A number of items that must be considered in designing and choosing a suitable model for initiation and promotion testing have been described. Although these items may seem complex, tests for initiation and promotion are, in reality, quite simple and provide a rational approach to carcinogen testing. Several tests have been described here and Eastin, elsewhere in this book, describes the validation of a simple and highly recommended test. The processes involved in initiation and promotion are qualitatively different. The criteria for concern about possible human hazards as well as for regulation of initiators and promoters should be based on these qualitative differences. Realistic appraisal of the risk must be based on the level and nature of the potential hazard. In particular, it must be recognized that promoting action is reversible, that a threshold exists, and that promotion is readily inhibited. Therefore, animal tests that differentiate between potential initiators and promoters are essential to enable a logical assessment of human risk and the implementation of appropriate protective measures based on scientific facts.