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ATLA 28, 241–258, 2000 241 Three Rs Approaches in the Production and Quality Control of Avian Vaccines The Report and Recommendations of ECVAM Workshop 41 1,2 Lukas Bruckner,3 Johan Bongers,4 Peter Castle, 5 Pieter H. Flore,6 Michèle Guittet,7 Marlies Halder,8 Carmen Jungbäck,9 François Xavier Le Gros,10 Maria Tollis, 11 Venugopal K. Nair,12 Manfred Wilhelm,9 Joseph Zeegers13 and Guy Zigterman14 3Institut für Viruskrankheiten und Immunprophylaxe, 3147 Mittelhäusern, Switzerland; P.O. Box 65, Edelhertweg 15, 8200 AB Lelystad, The Netherlands; 5European Pharmacopoeia, Council of Europe, 226, avenue de Colmar, P.O. Box 907, 67029 Strasbourg 01, France; 6Lohmann Animal Health GmbH, Heinz-Lohmann-Strasse 4, 27472 Cuxhaven, Germany; 7Laboratoire Central de Recherches Avicole et Porcine, Agence Francaise de Securite Sanitaire des Aliment, BP 53, Zoopole, 22440 Ploufragan, France; 8ECVAM, JRC Institute for Health & Consumer Protection, European Commission, 21020 Ispra (VA), Italy; 9Paul Ehrlich Institute, Paul-Ehrlich-Strasse 51–59, 63225 Langen, Germany; 10Merial S.A.S., 29 Avenue Tony Garnier, P.O. Box 7123, 69348 Lyon 07, France; 11Laboratorio di Medicina Veterinaria, Istituto Superiore di Sanità, Viale Regina Elena 299, 00161 Roma, Italy; 12Viral Oncogenesis Group, Institute for Animal Health, Compton, Berkshire RG20 7NN, UK; 13Fort Dodge Animal Health, C.J. van Houtenlaan 36, 1381 CP Weesp, The Netherlands; 14Intervet International B.V., Wim de Korverstraat 35, 5831 AN Boxmeer, The Netherlands 4ID-DLO, Preface This is the report of the forty-first of a series of workshops organised by the European Centre for the Validation of Alternative Methods (ECVAM). ECVAM’s main goal, as defined in 1993 by its Scientific Advisory Committee, is to promote the scientific and regulatory acceptance of alternative methods which are of importance to the biosciences and which reduce, refine or replace the use of laboratory animals. One of the first priorities set by ECVAM was the implementation of procedures which would enable it to become well informed about the state-of-the-art of non-animal test development and validation, and the potential for the possible incorporation of alternative tests into regulatory procedures. It was decided that this would be best achieved by the organisation of ECVAM workshops on specific topics, at which small groups of invited experts would review the current status of various types of in vitro tests and their potential uses, and make recommendations about the best ways forward (1). The joint ECVAM/AGAATI (Advisory Group on Alternatives to Animal Testing in Address for correspondence: Dr Lukas Bruckner, Institut für Viruskrankheiten und Immunprophylaxe, 3147 Mittelhäusern, Switzerland. Address for reprints: ECVAM, JRC Institute for Health & Consumer Protection, TP 580, 21020 Ispra (VA), Italy. 1ECVAM — The European Centre for the Validation of Alternative Methods. 2This document represents the agreed report of the participants as individual scientists. 242 Immunobiologicals) workshop on Three Rs Approaches in the Production and Quality Control of Avian Vaccines was held in Langen, Germany, on 11–13 June 1999, under the co-chairmanship of Lukas Bruckner (Institute of Virology and Immunoprophylaxis, Mittelhäusern, Switzerland) and Guy Zigterman (Intervet, Boxmeer, The Nether lands). The participants, all experts in vaccine quality control, avian vaccines or avian diseases, came from international regulatory or government organisations, national control laboratories, vaccine manufacturers and academia. The objectives of the workshop were: a) to review the monographs of the European Pharmacopoeia on avian live viral vaccines in the light of animal welfare aspects; b) to propose and recommend strategies to replace, reduce and/or refine the use of animals; c) to review the state-of-the-art and the suitability of the tests proposed for their intended purposes; and d) to comment on the draft monographs on avian live viral vaccines which had been published in Pharmeuropa (2–12). The outcome of the discussions and the recommendations agreed by the workshop participants are summarised in this report. Introduction Vaccines are considered to be the most costeffective tools in the prevention of infectious diseases; this applies, in particular, to avian live viral vaccines. The minimal requirements for the production and quality control of vaccines are given in the European Pharmacopoeia. Its actual Third Edition & Supplements include 13 monographs on avian vaccines (live and inactivated) and the text for extraneous agents testing (Table I). Most of these monographs are more than 15 years old and have only occasionally been revised since they were first published. It is questionable whether all of the tests prescribed are still relevant. In particular, some of the “safety tests” might be superfluous, and it is debatable whether the high numbers of animals required can still be justified. Tests in animals are prescribed for testing for safety, extraneous agents and potency. Since the quality of vaccines is controlled not only during development, but also on a batch-to-batch basis, large numbers of animals are used. The representatives of vac- L. Bruckner et al. cine manufacturers at the workshop estimated that about 51,000 chickens and other birds are used each year for the quality control of 1800 batches of avian vaccines. In recent years, the European Pharmacopoeia Commission and its Group of Experts 15V, which is responsible for veterinary vaccines, have made great efforts to revise these old monographs and to harmonise them. In March 1999, draft revisions of the monographs on live avian vaccines (2–9) and extraneous agents testing (10, 11), and the draft monograph on Avian Viral Tenosynovitis Vaccine (Live) (12), were published in Pharmeuropa. As soon as a draft monograph is published in Pharmeuropa, members of the public are invited to submit comments on the text to the European Pharmacopoeia Commission. The comments received are discussed in the relevant Group of Experts and, if considered to be appropriate, the comments are incorporated into the monographs. One of the aims of the workshop was to comment step-by-step on the published texts in the light of the Three Rs. Comments representing the conclusions of the participants in the workshop were sent to the European Pharmacopoeia Secretariat in September 1999. This workshop report summarises these comments, and includes additional information on the current status of alternative methods for the testing of inactivated poultry vaccines. Testing for Extraneous Agents in Avian Live Viral Vaccines Testing for extraneous agents in avian live viral vaccines is regulated by two monographs (Table I), which apply to all of the individual monographs on avian live viral vaccines. The methods proposed are animal and non-animal tests that have to be performed on the seed lot and on each batch of the finished product. Ten 2-week-old chicks are twice inoculated in a given period with multiple doses of the vaccine, by intramuscular injection and by eye drop. Serum is collected from each chick before the inoculation and at the end of the test period. The animals are observed, and should not show other than mild signs of infectious disease. The serum samples are tested for antibodies against a given list of infectious agents. ECVAM Workshop 41: avian vaccines 243 Table I: European Pharmacopoeia texts on avian vaccines Texts Revision Reference General texts 2.6.3 Avian Viral Vaccines: Tests for Extraneous Agents in Seed Lots 2.6.4 Avian Live Virus Vaccines: Tests for Extraneous Agents in Batches of Finished Product Individual monographs Avian Infectious Bronchitis Vaccine (Live) Avian Infectious Bronchitis Vaccine (Inactivated) Avian Infectious Bursal Disease Vaccine (Live) Avian Infectious Bursal Disease Vaccine (Inactivated) Avian Infectious Encephalomyelitis Vaccine (Live) Avian Infectious Laryngotracheitis Vaccine (Live) Avian Viral Tenosynovitis Vaccine (Live) Duck Viral Hepatitis type 1 Vaccine (Live) Egg Drop Syndrome ’76 Vaccine (Inactivated) Fowl-pox Vaccine (Live) Newcastle Disease Vaccine (Live) Newcastle Disease Vaccine (Inactivated) Marek’s Disease Vaccine (Live) Comments on 2.6.3. Avian Viral Vaccines: Tests for Extraneous Agents in Seed Lots (10) The current scheme requires the testing for extraneous agents to be carried out with embryonated hens’ eggs, in cell cultures and in chicks. A polymerase chain reaction (PCR) method is proposed for the detection of avian leukosis virus (17). The workshop participants agreed that the test in chicks is necessary with regard to the safety of the vaccine; however, to avoid unnecessary test repetitions, and to enhance the safety of the vaccine, several items should be stated more clearly. 1) It should be clearly indicated in the text that the tests for extraneous agents in chicks need to be performed only once during development, preferably on the master seed lot. If insufficient master seed lot is available, testing should be allowed on a working seed lot, preferably as close as possible to the master seed lot. yes 10 yes 11 yes 4 13 3 14 2 yes yes yes new draft yes yes yes yes 9 12 5 15 6 7 16 8 2) The test for extraneous agents in chicks must include clinical observation of the animals and the testing of serum samples. 3) The list of agents against which the serum samples should be tested, and the list of test methods to be used, should include the agents and methods that are given in the general monograph on specific pathogen-free (SPF) eggs (Table II; 18). This would increase the certainty that the product is free of these agents. With regard to the testing of turkey vaccines, deletion of the extraneous agents test for turkey lymphoproliferative disease virus is recommended, since there is only a low incidence of the virus, and the test currently performed has not been validated. 4) It is recommended that the sera of the test animals should be stored under suitable conditions as long as seed material 244 L. Bruckner et al. Table II: Agents against which serum samples should be tested in the extraneous agents test using chicks (text 2.6.3) Microorganism Type of test Avian adenoviruses Avian encephalomyelitis virus* Avian infectious bronchitis virus Avian infectious laryngotracheitis virus Avian leucosis viruses Enzyme-linked immunosorbent assay Enzyme-linked immunosorbent assay Enzyme-linked immunosorbent assay Serum neutralisation Serum neutralisation Avian nephritis virus* Avian reoviruses Avian reticuloendotheliosis virus* Chicken anaemia virus Haemagglutinating avian adenovirus (egg drop syndrome EDS 76 virus)* Fluorescent antibody Enzyme-linked immunosorbent assay Fluorescent antibody Fluorescent antibody Haemagglutination inhibition Infectious bursal disease virus* Influenza A virus Marek’s disease virus* Newcastle disease virus Turkey rhinotracheitis virus* Serum neutralisation Enzyme-linked immunosorbent assay Enzyme-linked immunosorbent assay Haemagglutination inhibition Enzyme-linked immunosorbent assay Mycoplasma gallisepticum Agglutination and, to confirm a positive test, haemagglutination inhibition Agglutination and, to confirm a positive test, haemagglutination inhibition Agglutination Mycoplasma synoviae Salmonella pullorum* * = infectious agents included in the revised monograph. obtained from the tested master seed lot is being used for production of the vaccine. This will facilitiate the testing for antibodies against agents which were not known when the master seed was established, and will provide information on the possible contamination of the product with agents discovered subsequently. Comments on 2.6.4. Avian Live Virus Vaccines: Tests for Extraneous Agents in Batches of Finished Product (11) The proposed scheme requires tests in eggs, cell cultures and chicks in order to cover the range of possible contaminants. With regard to the numbers of animals used, far more animals are needed for the testing of each batch than for testing seed lots. The test in chicks is intended to cover 16 infectious agents. It is often not the most sensitive method for the detection of contaminants, but its lack of sensitivity is partially compensated for by inoculating the chicks with multiple vaccine doses. Alternative methods that are at least as sensitive as the animal test (17, 19–24) are now available. Some of the tests that have recently been developed (for example, PCR methods for detection of chick anaemia virus and avian infectious haemorrhagic enteritis virus; 20, ECVAM Workshop 41: avian vaccines 24) could be fully validated for use as routine tests by the time the revised monographs are expected to become official (January 2002). Table III includes the agents to be tested, and possible alternative methods and their stages of development. Efforts should be made to develop and validate the PCR method for the detection of avian infectious haemorrhagic enteritis virus, and to validate the PCR method for the detection of chick anaemia virus. Some of the alternative methods are already included in the draft text of 2.6.3. Avian Viral Vaccines: Tests for Extraneous Agents in Seed Lots (10). In the light of the availability of alternatives methods that are at least as relevant and reliable as the animal test, it is recommended, in accordance with obligations under the European Convention for laboratory animal protection (26) and Council Directive 86/609/EEC (27), that the test for extraneous agents on batches of the finished product using chicks should be deleted. A Good Manufacturing Practice (GMP) environment minimises the risk of contamination of the product. Extraneous agents testing should be performed on the agents which are handled in the individual production facility. This would significantly reduce the list of agents to be tested, and the reduced number of tests to be carried out might increase willingness to apply the nonanimal methods. In situations where such viruses as Newcastle disease virus (NDV), infectious bursal disease virus (IBDV), infectious laryngotracheitis virus (ILTV), and infectious bronchitis virus (IBV), which are not included in the table given in the revised text (11), are handled in the production facility, they should be considered for extraneous agents testing. PCR methods are available for NDV (21), IBV (22) and ILTV (23), and are under development for IBDV (Table III). Avian Live Viral Vaccines The revised monographs on avian live viral vaccines are divided into three sections: Definition, Production and Batch Tests. The Definition section briefly describes the vaccine and its scope. The Production section covers the requirements on the preparation of the vaccine, the substrate for virus propagation, seed lots, and choice of vaccine virus, which includes tests for safety, increase in viru- 245 lence and immunogenicity. These tests have to be fulfilled for the licensing of a vaccine. Most of them involve the use of animals. The Batch Tests section includes the requirements that have to be met by each batch to be released. Animals are used for the tests for extraneous agents and for safety testing. General comments A number of animal tests are stipulated for each monograph, and have been harmonised during revision (for example, the number of animals used for the safety testing). Production Safety testing. As the text reads in the revised monographs, at least 20 animals are inoculated with a 10fold dose of the test vaccine for each route and method of administration and category of animal. The animals are observed for 21 days, and should not show noticeable clinical signs of disease or die from causes attributable to the vaccine virus. As the text reads now, far more animals would be used than necessary, since the safety test should be performed in different categories of chicken. The general opinion was that differences in the susceptibility between the various categories versus the various viruses are not evident, except in the case of IBDV. SPF chickens are regarded as a fully susceptible category of animals. In addition, the monograph does not clearly define the categories, and the current vague requirement is therefore subject to individual interpretation (for example, broilers, layers, different breeds, and white or brown lineage). It is recommended that SPF chickens should be the only category of animals to be used. During revision of the monographs, the observation period has been prolonged from 14 days to 21 days. If this prolongation is adopted, all the vaccines on the market will have to be retested, which would require a large number of chickens. Retesting of these vaccines is not considered to be appropriate, since they have already been tested with a 14-day observation period during their development and, in addition, batch safety tests have been carried out with a 21-day observation period. It is recommended that only newly licensed vaccines need be tested with a 21day observation period. 246 L. Bruckner et al. Table III: Agents against which serum samples should be tested and available non-animal methods for extraneous agents testing of batches of the finished product (monograph 2.6.4) Agent Alternative method Status and Reference Infectious avian encephalomyelitis Eggs (intravitelline injection) Covered by paragraph 2.6.3.1 in (10) Avian leucosis viruses Cell culture PCR Covered by paragraph 2.6.3.3 in (10) Available (17) Avian nephritis virus Kidney cell culture Covered by paragraph 2.6.3.2 of (10) Avian reticuloendotheliosis virus Chick (or duck) embryo fibroblasts Covered by paragraph 2.6.3.4 in (10) + immunofluorescence; PCR Available (19) Egg drop syndrome virus Production substrate (fibroblasts, duck eggs) or other sensitive cells Available for substrates given in 2.6.3.1 and 2.6.3.2 in (10) Chicken anaemia virus Cells; PCR Covered by paragraph 2.6.3.5 in (10) Available (20) Marek’s disease virus Chick embryo fibroblasts Covered by paragraph 2.6.3.2 in (10) Newcastle disease virus Eggs (intra-allantoic inoculation) PCR Covered by paragraph 2.6.3.1 in (10) Available (21) Infectious bursal disease virus Eggs (chorio-allantoic membrane and intra-allantoic inoculation) PCR Covered by paragraph 2.6.3.1 in (10) Under development Infectious bronchitis virus Eggs (intra-allantoic inoculation) PCR Covered by paragraph 2.6.3.1 in (10) Available (22) Infectious laryngotracheitis virus Eggs (chorio-allantoic membrane inoculation) PCR Covered by paragraph 2.6.3.1 in (10) Salmonella pullorum Culture Covered by the sterility test stipulated in (25) Turkey rhinotracheitis virus Vero cells, chick embryo fibroblasts Available for substrates given in 2.6.3.2 in (10) Chlamydia spp. Eggs (intravitelline injection) Covered by paragraph 2.6.3.1 in (10) Avian infectious hemorrhagic enteritis virus PCR Available (24) Avian paramyxovirus-3 Eggs Covered by paragraph in 2.6.3.1 in (10) Duck/goose parvoviruses Duck eggs/duck embryo fibroblasts Available for substrates given in 2.6.3.1 and 2.6.3.2 in (10) Duck enteritis virus Duck embryo fibroblasts Available for substrates given in 2.6.3.1 and 2.6.3.2 in (10) Duck hepatitis viruses I and II Eggs Covered by paragraph 2.6.3.1 in (10) Available (23) ECVAM Workshop 41: avian vaccines Increase in virulence Avian live viral vaccines contain attenuated virus, which means that their virulence is reduced. During its spread (passaging), the virus can increase in virulence and can eventually induce an outbreak of the disease. Only sufficiently attenuated strains, which show no increase of virulence, should be used for the production of a vaccine. Increase in virulence is tested by artificially passaging the virus at least five times in five 1-day-old chicks. The individual monographs state that a quantity of the vaccine virus that will allow maximum recovery of virus has to be used for the passaging. The determination of this dose (maximum recovery) would require many animals. However, the exact determination of this dose is not relevant for the outcome of the test, and the use of additional animals is therefore not justified. The word “maximum” should be deleted from avian live vaccine monographs. With regard to the state-of-the-art of the test, two comments were made: animals of the minimum age recommended for vaccination should be used for the test, and passaging under natural conditions should be allowed for viruses showing natural spread, since artificial passaging is very often not as effective as natural passaging from a group of animals to another group of animals. Immunogenicity Since the immunogenicity tests vary in the individual monographs, depending on the scope of the vaccine, a general description of the test is not possible. However, some of the individual monographs require that the test should be performed in “each category of chickens for which the vaccine is intended”. As explained under Safety testing, the general opinion was that differences in the susceptibility between the various categories versus the various viruses are not evident, except for IBDV. SPF chickens are regarded as a fully susceptible category of animals. It is therefore not necessary to perform the test with different categories. Batch tests Two of the tests prescribed for the batch quality control of avian live virus vaccines, which have to be performed on each batch of the finished product before its release, involve the use of animals: the test for extraneous agents and the batch safety test. 247 Extraneous agents test The monographs stipulate that the vaccines have to comply with the tests for extraneous agents in batches of finished products (2.6.4). As explained earlier under Testing for Extraneous Agents in Avian Live Viral Vaccines, the workshop participants recommend the replacement of the extraneous agent test in chicks by alternative test methods. On the basis of the figures given above, the release of 1800 batches/year by four manufacturers, and the use of ten chicks in the test, a total reduction of 18,000 animals could be achieved by deleting this test. Batch safety test At least ten chickens are inoculated by a given route with ten doses of the vaccine to be tested. The animals are observed for 21 days and, for compliance with the requirements, should not show “abnormal clinical signs or die from causes not attributable to the vaccine”. This safety test in the target animal is required by most of the Europoean Pharmacopoeia monographs and various EU guidelines on veterinary vaccines. Its initial purpose was the detection of non-specific contamination. During recent years, the relevance of the safety test has increasingly been questioned (28–30), because the introduction of Good Laboratory Practice and Good Manufacturing Practice into the manufacture of vaccines has significantly increased the safety and quality of the products, and contamination with non-specific agents should not occur. Two studies are currently being performed by a working group at the Paul Ehrlich Institute (Langen, Germany) and by AGAATI (with the financial support of the European Commission through ECVAM). Data on the target animal safety test are being collected from vaccine manufacturers and control authorities in Europe, then analysed retrospectively. The results concerning poultry vaccines show that all batches tested in the last few years passed the test. Passing the test had no influence on the number of the reports on vaccinovigilance collected from the field. Therefore, the workshop participants questioned the purpose and relevance of this test, and recent experience has shown that the test is not capable of detecting major problems with vaccine batches. Comparison of the number of animals stipulated for the target animals safety test in veterinary monographs reveals that two animals are required for mammalian vaccines, but at 248 least ten are necessary for poultry vaccines. There is no scientific or statistical rationale for this difference. The data given in Appendix 1 show that, in order to obtain statistically reliable results, it would be necessary to increase the numbers of animals markedly. For the given requirement (ten out of ten animals do not show abnormal clinical signs or die), it can be concluded with 95% confidence that 74.1% of the true population would not show abnormal clinical signs or die. A sample size of at least 14 animals would be required to conclude with 95% confidence that 80% of the true population met the requirement. However, in the interests of animal welfare and good science, and for economic rea sons, such an increase cannot be justified for a test which might no longer be relevant. In the opinion of the workshop participants, the batch safety test should be restricted to two situations: a) for demonstration of consistency of production, when the batch safety test should be carried out on a limited number of batches; and b) after relevant changes in the production process (for example, new batches of critical components of the final product), when the batch safety test should be carried out on a limited number of batches. In all other cases, the need for batch safety testing is not justified. Therefore, it is recommended that the batch safety test should be deleted from the individual monographs on avian vaccines. On the basis of the figures given above, the release of 1800 batches/year by four manufacturers, and the use of ten chicks in the test, a total reduction of 18,000 animals used could be achieved by deleting this test. Humane endpoints Whenever applicable to a test stipulated in these monographs, animals showing typical signs of disease should be humanely killed to avoid unnecessary suffering. Specific comments on individual monographs Most of the specific comments on avian live vaccines apply to the tests stipulated for the choice of the vaccine strain in the Production section. In general, animal tests are required for assessing safety, increase in virulence, and immunogenicity. Depending on the vaccine virus, additional animal tests are included in L. Bruckner et al. the monographs, which should cover certain aspects of safety and immunogenicity. Avian Infectious Bronchitis Vaccine (Live) A safety test for the reproductive tract should be conducted during development, if the vaccine is intended to be used for hens; however, a detailed design of the test is not given. The participants of the workshop underlined the need for a defined model, and forwarded a proposal to the European Pharmacopeia Commission. Two animal tests are stipulated for the immunogenicity testing of this vaccine. Equivalent information on the vaccine strain can be achieved with either of the tests. It is therefore recommended that the monograph should clearly state that performance of one of the tests is sufficient. Avian Infectious Bursal Disease Vaccine (Live). As already stated in the general comments, SPF chickens might be too sensitive for the safety testing of this vaccine. The monograph should state that “commercial animals with representative levels of maternally derived antibodies should be used”. This recommendation applies also to the test for damage to the bursa of Fabricius and the test for immunosuppression, which are two additional tests in animals to be performed during development. The present test for damage to the bursa of Fabricius involves 20 chickens, which are inoculated with the vaccine virus; after given observation periods, the animals are killed and the bursa of Fabricius is examined histologically. Clear criteria for estimation of the degree of the bursal damage are not given, which might lead to subjective interpretation of the test. It is recommended that clear criteria should be established and incorporated into the test protocol. The monograph includes two tests for immunosuppression. The first test is a potency test for Newcastle disease (ND) vaccines carried out in groups of chickens inoculated with: a) the vaccine virus and a given ND vaccine; b) the ND vaccine only; or c) no vaccine. The three groups of animals are challenged with NDV and the protection rates are compared. This test differs significantly from the potency test given in the monograph on Newcastle Disease Vaccine (Live) with regard to the challenge strain used and the observation period. Since there ECVAM Workshop 41: avian vaccines is no scientific rationale for this difference, this test should be carried out as the immunogenicity test stipulated for ND live vaccines. The second test for immunosuppression stipulated by the monograph is carried out with 20 chickens, of which 10 are immunised with the vaccine virus. The animals are inoculated with Brucella abortus and the immune responses of the immunised and non-immunised groups to B. abortus are compared. The workshop participants criticised the lack of evaluation criteria for this test, and the fact that vaccination against B. abortus is not performed in practice. In addition, the test cannot provide additional information on any immunosuppressive effects of the vaccine strain. There was agreement that the first test is better for this purpose, and it is recommended that the second test should be deleted. Increase in virulence should also be evaluated with two animal tests after passaging of the vaccine virus, the safety test and the test for damage to the bursa of Fabricius. However, performance of the latter test appears to be sufficient for this purpose, since it is more sensitive than the safety test. Avian Infectious Encephalomyelitis Vaccine (Live) The test for intracerebral virulence should be deleted, since it cannot discriminate between attenuated and virulent virus strains, due to the inappropriate 8-day observation period. Prolongation of the observation period might improve the test, but vaccines that are currently in use and have proved to be efficacious would be rejected. In addition, the vaccine is mainly intended for use in animals above the age of 10 weeks, at which age, the animals are no longer susceptible to the agent. Two tests are required for the testing of immunogenicity, the test for active immunity in the chicken and the test for passive immunity in chicks. There is no need to demonstrate active immunity in adult chickens, since it is not relevant to the purpose of this vaccine. Deletion of the test for active immunity in adult chickens is therefore recommended. The purpose of the vaccine is protection against vertical transmission and the conferment of passive immunity. Conferment of passive immunity could be tested by demonstrating the neutralisation of mater- 249 nally derived or egg yolk-derived antibodies. An embryonated-egg challenge test (31) should be incorporated into the monograph for this purpose. In the Batch tests section, the virus titre of the vaccine can be estimated by titration in embryonated hens’ eggs or in cell cultures. However, titration of the avian encephalomyelitis virus in tissue culture is not yet feasible. In order to permit titration in eggs, the monograph should state “suitable in vitro methods” instead of “cell cultures”. Avian Infectious Laryngotracheitis Vaccine (Live). See General comments. Avian Viral Tenosynovitis Vaccine (Live) It is questionable whether the proposed test for immunogenicity reflects the use of the vaccine in the field. Live tenosynovitis vaccine is usually only applied for the priming of chicks. Boosting is performed with an inactivated vaccine. It cannot be expected that vaccines, which are recommended for use with a booster injection, will confer protection if used for priming alone. In the Batch tests section, immunofluorescence methods should be allowed for the identification of the vaccine, since neutralisation of tenosynovitis virus with antiserum might be difficult or even impossible. Duck Viral Hepatitis type 1 Vaccine (Live) It is recommended that the tests stipulated in the monograph are carried out with only one species of duck, namely, the domestic duck (Anas platyrhynchus), since differences in susceptibility between the various species of ducks versus duck hepatitis virus 1 are not evident. In the immunogenicity test, which is performed with vaccines for active immunisation of ducklings, virus shedding in the faeces should be used for test evaluation, in addition to observation for clinical signs and mortality. Fowl-pox Vaccine (Live) In the test for increase of virulence, the passage material is administered by cutaneous scarification of the chicken comb. Since this could lead to cannibalism, it is recommended that scarification of other unfeathered parts of the body should be permitted. Newcastle Disease Vaccine (Live) This monograph stipulates that nine passages should be performed in the test for increase in virulence; however, the NDV is no more likely 250 to revert to virulence than other avian viruses are. Therefore, only five passages should be required, as in the other monographs. For detection of increased virulence, three tests should be carried out with the unpassaged vaccine virus and the maximally passaged virus. In addition to the two specific tests — the intracerebral pathogenicity index and the test for amino-acid sequence — the more-general safety test is stipulated. The workshop participants agreed that the safety test provides neither additional information nor additional assurance that reversion to virulence has not occurred, and therefore should be deleted. Two tests for immunogenicity are given in the monograph, and should be applied according to the use of the vaccine. The design of the immunogenicity test for vaccines for use in chickens deviates from the test protocol in the monograph currently used. For vaccines on the market, the introduction of a new test protocol would require retesting in animals, which would not increase the quality of the vaccines, but would unnecessarily increase the numbers of animals used. Therefore, maintenance of the current protocol is recommended. With regard to vaccines for use in avian species other than chickens, prolongation of the observation period from 14 days to 21 days is recommended, since the development of the disease could be different in birds other than SPF chickens. In addition to death and clinical signs, virus shedding in faeces should be monitored, and the criteria for a valid test should be modified accordingly. Marek’s Disease Vaccine (Live) The monograph stipulates that two safety tests should be carried out during development. The first test can be regarded as a safety test comparable with the ones required by the other monographs. In addition to the modifications given above in the general comments, the observation period should be extended to 120 days. The purpose of the second test is to demonstrate that SPF chicks are susceptible to Marek’s disease virus, and that lesions similar to those of Marek’s disease virus do not occur naturally in SPF chicks. Both criteria are fulfilled by the available SPF chicks, and that these criteria have to be demonstrated for each product is not justified. Since the second test does not provide any additional information to the first test, its deletion is recommended. L. Bruckner et al. Inactivated Avian Vaccines Four monographs on inactivated avian vaccines are included in the European Pharmacopoeia (Table I). Since the workshop was focused on the live avian vaccines currently under revision, only the current status of alternative methods for the potency testing of inactivated avian vaccines was discussed. The potency of inactivated avian vaccines has to be tested on each vaccine batch. This requires a large number of animals and involves suffering to the animals if, under certain circumstances, challenge with the infectious agent is required. In most cases, serological methods are used for antibody estimation after immunisation. In recent years, efforts have been made to develop antigen-estimation-based in vitro methods which do not require animals. Most progress has been achieved with models for the potency testing of inactivated ND vaccines (32–34). The approach used is based on the quantification of the NDV antigens, the HNprotein and F-protein, which induce the production of neutralising antibodies after vaccination. Two ELISA procedures have been developed for this purpose. Preliminary results show that the method is sensitive, specific and reproducible. There is a good correlation between the amount of virus estimated in the vaccine and the antibodies detected in the serum after immunisation (34). Whether antigen quantification can be used for the potency testing of inactivated bursal disease vaccine is also now under investigation. The participants of the workshop recommended that further research activities for the development of alternative methods for the potency testing of inactivated avian vaccines should be encouraged and undertaken; and that the in vitro method developed for the potency testing of inactivated ND vaccines should be prevalidated/validated under the auspices of independent institutions such as ECVAM and the European Directorate for the Quality of Medicines (EDQM). Summary of Recommendations Extraneous agents testing 1. The tests for extraneous agents of seed lots in chicks should be performed only once during development, preferably on the ECVAM Workshop 41: avian vaccines 251 master seed lot. If sufficient material of the master seed lot is not available, testing should be on a working seed lot, preferably as close as possible to the master seed lot. 2. The test for extraneous agents of seed lots in chicks must include clinical observation of the animals and the testing of the serum samples. It is recommended that the sera of the test animals should be stored under suitable conditions, as long as seed material obtained from the tested master seed lot is being used for production of the vaccine. This will facilitiate the testing for antibodies against agents which were not known when the master seed was established, and will provide information on the possible contamination of the product with agents discovered subsequently. stipulated during production, since they are regarded as a fully susceptible category of animal and differences between the categories versus the various viruses are not evident. 9. In order to avoid unnecessary retesting of already licensed vaccines, a 21-day observation period for safety testing during production should be required only for newly licensed vaccines. 10. For the outcome of increase in virulence testing, it is not necessary that passaging of the virus is performed with a dose which allows maximum recovery of the virus. Therefore, the word “maximum” should be deleted from avian live vaccine monographs, since the use of additional animals for the determination of the necessary virus dose is not justified. 3. The list of agents against which the serum samples should be tested, and the list of test methods to be used, should also include the agents and methods that are given in the general monograph on specific pathogen-free (SPF) eggs. 11. Animals of the minimum age recommended for vaccination should be used for the test, and passaging under natural conditions should be allowed for viruses showing natural spread. 4. With regard to turkey vaccines, the test for extraneous agents of seed lots against turkey lymphoproliferative disease virus should be deleted. There is only a low incidence for the virus, and the test currently performed has not been validated. 12. The test for extraneous agents on batches of the finished product using chicks should be replaced with the available alternative test methods. 5. The test for extraneous agents on batches of the finished product in chicks should be replaced with the available non-animal methods. 6. Efforts should be undertaken to further develop and validate the PCR method for the detection of avian infectious haemorrhagic enteritis virus. 7. Efforts should be made to validate scientifically the available alternative methods which have not yet been incorporated into Monograph 2.6.3. Avian Viral Vaccines: Tests for Extraneous Agents in Seed Lots , and to promote their acceptance. Avian live viral vaccines General recommendations with regard to the Production section 8. Only SPF chickens should to be used for the safety and immunogenicity tests General recommendations to the Batch test section 13. The batch safety test should be deleted from the individual monographs on avian vaccines. It should only be allowed for two situations: a) for demonstration of consistency of production, when the batch safety test should be carried out on a limited number of batches; and b) after relevant changes in the production process (for example, new batches of critical components of the final product), when the batch safety test should be carried out on a limited number of batches. 14. Whenever applicable to a test stipulated in these monographs, animals showing typical signs of disease should be humanely killed to avoid unnecessary suffering. Specific recommendations to individual monographs 15. The monograph, Avian Infectious Bronchitis Vaccine (Live), should include a detailed design for the safety test for the 252 L. Bruckner et al. reproductive tract stipulated for vaccines intended to be used in hens. The proposal forwarded by the participants in the workshop should be considered by the Group of Experts 15V of the European Pharmacopoeia Commission. 16. It should be clearly stated in the monograph, Avian Infectious Bronchitis Vaccine (Live), that only one of the two tests for immunogenicity needs to be performed. 17. Clear criteria should be stated in the monograph, Avian Infectious Bursal Disease Vaccine (Live), for the histological examination of the bursa of Fabricius in the test for damage to the bursa of Fabricius. 18. In the monograph, Avian Infectious Bursal Disease Vaccine (Live), of the tests for immunosuppression, only the potency test for ND vaccines should be stipulated. The second test for immunosuppression, involving challenge with B. abortus, should be deleted. 19. Performance of the test for damage to the bursa of Fabricius appears to be sufficient for increase in virulence testing of avian infectious bursal disease live vaccine. The safety test stipulated for this purpose should be deleted from the monograph, Avian Infectious Bursal Disease Vaccine (Live). 20. The test for intracerebral virulence in the monograph, Avian Infectious Encephalomyelitis Vaccine (Live), should be deleted, since it cannot discriminate between attenuated and virulent virus strains, due to the inappropriate 8-day observation period. Prolongation of the observation period might improve the test, but would lead to the rejection of vaccines that are currently in use and have proven to be efficacious. 21. Deletion of the test for active immunity in the chicken from the monograph, Avian Infectious Encephalomyelitis Vaccine (Live), is recommended. Since one of the purposes of this vaccine is protection against vertical transmission, there is no need to demonstrate active immunity in adult chickens. 22. The second purpose of avian infectious encephalomyelitis live vaccines, which is conferment of passive immunity, could be tested by demonstrating the neutralisation of maternally derived or egg yolk-derived antibodies. An embryonated-egg challenge test should be incorporated into the monograph, Avian Infectious Encephalomyelitis Vaccine, for this purpose. 23. It is recommended that the tests stipulated in the monograph, Duck Viral Hepatitis type 1 Vaccine (Live), should be carried out with only one species of duck, namely, the domestic duck (A. platyrhynchus). 24. In the test for increase of virulence in the monograph, Fowl-pox Vaccine (Live), the passage material is administered by cutaneous scarification of the chicken comb. Since this could lead to cannibalism, it is recommended that scarification of other parts of the unfeathered body be permitted. 25. In the monograph, Newcastle Disease Vaccine (Live), only five passages should be required for the test for increase in virulence, as in the other monographs for avian live vaccines. 26. For detection of an increase in virulence, it is sufficient to estimate the intracerebral pathogenicity index and to conduct the amino-acid sequence test. The third test stipulated for this purpose, the safety test, should be deleted from the monograph, Newcastle Disease Vaccine (Live). 27. The currently used immunogenicity test for vaccines for use in chickens should not be modified as proposed in the revised monograph, Newcastle Disease Vaccine (Live), since the modification would require retesting of the vaccines on the market, and, although this would not increase the quality of the vaccines, it would unnecessarily increase the numbers of animals used. 28. The second safety test included in the revised monograph, Marek’s Disease Vaccine (Live), does not provide additional information and should be deleted. One safety test in an SPF chicken, with an observation period of 120 days, would be appropriate. Inactivated Avian Vaccines 29. Further research activities for the development of alternative methods for the ECVAM Workshop 41: avian vaccines 253 potency testing of inactivated avian vaccines should be undertaken and encouraged. 30. The in vitro method developed for the potency testing of inactivated ND vaccines should be prevalidated/validated under the auspices of independent institutions such as ECVAM and EDQM. References 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. ECVAM (1994). ECVAM News & Views. ATLA 22, 7–11. Council of Europe (1999). Avian Infectious Encephalomyelitis Vaccine (Live). Pharmeuropa 11, 158–160. Council of Europe (1999). Avian Infectious Bursal Disease Vaccine (Live). Pharmeuropa 11, 160–163. Council of Europe (1999). Avian Infectious Bron chitis Vaccine (Live). Pharmeuropa 11, 163–166. Council of Europe (1999). Duck Viral Hepatitis Type 1 Vaccine (Live). Pharmeuropa 11, 166–168. Council of Europe (1999). Fowl-pox Vaccine (Live). Pharmeuropa 11, 168–170. Council of Europe (1999). Newcastle Disease Vaccine (Live). Pharmeuropa 11, 170–172. Council of Europe (1999). Marek’s Disease Vaccine (Live). Pharmeuropa 11, 172–175. Council of Europe (1999). Avian Infectious Laryn gotracheitis Vaccine (Live). Pharmeuropa 11, 175–177. Council of Europe (1999). 2.6.3. Avian Viral Vaccines: Tests for Extraneous Agents in Seed Lots. Pharmeuropa 11, 188–191. Council of Europe (1999). 2.6.4. Avian Live Virus Vaccines: Tests for Extraneous Agents in Batches of Finished Product. Pharmeuropa 11, 191–193. Council of Europe (1999). Avian Viral Tenosynovitis Vaccine (Live). Pharmeuropa 11, 156–158. Council of Europe (1997). Avian Infectious Bron chitis Vaccine (Inactivated). In European Pharmacopoeia, 3rd edn. Strasbourg, France: Council of Europe. Council of Europe (1997). Avian Infectious Bursal Vaccine (Inactivated). In European Pharmacopoeia, 3rd edn. Strasbourg, France: Council of Europe. Council of Europe (1998). Egg Drop Syndrome ’76 Vaccine (Inactivated). European Pharmacopoeia, 3rd edn, Suppl. Strasbourg, France: Council of Europe. Council of Europe (1997). Newcastle Disease Vaccine (Inactivated). European Pharmacopoeia, 3rd edn. Strasbourg, France: Council of Europe. Häuptli, D., Bruckner, L. & Ottiger, H.P. (1997). Use of reverse transcriptase polymerase chain reaction for detection of vaccine contamination by avian leukosis virus. Journal of Virological Methods 66, 77–81. Council of Europe (1997). 5.2.2. Chicken flocks free from specified pathogens for the production and quality control of vaccines. European Pharmacopoeia, 3rd edn. Strasbourg, France: Council of Europe. Tagaki, M., Ishikawa, K., Nagai, H., Sasaki, T., 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. Gotoh, K. & Koyama, H. (1996). Detection of contamination of vaccines with the reticuloendotheliosis virus by reverse transcriptase polymerase chain reaction (RT-PCR). Virus Research 40, 113–121. Falcone, E., Tarantino, M., Massi, P., Di Pasquale, I., Vignolo, E. & Tollis, M. (2000). Detection of vaccine contamination by chicken anaemia virus by polymerase chain reaction. In Proceedings of the 3rd World Congress on Alter natives and Animal Use in the Life Sciences (ed. M. Balls, A-M. van Zeller & M. Halder), in press. Stäuber, N., Brechtbühl, K. Bruckner, L. & Hofmann, M.A. (1995). Detection of Newcastle disease virus in poultry vaccines using polymerase chain reaction and direct sequencing of amplified cDNA. Vaccine 13, 360–364. Falcone, E., D’Amore, E., Di Trani, L., Puzelli, S. & Tollis, M. (1997). Detection of avian infectious bronchitis virus in poultry vaccines by the polymerase chain reaction. In Animal Alternatives, Welfare and Ethics (ed. L.F.M. van Zutphen & M. Balls), pp. 1007–1012. Amsterdam, The Netherlands: Elsevier. Vögtlin, A., Bruckner, L., & Ottiger, H-P. (1999). Use of polymerase chain reaction (PCR) for the detection of vaccine contamination by infectious laryngotracheitis vaccine. Vaccine 17, 2501–2506. Hess, M., Raue, R., & Fafez, H.M. (1999). PCR for specific detection of haemorrhagic enteritis virus of turkeys, an avian adenovirus. Journal of Virological Methods 81, 199–203. Council of Europe (1997). Vaccines for veterinary use. In European Pharmacopoeia, 3rd edn. Strasbourg, France: Council of Europe. Council of Europe (1997). Multilateral consultation of parties to the European convention for the protection of vertebrate animals used for experimental and other scientific purposes (ETS 123). Council of Europe: Report of the meeting, Strasbourg, 30 June 1997. EEC (1986). Council Directive 86/609/EEC of 24 November 1986 on the approximation of laws, regulations and administrative provisions of the Member States regarding the protection of animals used for experimental and other scientific purposes. Official Journal of the European Communities L358, 1–29. Roberts, B. & Lucken, R.N. (1996). Reducing the use of the target animal batch safety test for veterinary vaccines. In Replacement, Reduction and Refinement of Animal Experiments in the Development and Control of Biological Products (ed. F. Brown, K. Cussler & C. Hendriksen), pp. 97–102. Basel, Switzerland: S. Karger. Weisser, K. & Hechler, U. (1997). Animal Welfare Aspects in the Quality Control of Immunobiologicals: A Critical Evaluation of Animal Tests in Pharmacopoeial Monographs , 348pp. Nottingham, UK: FRAME. Zeegers, J.J.W., de Vries, W.F. & Remie, R. (1997). Reducing the use of animals by abolishment of the safety test as a routine batch control test on veterinary vaccines. In Animal Alternatives, Welfare and Ethics (ed. L.F.M. van Zutphen & M. Balls), pp. 1003–1005. Amsterdam, The Netherlands: Elsevier. Van der Heide, L. (1989). Encephalomyelitis monograph. In Laboratory Manual for the Isolation of Avian Pathogens. American Association of Avian 254 Pathologists, 3rd edn (ed. L.H. Arp, C. Domermoth & J.E. Pearson), pp. 149–151. Dubuque, IA, USA: Kendall/Hunt Publishing Company. 32. Maas R.A., Oei, H.L., Kemper, S., Koch, G. & Visser, L. (1998). The use of homologous virus in the haemagglutination-inhibition assay after vaccination with Newcastle disease virus strain La Sota or clone 30 leads to an overestimation of protective serum antibody titers. Avian Pathology 27, 625–631. 33. Maas R.A., Oei, H.L., Venema-Kemper, S., Koch, L. Bruckner et al. G. & Bongers, J. (2000). Dose–response effects of inactivated Newcastle disease vaccines: influence of serological assay, the time after vaccination and type of chickens. Avian Disease, in press. 34. Maas, R., de Winter, M., Koch, G., Oei, H. & Bongers, J. (2000). Development of an in vitro potency test for inactivated Newcastle disease vaccines. In Proceedings of the 3rd World Congress on Alternatives and Animal Use in the Life Sciences (ed. M. Balls, A-M. van Zeller & M. Halder), in press. ECVAM Workshop 41: avian vaccines 255 Appendix 1 Sample Size Determination with Dichotomous Responses Manfred Wilhelm Biostatistics Section, Paul Ehrlich Institute, 63207 Langen, Germany Dichotomous Response A variable of interest in an animal trial that is designed to result in two categories (for example, survival/death, presence/absence of disease, positive/negative outcome) is called a dichotomous response; it can be quantified by rates and proportions. Thresholds of test procedures, as specified in monographs on avian live virus vaccines, are usually given as rates that allow the decision to be made: is the test valid and/or does the vaccine virus comply with the test? Statistical Inference In general, statistical inference is the procedure by which we reach a conclusion about a population on the basis of the information contained in a sample that has been randomly drawn from that population. Inference from a sample to a population relies on the assumption that the animals in the random sample are representative of all animals in the population. The empirical rate ∧ p∧ (0% ≤ ∧ ∧ p ≤ 100%) of positive (negative) test results in a sample of animals due to monograph procedures is an estimate of the true rate of positive (negative) test results in the population. Since ∧ p∧ is only a point estimate, we have to take into consideration its precision by calculating its confidence limits, which depend heavily on sample size. With regard to these principles of statistics, it remains unclear whether the thresholds specified in the monographs under investigation are intended to be controlled in the sample or in the population. Confidence limit and sample size Assuming a Binomial distribution, the exact two-sided lower (1 – α)% confidence limit for an observed proportion of p ≡ x/n < 100%, is given (1) by: x πlower, 1–α = x + (n – x + 1) F [1] df1 ,df2, 1 –α/2 where x = number of positive (negative) events (x < n), n = sample size, Fdf1,df2, 1–α/2 = 1 – α/2)% quantile of F distribution with df1 = 2(n – x + 1) and df2 = 2x degrees of freedom. In the case of x = n, formula [1] reduces to: n πlower, 1–α = n + F [2] 2,2n,1–α which is now the exact one-sided lower (1 – α)% confidence limit for an observed pro∧ ∧ portion of p = 100%. Based on formulae [1] and [2], Figures 1–3 illustrate the relation between the sample size and the exact two-sided and one-sided ∧ ∧ lower 95% confidence limits for p = 80%, p∧∧ = 90% and ∧ p∧ = 100% (2). In practice, determination of sample size has to be based on visual inspection of graphs such as those in Figures 1–3 or on statistical tables, as in (1). Nevertheless, after having chosen an adequate sample size n visually, we can check it by applying formulae [1] and [2]. Example of Newcastle disease B1 strain AHI (PEI project # 92.2063.3-01.100, p. 13–29) The efficacy test revealed that all of n = 22 vaccinated and challenged chicks survived ∧ ∧ and did not show any signs of disease, i.e. p = 22/22 ≅ 100%. Apparently, there is stated ∧ ∧ an empirical test threshold of p = 90%, i.e. at least x = 20 (> 0.9·22) animals have to survive without showing any signs of disease in the sample. Given the least acceptable sam∧ ∧ ple of size n = 22, i.e. p = 20/22 > 90%, from [1] and F6,40,0.975 = 2.74, , it follows that: 256 L. Bruckner et al. Figure 1: Lower 95% confidence limit for observed proportion of 80% 100 90 80 70 60 50 40 30 20 10 0 0 5 10 15 20 25 30 35 40 sample size 45 50 55 60 65 Figure 2: Lower 95% confidence limit for observed proportion of 90% 100 90 80 70 60 50 40 30 20 10 0 0 5 10 15 20 25 30 35 40 sample size 45 50 55 60 65 ECVAM Workshop 41: avian vaccines 257 Figure 3: Lower 95% confidence limit for observed proportion of 100% 100 90 80 70 60 50 40 30 20 10 0 0 5 10 15 20 25 30 35 40 sample size 45 50 55 60 65 20 πlower,0.95 = 20 + 3·2.74 = 0.708 ≅ 70.8% [3] 10 πlower,0.95 = 10 + 3.49 = 0.741 ≅ 74.1% [4] Thus, if a proportion of at least 20 out of 22 chicks (> 90%) are observed to be healthy, we can be 95% confident that the lowest possible true proportion of surviving chicks that do not show any signs of disease in the population of all vaccinated chicks is 70.8%. By using only a sample of n = 22 chicks, we cannot be 95% confident that a true 90% threshold of surviving birds which show no signs of disease does hold in the population of all vaccinated chicks! Even in the actual situation that all of n = 22 chicks were observed to be healthy, a lower 95% confidence threshold of 90% would require at least n = 29 animals in vaccine testing for efficacy, as can be seen from Figure 3. i.e. we can be 95% confident that the true proportion of surviving chicks that do not show any serious clinical respiratory signs in the population of all chicks to be vaccinated is ≥ 74.1%, or reversibly ≤ 25.9% of all chicks to be vaccinated are expected to show signs of disease and/or die. By using a sample of only n = 10 chicks, we cannot be 95% confident that a true threshold of, say, 80% of surviving chicks that show no serious clinical respiratory signs can be expected in the population of all vaccinated chicks! Again, as can be seen from Figure 3, a lower 95% confidence limit of 80% (i.e. the desired true threshold in the population) requires at least n = 14 animals in vaccine testing for safety. The safety test revealed that all of n = 10 vaccinated and challenged chicks survived and did not show any serious clinical respiratory signs, i.e. ∧ p∧ = 10/10 ≅ 100%. Due to [2] and since F2,20,0.95 = 3.49, we get: The sample size n and minimum number of required positive (negative) events x out of n to hold an exact one-sided or two-sided lower confidence limit of at least π% in the population are: Summary 258 L. Bruckner et al. π = 80 n n–x 14*–25 0 26–33 1 29*–53 0 54–69 1 34–40 2 41–47 3 48–54 4 55–61 5 π = 90 n n–x * smallest possible sample size n. Discussion The main objective in biostatistics is to make statistical inferences from a random sample (of animals) of a certain size to the underlying population (of all such animals); the statistical validity of such conclusions is guaranteed by choosing the right sample size. Since it is apparently not the primary objective of almost all monographs under investigation to do significance testing, it is not feasible to perform a sample size calculation, which is usually based on type I and II errors, the underlying variability, the relevant effect size, the kind of testing hypotheses and methods, and so forth (3, 4). The method for sample-size determination in this case, where almost no information exists, is based on confidence limits for estimated rates of interest. It is accepted that the monograph is not intended to relate statistical conclusions from safety and efficacy testing under experimental conditions (for example, artificially high dose, kind of application) to the animal populations in the field, the statistical sample size considerations presented above are not applicable in this context. A reasonable sample size based on general requirements such as relevance, cost and animal welfare should be used instead. Without any power calculations, sample sizes of n ≥ 10 are recommended as a common guideline in such situations (4). References 1. Sachs, L. (1984). Applied Statistics: A Handbook of Techniques, 2nd edn, 701pp. New York, USA: Springer. 2. Anon (1997). S-PLUS 4 Guide to Statistics. Seattle, WA, USA: Data Analysis Products Division, MathSoft, 425pp. 3. Fleiss, J. L. (1981). Statistical Methods for Rates and Proportions, 2nd edn, 321pp. New York, USA: Wiley. 4. Hothorn, L. A., Lin, K.K., Hamada, C. & Rebel, W. (1997). Recommendations for biostatistics of repeated toxicity studies. Drug Information Journal 31, 327–334.