ICCVAM Evaluations of the Murine Local Lymph Node Assay (LLNA)
Guidance finalized in June 2023 stated that FDA no longer recommends that sponsors conduct the LLNA to assess the sensitization potential of topical drug products due to the limitations of the assay. FDA will consider a battery of in silico, in chemico, and in vitro studies that have been shown to adequately predict human skin sensitization with an accuracy similar to existing in vivo methods.
ICCVAM Evaluation of the LLNA
ICCVAM evaluated the LLNA in 1998 and recommended it as an alternative to guinea pig tests for assessing the potential for chemicals to cause allergic contact dermatitis (ACD). Compared to guinea pig methods originally used to identify skin sensitizers, the LLNA:
- Reduces the number of animals required for testing
- Requires less time to perform
- Provides dose-response information
- Eliminates the pain and distress associated with an allergic response in animals
Materials from the 1998 LLNA Evaluation
Peer Review Report
The Murine Local Lymph Node Assay: A Test Method for Assessing the Allergic Contact Dermatitis Potential of Chemicals/Compounds
The Results of an Independent Peer Review Evaluation Coordinated by the Interagency Coordinating Committee on the Validation of Alternative Methods (ICCVAM) and the National Toxicology Program Center for the Evaluation of Alternative Toxicological Methods (NICEATM)
February 1999 — NIH Publication No. 99-4494
Summary Minutes of the September 1998 Peer Panel Meeting
Letter from Dr. Kenneth Olden, Director, NIEHS, to Ms. Carol Browner, Administrator, U.S. EPA, transmitting results of the independent peer review evaluation of the LLNA (sent February 16, 1999)
Response from Dr. Steven Galson, EPA, on behalf of Ms. Browner (received October 19, 1999)
NICEATM LLNA Data Compilations
On behalf of ICCVAM, NICEATM conducted analyses to evaluate the usefulness of the LLNA to identify potential skin sensitizers. Data from these analyses are available as a reference for developing and evaluating approaches to testing and assessment that replace, reduce, or refine the use of animals for identification of potential skin sensitizers.
The Integrated Chemical Environment (ICE) has LLNA data compiled by NICEATM from literature reports and from sponsor submissions of toxicity data to EPA for pesticide registrations. Data can be explored using the ICE tools or downloaded as an Excel file from the ICE Data Sets page.
A more focused database of LLNA data was compiled by NICEATM during their evaluations of the LLNA on behalf of ICCVAM. Users of these database should note:
- The Excel spreadsheet contains three pages: (1) data, (2) references, and (3) abbreviations.
- The database includes data published through 2010.
These data have been extracted from published and unpublished data sources with permission. Users of this database should consult the original data source for questions regarding data quality and/or authenticity.
ICCVAM Evaluation of New Versions and Applications of the LLNA
In response to a 2007 nomination from CPSC, ICCVAM evaluated several other versions of the LLNA that reduce animal use and eliminate the need to use radioactive materials. ICCVAM also recommended the use of the LLNA for testing a wider range of chemicals.
References Relevant to the 2007 LLNA Nomination to ICCVAM
Use of the LLNA for Potency Categorization
ICCVAM evaluated the use of the LLNA for potency categorization for chemicals that cause ACD in humans. ICCVAM concluded that the LLNA can be used to categorize substances as strong skin sensitizers (GHS Subcategory 1A). However, substances that are not identified as strong sensitizers using the LLNA require additional information to categorize them as other than strong sensitizers (GHS Subcategory 1B).
ICCVAM Test Method Evaluation Report: Usefulness and Limitations of the Murine Local Lymph Node Assay for Potency Categorization of Chemicals Causing Allergic Contact Dermatitis in Humans
NIH Publication 11-7709
Transmittal to Federal Agencies of ICCVAM Recommendations for Use of the LLNA for Potency Categorization
- National Institute of Environmental Health Sciences (NIEHS)
- Letter from Linda Birnbaum, Ph.D., DABT, ATS, Director, NIEHS, to the ICCVAM Committee (August 5, 2011)
- Agency for Toxic Substances and Disease Registry (ATSDR)
- Letter from Dr. Birnbaum to Thomas R. Frieden, M.D., M.P.H., Director, Centers for Disease Control, and Administrator, ATSDR
- Response from Christopher J. Portier, Ph.D., Director, National Center for Environmental Health and ATSDR (received January 5, 2012
- Consumer Product Safety Commission (CPSC)
- Letter from Dr. Birnbaum to Inez Moore Tenenbaum, Chairman, CPSC
- Response from Todd Stevenson, Office of the Secretary (received February 7, 2012)
- Environmental Protection Agency (EPA)
- Letter from Dr. Birnbaum to Lisa P. Jackson, Administrator, EPA
- Response from John Fowle, Ph.D., DABT, Office of Pesticide Programs (received January 6, 2012)
- Food and Drug Administration (FDA)
- Letter from Dr. Birnbaum to Margaret Hamburg, M.D., Commissioner
- Response from Jesse L. Goodman, M.D., M.P.H. , Chief Scientist and Deputy Commissioner (Acting) for Science and Public Health (received January 6, 2012)
- National Cancer Institute (NCI)
- Letter from Dr. Birnbaum to Harold Varmus, M.D., Director, NCI
- Response from Dr. Varmus (received July 15, 2011)
- National Institutes of Health (NIH)
- Letter from Dr. Birnbaum to Francis S. Collins, M.D., Ph.D., Director, NIH
- Response from Dr. Collins (received December 12, 2011)
- National Institute for Occupational Safety and Health (NIOSH)
- Letter from Dr. Birnbaum to John Howard, M.D., Director, NIOSH
- Response from Dr. Howard (received November 8, 2011)
- National Library of Medicine (NLM)
- Letter from Dr. Birnbaum to Donald A.B. Lindberg, M.D., Director, NLM
- Response from Dr. Lindberg (received December 15, 2011)
- Occupational Safety and Health Administration (OSHA)
- Letter from Dr. Birnbaum to David Michaels, Ph.D., M.P.H., Assistant Secretary of Labor for Occupational Safety and Health, OSHA
- Response from Dr. Michaels (received December 13, 2011)
- U.S. Department of Agriculture
- Letter from Dr. Birnbaum to Tom Vilsack, Secretary of Agriculture
- Response from Jose Diez, Associate Deputy Administrator, Animal and Plant Health Inspection Service (received July 18, 2011)
- U.S. Department of Defense
- Letter from Dr. Birnbaum to Leon E. Panetta, Secretary of Defense
- Response from Patrick Mason, Ph.D., SES, Director, Human Performance, Training, and BioSystems (received December 16, 2011)
- U.S. Department of Energy
- Letter from Dr. Birnbaum to Steven Chu, Secretary of Energy
- Response from Dr. Michael Kuperberg, Office of Biological and Environmental Research (received October 31, 2011)
- U.S. Department of the Interior
- Letter from Dr. Birnbaum to Ken Salazar, Secretary of the Interior
- Response from David Russ, Regional Executive, Northeast Area, U.S. Geological Survey (received January 10, 2012)
- U.S. Department of Transportation
- Letter from Dr. Birnbaum to Ray LaHood, Secretary of Transportation
- Response from Cynthia Quarterman, Pipeline and Hazardous Materials Safety Administration (received December 20, 2011)
Nonradioactive Versions of the Murine Local Lymph Node Assay
ICCVAM made recommendations to federal agencies on the use of two nonradioactive versions of the LLNA. The availability of nonradioactive LLNA methods allows more institutions to take advantage of the animal welfare benefits of the LLNA.
ICCVAM Test Method Evaluation Report on the Murine Local Lymph Node Assay: BrdU-ELISA
A Nonradioactive Alternative Test Method to Assess the Allergic Contact Dermatitis Potential of Chemicals and Products
NIH Publication No. 10-7552
ICCVAM Test Method Evaluation Report on the Murine Local Lymph Node Assay: DA
A Nonradioactive Alternative Test Method to Assess the Allergic Contact Dermatitis Potential of Chemicals and Products
NIH Publication No. 10-7551
International Acceptance of the LLNA: DA and LLNA: BrdU-ELISA
NICEATM and ICCVAM, in conjunction with JaCVAM, drafted test guidelines for use of the LLNA: DA and LLNA: BrdU-ELISA and submitted them to the OECD Test Guidelines Programme. The new test guidelines, designated Test Guidelines 442A (LLNA: DA) and 442B (LLNA: BrdU-ELISA), were adopted by OECD in July 2010.
OECD Test Guideline 442A — Skin Sensitization: Murine Local Lymph Node Assay: DA
OECD Test Guideline 442B — Skin Sensitization: Murine Local Lymph Node Assay: BrdU-ELISA
Transmittal to Federal Agencies of ICCVAM Recommendations for Use of Nonradioactive Versions of the LLNA
The ICCVAM recommendations on the use of nonradioactive versions of the LLNA were communicated to Federal agencies in letters from Dr. Linda Birnbaum, Director, NIEHS. These letters and the responses from ICCVAM member Federal agencies are posted below.
- National Institute of Environmental Health Sciences (NIEHS)
- Letter from Linda Birnbaum, Ph.D., DABT, ATS, Director, NIEHS, to the ICCVAM Committee (December 7, 2010)
- Agency for Toxic Substances and Disease Registry (ATSDR)
- Letter from Dr. Birnbaum to Thomas R. Frieden, M.D., M.P.H., Administrator, ATSDR
- Response from Dr. Frieden (received January 4, 2011)
- Consumer Product Safety Commission (CPSC)
- Letter from Dr. Birnbaum to Inez Moore Tenenbaum, Chairman, CPSC
- Response from Todd Stevenson, Office of the Secretary (received February 3, 2011)
- Environmental Protection Agency (EPA)
- Letter from Dr. Birnbaum to Lisa P. Jackson, Administrator, EPA
- Response from John Fowle, Ph.D., DABT, Office of Pesticide Programs (received December 17, 2010)
- Food and Drug Administration (FDA)
- Letter from Dr. Birnbaum to Margaret Hamburg, M.D., Commissioner
- Response from Jesse L. Goodman, M.D., M.P.H. , Chief Scientist and Deputy Commissioner for Science and Public Health (received January 13, 2011)
- National Cancer Institute (NCI)
- Letter from Dr. Birnbaum to John E. Niederhuber, M.D., Director, NCI
- Response from Sandy Koeneman, Director, NCI Information Liaison Office (received October 26, 2010)
- National Institutes of Health (NIH)
- Letter from Dr. Birnbaum to Francis S. Collins, M.D., Ph.D., Director, NIH
- Response from Dr. Collins (received November 23, 2010)
- National Institute for Occupational Safety and Health (NIOSH)
- Letter from Dr. Birnbaum to John Howard, M.D., Director, NIOSH
- Response from Dr. Howard (received February 11, 2011)
- National Library of Medicine (NLM)
- Letter from Dr. Birnbaum to Donald A.B. Lindberg, M.D., Director, NLM
- Response from Dr. Lindberg (received January 13, 2011)
- Occupational Safety and Health Administration (OSHA)
- Letter from Dr. Birnbaum to David Michaels, Ph.D., M.P.H., Assistant Secretary of Labor for Occupational Safety and Health, OSHA
- Response from Dr. Michaels (received November 16, 2010)
- U.S. Department of Agriculture
- Letter from Dr. Birnbaum to Tom Vilsack, Secretary of Agriculture
- Response from Jose R. Diez, Associate Deputy Administrator, Animal and Plant Health Inspection Service (received June 28, 2010)
- U.S. Department of Defense
- Letter from Dr. Birnbaum to Robert M. Gates, Ph.D., Secretary of Defense
- Response from David Honey, PhD, Director, Research Directorate (received November 8, 2010)
- U.S. Department of Energy
- Letter from Dr. Birnbaum to Steven Chu, Secretary of Energy
- Response from Michael Kuperberg, Ph.D., Office of Biological and Environmental Research (received December 6, 2010)
- U.S. Department of the Interior
- Letter from Dr. Birnbaum to Ken Salazar, Secretary of the Interior
- Response from William Werkhiser, Regional Director, Eastern Region, U.S. Geological Survey (received August 21, 2010)
- U.S. Department of Transportation
- Letter from Dr. Birnbaum to Ray LaHood, Secretary of Transportation
- Response from Cynthia Quarterman, Pipeline and Hazardous Material Safety Administration (received December 26, 2010)
Applicability Domain for the Murine Local Lymph Node Assay
The 2007 CPSC nomination noted above requested that NICEATM and ICCVAM evaluate the applicability of the LLNA for testing formulations, metals, substances in aqueous solutions, and other products with the expectation that a wider applicability domain for the LLNA would enable wider use. A subsequent ICCVAM evaluation recommended use of the LLNA to test any chemical or product for ACD hazard potential unless the chemical or product has properties that may interfere with the ability of the LLNA to detect sensitizing substances.
ICCVAM Test Method Evaluation Report on Using the Murine Local Lymph Node Assay for Testing Pesticide Formulations, Metals, Substances in Aqueous Solutions, and Other Products
NIH Publication No. 10-7512
National and International Acceptance of the Expanded Applicability Domain of the LLNA
In April 2011, EPA announced that it was expanding the existing dermal sensitization test guideline to include testing of end-use pesticide products using the LLNA. The EPA policy notes the animal welfare advantages of the LLNA as well as the ability of the LLNA to provide a more quantitative assessment of dermal sensitization than traditional guinea pig methods. However, a draft Science Policy released in June 2018 announced that EPA would also accept data in vitro, in silico, and in chemico approaches to assess skin sensitization potential.
NICEATM and the ICCVAM Immunotoxicity Workgroup also developed a revision to OECD Test Guideline 429, which describes the conduct of the LLNA. The revised Test Guideline 429 incorporates the updated applicability domain for the LLNA. It also includes the updated protocol for the LLNA and provides for the use of the reduced LLNA method when appropriate.
Updated OECD Test Guideline 429 — Skin Sensitization: Murine Local Lymph Node Assay
Transmittal to Federal Agencies of ICCVAM Recommendations on the Expanded Applicability Domain of the LLNA
The ICCVAM recommendations on the applicability domain of the LLNA were communicated to Federal agencies in letters from Dr. Linda Birnbaum, Director, NIEHS. These letters and the responses from ICCVAM member Federal agencies are posted below.
- National Institute of Environmental Health Sciences (NIEHS)
- Letter from Linda Birnbaum, Ph.D., DABT, ATS, Director, NIEHS, to the ICCVAM Committee (December 7, 2010)
- Agency for Toxic Substances and Disease Registry (ATSDR)
- Letter from Dr. Birnbaum to Thomas R. Frieden, M.D., M.P.H., Administrator, ATSDR
- Response from Dr. Frieden (received January 4, 2011)
- Consumer Product Safety Commission (CPSC)
- Letter from Dr. Birnbaum to Inez Moore Tenenbaum, Chairman, CPSC
- Response from Todd Stevenson, Office of the Secretary (received February 3, 2011)
- Environmental Protection Agency (EPA)
- Letter from Dr. Birnbaum to Lisa P. Jackson, Administrator, EPA
- Response from John Fowle, Ph.D., DABT, Office of Pesticide Programs (received December 17, 2010)
- Food and Drug Administration (FDA)
- Letter from Dr. Birnbaum to Margaret Hamburg, M.D., Commissioner
- Response from Jesse L. Goodman, M.D., M.P.H. , Chief Scientist and Deputy Commissioner for Science and Public Health (received January 13, 2011)
- National Cancer Institute (NCI)
- Letter from Dr. Birnbaum to John E. Niederhuber, M.D., Director, NCI
- Response from Sandy Koeneman, Director, NCI Information Liaison Office (received October 26, 2010)
- National Institutes of Health (NIH)
- Letter from Dr. Birnbaum to Francis S. Collins, M.D., Ph.D., Director, NIH
- Response from Dr. Collins (received November 23, 2010)
- National Institute for Occupational Safety and Health (NIOSH)
- Letter from Dr. Birnbaum to John Howard, M.D., Director, NIOSH
- Response from Dr. Howard (received February 11, 2011)
- National Library of Medicine (NLM)
- Letter from Dr. Birnbaum to Donald A.B. Lindberg, M.D., Director, NLM
- Response from Dr. Lindberg (received January 13, 2011)
- Occupational Safety and Health Administration (OSHA)
- Letter from Dr. Birnbaum to David Michaels, Ph.D., M.P.H., Assistant Secretary of Labor for Occupational Safety and Health, OSHA
- Response from Dr. Michaels (received November 16, 2010)
- U.S. Department of Agriculture
- Letter from Dr. Birnbaum to Tom Vilsack, Secretary of Agriculture
- Response from Jose R. Diez, Associate Deputy Administrator, Animal and Plant Health Inspection Service (received June 28, 2010)
- U.S. Department of Defense
- Letter from Dr. Birnbaum to Robert M. Gates, Ph.D., Secretary of Defense
- Response from David Honey, PhD, Director, Research Directorate (received November 8, 2010)
- U.S. Department of Energy
- Letter from Dr. Birnbaum to Steven Chu, Secretary of Energy
- Response from Michael Kuperberg, Ph.D., Office of Biological and Environmental Research (received December 6, 2010)
- U.S. Department of the Interior
- Letter from Dr. Birnbaum to Ken Salazar, Secretary of the Interior
- Response from William Werkhiser, Regional Director, Eastern Region, U.S. Geological Survey (received August 21, 2010)
- U.S. Department of Transportation
- Letter from Dr. Birnbaum to Ray LaHood, Secretary of Transportation
- Response from Cynthia Quarterman, Pipeline and Hazardous Material Safety Administration (received December 26, 2010)
Performance Standards for the Murine Local Lymph Node Assay
ICCVAM prepared performance standards for the LLNA that can be used to evaluate the accuracy and reliability of new versions of the LLNA. These performance standards represent a set of internationally harmonized standards for the conduct of the LLNA (essential test method components, a minimum list of reference substances, and accuracy and reliability criteria).
Recommended Performance Standards: Murine Local Lymph Node Assay (January 2009)
Revision to OECD Test Guideline 429
NICEATM and the ICCVAM interagency Immunotoxicity Working Group subsequently developed a revision to OECD Test Guideline 429, "Skin Sensitization: Murine Local Lymph Node Assay." The revised Test Guideline 429, adopted by OECD in 2010, incorporates the harmonized performance standards and includes the updated protocol for the LLNA from the ICCVAM performance standards document. The updated protocol allows for a 20% reduction in animal use when compared to the original.
Transmittal to Federal Agencies of ICCVAM Recommended Performance Standards for the LLNA
- National Institute of Environmental Health Sciences (NIEHS)
- Letter from Linda Birnbaum, Ph.D., DABT, ATS, Director, NIEHS, to the ICCVAM Committee (March 17, 2010)
- Agency for Toxic Substances and Disease Registry (ATSDR)
- Letter from Dr. Birnbaum to Thomas R. Frieden, M.D., M.P.H., Administrator, ATSDR
- Response from Thomas R. Frieden, M.D., M.P.H., Director, Centers for Disease Control, and Administrator, ATSDR (received March 4, 2010)
- Consumer Product Safety Commission (CPSC)
- Letter from Dr. Birnbaum to Inez Moore Tenenbaum, Chairman, CPSC
- Response from Todd Stevenson, Office of the Secretary (received March 19, 2010)
- Environmental Protection Agency (EPA)
- Letter from Dr. Birnbaum to Lisa P. Jackson, Administrator, EPA
- Response from John Fowle, Ph.D., DABT, Office of Pesticide Programs (received March 18, 2010)
- Food and Drug Administration (FDA)
- Letter from Dr. Birnbaum to Margaret Hamburg, M.D., Commissioner
- Response from Jesse L. Goodman, M.D., M.P.H. , Chief Scientist and Deputy Commissioner (Acting) for Science and Public Health (received March 23, 2010)
- National Cancer Institute (NCI)
- Letter from Dr. Birnbaum to John E. Niederhuber, M.D., Director, NCI
- Response from Dr. Niederhuber (received October 9, 2009)
- National Institutes of Health (NIH)
- Letter from Dr. Birnbaum to Francis S. Collins, M.D., Ph.D., Director, NIH
- Response from Dr. Collins (received February 19, 2010)
- National Institute for Occupational Safety and Health (NIOSH)
- Letter from Dr. Birnbaum to John Howard, M.D., Director, NIOSH
- Response from Dr. Howard (received March 5, 2010)
- National Library of Medicine (NLM)
- Letter from Dr. Birnbaum to Donald A.B. Lindberg, M.D., Director, NLM
- Response from Dr. Lindberg (received March 22, 2010)
- Occupational Safety and Health Administration (OSHA)
- Letter from Dr. Birnbaum to Jordan Barab, Deputy Assistant Secretary of Labor and Acting Assistant Secretary, OSHA
- Response from David Michaels, Ph.D., M.P.H., Office of the Assistant Secretary for Occupational Safety and Health (received March 19, 2010)
- U.S. Department of Agriculture
- Letter from Dr. Birnbaum to Tom Vilsack, Secretary of Agriculture
- Response from Cindy Smith, Administrator, Animal and Plant Health Inspection Service (received October 16, 2009)
- U.S. Department of Defense
- Letter from Dr. Birnbaum to Robert M. Gates, Ph.D., Secretary of Defense
- Response from Dr. Robert Foster, Director, BioSystems (received January 4, 2010)
- U.S. Department of Energy
- Letter from Dr. Birnbaum to Steven Chu, Secretary of Energy
- Response from Dr. Anna Palmisano, Associate Director of Science for Biological and Environmental Research (received February 2, 2010)
- U.S. Department of the Interior
- Letter from Dr. Birnbaum to Ken Salazar, Secretary of the Interior
- Response from William Werkhiser, Regional Director, Eastern Region, U.S. Geological Survey (received March 25, 2010)
- U.S. Department of Transportation
- Letter from Dr. Birnbaum to Ray LaHood, Secretary of Transportation
- Response from Magdy El-Sibaie, Associate Administrator for Hazardous Materials Safety (received March 19, 2010)
Reduced Murine Local Lymph Node Assay
One of the LLNA modifications evaluated by NICEATM and ICCVAM in response to the CPSC nomination was the reduced LLNA (rLLNA). When used to test a substance for ACD potential, the rLLNA uses fewer animals than the LLNA to provide a “yes-no” result. ICCVAM has recommended the use of the rLLNA rather than the standard (multidose) LLNA when a negative result is expected or when dose–response information is not required. Use of the rLLNA reduces the number of animals needed for each test by 40% compared to the standard LLNA.
ICCVAM Test Method Evaluation Report: The Reduced Murine Local Lymph Node Assay: An Alternative Test Method Using Fewer Animals to Assess the Allergic Contact Dermatitis Potential of Chemicals and Products
NIH Publication No. 09-6439
National and International Acceptance of the Reduced LLNA
EPA adopted the rLLNA, noting in their announcement that the rLLNA allows for a 40% reduction in animal use compared to the multidose LLNA. April 2011 EPA policy document
NICEATM and ICCVAM subsequently developed a revision to OECD Test Guideline 429 that incorporates the rLLNA procedure. It was adopted by the OECD in July 2010. Revised OECD Test Guideline 429
Transmittal to Federal Agencies of ICCVAM Recommendations on the Reduced LLNA
- National Institute of Environmental Health Sciences (NIEHS)
- Letter from Linda Birnbaum, Ph.D., DABT, ATS, Director, NIEHS, to the ICCVAM Committee (March 17, 2010)
- Agency for Toxic Substances and Disease Registry (ATSDR)
- Letter from Dr. Birnbaum to Thomas R. Frieden, M.D., M.P.H., Administrator, ATSDR
- Response from Thomas R. Frieden, M.D., M.P.H., Director, Centers for Disease Control, and Administrator, ATSDR (received March 4, 2010)
- Consumer Product Safety Commission (CPSC)
- Letter from Dr. Birnbaum to Inez Moore Tenenbaum, Chairman, CPSC
- Response from Todd Stevenson, Office of the Secretary (received March 19, 2010)
- Environmental Protection Agency (EPA)
- Letter from Dr. Birnbaum to Lisa P. Jackson, Administrator, EPA
- Response from John Fowle, Ph.D., DABT, Office of Pesticide Programs (received March 18, 2010)
- Food and Drug Administration (FDA)
- Letter from Dr. Birnbaum to Margaret Hamburg, M.D., Commissioner
- Response from Jesse L. Goodman, M.D., M.P.H. , Chief Scientist and Deputy Commissioner (Acting) for Science and Public Health (received March 23, 2010)
- National Cancer Institute (NCI)
- Letter from Dr. Birnbaum to John E. Niederhuber, M.D., Director, NCI
- Response from Dr. Niederhuber (received October 9, 2009)
- National Institutes of Health (NIH)
- Letter from Dr. Birnbaum to Francis S. Collins, M.D., Ph.D., Director, NIH
- Response from Dr. Collins (received February 19, 2010)
- National Institute for Occupational Safety and Health (NIOSH)
- Letter from Dr. Birnbaum to John Howard, M.D., Director, NIOSH
- Response from Dr. Howard (received March 5, 2010)
- National Library of Medicine (NLM)
- Letter from Dr. Birnbaum to Donald A.B. Lindberg, M.D., Director, NLM
- Response from Dr. Lindberg (received March 22, 2010)
- Occupational Safety and Health Administration (OSHA)
- Letter from Dr. Birnbaum to Jordan Barab, Deputy Assistant Secretary of Labor and Acting Assistant Secretary, OSHA
- Response from David Michaels, Ph.D., M.P.H., Office of the Assistant Secretary for Occupational Safety and Health (received March 19, 2010)
- U.S. Department of Agriculture
- Letter from Dr. Birnbaum to Tom Vilsack, Secretary of Agriculture
- Response from Cindy Smith, Administrator, Animal and Plant Health Inspection Service (received October 16, 2009)
- U.S. Department of Defense
- Letter from Dr. Birnbaum to Robert M. Gates, Ph.D., Secretary of Defense
- Response from Dr. Robert Foster, Director, BioSystems (received January 4, 2010)
- U.S. Department of Energy
- Letter from Dr. Birnbaum to Steven Chu, Secretary of Energy
- Response from Dr. Anna Palmisano, Associate Director of Science for Biological and Environmental Research (received February 2, 2010)
- U.S. Department of the Interior
- Letter from Dr. Birnbaum to Ken Salazar, Secretary of the Interior
- Response from William Werkhiser, Regional Director, Eastern Region, U.S. Geological Survey (received March 25, 2010)
- U.S. Department of Transportation
- Letter from Dr. Birnbaum to Ray LaHood, Secretary of Transportation
- Response from Magdy El-Sibaie, Associate Administrator for Hazardous Materials Safety (received March 19, 2010)