Comment submitted by Ted W. Simon

Summary: Dr. Ted W. Simon, an academic researcher, supports the EPA's goal of reducing animal testing by proposing the use of the Threshold of Toxicological Concern (TTC) as a cost-effective screening step prior to the EPA Transcriptomic Assessment Product (ETAP). He argues that TTC provides a significantly higher return on investment and lower cost of delay compared to ETAP and traditional animal testing.