Regulatory Roadmap

Navigate FDA, EPA, USDA, and ICCVAM pathways relevant to NAM validation, qualification, and regulatory use with the UC Davis roadmap.

Understanding the regulatory landscape for Novel Alternative Methodologies is crucial for successful adoption. Our regulatory roadmap guides you through the validation requirements and approval processes for FDA, EPA, and international regulatory bodies.

Select Your Regulatory Domain

Food & Drug Administration (FDA)

For human drug and biologic development, FDA reliance on a NAM is still context-of-use-bound and evidence-driven. The key question is not whether a NAM is novel, but whether it is reliable, interpretable, technically characterized, and sufficiently validated for the specific development decision FDA will rely on. That can happen either through direct use in a submission or through a formal tool qualification pathway.

Which FDA route best matches how the NAM will be used?

Choose the option that best matches whether you are using NAM data directly in a submission or pursuing broader FDA tool qualification for reuse within a defined context of use.

NAM Use in Regulatory Submissions

For sponsors using NAM data directly in a drug-development submission or meeting package. This route focuses on fit-for-purpose validation, technical characterization, human biological relevance, transparent limitations, and early engagement with the relevant FDA review division rather than tool qualification for broad reuse.

1
Define the Decision and Submission Context

Start by stating what decision the NAM will inform, where the data will appear, what uncertainty it is meant to reduce, and which limits on interpretation must be carried with it.

2
Show Human Relevance and Technical Characterization

Describe why the NAM is biologically relevant to the drug-development question and provide enough technical detail on the platform, inputs, controls, outputs, and analysis workflow for FDA to assess whether the data are interpretable.

3
Build the Fit-for-Purpose Validation Package

Generate the evidence needed to show the NAM is reliable enough for its proposed use, which may include repeatability, reproducibility, robustness, transferability, comparator data, and uncertainty characterization.

4
Engage the Appropriate FDA Review Division Early

Use meetings and sponsor-review interactions to test whether the proposed evidence package, reporting format, and interpretation boundaries are aligned with the review context before locking the full submission strategy.

5
Submit the NAM Evidence With Clear Limits and Rationale

Present the NAM data so reviewers can see the scientific rationale, validation status, limitations, and why the method is fit for the specific nonclinical decision being supported.

Additional testing and validation support NAM testing at UC Davis can provide:
  • Submission-aligned evidence planning

    We can help map the testing plan to the exact regulatory question, identify the minimum defensible evidence package, and define the limitations that need to travel with the NAM data.

  • Technical characterization and SOP hardening

    We can help document execution conditions, controls, analysis workflows, and operating boundaries so the NAM is interpretable to reviewers rather than just novel to collaborators.

  • Benchmarking and orthogonal comparison studies

    We can generate side-by-side datasets against comparator assays, legacy evidence, or human-relevant reference materials that strengthen a fit-for-purpose submission package.

  • Reproducibility and uncertainty studies

    We can run targeted repeatability, robustness, and transferability studies that show where the NAM performs consistently and where the evidence remains bounded.

Innovative Science and Technology Approaches for New Drugs (ISTAND)

For novel drug development tools that do not fit existing DDT categories and are being considered for qualification. The program centers on a clearly bounded COU, early FDA dialogue, and a validation package showing the tool is reliable, relevant, and usable within stated limits.

1
Frame the Need and Proposed COU

Use the Letter of Intent to explain the unmet development need, what decision the NAM would support, why existing tools are insufficient, and the exact COU you want FDA to evaluate.

2
Engage FDA Early on Validation Expectations

If admitted, use early interactions with FDA to refine endpoints, study materials, comparator strategy, performance expectations, data standards, and any questions around transferability or limitations.

3
Build the Qualification Plan Around Validation Modules

The Qualification Plan should show how you will establish analytical or biological validity, repeatability, reproducibility, transferability, applicability domain, and conditions of use for the stated COU.

4
Assemble the Full Qualification Package

Submit the complete evidence package, including datasets, analyses, uncertainty characterization, limitations, and the boundaries within which the tool can be interpreted responsibly.

5
Qualification Decision and Lifecycle Use

If qualified, the tool may be relied on within the stated COU. Material changes to the assay, model, software, or operating environment can require additional evidence before the same conclusion still holds.

Additional testing and validation support NAM testing at UC Davis can provide:
  • COU-aligned validation planning

    We can help turn the proposed ISTAND use case into a fit-for-purpose validation plan with defined endpoints, controls, acceptance criteria, and study boundaries.

  • SOP hardening and technology transfer

    We can help make a novel platform more execution-ready by documenting workflows, operator steps, calibration checks, and transfer materials that reduce lab-to-lab drift.

  • Benchmarking and bridging datasets

    We can generate comparison data against existing assays, orthogonal methods, or human-relevant reference data so the tool's value is supported by more than novelty alone.

  • Repeatability, reproducibility, and version-change studies

    We can run targeted studies that show whether the tool stays stable across operators, runs, sites, and platform revisions.

Drug Development Tool (DDT) Qualification Program

For tools that fit established DDT categories and are intended for qualification. Qualification is still tied to a specific COU, but the review is anchored to agreed performance criteria, datasets, and evidence that the tool can be relied on across programs within that boundary.

1
Define the Tool Category and COU

The LOI should clearly state the tool category, the specific drug development decision it supports, the intended population or setting, and why qualification would improve decision-making.

2
Set Performance Criteria in the Qualification Plan

The Qualification Plan should define datasets, comparators, analysis methods, acceptance criteria, and how uncertainty, limitations, and applicability boundaries will be handled.

3
Generate the Confirmatory Validation Evidence

Produce the datasets that demonstrate the tool performs as expected for the stated COU, including robustness, variability, transferability where needed, and interpretability of the output.

4
Submit the Full Qualification Package

The full package should integrate the complete evidence story: method description, datasets, statistics, limitations, and the rationale for why the tool is ready to support the proposed decision.

5
Qualification Decision and Ongoing Fitness

If qualified, the DDT can be cited across submissions within the accepted COU, but continued confidence still depends on maintaining the tested operating conditions and understanding when new evidence is needed.

Additional testing and validation support NAM testing at UC Davis can provide:
  • DDT validation study design

    We can help structure the datasets, comparators, controls, and acceptance thresholds needed to test whether the tool is fit for its stated COU.

  • Bridging and benchmarking studies

    We can generate evidence that compares the DDT against legacy measures, orthogonal assays, or clinically relevant reference datasets.

  • Reproducibility and transferability testing

    We can run studies that show whether the tool performs consistently across operators, runs, labs, and implementation environments.

  • Evidence package readiness support

    We can help organize the testing outputs into coherent datasets, summaries, and limitation statements that support review without claiming to draft the regulatory paperwork for you.

Environmental Protection Agency (EPA)

For industrial chemicals and pesticides, EPA generally looks for fit-for-purpose evidence that a NAM is relevant to the regulatory question, reproducible, transparent about limitations, and usable alongside other evidence streams. Acceptance often depends on the specific program context rather than a single universal designation.

1
Define the Decision Context and Applicability Domain

Start by identifying the endpoint, the regulatory decision the NAM is meant to inform, the chemical or product space it applies to, and the limits of interpretation that should be stated up front.

2
Check EPA's Accepted NAMs List and Nominate New Methods

EPA maintains a public list of NAMs accepted for TSCA and FIFRA testing and updates it over time. Check whether the method is already recognized for the relevant endpoint; if it is not, EPA offers a streamlined process to nominate a NAM for evaluation on relevance, reliability, transparency, and reproducibility.

3
Engage the Program Early on Evidence Expectations

Early discussions with the relevant EPA program can clarify what level of validation, reporting, comparator data, and uncertainty characterization will be persuasive in that context.

4
Build the Fit-for-Purpose Validation Package

Generate evidence on relevance, repeatability, reproducibility, robustness, transferability, and how the NAM aligns with the decision framework the program will use.

5
Submit the NAM Evidence in the Right Program Pathway

Submit the evidence in the context that fits the regulatory action, such as TSCA submissions, waiver requests, pesticide programs, or another program-specific route.

6
EPA Review, Integration, and Follow-Up Testing

EPA may rely on the NAM directly, combine it with other evidence streams, or request additional data if the limitations are not fully resolved for the intended regulatory use.

EPA NAM Nomination Process
  • How the nomination process works
    1. Email an initial nomination to nam@epa.gov describing the method and how it would be used.
    2. EPA triages submissions and, for promising methods, sends an in-depth form to complete.
    3. Return the completed form with the method's data and supporting documentation.
    4. EPA scientists evaluate the method against its criteria: context of use, biological relevance, reliability and reproducibility, transparency, and fit-for-purpose.
    5. Accepted methods are added to EPA's public list of NAMs for TSCA and FIFRA testing.
Additional testing and validation support NAM testing at UC Davis can provide:
  • Fit-for-purpose study design

    We can help match the study design to the EPA decision context so the data answer the actual regulatory question rather than just showcasing the method.

  • Reference chemical and applicability domain studies

    We can build the benchmarking sets needed to show where the NAM performs reliably and where extrapolation would be inappropriate.

  • Reproducibility, transferability, and waiver-support data

    We can generate the repeatability and transfer evidence that strengthens waiver requests or program-specific proposals to use a NAM in place of additional animal testing.

  • Weight-of-evidence dataset generation

    We can produce orthogonal or supporting datasets that help place the NAM within a larger evidence framework instead of asking it to carry every claim by itself.

United States Department of Agriculture (USDA)

For veterinary biologics, the emphasis is usually on batch release, potency, identity, or safety decisions tied to manufacturing consistency. Acceptance depends on showing that the NAM is reliable, transferable, and appropriately linked to product quality for the stated use.

1
Define the Intended Use and Quality Linkage

Clarify whether the NAM is meant for potency, identity, safety, serial release, or another manufacturing control, and show how the readout connects to product quality for that use.

2
Align Early with CVB on Study Design and Acceptance Criteria

Early discussion with the Center for Veterinary Biologics can help define expected study design, bridging strategy, acceptance windows, and any product-specific protocol constraints.

3
Generate Validation, Bridging, and Transferability Evidence

Build the evidence package around repeatability, reproducibility, robustness, transferability, and comparability to the existing assay or release method where required.

4
Submit Protocols and the Validation Package

Submit the relevant protocols, datasets, analyses, and implementation details so CVB can evaluate whether the NAM is suitable for the stated regulatory use.

5
Implementation, Licensure Integration, and Ongoing Monitoring

If accepted, the NAM may be tied to licensure, serial release, the Outline of Production, and ongoing quality monitoring, so post-implementation stability still matters.

Additional testing and validation support NAM testing at UC Davis can provide:
  • Batch-release and potency study design

    We can help design studies that directly test whether the NAM is suitable for the manufacturing or release decision you need it to support.

  • Bridging to legacy assays

    We can generate side-by-side datasets against the current assay so comparability is demonstrated with the materials and lots that matter to CVB.

  • Transferability across operators and sites

    We can test whether the method remains reliable when execution moves beyond the originating team or site.

  • Quality control and lifecycle evidence

    We can help produce the operating range, control behavior, and follow-up testing evidence needed to keep the assay defensible after implementation.

Interagency Coordinating Committee on the Validation of Alternative Methods (ICCVAM)Interagency Coordinating Committee on the Validation of Alternative Methods (ICCVAM)

ICCVAM is a cross-agency U.S. route for methods that may support federal safety and health decisions. The emphasis is on independent scientific evaluation, reproducibility, relevance for a defined COU, peer review, and recommendations that agencies can apply within their own programs.

1
Define the COU and Nomination Scope

Start with a precise statement of what the NAM measures, the decision it is meant to support, the populations or materials it applies to, and the key limitations that should already be acknowledged.

2
Build the Pre-Validation Package

Before broader review, assemble a method package that covers protocol maturity, within-laboratory repeatability, transfer expectations, data handling, applicability domain, and the rationale for why the method is relevant to the proposed COU.

3
Independent and Multi-Laboratory Evaluation

ICCVAM-related review typically depends on independent assessment of reliability and relevance, often including multi-site execution or other evidence that the method performs consistently outside the originating lab.

4
Peer Review and Public Comment

Scientific peer review and public input help test whether the claims, limitations, and use boundaries are adequately supported by the evidence package.

5
Interagency Recommendations and Program Uptake

ICCVAM may issue recommendations, but each participating agency still decides whether and how to rely on the method in its own authority, guidance, or program decisions.

Additional testing and validation support NAM testing at UC Davis can provide:
  • COU and validation gap analysis

    We can help translate the proposed use into a concrete testing plan: endpoint selection, comparator strategy, key uncertainties, and the minimum data needed before cross-agency review.

  • SOP hardening and transfer packages

    We can help convert a promising method into a study-ready protocol with operator instructions, quality controls, acceptance windows, and transfer materials other labs can execute consistently.

  • Reproducibility and multi-laboratory studies

    We can run or coordinate repeatability, reproducibility, and transferability work so the evidence shows what the method does consistently across analysts, runs, and sites.

  • Benchmarking and limitations mapping

    We can generate side-by-side datasets against legacy assays, reference chemicals, or human-relevant comparators and document where the NAM performs well, where it is limited, and what follow-up work is needed.

Roadmap Maintenance Note

Regulatory Changes Tracker

Internal summary of official changes affecting NAM validation, qualification, or regulatory use.

For site planning only, not legal or regulatory advice. Items without a dated official source and a clear process impact were excluded.

ICCVAMOrganizational change2026-06-15

NICEATM Moved Into the New NIH Office of Research Innovation, Validation, and Application (ORIVA)

NIH announced that NICEATM, the scientific-support arm behind ICCVAM's cross-agency validation work, will continue as a division of the newly created NIH Office of Research Innovation, Validation, and Application (ORIVA), which coordinates NIH-wide development, validation, and scaling of human-based NAMs.

  • The cross-agency validation route continues through ICCVAM and NICEATM, now organized under ORIVA, so method developers still engage NICEATM and ICCVAM during prevalidation and validation.
  • Placing NICEATM under an office chartered to scale NAM validation across NIH strengthens the institutional backing for the ICCVAM evaluation pathway.
  • This is an organizational change rather than a change to the ICCVAM validation steps themselves.
Official source

NIH news release on the ORIVA office, June 15, 2026

EPAList update and process change2026-06-02

EPA Adds 13 New Approach Methods to Its TSCA List and Opens a Nomination Process

EPA added 13 externally validated NAMs to its list of methods accepted for TSCA and FIFRA testing (its first list update since 2021) and introduced a streamlined process for stakeholders to nominate additional NAMs, evaluated on relevance, reliability, transparency, and reproducibility. Examples include a reconstructed-human-cell eye-hazard test, a 3D-tissue phototoxicity method, and OECD-validated dermal-sensitization combinations.

  • EPA now publishes an updated, concrete list of acceptable NAMs, so sponsors can check whether a method is already recognized before designing a submission.
  • The new nomination process gives method developers a defined route to have a NAM evaluated for EPA use, which is a process change for the chemical-safety domain.
  • It reinforces the EPA pathway's emphasis on relevance, reliability, and transparency for a defined regulatory endpoint.
  • Roadmap change applied 2026-07-08: added an EPA pathway step (now step 2) to check EPA's accepted-NAMs list and nominate a method when it is not yet listed. The earlier five-step EPA pathway had no explicit list-or-nominate step.
Official source

EPA announcement on NAMs under TSCA and FIFRA, June 2, 2026

FDAProgress report2026-04-20

Reducing Animal Testing in Nonclinical Studies: Year One Progress and the Path Forward

FDA published a one-year progress report on its 2025 roadmap to reduce animal testing. It reported qualifying the first AI-based (in silico) drug development tool for regulatory use, launching a public database that clarifies which alternative methods FDA considers acceptable, and updating monoclonal-antibody guidance to reduce or remove six-month nonhuman primate studies.

  • The first AI/in silico tool qualification shows the FDA qualification pathways now producing accepted NAM tools, not just accepting NAM data case by case.
  • The new acceptability database gives sponsors a reference for which methods FDA already treats as usable, which is relevant to both the direct submission-use and formal qualification routes.
  • This report builds on the March 2026 general NAM validation draft guidance and confirms the direction of travel rather than changing the underlying validation expectations.
Official source

FDA press announcement and year-one report, April 20, 2026

FDADraft guidance2026-03-19

General Considerations for the Use of New Approach Methodologies in Drug Development

FDA issued draft guidance describing a general validation framework for NAMs in drug development and explicitly encouraged use of NAM data in regulatory submissions when the method is fit for purpose and improves the human relevance and predictivity of nonclinical evidence.

  • This is the clearest recent FDA change separating NAM validation for submission use from formal DDT qualification.
  • The guidance emphasizes context of use, human biological relevance, technical characterization, reliability, and fit-for-purpose validation rather than treating qualification as the only route.
  • The roadmap now needs a direct submission-use route in addition to ISTAND and DDT qualification pathways.
Official source

FDA guidance document and Federal Register notice, March 19, 2026

FDADraft guidance2025-12-02

Monoclonal Antibodies: Streamlined Nonclinical Safety Studies

FDA issued draft guidance for certain monospecific monoclonal antibodies stating that six-month non-human primate toxicity studies can be reduced or eliminated for specific product types and that knowledge-based risk assessments may integrate computational toxicology, organoid systems, and real-world human safety data in regulatory decision-making.

  • This is a product-specific change rather than a general NAM validation framework, but it materially changes how FDA can accept non-animal evidence for some antibody programs.
  • The draft guidance shows FDA moving from routine long-duration primate studies toward risk-based use of human-relevant NAM evidence for defined products.
  • Any roadmap language about FDA expectations for biologics should now distinguish general NAM validation principles from this narrower monoclonal-antibody policy track.
Official source

FDA press announcement on draft guidance, December 2, 2025

FDAProgram change2025-07-31

ISTAND Established as a Permanent Drug Development Tool Qualification Program

FDA converted the ISTAND initiative (piloted since 2020) into a permanent qualification program for novel drug development tools that do not fit existing DDT categories, including complex in vitro models, organ-on-chip systems, AI-enabled tools, and other NAMs.

  • ISTAND is now a standing route rather than a time-limited pilot, so the roadmap's novel-tool qualification pathway should describe it as a permanent program.
  • Making the pathway permanent signals durable FDA support for qualifying NAM-based tools for reuse within a defined context of use.
  • It sits alongside the established DDT program, keeping ISTAND focused on tools that fall outside existing qualification categories.
Official source

FDA Voices announcement, July 31, 2025

FDAPolicy roadmap2025-04-10

Roadmap to Reducing Animal Testing in Preclinical Safety Studies

FDA announced a policy shift to reduce or potentially replace animal testing for monoclonal antibodies and other drugs with NAM data, including AI-based computational models, organoid testing, and other human-relevant methods. The agency said implementation would begin immediately for IND applications, where inclusion of NAM data is encouraged, and it planned a pilot program under close FDA consultation.

  • This changed the practical review posture for INDs by officially encouraging NAM data in the submission process rather than treating it only as a future possibility.
  • The roadmap introduced an FDA pilot pathway for primarily non-animal testing strategies under agency consultation, which is a process change relevant to how sponsors seek acceptance for NAM evidence.
  • It also set up later guidance changes, including the December 2025 monoclonal-antibody draft guidance and the March 2026 general NAM validation draft guidance.
Official source

FDA press announcement and roadmap release, April 10, 2025

ICCVAMValidation framework update2024-03-01

Validation, Qualification, and Regulatory Acceptance of New Approach Methodologies

ICCVAM published an updated validation document replacing the old single-method replacement emphasis with a more flexible framework that can integrate multiple in vitro, in chemico, and in silico approaches to establish confidence for a defined application or context of use.

  • This is a real framework change in how cross-agency validation is described: confidence can now come from integrated evidence rather than only from one-for-one animal replacement logic.
  • The document strengthens the roadmap's emphasis on context of use, usefulness and limitations, and agency-specific needs and priorities.
  • It supports keeping ICCVAM framed as an evidence and evaluation route rather than a simple substitute-method pathway.
Official source

ICCVAM Validation Workgroup document, March 2024