Comment submitted by S. D. Pesel

As a concerned citizen and member of the legal community, I urge your agency to reconsider its directive and take the following course of action: ? Reevaluate the data needs identified by ATSDR. ATSDR has already admitted that accidental oral exposure to chloroethane in doses large enough to result in death is highly unlikely. Hence, why must more tests in which animals are force- fed chloroethane through a tube inserted into their stomachs be conducted? Extensive inhalation data already exists. ? Use physiologically based pharmacokinetic (PBPK) models to fill ATSDR's data needs by extrapolating from existing data. These sophisticated mathematical models already exist for chloroethane and methylene chloride. This approach would be economical and humane. ? Accept test protocols that reduce the number of animals used by eliminating duplication and combining multiple tests. Using internationally accepted combination tests can drastically reduce the number of animals killed. Clearly alternatives exist ? surely in this day and age ? such cruel testing and killing is unnecessary. Please consider public opinion on this matter and/or please consider using humane alternatives?tests not involving animals?for testing.