Unclassified

ENV/JM/MONO(2013)13

Organisation de Coopération et de Développement Économiques
Organisation for Economic Co-operation and Development

21-Jun-2013___________________________________________________________________________________________English - Or. English

ENVIRONMENT DIRECTORATEENV/JM/MONO(2013)13
Unclassified

JOINT MEETING OF THE CHEMICALS COMMITTEE AND
THE WORKING PARTY ON CHEMICALS, PESTICIDES AND BIOTECHNOLOGYSTREAMLINED SUMMARY DOCUMENT SUPPORTING OECD GUIDELINE 437 ON THE BOVINECORNEAL OPACITY AND PERMEABILITY FOR EYE IRRITATION/CORROSION
Series on Testing and Assessment
No. 189

English - Or. English

JT03342251
Complete document available on OLIS in its original format
This document and any map included herein are without prejudice to the status of or sovereignty over any territory, to the delimitation ofinternational frontiers and boundaries and to the name of any territory, city or area.

ENV/JM/MONO(2013)13

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ENV/JM/MONO(2013)13
OECD Environment, Health and Safety Publications
Series on Testing and Assessment

No. 189

STREAMLINED SUMMARY DOCUMENT SUPPORTING OECD GUIDELINE 437 ON THE
BOVINE CORNEAL OPACITY AND PERMEABILITY FOR EYE IRRITATION/CORROSION

Environment Directorate
ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT
Paris 2013

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ENV/JM/MONO(2013)13
ABOUT THE OECDThe Organisation for Economic Co-operation and Development (OECD) is an intergovernmentalorganisation in which representatives of 34 industrialised countries in North and South America, Europe
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This publication was developed in the IOMC context. The contents do not necessarily reflect the views orstated policies of individual IOMC Participating Organisations.
The Inter-Organisation Programme for the Sound Management of Chemicals (IOMC) was established in
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Participating Organisations are FAO, ILO, UNDP, UNEP, UNIDO, UNITAR, WHO, World Bank andOECD. The purpose of the IOMC is to promote co-ordination of the policies and activities pursued by theParticipating Organisations, jointly or separately, to achieve the sound management of chemicals in
relation to human health and the environment.

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ENV/JM/MONO(2013)13
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Also published in the Series on Testing and Assessment link
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ENV/JM/MONO(2013)13
FOREWORD

This streamlined summary document (SSD) was developed to provide summary information in
support of OECD Test Guideline 437 on the Bovine Corneal Opacity and Permeability Test Methodaddressing the endpoint eye irritation/corrosion. This SSD was developed by a Secretariat consultant
and submitted to the Working Group of the National Coordinators of the Test Guidelines Programme(WNT) in March 2013, together with the updated version of TG 437 (originally adopted in 2009). The
SSD provides useful and more detailed information than is otherwise available from the Test
Guideline itself on: 1) the scientific basis of the test method, 2) the identified limitations, weaknesses
and strengths, 3) the applicability domain, 4) the sensitivity, specificity and accuracy, and 5) thewithin- and between-laboratory reproducibility of the method.
The SSD was approved by the WNT with a few changes to paragraph 12, including additionalreferences 23, 24, 25 and 26, on 30 April 2013.
The Joint Meeting of the Chemicals Committee and the Working Party on Chemicals, Pesticides
and Biotechnology agreed to its declassification on 14 June, 2013.
This document is published under the responsibility of the Joint Meeting of the Chemicals
committee and the Working Party on Chemicals, Pesticides and Biotechnology.

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ENV/JM/MONO(2013)13
Description of applicability domain and performance based on the retrospective validation
studies of the Bovine Corneal Opacity and Permeability (BCOP) Test Method (Test Guideline437) for identifying i) chemicals inducing serious eye damage and ii) chemicals not requiringclassification for eye irritation or serious eye damage

Introduction and BackgroundThe 2003-2006 Validation Studies
1.
Between 2003 and 2006, a retrospective evaluation was carried out concerning the validation
status of the Bovine Corneal Opacity and Permeability (BCOP) test method for identifying chemicals(substances and mixtures) inducing serious eye damage (“ocular corrosives and severe irritants”), i.e.,
its usefulness and limitations for initiating a Top-Down approach (1). This evaluation, counting with a
total of 161 chemicals, was performed by the US-Interagency Coordinating Committee on the
Validation of Alternative Methods (ICCVAM) and the US-National Toxicology Program Interagency
Center for the Evaluation of Alternative Toxicological Methods (NICEATM), in collaboration with
the EU-European Centre for the Validation of Alternative Methods (ECVAM) and the JapaneseCenter for the Validation of Alternative Methods (JaCVAM). For a full description, see the
Background Review Document (BRD) (2) and the ICCVAM Test Method Evaluation Report (TMER)(3).
2.
The study aimed at characterising the reproducibility and predictive capacity of the BCOP
for the following classification systems: UN GHS (Category 1) (4), US EPA (Category I) (5) and EU
DSD (R41) (6) (the EU CLP classification system (7) based on UN GHS had not yet been adopted in
the EU at that time). On the basis of all the collected data and information the BCOP was considered
as scientifically valid (reliable and relevant) for identifying chemicals inducing serious eye damage(i.e., to initiate a Top-Down approach (1)) and was recommended for regulatory hazard classificationand labelling purposes. Chemicals inducing serious eye damage are defined as those that produce
tissue damage in the eye, or serious physical decay of vision, following application to the anterior
surface of the eye in the in vivo Draize rabbit eye test (Test Guideline 405) (8), which is not (or notexpected to be) fully reversible within 21 days of application. Following these recommendations, theOECD officially adopted the BCOP as OECD Test Guideline (TG) 437 for identifying chemicals
inducing serious eye damage in September 2009 (9).
The 2006-2009 Validation Studies
3.
Following the 2003-2006 retrospective validation study NICEATM/ICCVAM, incollaboration with ECVAM and JaCVAM, further evaluated between 2006 and 2009 the usefulness
and limitations of the BCOP test method for the additional identification of chemicals (substances andmixtures) not causing sufficient effects on the eye to require hazard classification and labelling
according to the UN GHS (4), US EPA (5), US FHSA and EU DSD (6) classification systems (the EU
CLP classification system (7) based on UN GHS had not been adopted in the EU at that time), i.e., its
usefulness and limitations for initiating a Bottom-Up approach (1).
4.
The updated BCOP validation database comprises 238 studies on 213 chemicals (107substances and 106 mixtures) (UN GHS / EU CLP: 65 Cat 1, 32 Cat 2A, 3 Cat 2B, 1 Cat 2, 6 Cat
1/Cat 2, 1 No Cat/Cat 2A, 89 No Cat, 5 SCNM, 11 without in vivo data; US EPA: 63 Cat I, 23 Cat II,
1 Cat II/Cat III, 59 Cat III, 44 Cat IV, 13 SCNM, 11 without in vivo data), collected from sevenindividual studies (Gautheron et al. 1994 (10), Balls et al. 1995 (11), Swanson et al. 1995 (12),Southee 1998 (13), Swanson and Harbell 2000 (14), Bailey et al. 2004 (15), Antimicrobial Cleaning
Products (AMCP) BRD (16)), which were used to determine the predictive capacity of the BCOP test
method (for a comprehensive list see Annex 1). Another 54 mixtures and 13 surfactant substances
reported in Casterton et al. 1996 (17), Gettings et al. 1996 (18), Swanson and Harbell 2000 (14) and in
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ENV/JM/MONO(2013)13
the AMCP BRD (16) were considered by NICEATM-ICCVAM in the retrospective validation of
BCOP, but were not used to calculate the predictive capacity of the test method due to incomplete invitro and/or in vivo data (2) (3) (19). The components of each of the mixtures tested in the BCOP test
method can be found in Annexes 2-5 (copied from reference 19).
5.
In May 2009, NICEATM/ICCVAM convened a public meeting of an independentinternational scientific peer review panel (PRP) on alternative ocular safety testing methods,
composed of members from several EU Member States, USA, Japan and Canada. The PRP wascharged with reviewing the data compiled in view of evaluating the validation status of the BCOP test
method for identifying chemicals not classified for eye irritation or serious eye damage (UN GHS No
Category; EU DSD Not Classified; US EPA Category IV). The PRP concluded that the usefulness of
the BCOP for the identification of chemicals not classified for eye irritation or serious eye damage
depended on the intended purpose (i.e., the classification system) and that the BCOP can be used forthe identification of chemicals not classified for eye irritation or serious eye damage (i.e., to initiate a
Bottom-Up approach (1)) under the UN GHS and EU DSD classification systems for which no false
negatives were identified. Since the BCOP showed 6% false negatives for the US EPA classification
system, the PRP did not recommend the BCOP for this classification system (20). The final ICCVAM
conclusions and recommendations on the use BCOP to identify chemicals not requiring classificationfor eye irritation or serious eye damage were published in a Test Method Evaluation Report (TMER),
to which, amongst other documents, a revised BRD and the PRP Report were annexed (19).
BCOP Issue Paper Supporting the Adoption of TG 437 for the Identification of Chemicals Not
Classified for Eye Irritation or Serious Eye Damage
6.
In April 2011, following the conclusions of the 2006-2009 retrospective validation study, anOECD project for updating TG 437 (9) was included in the work plan of the OECD Test Guidelines
Programme. The aim of the project was to address a possible update of TG 437 to allow its use also
for the identification of chemicals not requiring classification for eye irritation or serious eye damage
under UN GHS, EU CLP and EU DSD classification systems. An Issue Paper was prepared by aconsultant to the OECD Secretariat with the aim to review existing BCOP data and make a
recommendation on the use of TG 437 for the purpose described above (Annex 6). This document wastabled for discussion by the eye irritation/corrosion expert group at an OECD expert meeting that washeld on 6-7 December 2012. The BCOP Issue Paper reviewed the BCOP data presented in the
ICCVAM BCOP BRD (19) as well as other newly published data in connection with the use of BCOP
to identify chemicals inducing serious eye damage as well as chemicals not requiring classification foreye irritation or serious eye damage. The BCOP Issue Paper further attempted to analyse the added
value of BCOP to identify chemicals inducing serious eye damage as well as chemicals not requiringclassification for eye irritation or serious eye damage, when used together with other test methods in a
testing strategy. All information regarding the predictive capacity of BCOP included in this SSD isbased on the data reviewed in the BCOP Issue Paper and on the analysis presented in that paper.
7.
In 2013, the OECD officially adopted an updated version of TG 437 allowing the use of
BCOP for identifying chemicals inducing serious eye damage as well as for identifying chemicals not
requiring classification for eye irritation or serious eye damage.
Scientific Basis for the BCOP Test Method
8.
The BCOP test method (TG 437) is an organotypic ex vivo assay that uses living bovine
corneas isolated from the eyes of freshly slaughtered animals killed for human consumption. In thistest method, the irritation potential of a test substance is assessed by quantitative measurements ofchanges in opacity and permeability of the isolated exposed corneas, using an opacitometer and avisible light spectrophotometer, respectively (9). Both permeability and opacity are used to calculate
an in vitro irritancy score (IVIS), which is used to assign an in vitro irritancy hazard classification forprediction of the in vivo ocular irritation potential of a test substance.

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ENV/JM/MONO(2013)13
9.
The prediction model used by NICEATM/ICCVAM in their evaluations of BCOP predictive
capacity was based on the prediction model originally proposed by Gautheron et al. (1994) (10) andlater modified by Balls et al. (1995) (11) and Southee (1998) (13). This prediction model allows forthe categorisation of chemicals to four regulatory irritant categories, with cut-offs at IVIS values of 3,
25 and 55. In OECD TG 437 updated in 2013, an IIVS ≤ 3 is used to identify a chemical as not
requiring classification for eye irritation or serious eye damage (UN GHS No Category), an IVIS > 55
is used to identify a chemical as inducing serious eye damage (UN GHS Category 1), and no
prediction can be made if an 3 < IVIS ≤ 55 is obtained. Finally, it has also been recommended thatchemicals producing permeability values equal or greater than 0.6 be identified as inducing serious
eye damage (UN GHS Category 1). This may be especially important for chemicals that do not
produce appreciable opacity in the isolated bovine cornea, but that can damage the epithelium andincrease permeability, e.g., surfactant-based personal care formulations (2) (3).
Comparison of BCOP Test Method with the In Vivo Rabbit Eye Test Method
10.
In the BCOP test method, damage to the isolated cornea is assessed by measuring corneal
opacity and permeability in a short-term test that typically takes less than 8 hours to perform. The two
endpoints are measured quantitatively with an opacitometer and an ultraviolet/visible (UV/VIS)
spectrophotometer, respectively, after ten minutes exposure plus two hours post-exposure incubation
for liquid and surfactant chemicals or after four hours of exposure to solid chemicals (2).
11.
Depending on the physicochemical properties of the test substance, post-exposure
measurements may be extended to 24 hours (e.g., for chemicals with delayed responses). In contrast,
the in vivo rabbit eye test involves a qualitative visual evaluation of the severity of adverse effects on
the cornea, the iris, and the conjunctiva, as well as the reversibility of any ocular effects detected atselected intervals up to 21 days after exposure. In BCOP, liquids, semi-solids, creams and waxes areusually applied undiluted for 10 minutes, then rinsed off the cornea, followed by a 2-hour postexposure incubation of the cornea in assay medium. Neat surfactant substances are typically tested at aconcentration of 10% w/v, while mixtures containing surfactants may be tested undiluted or diluted toan appropriate concentration depending on the relevant exposure scenario in vivo. The same exposure
and post-exposure regime used for liquids is followed for surfactant substances and mixturescontaining surfactants. Solids are usually applied as a suspension or solution (20%) for four hours,
then rinsed off the cornea before opacity and permeability measurements are performed. Postexposure incubation is not required for solids. Whether the test substance is a liquid or a solid, theentire cornea is exposed for a specified duration. In the in vivo rabbit eye test, liquid and solid test
substances are applied to the conjunctival sac, usually in an undiluted form. Because the rabbit eye canblink and/or tear, exposure of the cornea to the test substance will be affected by these factors in termsof coverage or duration. The neurogenic components that drive tear film production are not present in
the BCOP. When compared with an in vivo rabbit eye study, application of a test substance in theabsence of this protective barrier might be expected to cause an increase in false positive outcomes.
One of the conclusions from a workshop on mechanisms of eye irritation highlighted the need for
additional research on the impact of chemicals on tear film and the consequences of tear film
disruption. Protective mechanisms for the eye (e.g., blinking, tear film) are built into in vivo testing,but are absent in in vitro / ex vivo testing. However, note that for some test substances (e.g., solids),
blinking can also induce mechanical damage in vivo, contributing to a higher degree of irritation.
Thus, the BCOP test method differs from the in vivo rabbit eye test method in the following significant
ways (2):•The BCOP evaluates only corneal effects and does not assess effects on the iris and the
conjunctiva as performed in the in vivo rabbit eye test. Measurements are performed
quantitatively in the BCOP assay, while they are assessed with qualitative observations in
the in vivo rabbit eye test.

•

Corneal exposure conditions, including test substance concentration and exposure duration,
are well controlled in the BCOP assay, but subject to potentially greater variation in vivo,
9ENV/JM/MONO(2013)13
due in part to the blink response and natural tearing of the eye in a live animal. Moreover, it
should be noted that solids may lead to variable and extreme exposure conditions in the invivo Draize eye irritation test, which may result in irrelevant predictions of their true
irritation potential (21).
•The observation period of the BCOP assay is typically less than 24 hours, whereas oculareffects are typically evaluated in the in vivo rabbit eye test for a minimum of 72 hours andcan extend up to 21 days.

•

Reversibility/irreversibility of corneal effects induced by a test substance cannot be observedin the BCOP assay per se, but histological evaluation of the exposed cornea may provide
additional information about the depth and type of injury that could aid predictions, as towhether damage is irreversible. It has been proposed, based on rabbit eye studies, that anassessment of the initial depth of corneal injury may be used to identify some types ofirreversible effects (22). However, further scientific knowledge is required to understandhow irreversible effects not linked with initial high level injury occur.

•

Protective mechanisms of the eye, such as tear production and blinking, are built into in vivo
testing, but are absent in in vitro / ex vivo testing.

•

The BCOP assay does not account for systemic effects following ocular instillation that may
be noted with the in vivo rabbit eye test (e.g., toxicity or lethality as in the case of certain
pesticides). However, these effects are typically predicted from other acute toxicity test
methods, and may not be relevant for the many consumer products that are formulated withwell characterized raw materials of known systemic toxicity.

Identified Limitations, Weaknesses and Strengths
12.
The potential shortcomings of the BCOP test method when used to identify chemicals
inducing serious eye damage (UN GHS Category 1) are based on the high false positive rates foralcohols and ketones and the high false negative rate for solids observed in the validation database (2)(3) (19). When substances within these chemical and physical classes are excluded from the database,the accuracy of the BCOP test method is substantially improved (2) (3) (19) (see Table 7 below).
However, since not all alcohols and ketones are over-predicted by the BCOP test method and some arecorrectly predicted as UN GHS Category 1, these two organic functional groups are not considered tobe out of the applicability domain of the test method. Positive results obtained with alcohols or
ketones should nevertheless be interpreted cautiously due to potential over-prediction. Moreover,given the fact that some solids are also correctly predicted by the BCOP test method as UN GHS
Category 1, and that all solids in the validation database that were underpredicted by BCOP showed an
3 < IVIS ≤ 55 (i.e., no prediction can be made) and would therefore need to be subsequently tested
with other suitable test method(s) in a sequential testing strategy (8) (Annex 6), this physical state isalso not considered to be out of the applicability domain of the BCOP test method. Evidence suggeststhat there is a certain probability that Cat 1 are predicted as Cat 2 due to the variability of individual
animal responses within the same test (23). Although not based on the same dataset, the resulting
probability seems to be in the same range as the BCOP/ICE under-prediction rate for identifying UN
GHS Category 1. However, variability between laboratories can further contribute to the variability ofin vivo responses (24)(25)(26). Quantitative estimates for such uncertainties, both for the in vivo tests
and for their in vitro alternatives, should be considered in the future development of testing strategies
for serious eye damage/eye irritation.
13.
When used to identify chemicals not requiring classification for eye irritation or serious eye
damage under the UN GHS classification system, the BCOP test method has a considerably high false
positive rate (in vivo UN GHS No Category chemicals producing an IVIS > 3) (19). This is however
not considered critical since all test substances that produce an 3 < IVIS ≤ 55 (i.e., no prediction canbe made) would need to be subsequently tested with other suitable test method(s) in a sequential
10ENV/JM/MONO(2013)13
testing strategy. The BCOP test method shows no specific shortcomings for the testing of alcohols,
ketones and solids when the purpose is to identify chemicals that do not require classification for eye
irritation or serious eye damage (UN GHS No Category) (see Table 8 below).
14.
Another limitation of the test method is that, although it takes into account some of theocular effects evaluated in the in vivo test method and to some degree their severity, it does notconsider conjunctival and iridal injuries. Nevertheless, the BCOP directly addresses corneal effects,
which are the major driver of classification in vivo when considering the UN GHS classification
system (Annex 6). Also, although the reversibility of corneal lesions cannot be evaluated per se in the
BCOP test method, it has been proposed, based on rabbit eye studies, that an assessment of the initial
depth of corneal injury (e.g., through histological evaluation) may be used to identify some types ofirreversible effects (22). However, further scientific knowledge is required to understand how
irreversible effects not linked with initial high level injury occur. Finally, the BCOP does not allow for
an assessment of the potential for systemic toxicity associated with ocular exposure.
15.
The BCOP test method is not recommended for the identification of test substances thatshould be classified as irritating to eyes (UN GHS Category 2 or Category 2A) or test substances thatshould be classified as mildly irritating to eyes (UN GHS Category 2B) due to the considerable
number of UN GHS Category 1 chemicals underclassified as UN GHS Category 2, 2A or 2B and UN
GHS No Category chemicals overclassifed as UN GHS Category 2, 2A or 2B (19). For this purpose,
further testing with another suitable method may be required.

Table 1: Physicochemical properties and compatibility with the BCOP
Is a material with this property
compatible with the BCOP
assay?

Physicochemical property
Fixative

Unknown

Solvent

Yes

Extreme pH

Yes

Gases

No

Liquids

Yes

Solid materials

Yes

Emulsions

Yes

Granular materials

No

Suspensions

Yes

Coloured materials

Yes

Diluted concentrations of chemicals

Yes

Highly viscous materials

Yes

Volatile materials

Yes

Reactive chemistries

Yes1

Hydrophobic/lipophilic chemicals

Yes

Neat concentrations of chemicals

Yes

1

Reactive chemistries may require the use of extended post-treatment incubations, up to 24 hours,
prior to the opacity and permeability endpoints for expression of effects. Histopathology is highly
recommended for such studies.
11ENV/JM/MONO(2013)13
Applicability Domain
16.
The Test Guideline can be used for testing all types of substances and mixtures, including
those outside the chemical classes defined by the chemicals used in the validation study, provided
there is no evidence that the method is not valid for the chemical tested.
Categories of Irritancy
17.
Based on the conclusions of the 2003-2006 and 2006-2009 retrospective validation studies(3) (19), TG 437 was approved for classification of chemicals inducing serious eye damage (UN GHS
Category 1) (in 2009), as well as for the identification of chemicals not requiring classification for eye
irritation or serious eye damage (UN GHS No Category), under the UN GHS classification system, in2013.
Potential Role in an ITS
18.
The BCOP can be used as a validated ex vivo test method in a tiered testing approach asrecommended in the supplement to TG 405 (8) with the purpose of identifying chemicals inducing
serious eye damage (UN GHS Category 1), as well as chemicals not requiring classification for eye
irritation or serious eye damage (UN GHS No Category) (Annex 6). Due to its low specificity whenused to identify chemicals not requiring classification for eye irritation or serious eye damage, theBCOP should not be the first choice to initiate a Bottom-Up approach (1), if other validated andaccepted in vitro methods with similar high sensitivity but higher specificity are available.
19.
Two studies have looked at the combination of BCOP with other in vitro test methods intesting strategies for the prediction of ocular hazards. Kolle et al. (2011) (27) combined BCOP with
EpiOcularTM EIT (the latter can only be used to identify UN GHS No Category) in a two-tier Bottomup/Top-Down test strategy and Hayashi et al. (2012) (28) combined BCOP with EpiOcularTM EIT, theShort Time Exposure (STE)1 test method and the Hen’s Egg Test - Chorioallantoic Membrane (HETCAM)2 in a two-stage Bottom-Up tiered approach. In the data published by Kolle et al. (2011), it canbe seen that chemical 10/0229-1, a UN GHS No Category (“non-irritant”) solid organophosphate, isoverpredicted by EpiOcularTM EIT but correctly predicted by BCOP. By using BCOP to identify both
UN GHS Category 1 and UN GHS No Category chemicals, this chemical can be correctly identified
as “non-irritant” using either a Bottom-Up testing strategy (EpiOcularTM EIT first followed by BCOP)
or a Top-Down testing strategy (BCOP first followed by EpiOcularTM EIT) (Annex 6) (27). Hayashi etal. tested 26 UN GHS No Category chemicals from the BCOP validation database in EpiOcularTM
EIT, STE and HET-CAM. Of these, 13 were overpredicted as irritant by EpiOcularTM EIT (50% false
positives). Two of the 13 EpiOcularTM EIT false positives (EDTA di-potassium salt, CAS # 25102-129; triethanolamine, CAS # 102-71-6) are correctly identified by BCOP as not requiring hazard
classification and labelling (UN GHS No Category). HET-CAM also correctly identifies two other1

The STE has undergone a full validation study in Japan, coordinated by JaCVAM, and an international peerreview of the study is currently being organised by ICCVAM. The STE was also submitted by Japanto the OECD for the development of a new Test Guideline, and was included in the OECD work planfor the Test Guidelines Programme in 2011.

2

The HET-CAM was evaluated by ICCVAM together with BCOP and ICE in the retrospective validation studiesof 2003-2006 (3) and 2006-2009 (19). ICCVAM considered that the HET-CAM might be useful for
identifying chemicals not requiring hazard classification and labeling for eye irritation but did notrecommend the test method due to lack of data in the mild/moderate irritancy range. ICCVAM
recommended that additional data be collected on mild and moderate irritants to more adequately
characterise the usefulness of HET-CAM. Following this recommendation, an international workshop
on HET-CAM was recently held at the BfR in Berlin to help advance regulatory acceptance of the test
method.

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ENV/JM/MONO(2013)13
EpiOcularTM EIT false positives as “non-irritant” (1-nitropropane, CAS # 108-03-2; 1-phenyl-3pyrazolidinone, CAS # 92-43-3), but in this case at the expense of 1 UN GHS Category 2A chemical
being underclassified as No Category (4-carboxybenzaldehyde, CAS # 619-66-9). However, if a TopDown approach would be used to test this chemical, starting with BCOP, it would be overclassified as
UN GHS Category 1 instead of underclassified as UN GHS No Category. Finally, STE correctly
identified 8 of 10 EpiOcularTM EIT false positives tested as “non-irritant” (including both chemicals
correctly identified by BCOP but not those identified by HET-CAM), but at the same it underpredicted
3 UN GHS Category 2A and 1 Category 2B as “non-irritants”. If a Top-Down approach would be used
to test these four chemicals, starting with BCOP, two of them (ethanol, CAS # 64-17-5, andisopropanol, CAS # 67-63-0) would be overclassified as UN GHS Category 1 but the other two(methyl acetate, CAS # 79-20-9; ammonium nitrate, 6484-52-2) would still be underclassified as UN
GHS No Category since for these, BCOP produced an IVIS between 3 and 55 (i.e., no prediction canbe made) (24). Methyl acetate produced a mean IVIS of 54.9 in the EC-HO validation study, which isborderline for the cut-off of 55 used to identify UN GHS Category 1. In fact, the same chemical was
predicted as UN GHS Cat 1 by BCOP at BASF with an IVIS of 58.1 (27). By using BCOP to identify
both UN GHS Category 1 and UN GHS No Category chemicals in combination with EpiOcularTM
EIT, the false positive rate for chemicals not requiring classification for eye irritation or serious eye
damage would be reduced by 7.7%, from 13/26 (50%) to 11/26 (42.3%). If HET-CAM is further
integrated in the strategy, the false positive rate would be further reduced to 34.6% (9/26). If STE
would also be integrated in the test strategy despite its higher false negative rate, the false positive ratewould decrease to only 11.5% (3/26) (Annex 6) (28).
Mode of Action (MoA)20.
An Expert meeting held at EC-ECVAM in 2005 (1) recommended to expand the concept ofdefining the applicability domain as not only chemical classes, but also as a function of the mechanismof eye irritation. The four identified MoA that were discussed included: (i) cell membrane lysis(breakdown of membrane integrity as might occur from exposure to membrane active materials, e.g.,surfactants), (ii) saponification (breakdown of lipids by alkaline action), (iii) coagulation(precipitation/denaturation of macromolecules, particularly protein, characteristic of acid, alkali, ororganic solvent exposure), and (iv) actions on macromolecules (chemicals that react with cellularconstituents/organelles that may or may not lead to overt lysis or coagulation, e.g., alkylation,oxidative attack on macromolecules such as essential proteins or nucleic acids). The BCOP test
method addresses the three first MoAs. In addition, it may also address the fourth MoA (actions on
macromolecules) when histopathological information is available.

13ENV/JM/MONO(2013)13
Table 2: Summary of events involved in chemical-induced eye irritation in vivo (text in italics
represents irreversible responses) with information on whether they are modelled by the BCOP test
method or not.
Modelled by the
Events involved in chemical-induced eye irritation
BCOP assay?
Chemical interaction with tear film

No

Chemical binding to the conjunctival epitheliumNo

Adhesion molecules compromised

Yes

Corneal epithelial damage

Yes

Inhibition of receptor-mediated transport

Unknown

Compromise of cell membrane integrity of upper corneal epithelium

Yes

Cell membrane lysis of all corneal epithelial layers

Yes

Hydration of corneal stroma

Yes

Cross-linking of proteins in corneal stroma

Yes

Erosion of corneal stroma

Yes

Cell damage to corneal epithelium and limbus
Dilation and increased lymphatic leakage from scleral vasculature

Yes (corneal
epithelium);
No (limbus)
No

Stimulation of nerve endings, i.e., enhanced blinking, tearing

No

Erosion of nerve endings in corneal and sclera

No

Duration of the response, i.e., length of time cell responses deteriorate.
Duration of response covers the effects of reactive chemicals, which cancause coagulation, saponification, that are effects, which develop andincrease over time.

No1

Recovery from response, i.e., length of time for cell responses to return tocontrol levels

No

1

In OECD TG 437, a time course is not specified. However, a time course for exposures, as well as atime course for post-exposure expression of changes, up to 24 hours, can be designed into the assay.
Chemical Classes
21.
A total of 213 individual chemicals (107 substances and 106 mixtures) were evaluated in the
2006-2009 test method evaluation (19), including representatives from a number of chemical andproduct classes that have been evaluated using in vivo rabbit eye data. Chemicals with a wide range ofindividual responses have been evaluated. Test data were collected from Gautheron et al. (1994) (10),Balls et al. (1995) (11), Swanson et al. (1995) (12), Southee (1998) (13), Swanson and Harbell (2000)(14), Bailey et al. (2004) (15) and the AMCP BRD (16) (Annex 1). The ICCVAM PRP (20)concluded that “the chemical database appeared adequate, however, additional chemicals in certain
chemical classes will provide a more robust statistical inference as these data become available”,
however, the PRP did not specifically identify any chemicals or product classes as being of special
concern. For a complete list of chemical and product classes see Annex 1. The components of each of
the mixtures tested in the BCOP test method can be found in Annexes 2-5 (copied from reference 19).
22.
Tables 3 and 4 show the chemical and product classes for the chemicals included in the
BCOP validation database. Information, including chemical name, Chemical Abstracts Service
14ENV/JM/MONO(2013)13
Registry Number (CASRN), chemical and/or product class, concentration(s) tested, purity, supplier orsource, and literature reference using the chemical are provided in Annex 1.
Table 3: Chemical classes tested in the BCOP test method.
Chemical Class
Acyl halide
Alcohol
Aldehyde
Alkali
Aluminum compound
Amide
AmidineAmine
Amino acid
Boron compound
Carboxylic acid
Ester
Ether/Polyether
Formulation
Heterocyclic compound
Hydrocarbon# of Chemicals
3
22
1
3
1
2
6
10
4
1
17
12
9
69
12
18

Chemical Class
Imide
Inorganic salt
KetoneLactoneNitrile compound
Nitro compound
Oil
Onium compound
Organic salt
Organic sulfur compound
Organophosphate
Organosilicon compound
PhenolPolycyclic compound
TerpeneWax# of Chemicals
2
6
12
3
1
2
1
12
3
5
1
1
1
3
1
1

Table 4: Product classes tested in the BCOP test method.
Product Class# of Chemicals

Product Class# of Chemicals

Adhesive
Agricultural chemical
Antifreeze agent
Antimicrobial
cleaning
product
Bactericide/Fungicide/
Disinfectant/Germicide
Beverage
BleachChelating agent

1
2
1
66

Fertilizer
Flame retardant
Flavor ingredient
Food additive

1
1
3
1

11

Herbicide

3

1
3
2

8
6
1

Chemical/synthetic
intermediate
Cleaner
Cleanser (personal care)28

Insect repellant
Lubricant/lubricant additive
Paint,
lacquer,varnish(component)
Pesticide
Petroleum productPhotographic
chemical/developing agent
Plant growth regulator
Plasticizer
Preservative
Reagent
Shampoo (hair)
Soap

16
2

Coupling agent
Cutting fluid
Degreaser
DessicantDetergentDrug/Pharmaceutical/
Therapeutic agent and/or
metabolite

15
13
1
2
1
1
11
17

15

8

2
4
2
5
14
3

ENV/JM/MONO(2013)13
Dry cleaning preparation
Dye, in manufacture ofEmulsifier
Etching and/or electroplating
Explosive
Fabric softener

1
3
1
2
1
1

Solvent
Surfactant
Anionic surfactant
Cationic surfactant
Nonionic surfactant
Thermometer fluid

34
39
3
6
5
1

Sensitivity, Specificity and Accuracy:
23.
The updated BCOP validation database contains a total of 213 chemical, most of which had
sufficient in vivo data to be assigned an ocular irritancy classification according to the UN GHS
classification system (4), sufficient for the calculation of accuracy to identify UN GHS Category 1(Top-Down) (191 chemicals: 65 Cat 1, 32 Cat 2A, 3 Cat 2B, 1 Cat 2, 1 No Cat/Cat 2A and 89 No Cat)or UN GHS No Category (Bottom-Up) (196 chemicals: 65 Cat 1, 32 Cat 2A, 3 Cat 2B, 1 Cat 2, 6 Cat
1/Cat 2 and 89 No Cat). The difference in the number of chemicals used in the two calculations (191vs. 196) derives from (i) the use of 1 chemical (Tetraaminopyrimidine sulphate) that has two in vivo
studies, one indicating UN GHS No Category (ECETOC) and the other UN GHS Category 2A(Gautheron et al. 1996 (10)), for the Top-Down calculations but not for the Bottom-Up calculations;and (ii) the use of 6 chemicals with in vivo Study Criteria Not Met (SCNM), but for which one can becertain they are either UN GHS Category 2 or UN GHS Category 1, for the Bottom-Up calculations
but not for the Top-Down calculations (see Annex 1). In order to calculate the appropriate ocular
irritancy hazard classification, detailed in vivo data consisting of cornea, iris, and conjunctiva scoresfor each animal at 24, 48, and 72 hours following test substance administration and/or assessment of
the presence or absence of lesions at 7, 14, and 21 days were evaluated. Some of the test substances
had insufficient in vivo data to assign a hazard classification (16 chemicals: 5 with study criteria notmet, 11 without in vivo data). These chemicals were therefore not used to evaluate test method
accuracy.

16

ENV/JM/MONO(2013)13
Table 5: False positive and false negative rates of the BCOP test method, by chemical class andproperties of interest, for the UN GHS1 classification system for distinguishing chemicals (substancesand mixtures) inducing serious eye damage (UN GHS Category 1) from all other categories.
False Positive Rate
False Negative Rate
Category
N2
3
%
No.
%
No.3
Overall
191
25
32/12614
9/65
4Chemical Class
Alcohol
17
50
7/14
67
2/3
Amine/Amidine
7
0
0/4
0
0/3
Carboxylic acid
14
37
3/8
33
2/6
Ester
10
12
1/8
0
0/2
Ether/Polyether
6
40
2/5
0
0/1
Heterocycle
13
14
1/7
17
1/6
Hydrocarbon
11
9
1/11
0/0
Inorganic salt
7
0
0/3
0
0/4
Ketone944
4/90/0
Onium compound
11
0
0/3
12
1/8
Properties of Interest
Liquids5
150
26
27/1028
4/48
5
Solids
33
15
3/20
38
5/13
Pesticide
8
66
2/3
40
2/5
Surfactant – Total6
75
17
6/35
7
3/40
-nonionic
25
21
3/14
9
1/11
-anionic
22
0
0/12
10
1/10
-cationic
7
0
0/1
0
0/6
7
pH – Total
34
21
4/19
13
2/15
- acidic (pH < 7.0)
13
27
3/11
0
0/2
- basic (pH > 7.0)
16
0
0/3
15
2/13
- equals 7
3
33
1/3
0/0
8
Category 1 Subgroup 17
9/52
Total
529
25
16
4/25
- 4 (CO=4 at any time)10
0/1- 3 (severity/persistence)
333
1/3- 2 (severity)
10
29
17
5/29
- 2-4 combined
23
17
4/23
- 1 (persistence)
1
GHS = Globally Harmonized System (UN 2011) (4).
2N = Number of chemicals.
3
Data used to calculate the percentage.
4
Chemical classes included in this table are represented by at least five substances tested in the BCOP
test method and assignments are based on the MeSH categories (www.nlm.nih.gov/mesh).
5
Physical form (i.e., solid or liquid) not known for some chemicals, and therefore the overall number
does not equal the sum of the solid and liquid chemicals.
6
Combines single substances labelled as surfactants along with surfactant-containing mixtures.
7
Total number of chemicals for which pH information was obtained.
8
NICEATM-defined subgroups assigned based on the lesions that drove classification of a UN GHS
Category 1 chemical. 1: based on lesions that are persistent; 2: based on lesions that are severe (not17ENV/JM/MONO(2013)13
including Corneal Opacity [CO]=4); 3: based on lesions that are severe (not including CO=4) andpersistent; 4: CO = 4 at any time.
9
The number of chemicals evaluated in the Category 1 subgroup analysis may be less than the total
number of in vivo Category 1 chemicals evaluated, since some chemicals could not be classified into
the subgroups used in the evaluation.
10
Subcategories 2 to 4 combined to allow for a direct comparison of UN GHS Category 1 chemicals
classified in vivo based on some lesion severity component and those classified based on persistentlesions alone.

18

ENV/JM/MONO(2013)13
Table 6: False positive and false negative rates of the BCOP test method, by chemical class andproperties of interest, for the UN GHS1 classification system for distinguishing chemicals (substancesand mixtures) not requiring classification for eye irritation or serious eye damage (UN GHS No
Category) from all other irritant categories.
False Positive Rate
False Negative Rate
Category
N2
%
No.3
%
No.3
Overall

196

69

61/89

0

0/107

Alcohol

17

0

3/7

0

0/10

Amine/Amidine

7

25

1/4

0

0/3

Carboxylic acid

14

83

5/6

0

0/8

Ester

10

75

3/4

0

0/6

Ether/Polyether

6

25

1/4

0

0/2

Heterocycle

13

67

4/6

0

0/7

Hydrocarbon

11

73

8/11

-

0/0

Inorganic salt

7

50

1/2

0

0/5

Ketone

9

67

4/6

0

0/3

Onium compound

11

100

2/2

0

0/9

Liquids5

154

75

54/72

0

0/82

Solids5

34

38

6/16

0

0/18

Pesticide

8

100

2/2

0

0/6

Surfactant – Total6

75

80

24/30

0

0/45

-nonionic

25

69

9/13

0

0/12

-anionic

23

82

9/11

0

0/12

-cationic

7

100

1/1

0

0/6

pH – Total7

34

78

7/9

0

0/25

- acidic (pH < 7.0)

13

75

3/4

0

0/9

- basic (pH > 7.0)

16

100

3/3

0

0/13

- equals 7

3

-

0/0

0

0/3

Chemical Class4

Properties of Interest

1

GHS = Globally Harmonized System (UN 2011) (4).
19

ENV/JM/MONO(2013)13
2

N = Number of chemicals.
Data used to calculate the percentage.
4
Chemical classes included in this table are represented by at least five substances tested in the BCOP
test method and assignments are based on the MeSH categories (www.nlm.nih.gov/mesh).
5
Physical form (i.e., solid or liquid) not known for some chemicals, and therefore the overall number
does not equal the sum of the solid and liquid chemicals.
6
Combines single substances labelled as surfactants along with surfactant-containing mixtures.
7
Total number of chemicals for which pH information was obtained.
3

Overall Predictive Capacity
Table 7: Predictive capacity of the BCOP test method for distinguishing chemicals (substances andmixtures) inducing serious eye damage from all other categories, as defined by the UN GHS
classification system1 (based on Table 2 in the BCOP Issue Paper; Annex 6).
ChemicalsNo.

Accuracy

Sensitivity

False
Negatives

Specificity

False
Positives

%

No.

%

No.

%

No.

%

No.

%

No.

All

191

79

150/191

86

56/65

14

9/65

75

94/12625

32/126

Substance
s

100

73

73/100

77

20/26

23

6/26

72

53/74

28

21/74

Mixtures

91

85

77/91

92

36/39

8

3/39

79

41/52

21

11/52

All
without
alcohols,
ketonesand solids

131

85

111/131

92

46/50

8

4/50

80

65/81

20

16/81

Substances withoutalcohols,
ketonesand solids

42

83

35/42

83

10/12

17

2/12

83

25/30

17

5/30

Mixtureswithout
alcohols,
ketonesand solids

89

85

76/89

95

36/38

5

2/38

78

40/51

22

11/51

Abbreviations: No. = data used to calculate the percentage.
1
UN GHS classification system (UN 2011) (4): Category 1 vs. No Category/Category 2A/2B.

20

ENV/JM/MONO(2013)13

Table 8: Predictive capacity of the BCOP test method for distinguishing chemicals (substances andmixtures) not requiring classification for eye irritation or serious eye damage from all other irritantcategories, as defined by the UN GHS classification system1 (based on Table 3 in the BCOP Issue
Paper; Annex 6).
ChemicalsNo.

Accuracy

Sensitivity

False
Negatives

Specificity

False
Positives

%

No.

%

No.

%

No.

%

No.

%

No.

All

196

69

135/196100

107/107

0

0/107

31

28/89

69

61/89

Substance
s

104

72

75/104

100

55/55

0

0/55

41

20/49

59

29/49

Mixtures

92

65

60/92

100

52/52

0

0/52

20

8/40

80

32/40

All
without
alcohols,
ketonesand solids

135

64

87/135

100

75/75

0

0/75

20

12/60

80

48/60

Substances withoutalcohols,
ketonesand solids

45

64

29/45

100

24/24

0

0/24

24

5/21

76

16/21

Mixtureswithout
alcohols,
ketonesand solids

90

64

58/90

100

51/51

0

0/51

18

7/39

82

32/39

Abbreviations: No. = data used to calculate the percentage.
1
UN GHS classification system (UN 2011) (4): No Category vs. Category 1/2A/2B.

Within- and Between-Laboratory Reproducibility:
24.
A thorough evaluation of the BCOP reliability was conducted in the 2003-2006 retrospective
validation study concerning the use of BCOP for identifying chemicals inducing serious eye damage(2) (3). This evaluation showed a median coefficient of variation (CV) for IVIS for replicate corneas(n=3) within individual experiments ranging from 11.8% to 14.2% in one study, and mean and median
CV values for IVIS for replicate corneas (n=4) within individual experiments of 71% and 35%,
respectively, in a second study. The between experiment mean CV values of IVIS for 16 chemicals
tested two or more times in three laboratories ranged from 12.6% to 14.8%, while the median CV
values ranged from 6.7% to 12.4%.
25.
Additional analyses of between-laboratory reproducibility were also conducted in the second
retrospective validation study (2006-2009) to evaluate the extent of agreement of BCOP hazard
21

ENV/JM/MONO(2013)13
classifications among the laboratories that participated in three different inter-laboratory validation
studies (10) (11) (13) (19). These analyses showed nearly 100% agreement of classification among thedifferent laboratories in each study, confirming the results that had been obtained in the firstevaluation. The extent of agreement was 100% when distinguishing chemicals inducing serious eye
damage from all other ocular hazard categories for 72% (91/127) of the chemicals according to the UN
GHS classification system. When distinguishing chemicals not requiring classification for eye
irritation or serious eye damage from all other ocular hazard categories, the extent of agreement was
100% for 80% (103/128) of the chemicals according to the UN GHS classification system (19).
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