"The Endocrine Society appreciates the opportunity to provide input on the forthcoming Commission Roadmap to phase out animal testing. As the world’s oldest, largest, and most active organization devoted to research on hormones and the clinical practice of endocrinology our membership consists of over 18,000 scientists, physicians, educators, nurses, and students in more than 100 countries, including the world’s leading experts on the health effects of endocrine-disrupting chemicals (EDCs). Our Society welcomes the development of new approach methodologies (NAMs) defined as “technologies and approaches (including computational modeling, in vitro assays, and testing using alternative animal species)” to reduce the use of vertebrate animals in regulatory assessments and ensure a high level of human health protection . However, we caution that NAMs have not been sufficiently developed to comprehensively assess biological complexity. Moreover, certain biological processes, including many developmental pathways that, if perturbed, result in later-life effects, may never be sufficiently replicated via NAMs to achieve the high level of protection required."
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