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In genotoxicity testing of pharmaceuticals the rodent alkaline comet assay is being increasingly used as a second in vivo assay in addition to the in vivo micronucleus assay to mitigate in vitro positive results as recommended by the ICH S2(R1) guideline. This paper summarizes a survey suggested by the Safety Working Party of European Medicines Agency (EMA), and conducted by the European Federation of Pharmaceutical Industries and Associations (EFPIA) to investigate the experience among European pharmaceutical companies by conducting the in vivo comet assay for regulatory purpose. A special focus was given on the typology of the obtained results and to identify potential difficulties encountered with the interpretation of study data. The participating companies reported a total of 147 studies (conducted in-house or outsourced) and shared the conclusion on the comet assay response for 136 studies. Most of the studies were negative (118/136). Only about 10% (14/136 studies) of the comet assays showed a positive response. None of the positive comet assay results were clearly associated with organ toxicity indicating that the positive responses are not due to cytotoxic effects of the compound in the tissue examined. The number of comet assays with an equivocal or inconclusive response was rare, respectively <1% (1/147 studies) and 2% (3/147 studies). In case additional information (e.g. repeat assay, organ toxicity, metabolism, tissue exposure) would have been available for evaluation, a final conclusion could most probably have been drawn for most or all of these studies. All (46) negative in vivo comet assays submitted alongside with a negative in vivo micronucleus assay were accepted by the regulatory authorities to mitigate a positive in vitro mammalian cell assay following the current ICH S2 guidance. The survey results demonstrate the robustness of the comet assay and the regulatory acceptance of the current ICH S2 guidance., (Copyright © 2014 The Authors. Published by Elsevier B.V. All rights reserved.)

Following the initial observation that methyl methanesulphonate induced binucleated cells in the AHH-1 line and a significant number of them contained micronuclei, human lymphoblastoid TK6 and mouse lymphoma L5178Y cells were treated with methyl methanesulphonate, methylnitrosourea, mitomycin C, cytosine arabinoside, colchicine and triton X. All except triton X induced binucleated cells in both lines but an increased micronucleus incidence in them was seen only in TK6. The two lines also differed in the numbers of binucleates in the control cultures with 2.0% and 0.5% in TK6 and L5178Y, respectively, and a much higher proportion of those in TK6 contained micronuclei. The differences in behaviour between the two cell lines could not clearly be ascribed to their P53 status. Colchicine induced binucleates in both cell lines but they did not contain increased numbers of micronuclei. The effect on binucleate incidence was not a non-specific cytotoxic response because no increase was seen with triton X even at highly cytotoxic concentrations. The initial concern that not scoring micronuclei in binucleated cells might lead to erroneous results in in vitro micronucleus tests not using a cytokinesis block, was not proven because all the genotoxins tested here induced significant increases in micronucleus frequency in mononuclear cells. When testing less potently active agents in in vitro micronucleus tests not employing a cytokinesis block, care should be taken to understand better this phenomenon and not to include these damaged cells until we do., (Copyright © 2014. Published by Elsevier B.V.)

The comet assay can be applied to virtually any tissue and it has been noted that it can be particularly useful in evaluating directly acting genotoxins at their initial site of action. Consequently, it has become relatively common practice to use the stomach comet assay after oral administration to test chemicals that have given positive in vitro genotoxicity results in the absence of metabolic activation. However, to test nontoxic substances up to the limit doses of 1000/2000mg/kg formulations approaching molar concentrations must be used resulting in the stomach mucosa being exposed to excessively high levels. Evidence is beginning to accumulate which shows positive results that do not indicate that potential carcinogenicity may be associated with such high levels of exposure. For pharmaceutical agents, toxicokinetic data are usually available to demonstrate systemic exposure after oral administration. In such cases, it is proposed that exposure of any tissue to levels of the drug substance greater than those that have given positive in vitro results in the absence of metabolic activation is sufficient. However, it is recognised that toxicokinetic data are not available for all chemicals and there are also agents designed not to leave the gastrointestinal tract (GIT). Where it is necessary to examine the GIT, the dose levels selected for examination should cover the likely or intended exposure levels, not necessarily to achieve the maximum tolerated or limit doses, even if the higher doses are required for genotoxicity endpoints in other tissues to be valid. There are usually two or three dose levels in in vivo genotoxicity studies, so when both systemically exposed tissues and the stomach are being examined, it would be possible to use one of the lower doses for the latter without increasing the numbers of animals required. It is important to consider the local concentrations achieved in the stomach or other parts of the GIT in order to avoid the comet assay generating artefactual positive results and it is hoped this will be addressed in the imminent Organisation for Economic Co-operation and Development guideline.

Various methods have been used to estimate cytotoxicity in mammalian cell genotoxicity assays since their introduction more than four decades ago, and although there is no agreement on whether any single method is optimal, there is now a better appreciation of their limitations. Methods based on aspects of cellular function are inevitably inaccurate unless some estimate of cell number is included, and those using some measure of cell proliferation give different results depending on the mathematical model used. Although it would be desirable, it is not possible to provide a universal measure of cytotoxicity because the phenomenon is so complex. There is some flexibility in the limits of cytotoxicity proposed in regulatory guidelines, and it can be argued these could be even less precise. Also, to make valid comparisons of the performance of different test systems, novel or established, it would seem essential to use similar measures of cytotoxicity.