The director of the Hamner Institute for Health Sciences, Russell Thomas proposed to use the National Research Council (NRC) report "Toxicity Testing in the 21st Century: A Vision and a Strategy" (Tox21) in chemical safety assessment. He reasoned that while it was not an ideal approach, making use of Tox 21 could increase chemical safety now.

Thomas contended that ideally chemical risk assessment would be based on molecular scale pathways (using in vitro testing) but conceded that this was still a couple of decades away. He argued that though currently available in vitro data was not accurate enough to predict in vivo hazards, it should be used to inform hazard identification. Further, he suggested that individual mode-of-action dose response assessment can be used to identify biological perturbation and argued for a tiered method. His approach uses potency tests to inform hazard identification and would necessitate much more exposure data than currently available for most chemicals.

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Environmental Factor (EPA)