Comment from Krishanu Saha
AnonymousSupportAcademic
Summary: The University of Wisconsin-Madison CRISPR Vision Program argues that the draft guidance lacks sufficient clarity on using New Approach Methodologies (NAMs) to establish proof-of-concept and minimum effective doses when animal models are unavailable. They propose specific, tiered standards for validating human cell-based models and dose-response characterization to reduce regulatory uncertainty in gene editing development.
See attached file