Comment from Stefano Gaburro
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Summary: Stefano Gaburro, an independent scientific consultant and lead of a working group, supports the intent of the draft guidance to integrate nonclinical testing alternatives into drug development. He argues for specific revisions to improve scientific precision, including replacing the broad term "NAM" with specific categories, adding dedicated validation for in silico methods, and explicitly integrating the 3Rs framework.
The comment are too long to be written here that is why I attached the file.