Regulatory Forum opinion piece: image analysis-based cell proliferation studies using electronic images: the CEPA industry working group's proposal.

Electronic images of histopathological changes are commonly and increasingly used in toxicologic pathology for morphological evaluation, illustration, peer review, or reporting. Toxicity studies in which cell proliferation is an end point are also pivotal in determining the carcinogenic potential of new molecules. In this article, we describe the approach of the European Cell Proliferation and Apoptosis working group (CEPA) for performing cell proliferation studies and morphometry using electronic images. The Society of Toxicologic Pathology (STP) has published a position statement on handling of pathology image data in compliance with 21 Code of Federal Regulations (CFR) Parts 58 and 11. CEPA supports the STP position and shares the issues involved in the use of electronic images in pathology. However, considering the experience and current know-how of members, particularly in conducting cell proliferation studies, CEPA would like to recommend in this article that electronic images acquired using state-of-the-art slide imaging techniques, including whole slide scanning, need not be considered as raw data, and therefore are not subject to 21 CFR Parts 58 and 11 regulations for archiving. In this article, we detail the reasons why we come to this proposal and we describe the measures that are taken to ensure Good Laboratory Practice-compliant execution of cell proliferation studies that include acquisition and validation of imaging and image analysis systems, development and validation of methods for their intended use, formulation, and use of standard operating procedures.