A call for action: Improve reporting of research studies to increase the scientific basis for regulatory decision-making

Stakeholders' perspectives and use of web-based knowledge support for environmental information on pharmaceuticals

Background

Pharmaceuticals treat and prevent diseases but can pose a risk to organisms, predominantly in aquatic environments. The use of pharmaceuticals is predicted to increase due to, among other factors, a growing and aging population and climate change. Therefore, it is important to develop mitigation strategies to prevent pharmaceutical residues from entering the environment. In Sweden, two public pharmaceutical web-based knowledge supports provide information on the environmental impact of pharmaceuticals.

Objective

To explore stakeholder perspectives, use and future opportunities related to two webbased knowledge supports publicizing environmental information on pharmaceuticals.

Methods

Stakeholders identified for their experience with the knowledge supports, pharmaceutical policy, and stakeholder collaboration were recruited using purposive and snowball sampling for semi-structured interviews. Interviews were conducted in person or via video calls. Respondents included twenty-one representatives from the pharmaceutical industry, regional and national authorities, academia, and an independent research institute. Interview transcripts were analyzed using content analysis.

Results

Respondents valued having environmental information on pharmaceuticals publicly accessible on two well-known pharmaceutical knowledge supports. The knowledge supports have been used in Sweden and internationally. Perceived differences were recognized between the impact and perspectives of the two knowledge supports with a general preference for the Janusinfo knowledge support. The preference was especially identified regarding transparency and the use of the information in clinical practice. Barriers to impact were a lack of resources and decision-making criteria. Respondents believed that the impact and value of the knowledge supports could be improved with more authority involvement.

Conclusion

Public knowledge support providing environmental information on pharmaceuticals has been valuable across sectors, especially, among Drug and Therapeutics Committees. We believe the results from this study could be useful for other countries interested in implementing a similar system.

Systematic evaluation of the evidence for identification of endocrine disrupting properties of Bisphenol F

Identification of endocrine disruptors (EDs) is a highly prioritized issue in the EU. However, scientific criteria to identify EDs have so far only been implemented for biocidal and plant protection products. The European Commission is working on developing a horizontal approach to the identification of EDs across legislations, based on these scientific criteria. With this study, our aim was to evaluate evidence on endocrine disrupting properties of Bisphenol F (BPF) by applying the process set out for biocidal and plant protection products in Europe. BPF is not registered under REACH and therefore assumed not to be produced in the EU > 1 ton/year, yet the substance has been detected in urine, serum, and breast milk in populations from different countries in Europe. BPF is raising concern since it is an analogue of the known ED and reproductive toxicant Bisphenol A. Relevant evidence on endocrine disrupting properties of BPF from the open literature was collected using systematic review methodology. Pre-defined inclusion criteria were developed to select relevant studies, and data was extracted. The reliability of included studies was evaluated by the Science in Risk Assessment and Policy tool, and results were converted into Klimisch categories to allow for categorization of study reliability. A weight-of-evidence approach was used to analyze the evidence and draw conclusions on endocrine-related activity and/or endocrine adversity. We found that there is sufficient evidence to conclude on an endocrine mechanism, and while evidence for adversity was not considered sufficient, we still conclude that BPF could also cause endocrine-mediated adversity. Two modes of action were postulated based on the collected data for BPF. Challenges of performing the ED assessment for data-poor chemicals and the importance of adequate reporting of studies in the open literature, especially for new approach methods, are discussed.

Enhancing Scientific Support for the Stockholm Convention's Implementation: An Analysis of Policy Needs for Scientific Evidence

The Stockholm Convention is key to addressing the global threats of persistent organic pollutants (POPs) to humanity and the environment. It has been successful in identifying new POPs, but its national implementation remains challenging, particularly by low- and middle-income Parties. Concerted action is needed to assist Parties in implementing the Convention's obligations. This analysis aims to identify and recommend research and scientific support needed for timely implementation of the Convention. We aim this analysis at scientists and experts from a variety of natural and social sciences and from all sectors (academia, civil society, industry, and government institutions), as well as research funding agencies. Further, we provide practical guidance to scientists and experts to promote the visibility and accessibility of their work for the Convention's implementation, followed by recommendations for sustaining scientific support to the Convention. This study is the first of a series on analyzing policy needs for scientific evidence under global governance on chemicals and waste.

A human biomonitoring (HBM) Global Registry Framework: Further advancement of HBM research following the FAIR principles

Data generated by the rapidly evolving human biomonitoring (HBM) programmes are providing invaluable opportunities to support and advance regulatory risk assessment and management of chemicals in occupational and environmental health domains. However, heterogeneity across studies, in terms of design, terminology, biomarker nomenclature, and data formats, limits our capacity to compare and integrate data sets retrospectively (reuse). Registration of HBM studies is common for clinical trials; however, the study designs and resulting data collections cannot be traced easily. We argue that an HBM Global Registry Framework (HBM GRF) could be the solution to several of challenges hampering the (re)use of HBM (meta)data. The aim is to develop a global, host-independent HBM registry framework based on the use of harmonised open-access protocol templates from designing, undertaking of an HBM study to the use and possible reuse of the resulting HBM (meta)data. This framework should apply FAIR (Findable, Accessible, Interoperable and Reusable) principles as a core data management strategy to enable the (re)use of HBM (meta)data to its full potential through the data value chain. Moreover, we believe that implementation of FAIR principles is a fundamental enabler for digital transformation within environmental health. The HBM GRF would encompass internationally harmonised and agreed open access templates for HBM study protocols, structured web-based functionalities to deposit, find, and access harmonised protocols of HBM studies. Registration of HBM studies using the HBM GRF is anticipated to increase FAIRness of the resulting (meta)data. It is also considered that harmonisation of existing data sets could be performed retrospectively. As a consequence, data wrangling activities to make data ready for analysis will be minimised. In addition, this framework would enable the HBM (inter)national community to trace new HBM studies already in the planning phase and their results once finalised. The HBM GRF could also serve as a platform enhancing communication between scientists, risk assessors, and risk managers/policy makers. The planned European Partnership for the Assessment of Risk from Chemicals (PARC) work along these lines, based on the experience obtained in previous joint European initiatives. Therefore, PARC could very well bring a first demonstration of first essential functionalities within the development of the HBM GRF.

In vitro prediction of clinical signs of respiratory toxicity in rats following inhalation exposure

To date there are no OECD validated alternative approaches to study toxicity following inhalation exposure to airborne chemicals. The available OECD test guidelines for acute inhalation toxicity aim to estimate a value of the lethal air concentration of the test chemical leading to the death of 50% of the exposed animals (LC50), to satisfy hazard classification and labelling requirements. This paper explores the view that alternative approaches must compare to outcomes of existing guideline methods to become accepted and implemented in a regulatory context. This case study describes the initiatives taken to validate the lung surfactant bioassay, an in vitro cell-free method, and discusses the challenges faced. While the lung surfactant bioassay could not predict the GHS classification for acute inhalation toxicity of 26 chemicals, the assay successfully predicted the clinical signs of respiratory toxicity observed during or shortly after exposure in vivo as reported in registration dossiers. The lung surfactant bioassay is a promising alternative approach to assess the potential of chemicals to cause changes to respiration remaining after exposure (indicating decreased lung function), and can be combined with other test methods in an integrated approach to testing and assessment of inhaled substances.

Management of bias and conflict of interest among occupational exposure limit expert groups

Our aim was to evaluate policies and procedures for management of conflict of interest (CoI) and other sources of bias, implemented in Occupational Exposure Limit (OEL) expert groups. First, we compiled procedural criteria applicable to OEL-setting, based on literature on CoI and systematic reviews. Second, we identified 58 global OEL-sources and sought the underlying expert groups and operating procedures. We identified eleven active groups, of which five have documented CoI policies. In all five, CoI management is based on declarations of interests (DoIs) and removal of experts from decisions in which they have an interest. Notable differences include publication of DoIs (three of five groups), limitation of DoI to current interests (two groups), quantitative limits for financial interests (none specified to ≥€10,000 per interest), control procedures for undisclosed CoI (one group), and procedures in case of discovery of undisclosed CoI (three groups). Methods to evaluate study quality are described by three groups, while reproducible and comprehensive strategies to identify and select data receive less attention. We conclude that procedures to manage CoI and bias are not broadly implemented, or at least not openly and transparently communicated. This lack of visible procedures is remarkable, considering OEL's impact on health and economy.

Non-Animal Strategies for Toxicity Assessment of Nanoscale Materials: Role of Adverse Outcome Pathways in the Selection of Endpoints

Faster, cheaper, sensitive, and mechanisms-based animal alternatives are needed to address the safety assessment needs of the growing number of nanomaterials (NM) and their sophisticated property variants. Specifically, strategies that help identify and prioritize alternative schemes involving individual test models, toxicity endpoints, and assays for the assessment of adverse outcomes, as well as strategies that enable validation and refinement of these schemes for the regulatory acceptance are needed. In this review, two strategies 1) the current nanotoxicology literature review and 2) the adverse outcome pathways (AOPs) framework, a systematic process that allows the assembly of available mechanistic information concerning a toxicological response in a simple modular format, are presented. The review highlights 1) the most frequently assessed and reported ad hoc in vivo and in vitro toxicity measurements in the literature, 2) various AOPs of relevance to inhalation toxicity of NM that are presently under development, and 3) their applicability in identifying key events of toxicity for targeted in vitro assay development. Finally, using an existing AOP for lung fibrosis, the specific combinations of cell types, exposure and test systems, and assays that are experimentally supported and thus, can be used for assessing NM-induced lung fibrosis, are proposed.

Towards 'one substance - one assessment': An analysis of EU chemical registration and aquatic risk assessment frameworks

With the Green Deal the EU aims to achieve a circular economy, restore biodiversity and reduce environmental pollution. As a part of the Green Deal a 'one-substance one-assessment' (OS-OA) approach for chemicals has been proposed. The registration and risk assessment of chemicals on the European market is currently fragmented across different legal frameworks, dependent on the chemical's use. In this review, we analysed the five main European chemical registration frameworks and their risk assessment procedures for the freshwater environment, covering 1) medicines for human use, 2) veterinary medicines, 3) pesticides, 4) biocides and 5) industrial chemicals. Overall, the function of the current frameworks is similar, but important differences exist between the frameworks' environmental protection goals and risk assessment strategies. These differences result in inconsistent assessment outcomes for similar chemicals. Chemicals are also registered under multiple frameworks due to their multiple uses, and chemicals which are not approved under one framework are in some instances allowed on the market under other frameworks. In contrast, an OS-OA will require a uniform hazard assessment between all different frameworks. In addition, we show that across frameworks the industrial chemicals are the least hazardous for the freshwater environment (median PNEC of 2.60E-2 mg/L), whilst biocides are the most toxic following current regulatory assessment schemes (median PNEC of 1.82E-4 mg/L). Finally, in order to facilitate a successful move towards a OS-OA approach we recommend a) harmonisation of environmental protection goals and risk assessment strategies, b) that emission, use and production data should be made publicly available and that data sharing becomes a priority, and c) an alignment of the criteria used to classify problematic substances.

Evaluating reliability and risk of bias of in vivo animal data for risk assessment of chemicals - Exploring the use of the SciRAP tool in a systematic review context

Within the field of health risk assessment, it is essential that evaluations of reliability or validity of toxicity data are conducted with structure and transparency. To this end, different tools for evaluating toxicity studies have been developed by different groups and organizations, for different specific purposes. The Science in Risk Assessment and Policy (SciRAP) tool was developed for use in the regulatory health risk assessment of chemicals and to promote structured and transparent evaluation of study reliability within European regulatory frameworks. As such, the SciRAP tool is not specifically tailored for use in a systematic review context. However, in light of the current movement towards applying systematic review in the field of environmental health and chemical assessments and European chemicals regulation, we were interested in exploring how SciRAP could be applied in such a context. To achieve this, the scope of the SciRAP tool was first compared to two tools developed based on systematic review principles at the US Environmental Protection Agency's IRIS program and the National Toxicology Program's Office of Health Assessment and Translation (OHAT). Next, the SciRAP and IRIS tools were both applied in a case study to evaluate the same nine in vivo animal studies and the resulting evaluations were compared. The SciRAP tool was found to address the majority of the elements included for study evaluation in the OHAT and IRIS tools. In the case study, no major differences were found in the conclusions drawn when using SciRAP or IRIS tools. However, future developments to bring the SciRAP tool more in line with systematic review principles were identified and are discussed. Overall, this work illustrates the advantages of applying structured and pre-defined methods for study evaluation and provides a unique case study comparing the impact of using different tools for evaluating animal toxicity studies.

Emerging investigator series: use of behavioural endpoints in the regulation of chemicals

Interest in behavioural ecotoxicology is growing, partly due to technological and computational advances in recording behaviours but also because of improvements of detection capacity facilitating reporting effects at environmentally relevant concentrations. The peer-reviewed literature now contains studies investigating the effects of chemicals, including pesticides and pharmaceuticals, on migration, dispersal, aggression, sociability, reproduction, feeding and anti-predator behaviours in vertebrates and invertebrates. To understand how behavioural studies could be used in regulatory decision-making we: (1) assessed the legal obstacles to using behavioural endpoints in EU chemicals regulation; (2) analysed the known cases of use of behavioural endpoints in EU chemicals regulation; and (3) provided examples of behavioural endpoints of relevance for population level effects. We conclude that the only legal obstacle to the use of behavioural endpoints in EU chemicals regulation is whether an endpoint is considered to be relevant at the population level or not. We also conclude that ecotoxicity studies investigating behavioural endpoints are occasionally used in the EU chemicals regulation, and underscore that behavioural endpoints can be relevant at the population level. To improve the current use of behavioural studies in regulatory decision-making contribution from all relevant stakeholders is required. We have the following recommendations: (1) researchers should conduct robust, well-designed and transparent studies that emphasize the relevance of the study for regulation of chemicals; (2) editors and scientific journals should promote detailed, reliable and clearly reported studies; (3) regulatory agencies and the chemical industry need to embrace new behavioural endpoints of relevance at the population level.

Reliability and relevance evaluations of REACH data

Regulatory authorities rely on hazard and risk assessments performed under REACH for identifying chemicals of concern and to take action. Therefore, these assessments must be systematic and transparent. This study investigates how registrants evaluate and report data evaluations under REACH and the procedures established by the European Chemicals Agency (ECHA) to support these data evaluations. Data on the endpoint repeated dose toxicity were retrieved from the REACH registration database for 60 substances. An analysis of these data shows that the system for registrants to evaluate data and report these evaluations is neither systematic nor transparent. First, the current framework focuses on reliability, but overlooks the equally important aspect of relevance, as well as how reliability and relevance are combined for determining the adequacy of individual studies. Reliability and relevance aspects are also confused in the ECHA guidance for read-across. Second, justifications for reliability evaluations were mainly based on studies complying with GLP and test guidelines, following the Klimisch method. This may result in GLP and guideline studies being considered reliable by default and discounting non-GLP and non-test guideline data. Third, the reported rationales for reliability were frequently vague, confusing and lacking information necessary for transparency. Fourth, insufficient documentation of a study was sometimes used as a reason for judging data unreliable. Poor reporting merely affects the possibility to evaluate reliability and should be distinguished from methodological deficiencies. Consequently, ECHA is urged to improve the procedures and guidance for registrants to evaluate data under REACH to achieve systematic and transparent risk assessments.

Evidence of citation bias in the pesticide ecotoxicology literature

As scientists, we are tasked with letting evidence guide our conclusions. In the world of pesticides this takes on added importance as the data can influence ecological and human health outcomes and regulations, and even the manner in which we grow food. Yet, there seems to be a reticence to engage with the totality of the pesticide ecotoxicology literature, especially papers that report few or no effects or low risk to non-target organisms. We suspected that these studies would have fewer citations than studies that report significant effects or risk for the same compound, and this would be unrelated to the strength of the study, e.g., high quality studies with few or no effects would be cited less frequently than weaker studies that reported effects. To investigate this, we examined a subset of literature around the herbicide atrazine. We found that papers reporting an effect had significantly more citations per year than those that did not (p < 0.05). There was no significant relationship between the strength of the study and number of citations, but a general trend for weaker studies to have greater number of citations. The impact factor of journals was not positively correlated with the strength of the study methods, but studies that reported effects were published in journals with a greater mean impact factor than those that reported no effects (p < 0.05). This analysis reveals evidence of citation bias within the pesticide ecotoxicology literature, as well as bias by journals to publish studies that report effects, regardless of study quality.

A call for action: Improve reporting of research studies to increase the scientific basis for regulatory decision-making

This is a call for action to scientific journals to introduce reporting requirements for toxicity and ecotoxicity studies. Such reporting requirements will support the use of peer-reviewed research studies in regulatory decision-making. Moreover, this could improve the reliability and reproducibility of published studies in general and make better use of the resources spent in research.