reporting defined in vitro approaches to testing and assessment. The format is suitable for this re-purposing and it appears that the potential multitude of approaches for integrating and interpreting data from standard animal testing may ultimately be conceptually similar to the challenge of integrating relevant in vitro and in silico data. This structured approach shall allow 1) fostering interest in developing improved defined in silico and in vitro approaches; 2) the definition of what type of effects should be predicted by the new approach; 3) selection of the most suitable reference data and assessments; 4) definition of the weight that the standard animal reference data should have compared to human reference data and mechanistic information in the context of assessing the fitness of the new in vitro and in silico approach; 5) definition of a benchmark for the minimum performance of the new approach, based on a conceptual recognition that correlation of alternative assessment results with reference animal results is limited by the uncertainties and complexity of the latter. A longer term perspective is indicated for evolving the definition of adversity for classification and regulatory purposes. This work will be further discussed and developed within the OECD expert group on non-genotoxic carcinogenicity IATA development.
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