Comment on Plugge et al. 2021 “Toward a Universal Acute Fish Threshold of Toxicological Concern”

We concur with the authors of the Letter to the Editor that precedents are indeed important in science (Embry et al. 2021, this issue). However, it is equally important to question existing precedents and their utility in the presence of data that exist in the real world. In addition, the context of toxicological assessments matters, and because context varies and assessments are carried out addressing different needs (often in different parts of the chemical space), we prefer to view contrasting approaches as complementary rather than competitive, so long as applicability and underlying limitations are clearly defined. We invite the authors to scrutinize our publication record to find that some of our past efforts would appear to be "ideologically" orthogonal to the study being discussed in their letter (Plugge et al. 2021); yet, we do not perceive this as a conflict with some agreed-on central dogma. It is horses for courses, and although the approach presented may appear crude, its utility cannot be denied in the context of real-world data.A threshold of toxicological concern (TTC) is a screening tool used to assess the risk for a chemical of unknown toxicity and has been around for nearly half a century. This was the common usage within science until the emergence of a different measure, eco-TTC. As specifically stated, we derived a TTC, not an eco-TTC. Calibrating with 4 different derivation methods assures that the derived TTC is at most a conservative estimate. Knowledge of mechanism of action is limited, as described elsewhere (Connors et al. 2019). Use of mechanism of action software would incur a high(er) level of uncertainty, assuming one was within the limits of domain applicability, and was not explicitly applied in EnviroTox. A mechanism of action for regulated commercial mixtures would be very hard to pin down (most regulated products are mixtures). Detailed quality control of every study imaginable is not possible-screening is the only option. As we acknowledged in our study (Plugge et al. 2021), derivation of say a water quality criterion

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Reply to Comment on Plugge et al. 2021 “Toward a Universal Acute Fish Threshold of Toxicological Concern”

Plugge

Das

Kostal

2021

Enviro Toxic and Chemistry

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Comment on Plugge et al. 2021 “Toward a Universal Acute Fish Threshold of Toxicological Concern”

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Reply to Comment on Plugge et al. 2021 “Toward a Universal Acute Fish Threshold of Toxicological Concern”

Reply to Comment on Plugge et al. 2021 “Toward a Universal Acute Fish Threshold of Toxicological Concern”

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