Balancing chemical safety and animal welfare considerations in the application of new approach methodologies for chemical safety assessment.

Despite some considerable advancement in developing different forms of new approach methodologies (NAMs) to assess the risk of chemicals, there is still limited progress in their application for regulatory purposes in the European Union (EU). Distinct divisions exist between non-governmental organisations (NGOs) with an animal welfare agenda, and those focusing on environmental protection. The conflicting views on NAMs held by these NGOs are a point of concern for policy makers in particular. This report gathers and reviews the perspectives of selected animal welfare and environmental NGO representatives who responded to our small-scale, anonymous online survey. The responses were analysed to identify areas where there is some space to accommodate the views of both groups. There exists strong consensus on the question of whether EU chemical legislation on risk assessment is sufficiently well adapted to incorporate new approach methodologies. Both NGO groups do acknowledge the merit of scientific advances to aid decision making, albeit with the cautious need to ensure that the information to truly determine the safe use of chemicals is available. Broad consensus was identified: i) for the need of a more precise definition of NAMs by making reference to using NAMs in specific contexts; ii) acknowledging that existing processes are not adequate to validate new approach methodologies; and iii) that there remain clear barriers to the regulatory deployment of NAMs. Finally, moderate consensus was identified for the question of whether animals are an effective and appropriate surrogate to assess the impact chemicals have on environmental health, with both groups acknowledging, to an extent, that animal tests in this context can be useful indicators and NAMs could assist in identifying further effects in complex systems. Understanding these areas of common ground will benefit future policy decision-making related to the acceptance of NAMs in chemical safety assessments.