Should the AOAC Use-Dilution Method Be Continued for Regulatory Purposes?

2012 ◽  
Vol 95 (2) ◽  
pp. 406-410
Author(s):  
Navid Omidbakhsh

Abstract Despite its very poor reproducibility, AOAC INTERNATIONAL's use-dilution method (UDM) for bactericidal activity (AOAC Methods 964.02, 955.14, and 955.15) has been required by the U.S. Environmental Protection Agency (EPA) since 1953 for regulatory purposes, while methods with better reproducibility have been adopted in Canada and Australia. This study reviews UDM from a statistical perspective. Additionally, the test's expected results were compared to those obtained from actual evaluation of several formulations. Significant gaps have been identified in the reproducibility of the test data as predicted by statistical analysis and those presented to the EPA for product registration. UDM's poor reproducibility, along with its qualitative nature, requires the concentration of the active ingredient to be high enough to ensure all or most carriers to be free of any viable organisms. This is not in accord with the current trends towards sustainability, human safety, and environmental protection. It is recommended that the use of the method for regulatory purposes be phased out as soon as possible, and methods with better design and reproducibility be adopted instead.

1999 ◽  
Vol 01 (03) ◽  
pp. 329-347 ◽  
Author(s):  
REBECCA A. EFROYMSON

The Toxic Substances Control Act (TSCA) is the legislation used by the U.S. Environmental Protection Agency to regulate releases of genetically engineered microorganisms. The rule defining the scope of the notification requirements for releases of microbial products of biotechnology was published in April 1997. The Environmental Protection Agency (EPA) had some latitude regarding the extent to which various categories of microorganisms would be regulated, but the agency was constrained by requirements of TSCA and an interagency agreement about how to regulate products of biotechnology. This paper investigates the extent to which the scope of oversight is based on risk. A risk-based rule is defined as one where the reporting requirements are based on potential for exposure or expected adverse effects. The evolution of the rule is described, and risk-based components are discussed. In conclusion, the scope of oversight of microbial releases is determined to be based on risk to the extent that legislation and institutional constraints permit.


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