r/EPA
            United States
            Environmental Protection
            Agency
            Office of Health and
            Environmental Assessment
            Washington DC 20460
EPA/625/3-87/013A
November 1 987
SAB Review Draft
            Research and Development
Special Report on
Ingested Inorganic
Arsenic:

Skin Cancer;
Nutritional
Essentiality
  SAB
  Review
  Draft
  (Do Not
  Cite or Quote)

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                                                               EPA/625/3-87/01 3A
                                                                   NovomlMir 19B7
                                                                  SAB Review Draft
        SPECIAL REPORT ON INGESTED INORGANIC ARSENIC:   SKIN CANCER;

                         NUTRITIONAL ESSENTIALITY
                             Prepared for the
                          Risk Assessment Forum
                   U.S. Environmental Protection Agency
                              Washington, DC

                              November 1987
                            PRINCIPAL AUTHORS
Tina Levine, Ph.D.
Amy Rispin, Ph.D.
Cheryl Siegel Scott, M.S.P.M.
William Marcus, Ph.D.
Office of Pesticides and
  Toxic Substances
Office of Drinking Water
Chao Chen, Ph.D.
Herman Gibb, M.P.H.
Office of Research and
  Development
                            TECHNICAL PANEL
Chao Chen, Ph.D.
Herman Gibb, M.P.H.
Frank Gostomski, Ph.D., Chairman
Tina Levine, Ph.D.
                         William Marcus, Ph.D.
                         Amy Rispin, Ph.D.
                         Reva Rubenstein, Ph.D.
                         Cheryl Siegel Scott, M.S.P.H.
RISK ASSESSMENT FORUM STAFF

Dorothy E. Patton, Ph.D., J.D., Executive Director
Judith S. Bellin, Ph.D., Science Coordinator
Linda C. Tuxen, B.S., Technical Liaison

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                          DRAFT—DO  NOT QUOTE  OR CITE

     This document is  a draft for  review purposes only and does  not constitute
Agency policy.   Mention of trade names or commercial  products does not consti-
tute endorsement or recommendation for use.

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                               TABLE OF CONTENTS



PREFACE	vi

EXTERNAL PEER REVIEW	vii

EPA RISK ASSESSMENT FORUM (1986-87) 	  viii

EPA RISK ASSESSMENT COUNCIL (1986-87)  	  viii

  I.  OVERVIEW	    1

 II.  EXECUTIVE SUMMARY 	    6

      A.  Background	    6

      B.  Validity of Data from Taiwan	    7

      C.  Biological  Considerations for Dose-Response Assessment.  ...    8

      D.  Dose-Response Assessment	   10

      E.  Nutritional  Essentiality	   13

      F.  Conclusion	   14

III.  HAZARD  IDENTIFICATION AND EPIDEMIOLOGIC STUDIES SUITABLE FOR

      DOSE-RESPONSE EVALUATION	   16

      A.  Preliminary Considerations	   16

      B.  Review of Studies	   17

          1.   Taiwan  Study	   17

          2.   Mexican  Study	   20

          3.   German  Study.	   23

      C.   Summary	   24

 IV.   SELECTED  ELEMENTS  OF HAZARD  IDENTIFICATION	   27

      A.   Pathologic  Characteristics and  Significance of
          Arsenic-Induced  Skin  Lesions	   27

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                       TABLE OF CONTENTS (continued)

         1.  Description and Malignant Potential of Skin Lesions  ...   27
         2.  Progression of Skin Lesions	   30
         3.  Case-Fatality Rate of Arsenic-Induced Skin Cancer  ....   31
     B.   Genotoxicity	   35
         1.  Introduction	   35
         2.  Possible Mechanisms of Genotoxicity 	   36
         3.  The  Use  of Arsenic Genotoxicity Data in the
            Evaluation of Carcinogenic Risk 	   38
     C.   Metabolism and Distribution  	   39
 V.   DOSE-RESPONSE ESTIMATE FOR ARSENIC INGESTION	   43
     A.   Introduction	43
         1.  Considerations Affecting Model Selection  	  43
         2.  Changes  in Methodology Relative to the 1984 Assessment  .  .  45
     8.   Estimation of Risk	47
         1.  Estimation of Risk using Taiwan Data	47
         2.  Comparison with Mexican Data	48
         3.  Comparison with German Data	48
     C.   Summary  of Dose-Response Evaluation	49
         1.  Numerical Estimates	49
         2.  Uncertainties	50
         3.  U.S. Populations	51
VI.   ARSENIC AS AN ESSENTIAL NUTRIENT	54
     A.   Background	54
     B.   Animal Studies	55
         1.  Data Summary	55
                                      iv

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                         TABLE OF CONTENTS (continued)



           2.   Evaluation of Data	58

       C.   Applicability to Humans	59

       D.   Summary and Conclusions	62

 VII.  FUTURE  RESEARCH DIRECTIONS 	  64

       A.   Epidemiologic Studies  	  64

       B.   Mechanisms of Carcinogenesis for Arsenic-Induced
           Skin Cancer	65

       C.   Pharmacokinetics/Metabolism of Arsenic 	  65

       D.   Essentiality	65

VIII.  APPENDICES

       APPENDIX A:  Summary of Epidemiologic Studies and  	  A-l
                    Case Reports on  Ingested Arsenic Exposure

       APPENDIX B:  Quantitative Estimate of Risk for Skin	B-l
                    Cancer Resulting from Arsenic Ingestion

       APPENDIX C:  Internal  Cancers Induced by Ingestion
                    Exposure to Arsenic	C-l

       APPENDIX D:  Individual  Peer  Review Comments  on
                    Essentiality  	  D-l

       APPENDIX E:  Metabolic Considerations  	  E-l

  IX.  REFERENCES	R-1

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                                    PREFACE

     The U.S.  Environmental  Protection  Agency  (EPA^  Risk  Assessment Forum was
established to promote  scientific  consensus  on  risk  assessment  issues  and to
ensure that this consensus is  incorporated into appropriate  risk  assessment
guidance.  To  accomplish this,  the Risk Assessment Forum  assembles experts from
throughout the EPA in a formal  process  to study and  report on  these issues from
an Agency-wide perspective.
     For major risk assessment activities, the  Risk  Assessment  Forum may estab-
lish a Technical Panel  to conduct  scientific review  and analysis.  Members are
chosen to assure that necessary technical  expertise  is  available.  Outside
experts may be invited to participate as consultants or,  if  appropriate, as
Technical Panel  members.
     Major scientific controversies have existed for many years within EPA con-
cerning the health effects of  exposure  to ingested arsenic.   To help  resolve
these issues,  a Technical  Panel on Arsenic was  formed within EPA  by the Risk
Assessment Forum.  The Technical Panel  was charged with preparing a report on
arsenic health effects for Agency-wide  concurrence and  use.

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                              EXTERNAL PEER REVIEW



     A draft of this report was  reviewed  at a  peer  review workshop of  scientific

experts in Hunt Valley,  Maryland,  on  December  2-3,  1986.  The workshop was highly

instructive for the EPA Technical  Panel,  and the  current draft  incorporates

many of the peer reviewers'  comments.
Dr. Roy Albert
Department of Environmental  Health
University of Cincinnati  Medical  Center

Dr. Julian B. Andelman
University of Pittsburgh
Graduate School  of Public Health

Dr. John Bailar
Harvard University and
  U.S. Department of
  Health and Human Services

Dr. Mariano Cebrian
Department of Pharmacology
  and Toxicology (Mexico)

Dr. C.J. Chen
Institute of Public Health
National Taiwan University
  College of Medicine

Dr. Philip Enterline
Center for Environmental  Epidemiology
University of Pittsburgh

Dr. Kurt J. Irgolic
Department of Chemistry
Texas A & M University

Dr. Ruey S. Lin
College of Medicine
National Taiwan University

Dr. Kate Mahaffey
National Institute of
  Occupational Safety and Health
Dr. Daniel  B. Menzel
Department of Pharmacology
Duke Medical  Center

Dr. Paul Mushak
Pathology Department
University of North Carolina

Dr. Forrest Nielson
United States Department
  of Agriculture
Grand Forks Human Nutrition
  Research Center

Dr. Joseph Scotto
National Institute of Health
National Cancer Institute

Dr. David Strayer
Department of Pathology
University of Texas Medical School

Dr. Wen-Ping Tseng
Department of Medicine
National Taiwan University
  College of Medicine

Dr. Marie Vahter
National Institute of Environmental
  Medicine
Karolinska Institute (Sweden)

Dr. Roland R. Weiler
Hazardous Contaminants Coordination
  Branch
Environment Ontario (Canada)
     The Technical  Panel  acknowledges  with  appreciation  the  special  contributions

of Dr. Vicki  Dellarco,  Dr.  David Jacobson-Kram,  Mr.  Paul  White,  Dr.  Ken  Brown,

Dr. Kerrie Boyle,  and Ms.  Pamela Bassford.

                                      vii

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                      EPA RISK ASSESSMENT FORUM (1986-87)



     Drafts of this report were reviewed by EPA's Risk Assessment Forum in

October 1986 and in March 1987.  In July 1987,  the final  report was submitted

to EPA's Risk Assessment Council  for concurrence.

Forum Members

Peter W. Preuss, Ph.D.,  Office of Research and  Development,  Chairman
Mary Argus, Ph.D., Office of Pesticides and Toxic Substances
Donald Barnes, Ph.D., Office of Pesticides and  Toxic Substances
Barbara Beck, Ph.D., Region 1
Michael Dourson, Ph.D.,  Office of Research and  Development
William Farland, Ph.D.,  Office of Research and  Development
Penelope Fenner-Crisp, Ph.D., Office of Pesticides and Toxic Substances
Richard N. Hill, M.D., Ph.D., Office of Pesticides and Toxic Substances
Carole Kimmel, Ph.D., Office of Research and Development
Arnold M. Kuzrnack, Ph.D., Office of Water

Designated Representatives

James Baker, Region 8
Timothy Barry, Office of Policy Planning and Evaluation
Arnold Den, Region 9
Kenneth Orloff, Region 4
Maria Pavlova, Region 2
Patricia Roberts, Office of General Counsel
Samuel Rotenberg, Region 3
Reva Rubenstein, Office  of Solid Waste and Emergency Response
Deborah Taylor, Office of the Administrator
jeanette Wiltse, Office  of Air and Radiation


                 EPA RISK ASSESSMENT COUNCIL (1986-87)
John A. Moore, Office of Pesticides and Toxic Substances, Chairman
Daniel  P. Beardsley, Office of Policy Planning and Evaluation
Theodore M. Farber, Office of Pesticides and Toxic Substances
Victor Kimm, Office of Pesticides and Toxic Substances
Hugh McKinnon, Office of Research and Development
William Muszynski, Region 2
yaun A. Newill, Office of Research and Development
Peter W. Preuss, Office of Research and Development
Roseniarie Russo, Office of Research and Development
Deborah Taylor, Office of the Administrator
Stephen R. Wassersug, Region 3
Donald Clay, Office of Air and Radiation
Michael Cook, Office of Water
Marcia Williams, Office of Solid Waste and Emergency Response
Terry Yosie, Office of the Administrator
                                      vm

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                                  I.  OVERVIEW

     Arsenic exposure has long been associated with several different forms of
human cancer.  The association between inhaled arsenic and an elevated risk of
lung cancer is well documented (Enterline and Marsh, 1980; Lubin et al.,  1981;
Welch et al., 1982; Lee-Feldstein, 1983).  Other studies have reported an
association between ingested inorganic arsenic and an increased incidence of
nonmelanoma skin cancer in a Taiwanese population (Tseng et al., 1968; Tseng,
1977; hereafter "Taiwan study") (Appendix A).  Also, exposure to ingested
arsenic is associated with an elevated but unquantifiable risk for cancer of
internal organs (e.g., liver, kidney) in some studies (Chen et al., 1985, 1986).
     The U.S. Environmental  Protection Agency's Health Assessment Document (HAD)
for Inorganic Arsenic (U.S.  EPA, 1984a) contained qualitative and quantitative
carcinogen risk assessments  for both inhalation and ingestion routes of  exposure,
Several EPA offices raised questions about the assessment for the ingestion
exposure, including:  the validity of the Taiwan study and applicability  of the
dose-response assessment to  the U.S. population, the interpretation and  use
of arsenic-associated skin lesions, and the role of arsenic in human nutrition
(the "essentiality" issue).
     A Technical  Panel was convened by the Risk Assessment Forum to address
these issues.  In the course of its deliberations, the Technical  Panel examined
several other issues relating to hazard identification and dose-response  assess-
ment for arsenic-induced skin cancer, including some aspects of the pathology
of arsenic-associated skin lesions, the genotoxicity of arsenic,  the metabolism,
body burden, and  distribution of this element, and the possibility of threshold
effects.  The Technical  Panel's findings are summarized in the Executive  Summary
(Part II)  and detailed in the remainder of this report.   Additional  technical
                                       1

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analyses appear in the five  appendices.

     A draft of the Technical  Panel 's  Special  Report was peer  reviewed at a

public workshop held in Hunt Valley, Maryland,  on  December  2-3,  1986.  The Panel

revised its report in line with  many helpful peer  review comments  and presented

a revised document to the  Risk Assessment Forum on March 27, 1987.  The Forum's

comments and recommendations have  been  incorporated.

     This report is designated as  a "Special Report" to distinguish this analysis,

which is deliberately limited to the skin cancer and nutritional essentiality

issues identified above, from comprehensive  risk assessments that  fully analyze

all indicated health effects and fully conform with  EPA's Guidelines  for Carcin-

ogen Risk Assessment (U.S. EPA,  1986;  hereafter "cancer guidelines").  The

Special Report addresses many of the hazard  identification, dose-response

assessment  (Appendix B), and risk  characterization parameters  called  for in  the

cancer guidelines, but it does not fully assess or characterize  arsenic risks

for skin cancer nor does it  analyze the other  cancers  associated with exposure

to this element. V

     Agency scientists and decision-makers  should  be aware  that  the lifetime
I/  There is evidence of an association between arsenic  ingestion and  an
~   elevated risk of cancer of various internal  organs (e.g.,  lung,  liver,
bladder) (see Appendix C and text p.  17).   This association is not discussed in
detail in this report because information  needed to quantify the dose-response
for internal cancers was not available.  As developed in Parts V and VI, the
available information merits consideration in the overall  assessment of arsenic
risk to humans, and further research  is warranted.

    The skin cancer analysis presented here, as well as  the ancillary  issues
discussed in connection with this analysis, supersedes corresponding discussions
in the 1984 HAD.  The Panel recommends, however, that EPA offices consult the
HAD for information on the other forms of arsenic-induced cancer and other
arsenic health effects.  Also, as explained in the cancer guidelines (U.S.  EPA,
1986), appropriate exposure information must be considered along with  the
health effects data to develop complete risk assessments for this element.

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cancer risks and other analyses in this report apply to a form of cancer that

is treatable and that generally has a good survival  rate in the United States.

For this reason, the estimates for arsenic-induced skin cancer may have different

implications for human health status than comparable numerical  estimates would

have for more fatal  forms of cancer, including arsenic-induced lung cancer for

which the lifetime cancer risk is 4.3 x 10~3 per ug/cubic meter.  Because an

examination of the regulatory significance of this difference was beyond the

purview of the Risk Assessment Forum, the Forum directed this question to EPA's

Risk Assessment Council.

     Based on its review  of the Forum's Special  Report, the Council  developed

the guidance for Agency decisions on the risk of skin cancer from exposure to

arsenic.  The Council's statement is set forth below.

          In most of its  cancer risk assessments,  EPA does not distin-
     guish between the projected number of cancer  cases and the
     projected number of  fatalities resulting from those cases.  This
     is appropriate in most cases, since we are  usually dealing with
     cancer of internal tissues which generally  have a high fatality
     rate.  (Two instances in which the Agency has explicitly distin-
     guished between fatal  and non-fatal  cancers are skin cancers
     resulting from increased UV exposure due to ozone depletion and
     cancers of various sites resulting from exposure to radionuclides.)
     These projections are usually based on extrapolations from animal
     studies where human  data are lacking.   While  there is some
     agreement between the sites of action of carcinogens in animals
     and human data, there are many instances in which the target
     organs are different.   This uncertainty is  eliminated when we have
     human data.   Also, in most cases of chemical  carcinogens,  the
     risk assessment shows  that non-cancer health  effects are not
     likely to occur at exposure levels established  to protect  against
     potential  cancer impacts.

          In contrast to  the usual  situations faced  by the Agency,
     human evidence  is available in the case of  ingested inorganic
     arsenic.   There are  epidemiological  studies sufficient for risk
     extrapolation which  show that  arsenic  causes  several  forms of
     non-melanoma  skin cancer,   in  weighing the  cancer evidence,  three
     end  points are  relevant:   total  skin cancers, the fraction of
     those cancers that are  fatal,  and  internal  cancers.   The Forum
     Report  reviews  qualitative  considerations and develops  risk
     estimates  for total  skin  cancer.   It  also provides  information
     relating  to the  fraction  of  those  cancers that  are  likely  to  be

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fatal.  This latter estimate is uncertain because of a lack of
data on arsenic-induced skin cancer in the U.S.  population.  The
document concludes that the percentage of fatal  tumors could
range from 1% (based upon the experience of Caucasians in the U.S.
with non-melanoma sun-induced skin cancer, which are similar in
type, but not location, to the arsenic-induced tumors) and 14%
(based upon the experience of Taiwan population, which may have
standards of nutrition and health care which are different from
those in the U.S.).  Finally, the potential for an internal
cancer end point can only be recognized qualitatively since data
necessary to quantify this risk are currently unavailable.  There-
fore, the contribution of this end point to total mortality
associated with exposure to ingested inorganic arsenic is unknown.

     An additional factor of concern is the possibility that
arsenic may be a nutritional requirement for humans.  There are
no relevant data from human populations to decide this issue,
but laboratory studies suggest that arsenic may be an essential
nutrient in animals.  This possibility should be considered in
evaluating the impacts of attempting to control  exposure and,
therefore, risk to very low levels.

     Finally, there is some concern that the method of high-to-
low dose extrapolation used in the quantitative assessment might
lead to an overestimate of the risk.  As the Report discusses,
there are data on the genotoxicity, metabolism and pathology of
arsenic which would argue for a sublinear dose-response relation-
ship.  However, a more complete understanding of these data is
needed before they can be factored with confidence into the risk
assessment process.

     Therefore, risk management decisions need to reflect consid-
eration of all of these factors.  Quantitative estimates can be
made for the total number of cancers, both fatal and non-fatal.
Both are clearly adverse health effects.   In addition to the
risk of death they impose, these skin cancers result in
increased medical costs, a small increased risk as a result of
medical treatment, and in increased anxiety for patients and
their families.  Limitations in data, however, limit the quantita-
tive accuracy with which we can determine  the distribution of
fatal vs. non-fatal cancers.  Similar data limitations preclude
a quantitative statement about the impact  of the potential essenti-
ality of arsenic, the possible association of ingested arsenic
with the generation of internal cancers, or the appropriateness
of alternative risk extrapolation  procedures.

     Experience has shown that in  such cases of  scientific uncer-
tainty, the Agency is well-served  by adopting a  generally  applicable
science policy position, based upon the existing scientific data
that can change in response to significant changes  in the  data
base.  Adopting a uniform science  policy position that is  consistent
with the science  improves the cross-Agency consistency of  both
the  risk assessments and the risk  management decisions based
upon those assessments.

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          Therefore,  in  view of  the  following  considerations, which
     are discussed  in detail  in  the  Report,

          1.   The Taiwanese studies  are  appropriate  for  use  in  assess-
              ing the risk  of arsenic-induced  skin cancers.

          2.   Only  a  small  fraction  of arsenic-induced skin  cancers
              are fatal.

          3.   The non-fatal skin cancers remain  of some  concern.

          4.   The dose-response  curve for the  skin cancers may  be
              sublinear,  in which case the cancer potency  in this
              Report  will  overestimate the risks.

          5.   Arsenic may  cause  cancer in internal organs, a consider-
              ation which  is beyond  the  scope  of this Report.

          6.   Arsenic is  a  possible, but not proven, nutritional
              requirement  in animals. There are no  direct data on
              the essentiality of arsenic in humans.

     the Risk Assessment Council  recommends  that, for purposes  of
     consistency in risk  assessment,

          a.   Risks of skin cancers  associated with  the  ingestion of
              inorganic  arsenic  be estimated using a cancer  potency
              (slope  factor) of  5 x  1CT5 (ug/L)"1, derived in the
              Forum's Report.

          b.   The estimates of risk  resulting  from ingestion of in-
              organic arsenic be modified downwards  by one order of
              magnitude,  through the use of  a  modifying  factor  of 10
              to reflect  the seriousness of  impacts  of the exposure,
              primarily  the likelihood of inducing lethal  cancer.

     The Administrator has  requested Science Advisory Board  review

of the Council's recommendation.

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                             II.   EXECUTIVE  SUMMARY

A.  BACKGROUND
     A Technical  Panel  of the U.S.  Environmental  Protection  Agency's  Risk
Assessment Forum has  studied three  special issues regarding  certain health
effects, particularly skin cancer,  associated  with arsenic  ingestion:   (1)  the
validity of the Taiwan  study and  its  use  for dose-response assessment  in the
U.S. population,  (2)  the interpretation and  use  of skin  lesions  reported as
arsenic-induced skin  cancers, and (3)  the role of arsenic as an  "essential"
nutritional requirement in the human  diet.   The  Technical Panel  also  reviewed
auxiliary information on genotoxicity, metabolism, and other factors  that might
suggest the most appropriate approach  to  dose-response assessment.
     In brief summary,  the analysis shows a  causal relationship  between ingestion
exposure to arsenic and an increased  risk of skin cancer.  This  leads  to classi-
fication of this  element as a Group A human  carcinogen under EPA1s cancer guide-
lines (U.S. EPA,  1986).  Analyses of  data on genotoxicity, metabolism,  and
pathology yielded information on  possible carcinogenic mechanisms for  arsenic.
However, there is not sufficient  information to  evaluate a  dose-response according
to any specific mechanism that one  may postulate.  In the absence of  fully
persuasive evidence for any of the  possible  mechanisms,  a generalized  multistage
model that is linear  at low doses was  used to  place  an upper bound on  the
expected human cancer dose-response.
     Using data from  a  human population  for  which the lowest dose level  in  drinking
water was approximately 10 ug/kg/day,  the maximum likelihood estimate (MLE) of
skin cancer risk  for  a  70-kg person consuming  2  liters of water  per  day contami-
nated with 1 ug/L arsenic ranyes  from 3  x 10~5 (based on Taiwanese  females) to
7 x iu~5 (based on Taiwanese males).   In  other terms, the MLE of risk due to

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1 ug/kg/day of arsenic  intake ranges from 1  x  10'3  to  2  x  1CT3.   These  estimates
are about an order of magnitude  lower than those  presented in  the 1984  HAD.
These risk estimates are based on  a  dose-response model  that assumes  linearity
at low doses and would  overestimate  risk  if  risk  decreases faster than  linear
at low doses or if a threshold for arsenic-induced  skin  cancer exists.
     The available data on nutritional  "essentiality"  do not fully resolve  the
questions raised.  Arsenic is a  possible  but not  proven  nutritional  requirement
in animals.  If arsenic is in fact an essential nutrient in animals,  it is
likely to be essential  in humans,  but there  are no  data  on this  issue.   If
arsenic is essential, there is no  clear scientific  basis for deciding how to
use this information in relation to the dose-response  information.
     This report summarizes the  Technical Panel's review and analysis of relevant
data.  To fully characterize the risk from arsenic  exposure in human  populations,
exposure information and the 1984  HAD on  the inhalation  route  of exposure must
be considered along with the findings in  this  report.   A brief synopsis follows.

B.  VALIDITY OF DATA FROM TAIWAN
     The Technical Panel believes  that results from the  Tseng  et al.  (1968)  and
Tseng (1977) studies demonstrate a causal association  between  arsenic ingestion
and an elevated risk of skin cancer subject  to certain limitations.   These
investigators studied the prevalence of hyperpigmentation, hyperkeratosis,  and
skin cancer in 40,421 residents  of 37 Taiwan villages  in which arsenic  in well-
water ranged from <0.001 ppm in  shallow wells  to  1.82  ppm. The  428  cases of
skin cancer (10.6/1,000) showed  a  clear-cut  increase in  prevalence with exposure.
No cases of skin cancer, hyperpigmentation,  or hyperkeratosis  were reported  in a
comparison population of 7,SOU people who were essentially not exposed  to arsenic
in drinking water.

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     Reliance on  these  data  is  based  on  several  considerations:   (1)  the  study
and comparison populations were large enough  (40,421  and  7,500,  respectively)
to provide reliable estimates of the  skin  cancer prevalence  rates;  (2)  a  statisti-
cally significant elevation  in  skin cancer risk  among the exposed population
over the comparison population  was observed many years after first exposure;
(3) the data show a pronounced  skin cancer dose-response  by  exposure  level;
(4) the exposed and comparison  populations were  similar in occupational  and
socioeconomic status, with arsenic-contaminated  water the only  apparent
difference between these two groups;  and (5)  over 70% of  the observed skin
cancer cases were pathologically confirmed.
     There are also important uncertainties in the studies of the Taiwanese
population, including (1) chemicals other  than arsenic in the drinking water,
which may have confounded the observed association between skin cancer and
arsenic ingestion; (2)  the  lack of blinding of the examiners, which may have
led to a differential  degree of ascertainment between the exposed and comparison
populations; and (3) the role of diet in the  skin cancer  response observed  in  the
exposed population.  The influence of these uncertainties remains to  be deter-
mined, but they signal  a need for cautious characterization  of  the risk.
     Given the findings in this and other  studies (see Appendix A), arsenic  is
classified as a Group A human carcinogen for  which there  is  sufficient evidence
from epidemiologic studies to describe a causal  association between exposure  to
this agent and human cancer.

C.  BIOLOGICAL CONSIDERATIONS FOR DOSE-RESPONSE  ASSESSMENT
     To develop the dose-response assessment, the Technical  Panel considered
auxiliary information on the pathology of arsenic-associated skin lesions,
yenotoxicity, and the metabolism of this element that might shed light on
biological or chemical  processes leading to arsenical-induced cancer.  The
                                       8

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Technical Panel  looked particularly for information  that would help  determine
whether arsenically-induced cancer is more appropriately analyzed using non-
threshold or threshold assumptions, and whether arsenic-induced carcinogenicity
is linear at low doses.
     The Panel  studied the possibility that nonmalignant arsenic-induced skin
lesions  (e.g.,  hyperpigmentation, hyperkeratosis)  occur more frequently at
exposure levels below which skin cancer is observed, providing a basis  for
analyzing arsenic-induced skin cancer as a threshold phenomenon.  The Panel
found, however, that these lesions are not always  precursors to malignant lesions
and that some malignant lesions arise de novo.   Thus,  characterization  of the
skin lesions established end points of interest for  dose-response assessment,
and suggested that nonmalignant lesions may serve  as useful  biological  markers
of exposure to arsenic, but did not resolve uncertainties regarding  nonthreshold
approaches for quantifying arsenical  skin cancer.
     Data from genotoxicity studies raise a number of  questions.  Arsenic does
not appear to induce point mutations, but arsenicals increase the frequency  of
sister chromatid exchanges and chromosome breakage in  cultured cells, including
human cells.  Such chromosome breaks could lead to stable chromosome aberrations,
which require a minimum of two hits with a loss or exchange  of genetic  material,
events that would be compatible with nonlinear kinetics and, therefore, a sub-
linear dose-response relationship.
     Information on the absorption, deposition, and  excretion of ingested arsenic
shows that arsenic is handled by enzymatic and nonenzymatic  reactions.   It  shows
that,  except for high exposure levels, inorganic arsenic is  converted non-
enzymatically to arsenite (+3).   In vivo methylation of arsenic to monomethyl
and dimethyl arsenic (the latter being the major methylated  metabolite) appears
to be a  route of detoxification for acute of frets  and  a general  route of

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elimination.   Although  some  data  suggest  that methylating  capacity  in  humans
can become saturated,  studies  to  delineate  the  role  of  biomethylation  in  chronic
arsenic toxicity are needed.   Arsenic  is  known  to  deposit  in  certain organs,
including the skin,  liver, lung,  and kidney, a  pattern  compatible with arsenic-
associated cancer in these organs.
     Scientists at EPA  and elsewhere,  faced with uncertainty  about  mechanisms
of chemical  carcinogenesis,  often analyze chemical carcinogens  as though  simple
genetic changes initiate a carcinogenesis process  that  is  linear at low levels
of exposure.   Extrapolation  procedures from high to  low doses then  depend on
models that are also linear  at low  doses.  Since for arsenicals, as for a
number of other carcinogens,  there  is  no  evidence  of point mutations in standard
genetic test systems,  the single-hit theory for chemical carcinogenesis may not
be applicable.  Similarly, the structural chromosomal rearrangements that have
been implicated in some cases of  carcinogenesis would be expected to require  at
least two "hits", if not more.  In  addition, the known  toxic  effects of the
inorganic arsenicals are not inconsistent with  the idea that  multiple  inter-
actions are involved in producing adverse cellular effects.
     While consideration of  these data on the  genotoxicity, metabolism, and
pathology of arsenic has provided information  on the possible mechanism by
which arsenic may produce carcinogenic effects, a  more  complete understanding
of these biological  data in  relation  to carcinogenesis  is  needed  before they
can be factored with confidence into  the risk  assessment process.

D.  DOSE-RESPONSE ASSESSMENT
     The data from Taiwan have several strengths  for quantitative  risk assessment:
(1) the number of persons in the  exposed population and the comparison populations
(40,421 and 7,500, respectively)  is large;  (2)  the number  of  skin  cancer  cases
in the exposed population is relatively large  (428 observed); (3)  the  skin cancer
                                       10

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prevalence rates are reported by 12  different age  and  dose  groups;  and  (4)  the
data show a pronounced skin  cancer  dose-response.
     At the same time, limitations  in the Taiwanese studies introduce uncertain-
ties regarding applicability of this information to the U.S.  population.   These
uncertainties include:  (1)  the potential exposure to  sources of arsenic  other
than drinking water (e.g.,  diet) which could result in an overestimation  of the
cancer risk; (2) the higher case-fatality rate and earlier median age of  onset
for Blackfoot disease, which may also be arsenic related, thus resulting  in an
underestimation of cancer risk; and (3) differences in diets other than arsenic
content, between the Taiwanese and  U.S. populations, which could modify the
carcinogenic response to arsenic observed in Taiwan.  (The diet of the arsenic-
exposed population was reported to  be "low in protein  and fat and high in
carbohydrates, particularly rice and sweet potatoes.")
     Skin cancer cases in these studies included squamous cell carcinoma, basal
cell carcinoma, in situ squamous cell carcinoma (Bowen's disease) and Type B
keratoses, which Yen (1973)  defines as intraepidermal  carcinomas.  Type A
keratoses were defined by Yeh (1973) as benign tumors.  Although these keratoses
are also found in the exposed population and may pose  a carcinogenic hazard,
they were not included in the quantitative estimate of cancer risk because of
uncertainty regarding their progression to squamous cell or basal cell  carcinomas.
In addition, there was no information on age-specific  prevalence rates for this
lesion.
     The Technical Panel  developed  the dose-response assessment using a multistage
extrapolation model that incorporates low-dose linearity.  This choice was guided
by principles laid down by  the Office of Science and Technology policy (OSTP,
1985)  and in EPA's cancer guidelines (U.S. EPA, 1986), which set forth the
principles that follow.
                                       11

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     No sirujle mathematical  procedure  is  recognized  as  the  most  appropriate  for
     low dose extrapolation  in  carcinogenesis.   When relevant  biological  evidence
     on mechanism of action  exists  (e.g.,  pharmacokinetics, target  organ  dose),
     the models or procedures  employed should  be consistent with the  evidence.
     When data and information  are  limited,  however, and when  much  uncertainty
     exists regarding the mechanism of carcinogenic  action, models  or procedures
     which incorporate low dose linearity  are  preferred when compatible with
     the limited information.

     The multistage model chosen by the Technical  Panel  differed from the model

used in the Agency's Health  Assessment Document  for  Inorganic  Arsenic (U.S.  EPA,

1984) in that the current model is  both linear and quadratic in  dose. Other

changes between the current model and  that presented in 1984 include  the  use of

a life-table approach in the current analysis  to calculate  a lifetime risk of

skin cancer.  The previous estimate of risk  was  a lifetime  estimate,  assuming

that an individual lived to be 76.2 years  of age. The  current model  uses a

maximum likelihood approach  whereas the previous model  was  a least  squares

linear regression of prevalence rates.  Also,  the current analysis  assumes that

Taiwanese males in the arsenic-endemic area  of Taiwan drank 75%  more  water than

does the U.S. population.  The current analysis  also estimated a risk from the

data on Taiwanese females, which was not done  in the 1984 analysis  and assumed

that Taiwanese females drink the same  amount of  water per day  as does the U.S.

population.

     Based on the current model and the Taiwanese data, the MLE  of  cancer risk

for a 70-kg person who consumes 2 liters of water per day contaminated with

1 ug/L of arsenic ranges from 3 x 10~5 (on the basis of Taiwanese females)

to 7 x 10-5 (on the basis of Taiwanese males); or, equivalently, the  MLE  due

to 1 ug/kg/day of arsenic intake from  water ranges for  1 x 10"3  to  2  x 10~3.

These estimates are about an order  of  magnitude  less than those  presented in

the 1984 HAD.  Data from two studies (Cebrian et al., 1983; Fierz,  1965)  were

not suitable for dose-response estimation because of lack of information  on

population age structure or lack of a  control  group.  These studies were

                                       12

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suitable, however, for comparing with the Taiwanese-based risk  estimates,  and
were consistent with the dose-response for Taiwan.
     The proportion of nonmelanoma skin cancer cases  in the United States
attributable to inorganic arsenic in the diet, the  largest arsenic exposure  for
most Americans, is quite low.  Assuming that the dietary intake of inorganic
arsenic, including the intake from water and beverages, is 0.25 ug/kg/day  and
has been constant for the past 85 to 100 years, the number of skin cancer  cases
per year attributable to inorganic arsenic in food, water, and other beverages
would be 1,684.  This is about 0.34% of the 500,000 cases of nonmelanoma skin
cancer cases that occur among U.S. Caucasians each  year.  For reasons described
in the text, even 0.34% is an overestimate, however.

E.  NUTRITIONAL ESSENTIALITY
     The Technical Panel also reviewed several studies on arsenic as a possible
essential element in the diet to determine the overall impact of arsenic exposure
on human health.  The information bearing on whether arsenic may be an essential
element in human nutrition is incomplete.  The studies of chickens and goats
suggested that adverse growth and reproductive effects may be attributable to
arsenic deficient diets, and that arsenic may be required in the diets of  these
animals.  The Technical Panel is unaware of comparable studies in human populations,
While it is plausible that arsenic is a nutritional  requirement in animals and a
possible requirement in humans, additional studies  are needed.
     In the absence of definitive information, the  likelihood that arsenic is  a
human nutrient must be weighed qualitatively along  with risk assessment
information for carcinogenic effects.  There is little information to determine
the levels of arsenic that would be essential  in the  human diet, the nature  of any
human effects,  or the degree to which current dietary levels are adequate.  It
is reasonable to assume, however, that there is no  sharp threshold of essentiality
                                       13

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and that a spectrum of effects  would  occur  below  adequate  levels,  with  the  adverse
effects of arsenic  deficiency increasing  in severity  as  exposure  is  reduced.   The
risk of cancer would decrease as exposure is reduced,  but  some  risk  is  assumed
to exist at all  levels of exposure.   At low levels  of exposure,  it is  possible
that both could occur.

F.  CONCLUSION
     The Technical  Panel  concludes that the Taiwan  study demonstrates  a causal
association between arsenic ingestion and elevated  skin  cancer  risk.  In consider-
ing the weight of the human evidence  of carcinogenicity, the possibility of
bias, confounding,  or chance has been considered.  However, there is a  strong
dose-response relationship, and independent studies in other countries  are
concordant in showing the association between arsenic ingestion and elevated
skin cancer risk.
     Using a multistage model of the skin cancer dose-response data for Taiwan,
the MLE of lifetime cancer risk for a 70-kg person who consumes 2 liters of
water  per day contaminated with 1 ug/L of arsenic ranges from 3 x 10~5 (on  the
basis  of Taiwanese females) to 7 x 10~5  (on the basis of Taiwanese males).
The MLE due to 1 ug/kg/day of arsenic intake from water ranges from 1 x 10~3  to
2  x 10~3.  Although the absence of point mutations in genetic tests and certain
metabolic  information  provide some basis for considering alternative risk
assessment approaches, conservative assumptions  are consistent with arsenic's
known  carcinogenic effects  in human populations, and  an absence of  significant
information that provides  a  sound basis  for an alternative  approach.
     An  important  consideration in evaluating the estimated risks has  to do with
the  nature of the  carcinogenic  response  following arsenic  exposure.  Basal  cell
carcinomas generally  do  not rnetastasize  and, thus, do not  have much potential
to cause  death.  They  may  invade  locally,  however, and  if  not  attended to, can
                                        14

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spread to vital  centers and lead to morbidity and death.   Squamous cell  carcinomas
have some potential  to metastasize to contiguous  structures.   Mortality  for
squatnous cell  carcinomas is greater than for basal  cell  carcinomas,  but  is lower
than that for  the other primary skin tumors, malignant melanomas (not associated
with arsenic exposure).
     In summary, skin cancers arise in humans following certain exposures to
arsenical compounds.   The tumors are generally superficial,  easily diagnosed
and treated, and are associated with lower mortality than cancers at most other
sites.  Certain  internal cancers also appear to be associated with arsenic
exposure.  Lacking definitive information on mechanism of carcinogenic action
and pharmacokinetics, the Agency has relied on a  linear model  for extrapolation
from higher to lower daily exposures to place an  upper bound  on the  dose-response
estimates.  Even in  the absence of definitive biological  information, aspects
of the analysis, including lack of genotoxicity and pharmacodynamic  considerations,
suggest that a linear extrapolation may overestimate the  risks from  low-level
arsenic exposure.  Risks may fall  off faster than linearly and it is possible
that thresholds  might exist, but additional  data  are needed  to develop this
premise.
                                       15

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         III.   HAZARD  IDENTIFICATION AND EPIDEMIOLOGIC STUDIES SUITABLE



                          FOR  DOSE-RESPONSE EVALUATION








     A primary issue  before  the  Technical  Panel  was  the  validity  of  the  Taiwan



study (Tseng et al.,  1968; Tseng,  1977), which  had been  used  in developing  the



1984 quantitative risk assessment  for  skin cancer  from ingested arsenic.  After



reviewing the epidemiologic  literature,  which  includes many reports  of an



association between  arsenic  exposure  and skin  cancer (see  Appendix  A), the  Panel



focused on three studies.  The Panel  found that the  Taiwan study  provided



evidence of a causal  association between arsenic ingestion and  skin  cancer  in



humans, resulting in  its classification  as a  Group A human carcinogen under



EPA's cancer guidelines (U.S.  EPA, 1986).   Two other studies  (Cebrian et al.,



1983; Fierz, 1965) showing a skin  cancer response  from arsenic  ingestion were



used for comparison  with predictions  from  the dose-response seen  in the  Taiwan




study.





A.  PRELIMINARY CONSIDERATIONS



     Several of the studies  reviewed  in this  section describe medical conditions



other than arsenic-induced skin cancer.   Before the  epidemiologic studies are



discussed, clarification of these conditions  are needed.



     As discussed below, sun-induced  skin  cancer features skin  lesions comparable



in many respects to those produced by arsenic.  However, since arsenic-induced



skin cancer generally occurs on parts of the  body where  sun-induced skin cancer



lesions are rarely found, the former can be distinguished from the latter.



     Blackfoot disease or gangrene is another medical condition observed in



areas of  chronic arsenicism.  In the Taiwan study,  persons with Blackfoot



disease were more likely  to have developed skin cancer than persons who did not



have Blackfoot disease.   Because Blackfoot disease  patients in Taiwan had  a low



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survival  rate and because Blackfoot disease had an earlier median  age of onset
than did skin cancer, it is possible that some potential  cancer cases among the
Blackfoot disease cohort died without being counted in the Tseng et al.  (1968)
prevalence study.
     Finally, excess incidences of some life-threatening  malignancies (e.g.,
cancer of the lung,  liver, and bladder) are observed in arsenic endemic  areas.
This information has not been fully used in this report because data necessary
to quantify risk (e.g., dose-response data, information on mortality rates, and
population age structure) were not available to EPA.  Studies and  case reports
that describe an association between arsenic ingestion and internal  cancer are
briefly reviewed in  Appendix C.  Additional data from the studies  by Chen et
al. (1985, 1986) showing an association between internal  cancer of several
sites and arsenic ingestion have been requested for use in dose-response
estimation.

B.  REVIEW OF STUDIES
    Three studies identified in the literature review are suitable for quanti-
tative evaluation of skin cancer risk.  Two are retrospective studies of persons
exposed to arsenic in drinking water and one is of persons who had been treated
with a trivalent arsenical medicinal (Fowler's solution).  As stated above,
none of the studies  reviewed for this report provides enough data  to quantify
the internal  cancer  dose-response due to arsenic ingestion.
     1.  Taiwan Study
     Tseng et al. (1968) and Tseng (1977) reported the results of  a large
cross-sectional  survey concerning health problems of persons living in an area
of Taiwan where there were high concentrations of arsenic in the artesian well
water supply.  Use of these wells began in the years 1900 to 1910.  The wells
were reported to be  100 to 280 meters deep, with 80% being between 120 and 180
                                       17

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meters in depth.   The wells were drilled to solve  the problem of drinking  water
in the area since the water from shallow wells near the seacoast was often
salty.  Water from the shallow wells was usually free from arsenic (<0.001 ppm),
although some had a considerably higher concentrations (1.097 ppm).   In 1956,
water containing  0.01 ppm arsenic was piped to many places from the  reservoir
of the Chia-Nan irrigation system.  In February 1966, a tap water supply was
made available to almost the whole endemic area in Tainan County.  (Personal
communication with Drs.  Tseng and Chien-Jen Chen of the National Taiwan University
indicates that the artesian wells are still used [to some extent] during dry
periods.)  The arsenic level  in the wells varied somewhat over time  but appeared
to be highest during Taiwan's rainy season.  In the early 1960s the  concentrations
of arsenic in the different wells ranged from 0.01 to 1.82 ppm.
     By 1965, physical examinations had been performed on a total population of
40,421 in 37 villages.  The entire population in all villages in the study area
numbered 103,154.  The period of the survey was not specified by the authors in
their publication, but personal communication indicates that the survey period
was about 2 years.  Investigators gave special attention to hyperpigmentation,
hyperkeratosis, and skin cancer.  A control population of 7,500 persons, with
age distribution  similar to that of the study population but from areas in
which arsenic was not endemic in the drinking water supply, was examined in the
same way as the arsenic-exposed persons.  The arsenic in the drinking water of
this comparison population ranged from non-detectable (detection limit not
specified) to 0.017 mg/L.  Males in the study and control populations were
engaged in similar occupations (fishing, farming,  and salt production).  Four
hundred and twenty-eight cases of skin cancer (10.6/1,000) were found in the
study population.  Of these, 153 were reported to be histologically confirmed.
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There were no cases in persons less  than 20 years  old and the  prevalence increased
markedly with age,  except For women  over 70.  The  male-to-female skin cancer
prevalence ratio was 2.9:1.   There was a clear-cut increase in prevalence with
exposure.
     Of the 428 people with  clinically-diagnosed skin cancer,  72% also had
hyperkeratosis £/ and 90% had hyperpigmentation.  Seventy-four percent of the
malignant lesions were on areas not  exposed to the sun.   Ninety-nine percent
of the people with skin cancers had  multiple skin  cancers.   Yeh (1973) studied
303 of the 428 skin lesions  originally reported by Tseng et al. (1968) histo-
logically:  57 were squamous cell  carcinomas; 45 were basal cell carcinomas (28
deep, 17 superficial ); 176 were intraepidermal carcinomas (23  Type B keratoses,
153 Bowen's disease); and 25 were  combined forms.
     The prevalence rate for Blackfoot disease was 8.9 per 1,000 in the study
population.  Prevalence rates for  keratosis and hyperpigmentation in the study
population were 183.5 and 71 per 1,000, respectively.  The youngest patient
with hyperpigmentation was 3 years old, the youngest with keratosis was 4, and
the youngest with skin cancer was  24.
     No cases of skin cancer, Blackfoot disease, hyperkeratosis, or hyper-
pigmentation were found in the control population  of 7,500.  One could argue
that this suggests a potential bias  on the part of the examiners since they
were not "blinded" as to whether the persons being examined were from the
arsenic area or not.  Thus,  they might have made a greater effort to ascertain
cases in the study population than in  the comparison population.  All of the
study subjects were examined by the  same physicians according  to a common
2y  These are assumed to be benign hyperkeratoses as opposed to the Type "B"
    hyperkeratoses described by Yeh (1973) as intraepidermal carcinomas and
which were counted as skin cancer.
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protocol  however,  the  disease was  relatively easy to  diagnose  differentially
(Chen et  al.,  1986).   Furthermore,  over  70% of  the  skin  cancer in  the  exposed
population were histopathologically confirmed.   Lastly,  at  least with  regard to
skin cancer,  the fact  that no  cases were found  in  the comparison  population  is
not inconceivable, since the expected  number of skin  cancer cases  in the  control
population of 7,500 persons (using the skin cancer rate  for Singapore  Chinese
from 1968 through 1977) is a little less than 3.  Using  this as the expected
prevalence, the probability of observing no cancer cases is 0.07.
     Subsequent analysis of the drinking water  revealed  substances other  than
arsenic including bacteria and ergot alkaloids   (Andelman and Barnett,  1983).
Neither of these two substances has been previously associated with skin  cancer,
and  it seems unlikely that these two substances could be considered confounders.
Also, as outlined in Appendix  A, a multitude of studies  have demonstrated an
association between arsenic ingestion and skin   cancer.  It seems unlikely that
the  same confounders that might have been present in the Tseng et al. (1968)
study would have  been present in the other studies as well.  Chen noted,  however,
that the presence of substances in the well water other thap arsenic, although
not  confounding,  might  have produced a  synergistic effect  (Chen,  1987).
      2.  Mexican  Study
      Ccbri.m <>t. .il . (19R3)  <»nd  Alborps  ot.  
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water.  Monitoring from August 1975 to May 1978 showed the average arsenic
level to be 0.411 +_ 0.114 mg/L (20 samples)  in El  Salvador de Arriba and 0.005
+ 0.007 mg/L (18 samples) in San Jose del  Vinedo Diego (in each case about 70%
pentavalent, 30% trivalent), varying somewhat over time.   Historical exposure
levels are not known; organoarsenical pesticide runoff into the water supply
may have been an additional  source of arsenic (in both towns) before 1945.
     Dr. Mariano Cebrian (1987), the primary investigator, indicates that there
was one well per community,  and that the well was located in the center of each
of the respective towns.  Each well had been drilled to a depth of about 70 to
100 meters.  The water was then distributed to approximately ten holding tanks
from which the residents drew their water.  In addition to arsenic, fluoride
was also reported to be present in the water supply of the exposed town.
Arsenic concentrations in the water supply were reported to correlate with
fluoride concentrations in the Region Lagunera (Cebrian,  1987).  Chemical
analysis was not done for any substances other than fluoride and arsenic.
     Every third household in the two towns was sampled,  and each member
present in the household was examined.  Data on exposure sources and number of
years of exposure were obtained by means of questionnaires from 296 people from
El Salvador de Arriba and 318 people from San Jose del Vinedo Diego.  Physical
examinations were performed on each resident in the sampled households to assess
hyperpiginentation, hypopigmentation, papular and palmoplantar keratoses, and
ulcerative lesions.
     A 3.6-fold greater risk of ulcerative lesions, compatible with a clinical
diagnosis of epidermoid or basal cell carcinoma, was reported in the exposed
population as compared to the controls.  This report was based on four cases
(which were not histologically confirmed)  from El  Salvador de Arriba (preva-
lence rate of 14/1,000) and  no cases from San Jose del Vinedo Diego.  In con-

                                       21

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trast to the observation  of  Tseng  et  al .  (1968),  there was  no  sex  difference in
the distribution of lesions.   The  shortest latency  period  for  skin cancer  (one
case) was 38 years which  was also  the age of  the  individual  (age was  similar to
residence in 75% of the patients.) Of the remaining  three  cases,  two were  in
the 50 to 59 age group and one was in the _>_ 60 age  group.   Hypopigmentation was
discovered in 17.6% of the exposed persons, hyperpigmentation  in 12.2%,  and
palmoplantar keratoses in 11.2%.   No  biopsies were  taken.   No  other skin lesions
were reported for the exposed town; however,  peripheral  vascular disease such
as that reported in Taiwan (i.e.,  Blackfoot disease)  has also  been reported in
the arsenic endemic area  of  Region Lagunera in Mexico (Salcedo et  al.,  1984). £/
The shortest latency for hypopigmentation was estimated  to be  8 years,  for
hyperpigmentation and palmoplantar keratosis  12 years, and for papular  keratosis
25 years.  Based on average  drinking  water arsenic  concentrations  of 0.41  mg/L,
Cebrian calculated the following minimum total ingested  doses  for  the development
of cutaneous toxicity:  hypopigmentation, 2 g; hyperpigmentation,  3 g;  keratoses,
3 g; invasive carcinoma,  2 g.  The minimum detection  time and  the  lowest cumulative
dose may have been overestimated,  since it is not known  at what age the lesions
may have first become clinically apparent. A few classical arsenic-induced
skin lesions were identified in the control population:   hypopigmentation  in
2.2%, hyperpigmentation in 1.9%, and  palmoplantar keratosis in 0.3%  (Cebrian  et
al., 1983).  The authors speculated that the  occurrence  of lesions in the control
town may have resulted from ingestion of foodstuffs produced in the same region
and contaminated with arsenic.
     In contrast to the situation in  Taiwan,  the Mexican population had limited
3/  The reported Blackfoot disease in Mexico and Taiwan is consistent with a
    report  (Borgono and Greiber, 1972) of Blackfoot disease in an area of Chile
where there is arsenic contamination of the water supply.

                                       22

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 water  supplies, thus enabling more accurate estimates of exposure.  This study
 also presents potential  problems, however.  The study may be biased since the
 examiners knew who were  exposed and who were not.  The possibility of preferen-
 tial diagnosis may not have been as great in this study as it was in the Taiwan
 study,  since cutaneous signs other than ulcerative lesions were observed in the
 control  population.  Also, there was no estimate of non-response  (i.e., the
 number of individuals not present at the time of the interview and/or examination
 is  not reported).
     3.  German Study
     Fierz  (1965) reported on a retrospective study of patients treated with a
 1:1 dilution of Fowler's solution containing 3.8 g arsenic/L.  An accurate
 assessment  of the total  arsenic intake was available from patient records.  A
 total  of 1,450 patients were identified as having received arsenic treatment 6
 to  26  years previously.  Invitations for a free medical examination were mailed
 to  them.  Two hundred sixty-two persons presented themselves for examination;
 100 patients refused to  participate, and 280 could not be located.  The status
 of  the other 808 persons to whom invitations had been mailed was not reported.
 Of  the 262  examined, 64 had been treated with Fowler's solution for psoriasis,
 62 for neurodermatitis, 72 for chronic eczema, and 64 for other disease.
 Twenty-one  cases of skin cancer were found,  comprising 8% of the subjects
 examined.  Multiple carcinomas were found in 13 of the 21 patients;  10 of these
 were multiple basal  cell  carcinomas, described as polycyclic, sharply bounded
 erythemas with slight infiltration.   Single  basal  cell  carcinoma,  squamous cell
 carcinoma,  and Bowen's disease were less frequently encountered.   Of the 21
 patients with carcinomas, 16 showed  distinctly developed "arsenic  warts" on the
 palms and soles,  simultaneously with skin tumors.   The author estimated the
minimum and  mean  latency  period for  carcinomas to be  6 and 14 years,  respec-

                                       23

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tively.   However,  the  latency  period  did  not  appear  to be correlated with dose.
     Hyperkeratosis  was  the  most  frequent sign  of  arsenic toxicity, occurring
in 106 of 262  (40.4%)  of the patients.   In patients  who  had  received the equivalent
of 3 g of arsenic  as the diluted  Fowler's solution,  the  incidence  of hyper-
keratosis was  50%.  The  minimal  latency period  for hyperkeratosis  was  reported  to
be 2.5 years;  the  mean latency period was not reported.   Melanotic hyperpigmen-
tation was found in  only 5 of 262 persons (2%); however, 3  persons reported
that they had  looked "stained" shortly after  taking  arsenic, but that  this
condition had  regressed  over the years.  The  incidence  rates of both  skin
cancer and hyperkeratosis increased with dose.   The  size of the hyperkeratoses
also increased with  dose.  The author also found that the original diagnosis
(psoriasis, neurodermatitis, chronic eczema,  or acne) did not affect  the
development of skin  cancer when dose was controlled for.
     One problem with this study is that a significant proportion of  the ex-
posed population did not participate in the study.  Three hundred and eighty
persons of a total of 1,450 (59%) refused to participate or could not be contacted.
It  is not known what became of 808 other persons to whom invitations  had been
mailed.  The author classified the 262 who did present themselves for examination
into three groups:  those satisfied with the results of the arsenic treatment
and wishing to express  thanks; those in whom side effects were occurring (e.g.,
skin cancer, hyperkeratosis, etc.); and those who were still suffering from the
initial disease and who were eager to get consultation.  This description makes
apparent the possibility of selection bias.  Another problem is the lack of a
control group.

C.  SUMMARY
     The Taiwan (Tseng  et al., 1968; Tseng, 1977), Mexican  (Cebrian et al., 1983),
and German (Fierz, 1965) studies have been discussed in detail because they
                                       24

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have been used as  part of the dose-response  assessment  in  Part  V.   Additional
reports of the association of arsenic  ingestion  and  cancer risk are found  in
Appendix A.  (Reports of an association  between  ingested arsenic and cancers  of
internal organs are discussed in Appendix C.)
     Strengths of  the Taiwan study include:   (1) the study and  comparison  popu-
lations were large enough (40,421 and  7,500  respectively)  to provide reliable
estimates of the skin cancer prevalence  rates,  (2)  a statistically significant
elevation in the skin cancer prevalence  among  the exposed population over  that
of  the comparison  population was observed many years after first exposure, (3)
there was a pronounced skin cancer response  by arsenic  exposure level, (4) the
exposed and comparison populations were  similar in socioeconomic status and
occupation with the only apparent difference between the two populations being
that of arsenic exposure, and (5) over 70% of  the observed skin cancer cases
were pathologically confirmed.
     Important uncertainties of the Taiwan study include:  (1)  chemicals other
than arsenic in drinking water which may have  confounded the observed association
between skin cancer and arsenic ingestion, and  (2) the lack of blinding of the
examiners which may have led to a differential  degree of ascertainment between
the exposed and comparison populations.   Another uncertainty relates to the
possibility that diet may have modified the response.
     The Mexican study found the prevalence of  skin cancer increased in a pop-
ulation exposed to arsenic via drinking water versus a comparison population,
but the sample sizes of the exposed and comparison groups (296 and 318, respec-
tively) were much  smaller than the Taiwan study.  Futhermore, there were only
four cases of skin cancer among the exposed.  The German study of patients who
ingested arsenical medicinals reported a skin  cancer dose-response by the
amount of arsenic  ingested, but there  was no comparison group and many of the

                                       25

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exposed population did not participate  in  the  study.   Both  studies  (Mexican and
German), despite their limitations,  were considered  useful  for quantitative
comparison with the results from Taiwan.  (See Part  V.  Dose-Response  Estimate
for Arsenic Ingest.ion)
     In reviewing the weight of the  human  evidence of carcinogenicity,  the
possibility of bias, confounding or  chance has been  considered.   However,  there
is a strong dose-response relationship, and independent studies in other countries
are concordant in showing the association between arsenic ingestion and elevated
skin cancer risk.
     Considering the above, arsenic  is classified as a Group A human  carcinogen
(U.S. EPA, 1986), for which there is sufficient evidence from epidemiologic studies
to support a causal association between exposure to this agent and cancer.
                                        26

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                IV.   SELECTED ELEMENTS OF HAZARD IDENTIFICATION



     This part summarizes  biological  information relating  to  the  skin  cancer

dose-response for ingested arsenic.   Section  A  reviews  certain pathologic

features of skin lesions associated with  arsenic exposure  and comments on  their

significance.  Section B summarizes the genotoxicity  of arsenic and  discusses

its role in the cancer dose-response  assessment.   Section  C highlights relevant

metabolic information.


A.  PATHOLOGIC CHARACTERISTICS  AND SIGNIFICANCE OF ARSENIC-INDUCED SKIN LESIONS  V

     Several aspects of arsenical  skin  lesions  are briefly reviewed  here to

provide a background for distinguishing the nature and  relative health impact

of the skin lesions upon which  the dose-response assessment is  based.   The

discussion also shows that certain lesions  may  serve  as biological markers of

early arsenic exposure. Subsection  1 describes the pathology of  the various

skin lesions; subsection 2 discusses  the  interrelationship between  these

lesions with respect to progression  from  a  preneoplastic stage  to a  malignant

neoplasm; and subsection 3 examines  the  case-fatality rate of basal  cell and

squamous cell carcinoma.

     1.  Description and Malignant Potential  of Skin  Lesions

     Several different skin lesions  that  are described in various reports of

arsenic-exposed humans are discussed.  Yeh  et al.  (1968),  in  his  study of

patients with chronic arsenicism,  provides  the most complete  description of the

various skin lesions, particularly hyperpigmentation, hyperkeratosis,  and skin
4/  An expert pathologist, Dr. D.S.  Strayer of the University of Texas Medical
    School at Houston, was asked by the EPA Risk Assessment Forum to review the
literature on arsenical skin pathology.  Subsections 1 and 2 of this section are
based on that review.
                                       27

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cancer.   Skin cancer,  as  defined  by  Yen  et  al.  (1968),  includes  intraepidermal
carcinomas (Type B keratosis  and  Bowen's disease),  basal  cell  carcinomas,
invasive squamous cell  carcinomas, and  "combined  lesions."
     Hyperpigmentation is a pathologic  hallmark of  chronic  arsenic  exposure
and may occur anywhere on the body,  typically as  dark  brown patches showing
scattered pale spots.   Hyperpigmentation is not considered  to  be a  malignant
neoplasm or a precursor to malignancy.   Although  it may occur  together with
hyperkeratosis, hyperpigmentation does  not  appear to be directly related  to
hyperkeratosis (i.e.,  they are not different stages in the  evolution of a single
type of lesion, but, ratner,  are  of  different cellular lineage and  are related
only because of their common cause).
     Yen et al. (1968) and Yeh (1973)  reported that arsenical  hyperkeratosis
occurs most frequently on the palms  of  the  hands  and soles  of  the feet; however,
hyperkeratosis may occur at other sites.  Hyperkeratoses usually appear as small
corn-like elevations,  0.4 to 1 cm in diameter.  Yeh (1973)  concluded that in
the majority of cases, arsenical  keratoses  showed very little  cellular atypia
and are morphologically benign.  Thus,  Yeh  (1973) divided the  arsenical keratoses
in the Tseng study £/  (1977; Tseng et al .,  1968)  into two groups:  Type A,
which included mildly  atypical cells,  and a malignant Type B,  which included
cells with more marked atypia.  Authors of some other studies do not make this
distinction.   Yeh et al.  (1968) stated that keratotic lesions of chronic
arsenicism, although histopathologically similar, were distinguishable from
Bowen's disease.  Some pathologists, however,  state that arsenical  keratoses
are difficult  to distinguish from Bowen's disease;  some considered them one and
the same  (Hugo and Conway, 1967).  As discussed later, Type B keratoses may
    The Tseng study is the epidemiologic study that forms the basis of the cancer
    risk estimate associated with ingested arsenic (see sections B and C).

                                       28

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evolve into invasive squamous cell  carcinoma.
     Bowen's disease, an in situ squamous cell  carcinoma, represents a continu-
ation of the dysmaturation processes observed in Type B keratoses.  These lesions
may become invasive, but the frequency is not known.   These lesions are sharply
demarcated round or irregular plaques that may  vary in size from 1 mm to more
than 10 cm, and tend to enlarge progressively.   Arsenic-associated Bowen's
disease is usually multifocal  and randomly distributed and the lesions tend to
arise on the trunk more often than  do arsenical hyperkeratoses.
     Arsenical  basal cell  carcinomas most frequently arise from normal tissue,
are almost always multiple, and frequently occur on the trunk.  The superficial
spreading lesions are red, scaly, and atrophic  and frequently indistinguishable
from Bowen's disease by clinical examination.
     Arsenical  invasive squamous cell carcinomas (referred to as epidermoid
carcinomas in Yeh (1973) and Yeh et al.  (1968)  arise from normal tissue or within
preexisting hyperkeratoses or Bowen's disease.   Persistent fissuring, erosion,
ulceration, and induration are key  clinical features.  Although arsenic-associated
squamous cell carcinomas do not differ histopathologically from sun-induced
squamous cell carcinomas,  they can  be distinguished by their common occurrence
on the extremities (especially palms and soles) and trunk; sun-induced squamous
cell carcinomas appear primarily on sun-exposed areas (i.e., the head and neck).
     Finally, several  reports describe  "combined lesions" that were considered
attributable to arsenic that include both basal cell  carcinomas and Bowen's
disease (Yeh et al., 1968), or mixed squamous cell  carcinomas and basal  cell
carcinomas (Sommers  and McManus, 1953).   Whether these represent true mixed
lesions or coalescence of  two separate  lesions  has  been debated by Sanderson
(1976).   He argues that because arsenical  skin  cancer includes multiple foci,
separate foci  of the same  type of neoplasia or  two  different types of adjacent

                                       29

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neoplasias may eventually collide  and  blend  together,  producing  a  "combined

lesion."

     In summary,  distinguishing  characteristics  of  lesions  of  arsenical  skin

cancer, include multiplicity and distribution on unexposed  parts of the  body

(e.g.,  palms of the hands, soles of  the feet, other parts of the extremities,

and trunk).  Sun-induced basal  cell  carcinomas do not  metastasize  and the

metastatic potential  of squamous cell  carcinomas is low; whether this is also

true for arsenical  skin cancer is  unknown.   As discussed  in subsection 3 of  this

section, there is some basis for speculating that arsenical  skin cancer  may

have a higher metastatic potential than sun-induced skin  cancer.

     2.  Progression of Skin Lesions

     The interrelationship between the various lesions of chronic  arsenicism

was examined to further characterize lesions that would be  used to develop the

dose-response assessment.  For example, the  frequency  of  transformation  from

the benign lesions to the malignant lesions  would better  characterize the

proportion of benign lesions that might be factored into  the dose-response

assessment. 6/  Progression of lesions was also examined  to provide a qualitative

discussion of carcinogenic mechanisms that might indicate the  suitability  of a

particular extrapolation model.   There was not enough  information on progression

of lesions in arsenic-exposed humans for the Technical Panel  to develop a

mechanistic model.   As suggested in section  C of this  part, future studies may

provide useful information.

     The development of arsenical  keratosis   and Bowen's disease into invasive
6/  The EPA cancer guidelines (U.S. EPA, 1986) state that "Benign tumors should
~~   generally be combined with malignant tumors for risk estimates unless the
benign tumors are not considered to have the potential to progress to the
associated malignancies of the same histogenic origin."


                                       30

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 squamous cell carcinoma is documented in certain instances (see Table 1).  Note
 in Table 1 that Yeh et al. (1968) also cited one basal cell carcinoma that
 arose  from keratotic lesions.  Whether the keratoses referred to in the table
 are  of type A or B as described by Yeh et al. (1968) is unknown.  The frequency
 of malignant transformation, however, is difficult to determine because many
 case reports of arsenical skin cancer do not specify the pre-existing condition
 of the skin.  Moreover, analysis of some reports is complicated by lack of
 histopathologic examination or by uncertain terminology.
     Invasive squamous cell carcinoma, basal cell carcinoma,  and Bowen's disease
 ("in situ" squamous cell carcinoma) were used as end points for the cancer dose-
 response assessment.  Type B keratoses were also included since Yeh et al .
 (1968)  had classified them as an intraepidermal  carcinoma which, by inference,
 were malignant.  Although the Type A keratoses were classified by Yeh et al.
 (1968)  as benign, they may have malignant potential.  Type A keratoses were
 not  used in the dose-response assessment, however, because there was a lack  of
 information on the distribution of Type A keratotic lesions by age and dose,
 and  the malignant potential  was not clearly established.  Hyperpigmentation  was
 not  included in the dose-response assessment since hyperpigmentation is not a
 malignant condition, and it does not appear to be a pre-malignant stage in
 nonmelanoma skin cancer.   Both of these lesions  are indicators of arsenic
 exposure, and can serve as biological  markers.
     3.  Case-Fatality Rate of Arsenic-Induced Skin Cancer
     The Technical  Panel  examined the  public health impacts of arsenic-induced
 skin cancer for U.S.  residents by using case fatality rates for skin cancer,  data
that give the cumulative  incidence of  death  among people who  develop this condition,
However, since data  on case-fatality rates  for arsenic-induced skin cancer in
                                       31

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   TABLE 1.   INVASIVE MALIGNANT  TRANSFORMATION OF IN SITU ARSENIC-INDUCED SKIN LESIONS



Author,
year, MOE
Hutchinson,
1888, med
Geyer,
1898, water
Montgomery,3
1935, med
Argue! lo,
1938, water
Prunes, 1946
Neubauer,
1947, medb
Sommers,
1953, med
Roth, 1957, occ
Graham and Helwig
1963, med
Fierz,
1965, med
Yeh,
1968, 1973
water
Zal di var ,
1974,
water

Total
number of
patients

5
37

87

39

14
137

5

27
15

262

40,421


120
adults
337

Total
number with
keratoses

5
35

85

39

14
116-133

5

NS
15

106

2,868


most

NS
Mai
i gnant
Transformation
From:

Ker

5
2

3

10

13
30

1

5
1

1

24


2

0

BD

0
0

1

0

0
0

1

0
0

0


?20C

0

0

sec

-
_

4

9

0
10

2

4
1

1

24
?20

2

0
To:

BCC

-
—

0

0

0
1

0

0
0

0

0


0

0


NS

5
2

0

1

13
19

0

1
0

0

0


0

0
Number of
Malignant
de novo
or~N$~

0
0

1

29

0
107

3

NS
2

20

384


0

0
chil dren
aCited by Zaldivar, 1974.
t>Nlot including cases reported by Hutchinson (1888) and Montgomery (1935).
cYeh indicated that 20 probably arose from Bowen's disease.

MOE = method of exposure;  Ker = keratoses; BD = Bowen's disease;
SCC = squamous cell carcinoma; BCC = basal cell carcinoma;
NS = not specified; med = medicinal; occ = occupational.
Source:  Shannon and Strayer, 1987.
                                           32

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 the United States are not available, the Technical Panel drew on two sources
 to estimate  the case-fatality rate of arsenic-induced skin cancer in the United
 States.  The most direct information upon which to estimate a case-fatality
 rate  from arsenic-induced skin cancer in the United States would be derived from
 U.S.  arsenic-exposed populations.  However, the only case-fatality rate reported
 for an  arsenic-exposed population is that of Yen  (1973), who observed a 5-year
 case-fatality rate of 14.7% for patients with arsenic-induced skin cancer in
 Taiwan.
      Differences in medical care between the Taiwanese and U.S. populations may
 lead  to different case-fatality rates in the two countries.  Thus, approximations
 of the  case-fatality rates for basal and squamous cell carcinoma for both males
 and females  in Caucasian U.S. populations were derived from aggregate data on
 nonmelanoma  skin cancer and are presented in Table 2; these data primarily
 reflect sun-induced skin cancer.  Table 2 shows that nonmelanoma skin cancer,
 which is the most common malignant neoplasm among Caucasians in the United
 States  (Scotto and Fraumeni,'1982), is rarely fatal; less than 2% of all non-
 melanoma skin cancer cases die from the disease.  These low case-fatality rates
 probably reflect the ease of diagnosis and effectiveness of treatment.  Case-
 fatality rates could not be calculated for nonwhites due to lack of data on
 nonmelanoma skin cancer incidence rates.
     In conclusion, the estimated case-fatality rate attributable to arsenic-
 induced skin cancer ranges between <1% (U.S. populations) to 14.7% (Taiwanese
 populations).  There is currently not enough information to determine whether
 the case-fatality rates in Table 2 or that based on the Yen data realistically
describe the probability  of death in the  United States due to arsenic-induced
skin  cancer.   The higher  case-fatality rate of 14.7% reported by Yeh may reflect
differences  in medical  treatment between  Taiwan and the United States or may

                                       33

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            TABLE  2.   ESTIMATED CASE-FATALITY RATES FOR NONMELANOMA
                           SKIN CANCER BY CELL  TYPE*


Race-sex
group
White male
White male
White female
White female


Cell type
Squamous cell
Basal cell
Squamous eel 1
Basal cell

Incidence
rate/
100,0003
65.5
202.1
21.8
115.8
Estimated
mortality
rate/
lOO.OOQb
0.8
0.2
0.3
0.08

Estimated
case-fatality
rate0
1.2%
<0.1%
1.4%
<0.1%
aBased on annual  incidence rates,  age-adjusted to  the  1970 U.S.  population
(Scotto and Fraumeni,  1982).

^Race-specific nonmelanoma skin  cancer mortality rates were obtained  from
 Riggan et al . (1983)  and are age-adjusted to  the  1970 U.S.  population.  An
 assumption, based on  Scotto  and Fraumeni  (1982) was made for this  analysis
 that squamous cell  carcinoma deaths  accounted for 80% of the race-sex  specific
 age-adjusted mortality rate.

cEstimated case-fatality rate -  Estimated  mortality rate/Incidence  rate
 (MacMahon and Pugh, 1970).   The following three assumptions were made:   (1)
 incidence of nonmelanoma skin cancer remains  stable  for a period corresponding
 to the longest duration of  the  disease in the individual; (2) the  distribution  of
 disease duration remains stable;  and (3)  the  proportion of patients  with  various
 outcomes (death or recovery) remains stable.   All assumptions are  believed  to
 be met since disease  duration is relatively short and survival  is  good.
                                       34

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 reflect differences in disease aggressiveness for arsenic exposure relative to

 sun exposure resulting from several  factors.   For example, arsenical  nonmelanoma

 skin cancer often appears as multiple lesions on the body, presenting a higher

 probability of metastasis.  Arsenic-induced skin cancer has a higher  squamous  to

 basal  cell  ratio than does nonmelanoma skin cancer in the United States,  the

 majority of which, as stated above,  is believed to be sun-induced, and squamous

 cell carcinoma has a higher probability of metastasis than does basal cell.

 Finally, arsenic-induced skin cancer tends to occur on the trunk and  extremities,

 areas  that are not generally sun-exposed.   Lesions in these areas may not be as

 readily detected by the patient or physician, thus increasing the probability

 of not diagnosing the disease until  a more advanced stage.


 B.  GENOTOXICITY Tj

      1.  Introduction

      Various inorganic compounds of  arsenic have been tested for mutagenicity

 in a variety of test systems ranging in  complexity from bacteria to peripheral

 lymphocytes of exposed human beings.   Although  much of the data presents  many

 questions,  the weight of evidence  leads  to  five  conclusions:

       (1)   Arsenic is either inactive or extremely weak for the induction of
            gene mutations  in vitro.

       (2)   Arsenic is clastogenic  and induces  sister chromatid  exchanges  (SCE)
            in  a variety  of cell  types,  including human  cells,  in vitro; trivalent
            arsenic is approximately  an  order  of  magnitude  more  potent than
            pentavalent arsenic.

       (3)   Arsenic does  not  appear to induce  chromosome aberrations in  vivo  in
            experimental  animals.
l_l  With permission of the authors, this discussion is adapted from a review
    article prepared by Jacobson-Kram and Montalbano (1985) and the U.S. EPA
Health Assessment Document for Inorganic Arsenic (U.S. EPA, 1984a).
                                       35

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      (4)   Several  studies  suggest  that  human  beings  exposed  to  arsenic
           demonstrate higher frequencies  of SCE  and  chromosomal  aberrations  in
           peripheral  lymphocytes.
      (5)   Arsenic  may affect DNA by  the inhibition of  UNA  repair processes or
           by its occasional  substitution  for  phosphorous in  the DNA  backbone.
Several  reviews on  the mutagenicity of arsenic are available  Uacobson-Kram and
Montalbano, 1985; Flessel,  1978;  National  Academy of  Sciences,  1977;  Leonard  and
Lauwerys,  1980; World Health  Organization, 1981).
     2.   Possible Mechanisms  of Genotoxicity
     Arsenic is unusual in  several  respects.   First,  unlike the majority of
clastogenic agents, arsenic does not  appear to directly damage  DNA except,
perhaps, at highly cytotoxic  doses.  Rather,  it seems to have its effect through
some interference with DNA synthesis.  This contention is  supported by observations
that arsenic induces chromosomal  aberrations  and SCE  only when  it is  present
during DNA replication.  Incubation and removal of arsenic  before DNA synthesis
has no effect  (Nordenson et al., 1981; Crossen, 1983).
     Second, arsenic is unusual in that it induces chromosomal  aberrations ana
SCE while  it fails to  induce gene mutations.   In this regard it is like benzene,
another unusual  carcinogen (Dean, 1978).  Although capable  of producing chromosome
aberrations as well as gene mutations, x-irradiation is much more potent
for the former end point.  There is a small possibility, however, that the
discrepancy for  arsenic is an artifact.   Protocols for gene mutation assays
generally  involve cellular incubation with the test  agent for relatively short
time periods  (2-3 hr), while protocols for aberrations often involve the presence
of the  test agent for  one or two entire cell  cycles  (12-48 hr).  Thus, in the
latter  protocol, arsenic would be  present for at least an entire S-phase for
all cells, whereas, when tested  for  gene mutations,  arsenic would be present
for only a  small fraction of the S-phase  in approximately one-third to one-half
                                       36

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of the cells.  Since the evidence available suggests that arsenic has its effect
only during DNA replication, this may account for the discrepancy.
     Arsenic has long been known to be a sulfhydryl  reagent capable of inhibiting
a number of thiol-dependent enzyme systems, trivalent forms being much more
potent than pentavalent forms (Leonard and Lauwerys, 1980).  Thus, one possible
mechanism of action for arsenic would be the inhibition of DNA repair enzymes.
The work of Rossman in bacteria (1981) and Jung et al.  (1969) in human cells
in vitro lend support to this hypothesis.  Also the  observations of Sram (1976)
on the interactions of arsenic with trisd-aziridinyl)  phosphine sulphide (TEPA)
for the induction of chromosomal aberrations and dominant lethals support such
a contention.  The potencies of trivalent and pentavalent arsenicals as sulfhydryl
reagents are similar to their potencies as clastogens and SCE-inducing agents.
Observations that counter this hypothesis are the reports by Rossman that
arsenic has no effect on the frequency of UV-induced mutations in mammalian
cells in vitro and that arsenic does not affect the  frequency of EMS-induced
aberrations in vivo (Poma et al., 1981).
     Another possible mechanism for the action of arsenic may be through its
occasional  incorporation into the DNA backbone in place of phosphorous.  There
are several lines of evidence to support this mechanism.  First, for this to
occur, arsenic would have to be present during DNA synthesis and would have no
effect on nondividing cells.  Second, such a mechanism  could explain why arsenic
is clastogenic (such a bond would be weaker than the normal phosphodiester
bond) but does not induce gene mutation.  Third, arsenic has been shown to
cause strand breaks in DNA (Fornace and Little, 1979).   Also, x-irradiation, a
potent clastogen and poor inducer of gene mutations, predominantly causes strand
breaks as its major DNA lesion.   An argument against such a mechanism is the
observation that the trivalent forms are more potent than pentavalent forms,
                                       37

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while pentavalent arsenic  should be  more  likely  to  substitute  tor  phosphorous
in DMA.  Furthermore,  arsenic would  have  to be capable  of  beiny  phosphory'lated.
     3.  The Use of Arsenic Genotoxicity  Data in the  Evaluation  of
         Carcinogenic  Risk
     Genotoxicity at low doses is an important indicator of  irreversible  change
in genetic function.  Such changes are a  critical  feature  of many  postulated
mechanisms for chemical  carcinogenesis and the basis  for ascribing low-dose
linearity to carcinogenic processes.  Although the  lack of genotoxic response
does not preclude linearity at low doses, it is  potentially  important as  a
consideration in selecting a model for extrapolation  of carcinogenic risk.
     The in vitro dose-response function  for the induction of  chromosomal
aberrations by both trivalent and pentavalent arsenic is linear.  It is important
to note, however, that most chromosomal aberrations scored in  a  standard  cyto-
genetics assay, such as that used in the evaluation of arsenic,  are lethal events.
The cells scored in these assays carry lesions that do not permit them to survive
more than one or two additional cell cycles after damage and are,  therefore,
genetically of no consequence.
     Agents that are capable of breaking chromosomes are also capable of  causing
stable  chromosome rearrangements, such as trans!ocations or inversions.  To
induce  such a rearrangement, at least two chromosomes per cell must be damaged
(or  one chromosome  damaged twice).  Based on  simple target theory, one would
expect  a nonlinear  dose-response  relationship for the induction of rearrangements
at low  doses.  In this  case, there  are two targets per cell, both of which must
be hit  in order to  bring  about  a  rearrangement.   At low doses,  both targets
must be hit in order to bring about a  rearrangement, and the possibility  of
hitting both  targets in a single  cell  is  small, but finite.  Further,  if  as
discussed above, arsenic  acts by  interfering  with DMA  synthesis and repair

                                       38

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processes,  rather than by  causing  mutations,  the need  for  two  events  is  compounded
by the need for arsenic also to produce toxic effects  on DMA synthesizing enzymes.
With increasing doses, many  cells  will  contain a single  hit and  the dose effect
curve becomes linear.
     The size of any apparent "practical  threshold"  will  be determined  by the
"size" of the target; i.e.,  if a high percentage of arsenic molecules interact
with chromosomes to cause breaks,  the targets are large, and the observed thres-
hold is small.  Although these observations suggest the existence of  a  "practical
threshold," there is a measurable "spontaneous" frequency of chromosomal breaks.
Because a cell may already carry one break, the induction of the second break
(and the resulting rearrangement) would be a single hit phenomenon.   Indeed,
the induction of dicentrics  (a two-hit chromosomal  rearrangement) is  linear for
ionizing radiation even at very low doses.  Clearly, these arguments  do not
support the existence of a threshold, a dose level  below which aberrations
would not occur.  However, the possibility of a nonlinear dose-response relation-
ship at low doses should be  recognized.
     How chromosomal rearrangements would influence the carcinogenic  process is
only speculative at this time.  Although there are examples of oncogene activation
associated with cancers in humans and experimental  systems, arsenic-induced
chromosomal changes have not been observed in vivo, and no data are yet available
for arsenic-induced cancers  in regard to oncogene activation.   While  lack of
mutagenic activity may argue against the notion that single arsenic-cell inter-
actions may start a process  leading to malignancy,  gene mutation may  not be the
only factor leading to low-dose linear dose-response relationships.

C.  METABOLISM AND DISTRIBUTION  (See Appendix E)
     Inorganic arsenic is a  potent poison resulting in adverse effects   following
acute exposure.  Acute toxicity studies indicate that inorganic compounds are
                                       39

-------
more potent than organic forms, and valence state-3 inorganic arsenicals are
more toxic than valence state-5 compounds across a number of species.   Since
the mammalian body can interconvert inorganic arsenic species and can  methyl ate
valence state-3 compounds, it appears that methylation is a means of detoxifyiny
inorganic forms.  As more methyl  groups are added, the compounds become less
and less acutely toxic.
     Although there are many data gaps in our understanding of the body's
handling of arsenic, great strides have been made in recent years in the ability
to speciate among valence states  of arsenic.  The picture that unfolds is as
follows.  Inorganic arsenic (+5)  can be interconverted in the blood with (+3)-
inorganic forms, and the latter can be singularly methylated to form mono-methyl
arsenic (MMA); these are enzymatic and nonenzymatic processes.  It appears that
arsenite, but not arsenate can enter liver cells (at least HI vitro) where a
second methyl group can be added:  MMA becomes dimethyl  arsenic (DMA)  via a
rate-limiting enzymatic process.
     Under low-level exposures to arsenic, there seems to be a balance between
the amount entering the body and  the amount being excreted.  Most absorbed
arsenic is lost from the body in  the urine as inorganic  arsenite, MMA, DMA, and
other, yet uncharacterized, organic forms.  A small amount of arsenic  is lost
by desquamation of the skin.
     With increasing arsenic intake there is suggestive  evidence that  there is
some maximal  amount the body can  readily handle.  An early study (Valentine et
al., 1979) noted that ingested arsenic in blood did not  change as a function of
dose until water concentrations exceeded about 100 ug/L.  Buchet et al.  (1981,
1982) suggest that the body's ability to form DMA seems  hampered at exposures in
excess of about 500 ug/day, without affecting the excretion of inorganic arsenic
or MMA in the urine.  If this is  the case, then total urinary excretion of

                                       40

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arsenic may be compromised at high doses leading to increased tissue levels.
     Given the predilection of arsenic for tissues with high sulfhydryl groups,
like skin, it seems plausible that high arsenic loads may be associated with
increased deposition in the skin.  The nature of the binding of arsenic to the
skin is unknown at this time; however, radioisotopically labeled inorganic
arsenic is retained for longer times than are organic arsenicals.  In addition,
more drastic chemical treatments are required to remove arsenic from the skin
following administration of inorganic than organic arsenic.  These pieces of
evidence suggest that the binding in the skin after inorganic arsenical exposures
is more tenacious and more stable than that following exposure to organic
compounds.  Although these findings are interesting, the way that they may
influence the carcinogenic process, either qualitatively or quantitatively, has
not been ascertained.
     Another finding is that the methylating capacity of the body may change as
a function of exposure, such that maximal levels of excretion of methylated
arsenicals are reached after weeks of exposure to the compound.  In a like
manner, the ability to excrete methylated arsenicals seems to be lost as a
function of time after removal of arsenical  exposure.  Thus, with alternating
arsenical intake, individuals may go through periods of efficient metabolism
and excretion as well as a tendency to accumulate body stores of arsenic.
     It is possible that differences in diet between the United States and Taiwan
may have modified the carcinogenic effects of arsenic.  The Taiwan diet was
reported to be "low in protein and fat; carbohydrates, rice, and sweet potatoes
constitute the main part of the diet " (Tseng et al., 1968).  It is possible
that the reduced protein in the Taiwan diet may compromise the body's ability
to methylate and excrete arsenic.  Experiments in animals indicate that under
methloninedeficient conditions, the body's ability to methylate IShivapurkar

                                       41

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and Poirier, 1983)  and excrete arsenic  is  compromised  (Marafante  and  Vahter,



1986).  Some studies in South America where diets  seem to  be  protein  adequate,



however, indicate that skin cancer still occurs  even when  the level of  arsenic



in the drinking water is about equal  to that in  Taiwan.  Another  consideration



with regard to diet is that the low fat diets in Taiwan  may have  had  a  protective



effect against cancer.  Boutwell  (1983) found that underfeeding animals in  fat



or calories diminished the cancer occurrence during the  promotion stage of  skin



cancer.



     In summary, the metabolism and distribution data  are  important for evalu-



ating the carcinogenic properties of arsenic.  If  the  interconversion of inor-



ganic arsenic to its methylated forms is saturable, then total  urinary  excretion



of arsenic may be compromised at higher doses, leading to  increased tissue



levels.  The available studies, however, do not contain  sufficient information



for full evaluation of this hypothesis.  In addition,  the  studies do  not identify



drinking water exposure levels for humans  at which this  process may be  saturated.



Thus, their influence on the carcinogenic  process, either  qualitatively or



quantitatively, is uncertain, but merits further study.
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                V.  DOSE-RESPONSE ESTIMATE FOR ARSENIC INGESTION

A.  INTRODUCTION
     Dose-response assessment develops a numerical expression for the inter-
relationship between exposure and carcinogenic response at expected human
exposure levels.  Because this assessment often includes extrapolation from
high doses used in animal studies to low doses in the region of human exposure
and from animals to man, consideration of possible mechanisms of cancer develop-
ment are important in deciding on the most appropriate extrapolation procedures
for any particular chemical agent.  For ingested arsenic, the dose-response
estimate is based on human data (Tseng et al., 1968; Tseng, 1977) for which the
lowest dose level was about 10 ug/kg/day.
     Low-dose risk estimates based on customary linear assumptions would be
overestimates if a threshold exists, or if risk decreases faster than linear as
dose decreases.  To study these questions, data on genotoxicity, pathology,
metabolism, and pharmacokinetics were evaluated, particularly to help determine
whether a nonthreshold or a threshold approach was more appropriate for this
agent.  Because the mechanism by which arsenic induces skin cancer in humans
remains unknown and for other reasons developed below, the Technical  Panel  used
a generalized multistage model  with a time factor to develop dose-response
information on the relationship between exposure to arsenicals and skin cancer
in humans.
     1.  Considerations Affecting Model Selection
     After evaluating several  factors that might aid in selecting an  extrapolation
model  for cancer risk,  the available evidence is not persuasive as to any
particular approach,  and certain considerations seem to point in different
directions.   Some considerations suggest that a conservative approach—e.g.,

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methods assuming that there is  no  threshold  for  carcinogenic response—is
necessary to adequately predict arsenic  risks  for  humans, while  others suggest
that nonthreshold assumptions will  overestimate  the  risk to humans.
     For example, in deciding between  nonthreshold and  threshold approaches to
the dose-response for arsenic,  the development of  skin  lesions in persons exposed
to arsenic was evaluated.   Nonmalignant  lesions  (e.g.,  hyperpigmentation,
hyperkeratoses), which are often observed  before any  indications  of malignancy
and more frequently than cancer, can serve as  biological markers  of exposure to
arsenic.  It is not clear whether  these  lesions  can  also be regarded as precursors
to cancer that would identify an exposure  threshold  or  level below which exposure
to arsenic does not elicit a carcinogenic  response.   In particular, hyperpigmen-
tation does not appear to progress to  cancer,  and  data  are not available on the
progression of lesions that Yeh et al.  (1968)  called  Type A hyperkeratosis.
Although many squamous cell carinomas  arise  within pre-existing  lesions, most
basal  cell carcinomas arise de  novo.   This means that Type A hyperkeratoses as
a group cannot be viewed as precursors to  all  skin cancers.  Thus, although the
possibility of using data on lesions to  identify a threshold for arsenic-induced
carcinogenesis is intriguing,  additional information  is needed before  these
observations could justify using threshold rather  than  nonthreshold assumptions.
     Other considerations suggest  that a less  conservative approach is appropriate.
Since arsenical s do not appear  to  induce point mutations, one rationale for
assuming low-dose linearity and using  the generalized multistage model might  not
apply, and alternative, less conservative  models should be considered.  In this
regard, structural chromosomal  rearrangements  that have been  implicated in some
cases of carcinogenesis could  be expected  to involve at least two "hits" and
may imply a "theoretical" threshold.   While  such a "threshold"  for cancer  cannot
be proven, any requirement for  multiple  "hits" would suggest  a curvilinear dose-

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 response relationship.  Also, pharmacokinetic studies suggesting that tissue
 dosimetry of arsenic may change dramatically above some yet undisclosed exposure
 level suggest a nonlinear approach based on nonlinearity of dose.  The role
 of tissue deposition in inducing carcinogenesis is not known but, consistent
 with dose-response theory, at higher target-organ doses greater biological
 effects would be expected.
     On balance, then, there is a paucity of information on the mechanism of
 carcinogenic action or the pharmacokinetics of arsenic that leads to confidence
 that any particular extrapolation approach is more appropriate than another.
 In these circumstances, it seems reasonable to use an extrapolation model with
 low-dose linearity to place an upper bound on the expected human cancer dose-
 response.  It is considered an upper-bound estimate because the existing data on
 arsenic suggest that multiple hit or threshold considerations might apply to the
 extent these factors influence the carcinogenic process.  Thus, in interpreting
 the risk estimate derived from the linear extrapolation, it is important to keep
 in mind the possibility that the model  overestimates the dose-response to an
 unknown extent.  Certainly, at least some high level  exposures are associated
 with human carcinogenic risk, but as one decreases exposure, risks may fall
 off faster than linearity.  The risk at low doses may be much lower than the
 current estimates, as low as zero, due  to such factors as the metabolism or
 pharmacokinetics of arsenic.
     2.  Changes in Methodology Relative to the 1984 Assessment
     In 1984, EPA estimated the unit risk for arsenic concentrations in drinking
water using the data of Tseng et al. (Tseng et al.,  1968;  Tseng, 1977).  Some
modifications and additional  considerations to the 1984 assessment are made in
the current document to calculate a  new risk estimate.  These modifications
include an  adjustment for the laryer amount of water believed to be consumed by

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the Taiwanese males  in the study population  as  compared  to  persons  in  the  United
States.  The previous estimate assumed that  males  and females  in  Taiwan  and  the
United States drink  2 liters of water per day.   The  current estimate assumes  that
the Taiwanese male in the study population drinks  75% more  water  than  does a
person in the United States.  The current assumption is  based  on  the fact  that
the males of the study population performed  heavy  outdoor work in a very hot
climate.  As with the 1984 analysis,  the current analysis assumes that Taiwanese
females consume the  same amount of water per day as  a person in the United
States (2 liters per day).
     Also, the current analysis uses  a life-table  approach  using  age-specific
U.S. mortality data  to calculate a lifetime  risk of  skin cancers  from  chronic
ingestion of water containing 1 ug/L  of inorganic  arsenic.   The previous analysis
produces an estimate of the risk of developing  skin  cancer  from chronic  ingestion
of water containing  1 ug/L of inorganic arsenic by age 76.2 years,  assuming
that one lived to that age.  In addition, the current analysis uses a  maximum
likelihood approach, whereas the previous analysis used a least-squares  linear
regression of the prevalence rates.  The maximum likelihood approach  is  considered
a better approach because it takes account of the  relatively small  populations
in  the older age groups.  Furthermore, the current analysis used both  quadratic
and linear dose terms, whereas the previous  model  was only  linear in  dose.  The
fit of the data to the model employing linear and  quadratic terms is  significantly
better than if only a linear term is  used (p <  0.05).
     The cancer risk estimate so derived is  then used to predict the  number  of
skin cancer cases that would occur in two other study populations exposed  to
arsenic via ingestion (Cebrian et al., 1983; Fierz,  1965) for comparison with
the number that were actually observed in these studies. The details  of these
calculations are presented  in Appendix B.

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 B.   ESTIMATION OF RISK



      1.   Estimation of Risk using Taiwan Data



      The  study by Tseng et al.  (1968) and Tseng  (1977)  (see Part III) provides



 the  best  available data for quantitative risk assessment.  This study is useful



 for  risk  assessment for several reasons.  First, it is  a study of human populations,



 a point with  obvious advantages for assessment of risk  to humans.  The exposed



 and  comparison populations were large (40,491 and 7,500, respectively), and



 prevalence  rates in the exposed population were  presented according to ages and



 levels of water concentration so that it is possible to estimate cumulative



 cancer incidence by age and dose level.  The Technical  Panel concluded that



 this study  provides an adequate basis for quantitative  risk assessment despite



 the  important uncertainties.  Of the three studies, it  provides the largest



 study population, ascertained a large number of  skin cancer cases, and reported



 responses by  12 dose and age groups.



      The  quantitative assessment of hazard for arsenic  ingestion uses the



 generalized multistage model with both linear and quadratic dose assumptions.



 These calculations show that for the U.S. population, the risk of developing



 skin cancer from lifetime exposure of 1 ug/kg/day ranges from 1 x 10~3 to 2 x



 10-3 (see Table B-4 in Appendix B).  Had Singapore skin cancer rates been used



 to calculate  the background cancer rate for the Taiwanese population, the risk



 estimates are almost the same (see Table B-5).   As in previous EPA risk



 assessments,  including the 1984 arsenic risk assessment, the point estimate,



 rather than the 95% upper bound, is used when human data and a dose-response



model with a linear term are used in the calculation.   One  reason for using the



point estimate with human but not animal  studies, is that human data usually



involve exposure  levels  that are closer to  the  exposure range to  which one



wishes to extrapolate.   Secondly,  the difference between point and upper-bound





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estimates is of no practical  significance when there is low-dose linearity.
Assuming low-dose linearity holds for the Taiwan population,  this is especially
true for arsenic data because of the large population in that study.
     2.  Comparison with Mexican Data
     Cebrian et al. (1983) (also described in Part III), conducted a prevalence
study of skin lesions in two rural  Mexican towns,  one with arsenic-contaminated
drinking water.  The data from this study are not  as useful  for quantitative
risk estimation as those from the Taiwan study because there  was only one dose
group among the arsenic-exposed persons, and the study populations were relatively
small (the exposed and comparison populations numbered 296 and 318, respectively).
Moreover, this study identified only four cases of skin cancer.  It is useful,
however, to compare the dose-responses from the Taiwan study  with those in the
Mexican population studied.  The generalized multistage model  developed using
the Taiwan data was used to predict prevalence rates for the  Mexican population
studied by Cebrian.
     These calculations show that the model  developed from the Taiwan data
provides a prediction of skin cancer risk that is  consistent  with the results
of the Mexican study.
     3.  Comparison with German Data
     The study by Fierz (1965) (Part III) was, like the Cebrian et al. (1983)
study, not as suitable for quantitative risk estimation as the Taiwan study.
The poor response rate of the potential study participants,  the lack of a
comparison group, and the lack of information on dosing patterns were the
primary reasons why this study was not used for quantitative  risk calculations.
However, the results of this study, like those of  Cebrian et  al. (1983), were
compared with estimates of prevalence derived from the Taiwan study.
     At the lowest dose in Taiwan (10.8 ug/kg/day), the prevalence rate of skin

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cancer was 2%.  At the equivalent dose in the Fierz study, the prevalence
rate of skin cancer is estimated as 3.4% to 15.4%.  This 3.4% to 15.4% range is
the result of the non-response among the potential study subjects described in
Part II, Section A.  Further explanation may be found in Appendix B.  The Fierz
data are not inconsistent with the prevalence of cancer estimated from the
Taiwan data.  Differences in skin cancer prevalence rates of these two study
populations could be due to factors such as the following:  the difference in
exposure regimens and medium (Fowler's solution is a mixture of potassium
arsenite, potassium bicarbonate, alcohol, and water); the difference in the
valence states of arsenic (potassium arsenite is trivalent arsenic, whereas the
arsenic in the Taiwan wells was mostly pentavalent); other chemicals present;
genetic differences among Taiwanese, Mexicans, and Germans (Caucasians could be
more susceptible); and cultural or socioeconomic conditions.

C.  SUMMARY OF DOSE-RESPONSE EVALUATION
     1.  Numerical Estimates
     Dose-response analysis for skin cancer resulting from exposure to arsenic
in drinking water was performed on data from the epidemiologic study conducted
in Taiwan.  A generalized multistage model  in time and dose was used for this
analysis.  The results were compared to data obtained from epidemiologic studies
conducted in Mexico and Germany.  These comparisons are not inconsistent with
the risk estimates calculated from the Taiwan data.
     Based on the Taiwan data (Tseng et al., 1968; Tseng, 1977), the maximum
likelihood estimate of lifetime risk of skin cancer for a 70-kg person who
consumes 2 liters of water contaminated with 1 ug/L of arsenic per day is
calculated to range from 3 x 10~5 (on the basis of Taiwanese  females)  to 7 x 10~5
(on the basis of Taiwanese males);  or,  equivalently, the lifetime risk due to
                                       49

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1 ug/kg/day of arsenic intake from water ranges from 1 x 10~3 to 2 x 10-3.
The skin cancer risk in the United States is unlikely to be greater than these
estimates.
     2.  Uncertainties
     As described above, qualitative uncertainties in the hazard identification
include the possibility of competing mortality from Blackfoot disease, confounding
by other chemicals, and lack of blinding of the investigators.   In addition, the
Technical  Panel attempted to quantify two uncertainties in the dose-response
evaluation:  use of the Taiwan prevalence rate to estimate the cumulative incidence
rate, and the influence of arsenic from sources other than drinking water on
the Taiwan skin cancer prevalence.
     Regarding use of the prevalence rate, one assumption (see Appendix B)  in
using such data to estimate cumulative incidence rate is that the mortality
rates are the same in diseased (skin cancer) and non-diseased individuals.   As
indicated previously, the arsenic-exposed population in Taiwan had an elevated
risk of Blackfoot disease which has an earlier age of onset and a higher case-
fatality rate than skin cancer.  Also, persons with Blackfoot disease had a
higher probability of having skin cancer than persons who did not have Blackfoot
disease.  This association of skin cancer and Blackfoot disease would have
underestimated the risk of skin cancer due to arsenic since some of the persons
with skin cancer and Blackfoot disease may have died before being observed in
the Tseng et al. prevalence study.  The Technical Panel made certain presumptions
with respect to differential mortality and estimated its effects on the age-
specific skin cancer incidence (see Appendix B, pages B-23 to B-2fa).  Based on
this analysis, the Technical Panel estimated that differential mortality would
underestimate the dose-response by no more than 50%.
     A countervailing uncertainty relates to arsenic intake by the Taiwan

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 population.  Since arsenic-contaminated water was used for vegetable growing
 and  fish  farming, food consumption could have been an important source of arsenic
 in the  Taiwan population in addition to the water used for drinking.  Not enough
 information  is available on the arsenic content in food, however, for use in the
 risk  calculation.  Considering only arsenic in food contributed by water used for
 cooking,  the dose-response may have been overestimated by 30% (see Appendix B,
 pages B-26 to B-28).
      Finally, absent animal data or reliable human data under conditions of low
 exposure, the shape of the dose-response, if any, at low doses is uncertain.
      3.   U.S. Populations
      To evaluate the contribution of arsenic exposure to the incidence of skin
 cancer  in the United States, the Technical Panel considered estimating the number
 of cancer cases resulting from inorganic arsenic in the diet.  The amount of
 inorganic arsenic in the diet, including drinking water and beverages, is between
 17 and  18 ug/day (see Appendix E).  The midpoint of this range, 17.5 ug/day, is
 equivalent to 0.250 ug/kg/day.  Assuming that the amount of dietary inorganic
 arsenic has  remained constant over the past 85 to 100 years (the longest expected
 lifetime), the annual number of skin cancer cases in the United States resulting
 from  dietary inorganic arsenic would be 1,684 cases per year, based on the data
 for Taiwanese males (see Table B-4, Appendix B). *V
      In a telephone conversation with Herman Gibb of the Carcinogen Assessment
 Group (May 1987), Dr. Joseph Scotto of the National  Cancer Institute estimates
 that  currently about 500,000 Caucasians in the United States develop invasive
£/  This is based on a July 1, 1986, estimate of a U.S. population of 241,596,000
    people and the age distribution of the population at that point in time
(U.S. Bureau of the Census, 1987).
                                       51

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nonmelanoma skin cancer each  year.  9/   Thus,  the  proportion  of  nonmelanoma  skin

cancer cases in the United States  attributable  to inorganic  arsenic  in  the

diet, the largest source of arsenic exposure  for  most  Americans,  is  quite low

(0.34%).  10/

     Even 0.34% is an overestimate  for  several  reasons.   First, the  estimate of

arsenically induced skin cancer for diet and  drinking  water  is  based on skin

cancer prevalence data from the Taiwan  study  which  includes  both  invasive and

in situ carcinomas.  Only 42% of 303 cases  that were histopathologically examined

in the Taiwan study were invasive  nonmelanoma skin  cancer cases;  the balance

(58%) were intraepidermal carcinomas.   The  estimated annual  number  of United

States Caucasian nonmelanoma  skin  cancer cases  cited above as  500,000 includes

only invasive nonmelanoma skin cancer.   Second, the Taiwan study  involved

clinical  examination of individuals, while  the  estimate  of 500,000  cases in the

U.S. population was based on  a review  of clinical records.  Ascertainment of

cases will be better by actual  examination  than by  a review  of  records  where

cases may not be recorded, all sources  of records not  examined, or  sources  of

records which are examined are not available  or lost.   Third,  the above estimates

of arsenic-induced skin cancer in  the  United  States resulting  from arsenic

present in the diet and drinking water is based only on  the  male  data from

Taiwan.  The female data for Taiwan would give  an estimate that is  more than

two-fold lower.
    Not enough information is available for races other than Caucasian with
    which to make reasonable estimates of annual  nonmelanoma skin cancer cases.

     Although the denominator for this percentage is only causcasian Americans,
 ~~   Caucasians constitute 85% of the U.S.  population (U.S.  Bureau of the Census
1987).  Furthermore, the incidence of nonmelanoma skin cancer among nonwhites
is considerably less than that of whites (Scotto et al .,  1983) so that the
number of nonmelanoma skin cancer cases occurring each year among nonwhites is
minimal in comparison to the 500,000 cases  occurring among whites.

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     Finally, because of socioeconomic and ethnic differences between the United
States and Taiwan, the Technical  Panel's draft report to the workshop stated
that the applicability of these estimates to the U.S. population is of concern.
Several workshop participants responded to this stated concern by noting that
the United States was a culturally diverse society, as well  as a society which
included persons of all socioeconomic levels; thus, extrapolation from the
Taiwan study to the United States was reasonable.
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                     VI.   ARSENIC AS AN ESSENTIAL  NUTRIENT



A.  BACKGROUND

     In 1983, the National  Academy of Sciences reported that arsenic  is  an

"essential" nutrient for  humans.

     Research should also be designed to evaluate  the possible  essentiality
     of arsenic for humans--a requirement that has been demonstrated  in  four
     mammalian species.   In the absence of new data,  the conclusion reached  in
     the third volume of  Drinking Water and Health remains valid,  i.e.,  if
     0.05 mg/kg of dietary (total) arsenic is also a  nutritionally desirable
     level  for people, then the adequate human diet should provide a  daily
     intake of approximately 25 to 50 ug.  The current American diet  does  not
     meet this presumed  requirement (National  Academy of Sciences, 1983).

A report prepared for EPA also concluded that arsenic is essential to human

nutrition (O'Connor and  Campbell, 1985), and EPA has  relied on  this assessment

in a rule-making action  (U.S. EPA, 1985).

     In the draft Forum  report submitted for peer  review,  the Technical  Panel

questioned this conclusion and the role that a nutritional  requirement would

have in risk assessment  for cancer.  At the December  Peer  Review Workshop, the

Subcommittee on Essentiality summarized its conclusions on this question as

follows:

    (1)  Information from experimental  studies with rats,  chicks,  minipigs,  and
         goats demonstrates the plausibility H/ that arsenic,  at  least  in in-
         organic form, is an essential  nutrient.  A mechanism of action  has  not
         been identified  and, as  with other elements, is required  to  establish
         fully arsenic essentiality.

    (2)  The nutritional  essentiality of inorganic arsenic for  humans is not
         established.  However, the history of trace  element nutrition shows
         that, if essentiality of an element for animals is established, it  is
         highly probable  that humans also require  the element.   Accordingly,
         knowing a mechanism of action is needed for  a full  interpretation of
         the currently available  animal  data.
     Emphasis added.   The term "plausibility"  refers  to the term as employed in
     the framework  described in the  text on p.  58.


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    (3)  The group consensus position is that,  at this time,  it is only possible
         to make a general  approximation of amounts of arsenic  that may have
         nutritional  significance for humans.

    (4)  Elucidation  of the role of arsenic in  human nutrition  will  depend upon
         development  of specific information in the following areas:

         •  biochemical  and physiological mechanisms of action,
         •  biological activity and metabolic response to various chemical
           species of ingested arsenic, and
         •  dose-response relationships between  animal  species.

The scientific data on which these conclusions  were based are summarized below,

along with  some concluding comments on the use  of this information in the risk

assessment process.


B.  ANIMAL  STUDIES

     1.  Data Summary

     Two laboratories have independently reported that arsenic  is an essential

nutrient in goats and mini pigs (Anke et al., 1976; 1978) and  in rats and chicks

(Uthus et al., 1983).

     In a two-generation study, Anke et al. (1976, 1978) compared goats and

minipigs that were fed diets containing less than 50 ng arsenic/g (low arsenic)

with control animals  on diets supplemented with 350 ng arsenic/g. 12/  The diet

was based on beet sugar and potato starch, with arsenic added to the supplemen-

ted diet as arsenic trioxide.  There was no effect on the growth of the parental

generation  (FQ) animals.  However, animals fed  low-arsenic diets showed depressed

fertility;  only 58% of the goats and 62% of the minipigs conceived, as compared

to 92% and  100% of controls, respectively.  The offspring showed depressed birth
  /  Although investigators in this field often describe diets as arsenic
    "deficient" and the animals as arsenic "deprived,"  since dietary arsenic
levels are generally not established,  the term "low-arsenic" is used here.
Similarly, in most studies, the control  animals were maintained on a diet
supplemented with arsenic,  rather than a standard commercial  diet.  For this
reason, this report uses the term "supplemented" animals or diets.

                                       55

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weights (87% relative to the controls),  depressed skeletal  ash,  and elevated
perinatal mortality.  Some of the low-arsenic lactating goats  died; histologi-
cal examination revealed ultra structural  changes in the myocardium (Schmidt
et al., 1984).
     Nielsen and coworkers studied the essentiality  of arsenic  in  rats  and
chicks (Uthus et al., 1983).  In the rat study,  low-arsenic Sprague-Dawley  dams
were fed a diet containing 30 ng/g arsenic from  day  3 of gestation.  Controls
received 4.5 ug arsenic (4.0 ug as sodium arsenate,  the pentavalent form)/g and
0.5 ug as sodium arsenite.  Following weaning, the growth of low-arsenic  off-
spring was slower than that of the arsenic-supplemented controls.   The  low-
arsenic rats appeared less thrifty than  controls and their coats were rougher
and yellowish.  Elevated erythrocyte osmotic  fragility,  elevated spleen iron,
and splenomegaly were noted in these animals.
     In a separate three-generation study, dams  were placed on  a diet that  con-
tained less than 15  ng arsenic/g within  2 days of breeding.  Controls received
a supplement of 2 ug arsenic/g diet, as  sodium arsenate.   Growth depression was
the most consistent effect of the low-arsenic diet observed throughout  all  three
generations (Fj, F2, and F3).  In a replicate of this study (Uthus et al.,  1983),
only 2 of 12 low-arsenic FI females became pregnant  compared to  9  of 12 controls,
and the number of pups per litter was smaller in the low-arsenic group.
     In chicks, reduced arsenic (20 ng arsenic/g in  the diet)  depressed growth
after 17 to 20 days  (Uthus et al., 1983).   In addition,  these  chicks had  larger,
darker livers, elevated zinc in the liver j^/, elevated erythrocyte osmotic
fragility, depressed alkaline phosphatase, and depressed white  cell count,  as
compared to chicks on the supplemented diet.  Some dose-effect  information  may be
13/  The significance  of elevated  zinc  in  the  liver  is  not  known,

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gleaned from these studies.   In the course of these  investigations,  the  arsenic
content of the skim-milk powder base varied from 25  ng/g to 45 ng/g.  The most
marked changes were found in animals ingesting the 25 ng/g diet.   The chicks
fed 45 ng arsenic/g did not differ from controls, indicating that this may be a
minimum requirement for chicks.  The presence or concentration of arsenic in
the tissues of these animals was not reported.
     In an attempt to establish a biochemical function for inorganic arsenic,
Nielsen and coworkers have shown nutritional  interrelationships in studies using
arsenic, zinc, and arginine (Uthus et al., 1983). Similarly,  Cornatzer  et al.
(1983) have studied the role of arsenic in the biosynthesis of phosphatidyl
choline (PC).  They observed decreased PC  biosynthesis in liver endoplasmic
reticulum of Sprague-Dawley rats fed a diet containing 14 ng arsenate/g  diet
as compared with the values observed in rats maintained on a diet supplemented
with 2 ppm (2 ug) arsenate/g diet.  The authors hypothesized that the observed
depression was not caused by a direct effect of arsenic on the enzyme system
responsible for PC biosynthesis, but may have resulted from altered amino acid
and/or protein metabolism.  None of the studies to date have established a
biochemical function for arsenic.
     Organic forms of arsenic enhance growth in poultry.  The concentrations
used to enhance growth are at least 500-fold greater than the levels used in
the essentiality work.  However, organic arsenic is  less bioavailable.  Thus,
in these studies, the effective levels of  inorganic  arsenic may be comparable
to those used in studies of essentiality.   Many nutritionists feel that  organic
arsenic enhances growth in poultry by cleansing the  intestinal gut of flora, an
antibiotic action.  Further work with animals whose  guts have been sterilized
would be useful  in order to confirm this mechanism of growth enhancement and
may be useful  for interpreting the data on arsenic essentiality.
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     2.  Evaluation of Data

     The December Workshop's Subcommittee on Essentiality referred to a historical

framework for the determination of nutritional requirements.


            Framework for Determination of Nutritional Essentiality


    Empirical Observations            -  Establish Plausibility of Animal Models
           T
    Reproducible Syndrome             -  Use of Chemically Defined Diets, Animal
            I                             Models

    Biochemical Lesions               -  Characterize Specificity of Lesions
           4*-
    Specific Biochemical  Functions
    Absolutely Dependent on Factor
           4?
    Essentiality

     Data pertinent to application of this framework were described previously

in this report.  Several  laboratory studies described significant differences

between animals maintained on low-arsenic diets relative to those on diets

supplemented with this element.  However, several factors limit the usefulness

of these observations.

     Information on the composition and adequacy of the basal  diets is particu-

larly important in determining the specificity of the defiencies observed.  For

example, Uthus and Nielsen (1985)  state that the baseline arsenic diet in their

studies was borderline adequate in sulfur ami no acids.  Furthermore, because

details of the diet preparation are not provided in Anke's arsenic reports,  the

Technical  Panel  could not assess whether methods used to remove arsenic also

destroyed other essential  nutrients in the treated food. j-V  Factors such as

these make it difficult to evaluate fully the role of arsenic  deficiency in  the
     Certain procedures,  such  as  acid washing of corn,  were  described;  chelating
     agents were not used in preparation  of the feed.   (Dr.  Anke was invited to
the December workshop,  but was unable to  attend.)


                                       58

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reported change in health status.

     Despite these limitations, the Technical Panel  and Peer Review Workshop

participants concluded that these studies provide sufficient information to

suggest that a requirement for arsenic in animal diets is plausible, as contem-

plated in the first step of the framework.  However, the available studies

provide insufficient information to establish the remaining elements in the

framework, i.e., "reproducible syndrome," "biochemical lesion," and "specific

biochemical  functions dependent on the factor." 15/  since the last two factors

are particularly important, the essentiality of arsenic has not been rigorously

established, even for animals.


C.  APPLICABILITY TO HUMANS

     The Subcommittee on Essentiality cautioned (see point 3 of their conclusions

stated above, and Appendix D) that definition of the requirement for arsenic in

human nutrition must await the establishment of its essentiality.   They agreed

that an order of magnitude estimate is possible.  They cautioned,  however, that

uncertainties influence such an estimate.  Among these the reviewers cited lack

of knowledge of a biochemical mechanism and physiologic role, lack of knowledge of

arsenic species in foods, lack of information on the validity of biological

species comparison, and inability to specify how a putative intake requirement

varies with developmental stage.
15/  As explained in Appendix D, the written report of the Workshop Subcommittee
     on Essentiality is somewhat incomplete and ambiguous on the current status
of steps 2 and 3 in the framework,  and the recollections of different workshop
participants differ.  Some believe  that the group concluded that reproducibility
(step 2) has been established by the animal data, while others believe that only
plausibility (step 1) has been established.  The individual  comments presented
in Appendix D suggest that there was a range of views among the reviewers and,
perhaps, that the group was silent  on step 2 in the written report because full
agreement was lacking.
                                       59

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     Dose-effect information is lacking in the animal  studies,  which generally
compare reduced-arsenic diets to the same diets with substantial  supplemental
arsenic (for example,  30 ng/g versus 4 ug/g.   Despite  that lack of information
on arsenic levels in animal  tissues or food intake  that would allow estimates
of arsenic doses, several  methods have been used for quantitative extrapolations
to estimate a human requirement.  These methods described below,  are highly
speculative.  Nielsen  and coworkers cautiously estimated d human  requirement of
30 to 40 ug/day based  on the apparent adequacy for  chicks of the  diet containing
45 ng/g arsenic (Uthus et al., 1983).  This estimate assumes that the same intake
would be adequate for  chicks and humans and that humans consume 700 to 1,000 g of
food per day.  In other papers, Nielsen estimated human requirements in another
way.  He assumed a dietary requirement for these animals could  be somewhere
between 6.25 and 12.5  ug/1,000 kcal.  If humans and chicks consume calories in
the same way, humans eating 2,000 kcal/day would require 13 to  25 ug daily.
     These two estimates are consistent with  procedures used by nutritionists  to
estimate human requirements based on animal data.  A method of  extrapolation
consistent with that used by toxicologists doing risk  assessments for toxic
effects would use information on the body burdens of animals consuming arsenic-
adequate diets, and extrapolating from these  data what a human  would need to
consume to achieve a similar body burden.  For example, Nielsen's chicks required
40 ng arsenic/g diet.   Assuming that they weighed 0.40 kg and ate 50 g of food
per day, they would consume 5 ug arsenic/kg/day. Hove (1938) concluded that 2 ug
per day was adequate for a rat; this amount also extrapolates to  a dose of 5 ug
arsenic/kg/day.  If humans have a similar requirement, a 70-kg  person would need
about 350 ug arsenic/day, almost 10 times the current estimated adult intake.
Since it does not appear that current arsenic intake produces arsenic deficiency,
this procedure does not seem appropriate for  nutritional extrapolation.  An

                                        60

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extrapolation based on surface area  rather than  body  weight results  in an

estimate of 24 to 30 ug arsenic/day,  which is  more  nearly  consistent with  the

results of other methods.   The estimates should  therefore  be interpreted as

delineating a possible human nutritional  requirement  of the order of several

tens of ug/day.

     The Technical  Panel  is not aware of case  reports describing an  arsenic

requirement for humans, nor of experimental  or epidemiologic-type studies

designed to determine whether arsenic is essential.  Furthermore, if arsenic  is

a required nutrient for humans, current environmental arsenic exposures are  not

known to produce human arsenic deficiency. 16/  O'Connor and Campbell (1985)

noted that the Food and Drug Administration (FDA)  Market Basket Surveys reported

a decrease in arsenic (total dietary) from 68  to 21 ug arsenic/day between 1967

and 1974.  The FDA has revised its total diet  study and is currently reporting

higher levels of dietary arsenic, which now may  be fairly  stable at approximately

46 ug arsenic/day (an unknown fraction is inorganic).  Since most estimates

of a human nutritional requirement for arsenic fall between 10 and 30 ug/day,

the current estimated intake appears to be adequate.
  /  Even a well-controlled animal  environment appears to provide enough arsenic
     to confound essentiality studies.  In all of the studies of low-arsenic
diets, special steps were taken to exclude extraneous arsenic from the animals'
environment.  For example, goats were kept in polystyrene sties and supplied
with cellulose litter.  Frequently, more than one generation of low-arsenic
exposures was required to produce effects attributed to arsenic deficiency.


                                       61

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D.  SUMMARY AND CONCLUSIONS
     Two groups of investigators have studied the essentiality of arsenic in
control animals on conception rate, abortion rate, birth weight, growth, and
life expectancy.  The results of experiments in the chick and rat are less
definitive.  The diet used in the latter series of studies varied somewhat in
arsenic content, rendering replication difficult, and necessitating use of an
artificial diet which may have been borderline deficient in sulfur-containing
ami no acids.
     Despite some limitations in the available literature, the Technical Panel
and the workshop participants concluded that the first step in the framework
for essentiality has been established, that is, information from experimental
studies with rats, chicks, minipigs, and goats demonstrates the plausibility
that arsenic, at least in inorganic form,  is an essential  nutrient.
     With respect to the second step, identification of a reproducible syndrome,
both the Panel  and the workshop peer reviewers concluded that there is insufficient
published information available to determine the reproducibility of the arsenic
deficiency syndrome.  Moreover, the framework outlined above does not require
that this be unambiguously shown if a biochemical lesion is demonstrable.   A
mechanism of action has not been identified and, as with other elements, is
required to fully establish arsenic essentiality.  The evidence to date does
not allow one to identify a physiological  role for arsenic.
     In sum, the nutritional  essentiality  of inorganic arsenic for animals has
not been established, but is  a plausible assumption.   If an element is required
in animals, it is highly probable that humans also require it.   Therefore,
although no studies in humans on this question are known to the Technical  Panel,
a human requirement for arsenic is also possible.
     If arsenic  were an essential  element,  one still  does  not know how to  use
                                       62

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that information in an assessment of cancer dose-response.   One can  say  that
the risks from arsenic deficiency would increase as  a  function of reductions in
exposure below the threshold of essentiality.   One might say that cancer dose-
response decreases to the  threshold for essentiality,  but it does not follow
that the cancer risk is zero at that point.  It is possible  that, at doses  below
an essentiality threshold,  the  overall  risk to  an individual  would depend on
both the cancer and deficiency-induced  effects.
                                      63

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                        VII.   FUTURE  RESEARCH  DIRECTIONS



     The significant information gaps identified in  this  report  suggest  future

research directions relating  to cancer risk  assessment  of ingested  arsenic.

Crucial gaps in the data base are found for  (1)  epidemiology,  (2) mechanisms  of

arsenic-induced skin cancer,  (3) metabolic phenomena involving arsenic in

various species and its impact on the dose-response, and  (4)  essentiality.

Much of the proposed research requires international cooperation.   In addition,

efforts among different parts of government  and  the  private  sector  should  be

integrated for optimal  data development.


A.  EPIDEMIC-LOGIC STUDIES

     The Technical  Panel  has  identified several  data gaps that apply to  previously

conducted epidemiologic studies that  are critical  to further characterize  and

estimate the cancer risk for  ingested arsenic.   These points should be considered

in ongoing and future studies:

         •  level of species  of arsenic exposures  from  all sources  (e.g.,  soil,
            air, food,  cooking water) including  drinking  water;  better
            characterization  of personal  habits  (e.g.,  water consumption,  pica
            ingestion)  also needed

            further epidemiologic assessment of  internal  cancers

            rates of Blackfoot disease mortality by  age and  its  effects  on  the
            incidence of arsenic-associated  cancer

            studies of people who migrate in and out of areas with  high  levels
            of inorganic arsenic in drinking water to better ascertain the
            effects of age and dose on the cancer incidence

            analysis of drinking water supplies  for  presence of  contaminants
            other than arsenic, with  special  attention  given to  ergotamines

            information on diet to determine whether there is a  relationship
            between nutritional status and arsenic-induced cancers

         •  identification of biological  markers (e.g., genotoxicity,
            liver damage) which correlate with carcinogenic  risk

                                       64

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B.  MECHANISMS OF CARCINOGENESIS FOR ARSENIC-INDUCED SKIN CANCER

     Studies are needed to help elucidate the mechanism of arsenic-induced

carcinogenicity.  Some ideas, which are identified below, have been proposed;

however, the Technical Panel acknowledges that these are not all inclusive.

          •   in vivo studies of clastogenicity and further studies of the
             mechanisms underlying arsenic-induced genotoxicity

          •   study of oncogene activation in pre-cancerous and cancerous lesions

          •   the influence of arsenic on growth factors that may be related  to
             cancer induction


C.  PHARMACOKINETICS/METABOLISM OF ARSENIC

     A better understanding of pharmacokinetics and metabolism of arsenic is

needed to support the assumptions made with regard to the shape of the dose-

response.  It is critical  in all such studies that accurate and precise methodology

be used and  that special  attention be paid to sampling because of the potential

for interconversion among arsenic species.

             studies on metabolism and patterns of deposition in various
             tissues for acute and chronic exposure, in humans and animals,
             for arsenic and its methylated species

          •   studies on variations in biomethylation in different tissues


D.  ESSENTIALITY

     Elucidation of the role of arsenic in human nutrition will  depend on the

development  of specific information in the following areas:

             biochemical  and physiological mechanisms of action

             biological  activity and metabolic response to various chemical
             species of ingested arsenic

          •   dose-response relationships between animal species
                                      65

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           APPENDIX A







Summary of Epidemiologic Studies



  and Case Reports on Ingested



        Arsenic Exposure

-------
                 TABLE A-l.  SUMMARY OF  EPIDEMIOLOGIC  STUDIES AND CASE  REPORTS  ON  INGESTED  ARSENIC  EXPOSURE
Author
Type of study
      Study population
                                                                          Results
                            Highlights/deficiencies
Taiwan
Astrup, 1968
Case report
Chen et al
 1985
Ecologic
correlation
Two cases of Black foot disease.
The population of the townships
of Peimen, Hsucheia,  Putai,  and
Ichu on the southwest coast  of
Taiwan.  The area is  one where
the prevalence rate of Blackfoot
disease is higher than that  of
the rest of Taiwan, and where
there is an arsenic contamination
of artesian wells.
Both cases lived in
an area of Taiwan
where there were
endemically high
levels of arsenic
In the water supply.

The SMRs for cancers
of the bladder, kid-
ney, skin, lung, liver,
and colon were 1100,
772, 534, 320, 170,
160, respectively,
for males and 2009,
1119, 652, 413, 229,
and 168, respectively,
for females.  All were
statistically signifi-
cant (p < 0.05).
There was a dose-
response by type of
well used (artesian,
shallow, or both) for
bladder, kidney, skin,
lung, and liver cancer
SMRs.  NOTE:  The arte-
sian wells were contam-
inated with arsenic; the
shallow wells were not.
The SMRs for bladder,
kidney, skin, lung, and
liver cancer correlated
with prevalence rates
for Blackfoot disease
(i.e., the areas with
higher Blackfoot disease
had higher cancer SMRs).
                                                                                           (continued on the  following page]

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                                                        TABLE A-l.  (continued)
     Author
Type of study
      Study population
                                                                               Results
                           Highlights/deficiencies
     Taiwan (continued)

     Chen et al .,      Case-
      1986             control
i
ro
     Ch'i and
      Blackwell,
      1968
Case-
control
                69 bladder cancer,  76 lung
                cancer, and 59 liver cancer
                cases and 368 alive community
                controls matched as to age
                and sex were studied to eval-
                uate the association between
                high-arsenic artesian well
                water and cancers in the area
                of Taiwan studied by Tseng
                (1977) and Chen et al. (1985)
353 cases of Blackfoot disease
and 353 controls  matched  for
sex and age in an area of Tai-
wan with an endemic  arsenic
contamination of  the water
supply.
The age-sex-adjusted
odds ratios of devel-
oping bladder, lung,
and liver cancers for
those who had used
artesian well water
for 40 or more years
were 3.90, 3.39, and
2.67, respectively,
as compared to those
who never used arte-
sian well water.
Dose-response rela-
tionships were ob-
served for all three
cancer types by dura-
tion of exposure.
Multiple binary logis-
tic regression analyses
showed that the dose-
response relationships
and odds ratios remained
much the same while
other risk factors were
further adjusted.

Significantly (p <
0.01) more cases then
controls were found
to consume deep well
water known to be
contaminated with
arsenic.
Both economic and educa-
tional status were signi-
ficantly lower among the
cases than among the con-
trol s.
                                                                                                (continued on the following pagel

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                                                   TABLE  A-l.   (continued)
Author
Type of study
      Study population
     Results
    Highli ghts/defici encies
Taiwan (contlnuedT

Tseng et al.,
 1968;
Tseng, 1977
Cross-
sectional
Central and South America
ATbores et
 al., 1979
Cross-
sectional
40,421 residents of  37  villages
in an area of Taiwan with an
endemic arsenic contamination
of the drinking water supply.
Mexico
High exposure group:   296 inhab-
itants of El Salvador de Arriba
(mean annual arsenic  concentra-
tion in water =0.5 ppm).  Low
exposure group:   318  inhabitants
of San Jose de Vinedo (mean
annual arsenic concentration in
water = 0.001 ppm).
A skin cancer preva-
lence rate of 10.6/
1,000 for those drink -
ing well water was
found, compared to O/
1,000 for a control
area.  The skin can-
cer rate followed a
dose-response by
arsenic concentration
1n the water.
Rate of palmoplantar
hyperkeratosis was
14.8% in high expo-
sure vs. 0.3% In low
exposure and for dys-
chrom1a--3l.7% vs.
3.14%, respectively.
The physicians who conducted
the physical  examTseng, 1977
inations were not "blinded" as
to exposed and non-exposed
persons. The rate of Blackfoot
disease was 360 per 1,000 in
the study population vs.  0
per 1,000 in the control  popu-
lation.  Blackfoot disease and
skin cancer occurred together
more often than would be ex-
pected if they were random
occurrences.   Because of the
high case fatality rate and
lower median age of onset for
Blackfoot disease, this may
have underestimated the skin
cancer risk.   The studied
population had a protein-
deficient diet and poor medi-
cal care, both of which might
have increased the skin
cancer risk.
Clinical stages of chronic
hydroarsenicism could not be
distinguished.  33% of the in-
habitants of each town were
Included.  Rates exposure
were not age-adjusted, but
age distributions of popu-
lations at risk were given by
authors.  No other pathways of
exposure nor other causes were
suggested.
                                                                                           (continued on the following page)

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                                                   TABLE A-l.  (continued)
Author            Type of study     Study population

Central and South America(continued)
                                                    Results
                                                                High! ights/deficiencies
Alvarado et
 al., 1964
Cross-
sectional
Bergoglio,
 1964
Proportion-
ate morta-
lity
Biagini,
 1974
Clinical
study
Mexico
476 residents of the
colonies of Miguel
Aleman and Edwardo
Guerra.
Argentina
137,702 deaths in the
province of Cordoba
between 1949 and 1959.
Argentina
Cases:   14 persons  with
palmoplantar keratosis
and epitheliomas  (4 cases
had melanoderma)  who re-
sided in area with  high
arsenic concentrations.
Controls: 16 persons with  no
history of residing in area
of high arsenic concentrations.
61% of population had
arsenicism.  Highest in-
cidence was in children
(5-14 yrs).  In 297 cases,
73% were classified as be-
nign arsenicism, 24% with
advanced arsenicism, and 3%
with chronic arsenicism.
Reported arsenic level in
colonies' water sources
ranged from 0.5 to 3.9 ppm.

The proportion of deaths
attributed to cancer and
malignant tumors (23.8%)
was higher in a specific
region with high arsenic
levels in water compared
to cancer deaths (15.3%)
in the entire province.
Increased proportions of
mortality ratios were
noted for respiratory and
skin cancer in the high-
arsenic region.  Of all
cancer deaths in study
locations, 35% were due to
respiratory cancer and 2.3%
to skin cancer.  The pro-
portions in referent popu-
lation were not provided.

Retention rate of arsenic
by thyroid glands was
higher in cases.  Iodine
metabolism same for both
groups.
No control population.  Lack
of exposure and disease
duration information.
Satellite study performed to
validate death certifica
data.  Lack of arsenic expo-
sure data cited in paper.
Proportionate mortality
ratios not adjusted for age,
sex, or other confounding
factors.
Small sample size.   Selec-
tion criteria of cases and
controls were not described
by investigators.
                                                                                           (continued  on  the  following  pag*?]

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     AuthorType of study

     Central and South America(continued)
                                                   TABLE A-l.

                                    Study population
                                             (continued)

                                                    Results
                                                              High!ights/deficiencies
     Biagini,
      1972
                  Propor-
                  tionate
                  mortality
     Biagini et
      al., 1978
                  Case
                  report
i
en
Biagini et
 al., 1972
Cross-
sectional
     Biagini et
      al., 1974
                  Cross-
                  sectional
                Argentina
                Study population consis-
                ted of 116 patients from
                Cordoba who were being
                treated for chronic
                arsenic poisoning.
                Argentina
                276 adult patients,
                primarily from Cor-
                doba and Santiago
                del Estero.
Argentina
3 groups with 100 male
patients over 35 years
old in each.   Residents
of Cordoba.
                Argentina
                51 persons  in  Urutau
                (pop.  210)  whose  daily
                activities  did not
                require  them to leave
                village.
Of 78 who died from various
causes, 24 died from cancer.
The percentage of deaths
from cancer was 30.8% com-
pared to the general rate of
Cordoba, where the percentage
of deaths from cancer is 15%.
The rate was significantly
high.

15 of the 276 (5.4%)
patients with symptoms of
chronic hydroarsenicism
were found to have lung
cancer.  11 of 15 were
heavy or moderate smokers.

First group (with arsenic
exposure and symptoms of
chronic arsenic poisoning)
had 23 leucoplasias of the
oral cavity, 5 spinocellu-
lar cancers, and 2 cancers
of the larynx.  Second group
(those with arsenic exposure
and no symptoms of poisoning)
had 17 leucoplasias and 1
spinocellular epithelioma.
Third group (from area with-
out high arsenic concentra-
tions and no symptoms) had 8
leucoplasias.

Prevalence rate of palmo-
plantar keratoses was 25.4%
(13/51); for epHheliomas,
9.8% (5/51); and for melano-
derma, 11.8% (6/51).  Water
from two local sources had
arsenic levels of 0.76 ppm
to 0.8 ppm.
                                                              No exposure data reported.
                                                              Study was not population-
                                                              based.  No control popula-
                                                              tion was used.
Study was not population-
based.  Confounders or
other causes were not
studied.
                                                              Study did not include a
                                                              control  population.   Total
                                                              population at risk may have
                                                              been underestimated.
                                                                                                (continued on the following paqe)

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                                                  TABLE A-l.  (continued)
Author
Type of study     Study population
                                                                     Results
                                                             Highlights/deficiencies
Central  and South America   (continued)
Borgono et
 al., 1980
Cross-
sectional
Borgono et
 al., 1977
Cross-
sectional
 Borgono and
  Greiber,
  1972
 Cross-
 sectional
Chile
1,277 children
(11-15 yrs old)
of northern Chile
Chile
Group A:  Antofagasta
inhabitants over 6
years of age in 1976
who were exposed to
arsenic in drinking
water prior to the
operation of a water
treatment facility.
Group B:  Antofagasta
inhabitants under 6
years of age in 1976
who were not exposed to
high arsenic levels.

Chile
High-exposure  group:
204 residents  of
Antofagasta.
Control group:  96
residents of Iqulque.
Author reported that the
prevalence of cutaneous
lesions ranged from 3.5
to 64% 1n children resi-
ding in 5 localities.  The
rate of lesions was rough-
ly correlated with arsenic
levels in drinking water.
Levels of arsenic in hair,
nail, and urine samples and
water supplies exceeded
normal values in most cases.
Mo difference was found in
hair, nail, and urine levels
of arsenic between children
with or without skin lesions.

No cutaneous lesions in
the low exposure Group R.
Prevalence of lesions in
Group A was 15.3% (52/339)
in males and females.
Abnormal arsenic levels
were  found in the hair
and nail samples of both
groups.
 Antofagasta  residents had
 abnormal  skin  pigmentation
 and  a  mean arsenic  level
 of 0.61 mg/100 g 1n hair,
 and  subjects with normal
 skin had  an  arsenic level
 of 0.32 mg/100 g in hair.
 Iquique residents had no
 abnormal  pigmentation and
 the  mean  arsenic level  in
 hair was  0.08.  The preva-
 lence  rate,  among Antofa-
 gasta  residents, of abnor-
 mal  skin  pigmentation and
 hyperkeratosls was  80%  and
 36%, respectively.   Neither
 condition occurred  in
 Iqulque residents.
No control  group.   No spe-
cification of disease symp-
toms or their frequency.
Arsenic levels in drinking
water supplies of localities
presented in article.
Water treatment facility has
reduced arsenic levels in
drinking water.  Arsenic
levels were approximately
0.8 ppm prior to 1970 when
treatment plant started
operations.  Disease symp-
tomatology not specified.
Causative factors other than
the construction of a filter
plant in 1970 were not con-
sidered.
 No  exposure  data.   Sex  dis-
 tribution  differs  for expo-
 sure  groups.   Selection cri-
 teria were not explained by
 authors.
                                                                                            (continued on the following page)
                                                          A-6

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                                                   TABLE  A-l.   (continued)
Author
Type of study     Study  population
Results
Highlights/deficiencies
Central and South America  (continued)

Cebrian et        Cross-          Mexico
 al., 1983        sectional        Exposed population:
                                  296 of  998  (29.6%)
                                  inhabitants  of  El
                                  Salvador de  Arriba
                                  where arsenic levels
                                  in drinking  water
                                  were 0.41 ppm.
                                  Control  population:
                                  318 of  1,488 (21.4%)
                                  persons from San
                                  Jose del  Vinedo with
                                  arsenic concentration
                                  in drinking  water of
                                  0.005 ppm.
                                        Prevalence  rate  of cutanous
                                        signs  of  arsenic poisoning
                                        was 21.61 (64/296) in exposed
                                        population  vs. 2.2%  (7/318)
                                        1n control  population.  Preva-
                                        lence  rates of specific con-
                                        ditions in  exposed population
                                        were 17.6%  (52/296)  hypopig-
                                        mentation,  12.2% (36/296)
                                        hyperpigmention,  11.2% (33/296)
                                        palmoplantar  keratosis, 5.1%
                                        (15/296)  papular keratosis, and
                                        1.4% (4/296)  ulcerative zones.
                                        All of these  rates were signi-
                                        ficantly  greater than those in
                                        control population at p <0.05.
                                        Relative  risks of palmoplantar
                                        keratosis and hyperpigmentation
                                        were 36.0 and 6.4, respectively.
                                        Minimum total dose for skin le-
                                        sions  was 2 g for hypopigmenta-
                                        tion,  3 g for hyperpigmentation
                                        and palmoplantar keratosis, 8 g
                                        for papular keratosis, and 12 g
                                        for ulcerative lesions.  Short-
                                        est latency period for hypoplg-
                                        mentatlon was 8  years; for hy-
                                        perpigmentation  or palmoplantar
                                        keratosis,  12 years; for papular
                                        keratosis,  25 years; and for
                                        ulcerative  lesions,  38 years.
                          Study subjects selected by  a
                          systematic sampling scheme
                          of households.  Study popu-
                          lations derived from commu-
                          nities with similar socio-
                          economic conditions and age
                          and sex distributions.  Min-
                          imum total doses calculated
                          for specific dermal lesions
                          were not adjusted for body
                          weight or daily consumption
                          of arsenic.  Papular kerato-
                          sis and ulcerative lesions
                          were probably carcinomas.
                          Latency periods for dermal
                          lesions may have been sub-
                          ject to recall bias or study
                          artifacts due to use of pre-
                          valence data.  70% of arsenic
                          in drinking water of exposed
                          population was in pentavalent
                          form; the remainder was in
                          trlvalent form.
                                                                                           (continued on the  following page"]

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                                                                TABLE A-l.   (continued)
              Author
Type of study     Study  population
                                                                                  Results
                                                              Highlights/deficiencies
              Central  and South America  (continued)
              Chavez et
               al.,  1964
Cross-
sectional
i
CO
              Sanchez de
               la Fuente,
               undated
Cross-
sectional
Mexico
291 residents
(57.6%) of commu-
nity of Fim'sterre.
Mexico
6,287 (3,179
males, 3,108
females) from
17 rural com-
munities from
1962 through
1964.
38.8% (114/291) of the studied
population demonstrated symp-
toms of chronic arsenic poison
ing.  Prevalence of spotty
hyperkeratosis was 66% (92/
291); hyperpigmentation, 12.4%
(36/291); and carcinoma, 0.3%
(1/291).  Poisoning symptoms
were not present in subjects
younger than 7 years.  In
subjects over 10 years of
age, symptoms occurred more
frequently in males than in
females.  Frequency of disease
increased with age, years of
residency, and nutritional  de-
ficiency.  Prevalence rate of
various indices of nutritional
status in cases with chronic
poisoning was greater than
those without disease.

Study covered 6,287 of 7,271
(86%) persons at risk.  5.3%
(335 cases) of the sample
exhibited clinical signs of
chronic arsenicism.  Symptoms
had been present for 1-4 years
in over half of the cases.
Prevalence of symptoms in-
cluded:   5.0% (317/6,787)
hyperkeratosis, 4.0% (252/
6,287) melanoderma and dys-
chromia, 2.9% (183/6,287)
hyperdrosis, 2.4% (152/6,287)
nail deformation, and 0.05%
(3/6,287) epidermoid carcino-
ma.  Some wells in study area
had arsenic levels of 0.09 to
0.65 mg/L.
Detailed classification of
symptomatology and investi-
gation of socioeconomic and
nutritional factors in the
sample.  Mo control group
and no exposure data.  In-
sufficient data to determi
if poor nutritional status
preceded onset of disease
No specific exposure data.
Disease rates were apparent-
ly not age-adjusted.
                                                                                                         (continued on the following page)

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                                                   TABLE  A-l.   (continued)
Author
Type of study
  Study population
       Results
High! ights /deficiencies
Central and South America  (continued)
Zaldi var,
 1974
Cross-
sectional
Zaldi var
 and
 Guillier,
 1977
Case
report
Chile
Survey of 457
patients (208 males,
249 females) from
Antofagasta with
hydroarsenicism
lesions reported
between 1968 and
1971.  Comparison
of arsenicism rates
in Antofagasta be-
fore and after
introduction of a
water treatment
facility in 1970.
Chile
470 patients
(220 males,
250 females)
from Antofagasta
with arsenicism-
associated derma -
tosis between 1968
and 1971.
Arsenicism was most prevalent
in children.  Arsenic dose
decreased linearly as patient
age increased.  Yearly mean
arsenic concentrations in
drinkinq water were positively
correlated with incidence rates
between 1968 and 1971.  Lesions
included leukoderma, meianoderma,
hyperkeratosis, and squamous cell
carcinoma.  The mean arsenic con-
centration of drinking water sam-
ples from 1958 was 0.58 ppm, and
arsenicism incidence (per 100,000
population) was 146 for males and
168 for females.  In 1971, the
mean arsenic level was n.08 ppm,
and incidence rates declined to 9
and 10 (per 100,000) for males and
females, respectivelyK

Of the 470 patients, 50.n were
under the age of 10 years and
76.6% were under the age of 20
years.  High levels of arsenic
were found in the hai'- and
nails, but not in urine of
patients exposed in 1968.  Five
children out of 337 cases (0-15
yrs) died and autopsies indica-
ted fibrous intimal thickening
of arteries, epidermal  atrophy,
dermal fibrosis, and hyper-
keratosis.  Estimated yearly
mean doses of ingested arsenic
for the deceased children
ranged from 0.128 mg/kg bw/day
for the first year to 0.028
mg/kg bw/day in the seventh year.
Svmptoms we^e not
specified according to
dose.
Selection bias may have
existed since cases
originated from a hos-
pital.  Arsenic dosage
in sick children was ex-
trapolated from ingestion
experience of healthy
children during 1972.
                                                                                           (continued  on  the  following  page)

-------
                                                   TABLE A-l.  (continued)
Author
Type of study     Study population
                                  Results
                                    Highlights/deficiencies
Central and South America  (continued)
Tovar et
 al., 1964
Clinical
Zal di var,
 1977
Cross-
sectional
Mexico
12 of 294 persons
from community of
Finisterre with
varying degress of
arsenicism, inclu-
ding 3 persons with-
out the disease,
received calcium
trisodium diethyl-
tetra-ami no-penta
acetate (DTPA) to
test the efficacy
of the drug in elimi-
nating body burden of
arsenic.

Chile
Dietary and water
intake survey of 220
persons in 1972 rep-
presenting nine age
groups of each sex.
Arsenicism prevalence
rates were developed
from another popula-
tion (i.e., Antofa-
gasta Commune) for
1968 through  1971.
Administration of DTPA did
not result in excretion of
arsenic.
Arsenic dose levels were
inversely related to age
and ranged from 0.0022 to
0.0633  mg/kg/day.  Age-
specific prevalence rates
of chronic arsenic poison-
ing ranged from 0 to 726
per 100,000 and were posi-
tively correlated with age-
specific arsenic doses.
Children (0-15 yrs) had more
severe symptoms and higher
ingested arsenic doses.
Lesions included leukome-
lanoderma, hyperkeratosis,
and multiple squamous cell
carcinoma.
Investigators reported that
cases came from community
with arsenic concentration
in drinking water ranging
from 0.6 to 0.9 ppm.  Small
sample size.  All persons in
study were from same area
and similar backgrounds.
Very few studies have
reported dose-response
data.  Exposure was based
on 1972 data and disease
rates from 1968 through
1971.  Arsenicism symptoms
were not specified accord-
ing to dose.
                                                                                           (continued on the Tollowi ng~ pagol

-------
                                                  TABLE A-l.   (continued)
Author
Type of study
  Study population
       Results
Highlights/deficiencies
Germany

Geyer,
 1898
Case
reports
Liebegott,
 1952
Autopsy
series
Individuals in
mining region in
Silesia drinking
ground water con-
taining arsenic.
Wine growers ex-
posed to arsenic
from pesticides.
Author concludes
that principal
arsenic exposure
was through home-
made drink  from
grapeskins  re-
ported to contain
arsenic at  up to
5 mg/L.
Kerotoses and melanoses
reported in approximately
20 individuals In one
village who consumed con-
taminated water.  Several
cases were reported in fam-
ilies.  Individuals 1n broader
region were reported to have
short lifespan.  Nervous dis-
turbances similar to those
observed by Hutchinson were
noted.  Reports of three
individuals who developed skin
cancer, attributed to arsenic,
are presented.  In recent years,
water supply had been replaced
and health problems lessened.

In a series of 19 autopsied
growers, all were found to
have arsenical hyperkeratosis
on hands and soles of feet.
17 had liver cirrhosis attri-
buted to arsenic.  Three of the
latter had multlcentHc liver
carcinomas.  Two additional
cases with liver carcinoma
were examined.  An additional
group of 8 cases of skin car-
cinoma in conjunction with
hyperkeratosis were reported
In 5 patients, multiple car-
cinomas were seen; in untreated
cases, regional lymph node
metastases were seen.
Information limited to case
reports; however, these
reports represent careful
clinical observations of
related problems in indivi-
duals in a small geographic
area.
The size of the population
from which autopsied cases
were drawn was unspecified,
as were reasons leading to
autopsy.
                                                                                           (continued  on  the  FoTTowing

-------
                                                        TABLE  A-l.   (continued)
     Author
Type of study     Study population
                                  Results
                                   Highlights/deficiencies
     Germany (continued)
     Luchtraht,
      1972
Autopsy
series
>
 i
Moselle vintners
exposed to arsenic
pesticides.   Expo-
sures ceased in 1942;
autopsies were per-
formed from 1960 to
1977.  Autopsled cases
were stated to have
had chronic  arsenic
poisoning.
Among 163 patients, 108 with
lung tumors (66%), 30 (18%)
with skin carcinomas, 54
(33%) with Bowen's disease,
and 5 (3%) with liver tumors
were noted.  For comparison,
163 age- and sex-matched
postmortem examinations In
non-wine growers were re-
viewed.  In that group, 14
lung cancers (14%) and no
tumors of the other types
above were noted.  Additional
data from a local trade asso-
ciation registry of 417 wine
grower deaths contained sim-
ilarly high excesses of lung
and liver cancer (skin pft
mentioned).  Skin hyperMra-
toses were also a prominent
finding 1n author's examina-
tions, being found In almost
all those examined.
Analysis of data is
limited by lack of clearly
defined method of selec-
tion of autopsied cases.
Reported skin, lung, and
liver tumor occurrences
were strikingly high.
                                                                                                (continued on  the  following page]

-------
                                                   TABLE A-l.  (continued)
Author
Type of study     Study population
                                  Results
                                   Highlights/deficiencies
Germany (continued)
Roth,
 1957
Autopsy
series
Roth,
 1956
Autopsy
series
Moselle vintners
exposed to arsenic
trioxide were
autopsied to ascer-
tain whether arsenic
exposure led to
death.  Vintners had
been exposed to in-
secticides for 12 to
17 years, with death
occurring 8 to 14
years after cessation
of exposure.
See Roth  (1957).
Pathologic findings were
reported for 27 autopsies.
16 patients had a total of
28 malignant neoplasms,
including 12 cases with
bronchial carcinomas,
5 cases with skin car-
cinomas, and 3 with liver
tumors.  Hyperkeratoses
were prominent In the
group, 13 cases of liver
cirrhosis attributed to
arsenic were noted, and 1
Individual had peripheral
vascular damage leading to
amputation of a leg.

Provides greater detail
on 24 of the autopsies
reported in Roth (1957).
Estimates of arsenic expo-
sure levels are presented.
The size of the population
from which the autopsies
were drawn is not specified;
neither are the specific
circumstances that led to
an autopsy being performed.
See Roth (1957).
                                                                                           (continued on the following page)

-------
                                                   TABLE A-l.   (continued)
Author
Type of study     Study population
                                  Results
                                   Highlights/deficiencies
United States

Birmingham
 et al.,
 1965
Harrington
 et al.,
 1978
Kjeldsberg
 and Ward,
 1972
Community
medical
survey
Survey of
symptom
prevalence
and levels
of arsenic
exposure
Case
report
Residents near gold
smelter which pro-
duced substantial
arsenic dust.
Limited water sam-
ples showed 0.03
mg/L arsenic.

232 residents in
Fairbanks, Alaska,
divided into 4
groups according
to drinking water
source, e.g., bot-
tled water or high-
arsenic ground water
Woman who used
arsenical  pesti-
cides in gardening.
32/40 school children
showed "suspect arsenical
dermatoses."  Ulceration
was noted on hands.  Sev-
eral housewives also were
afflicted with skin pro-
blems.

A correlation between water
arsenic level and urine
arsenic level was demon-
strated.  The authors stated
that Information obtained by
questionnaire and clinical
exams did not demonstrate
any intergroup differences
in skin, peripheral nervous
system, or other abnormal-
ities.

Patient developed pancyto-
penia and later, melogenous
leukemia.  Physicians believed
illness was arsenic-related.
The sizes of examined groups
were small; exposure was
less than 10 years in dura-
tion; no data on the clin-
ical observations of symp-
toms was reported.
Single case report.
                                                                                           (continued  on  the  following  page)

-------
                                                   TABLE A-l.  (continued)
Author
Type of study     Study population
                                  Results
                                   Highlights/deficiencies
United States (continued)
Southwick
 et al.,
 1983
Clinical
examination,
disease
incidence
and mortal -
ity analy-
sis, and
exposure
assessment
Populations of
Hinckley and Desert,
Utah, who are ex-
posed to approximate-
ly 0.2 mg/L arsenic
in drinking water.
Population of nearby
Delta (<0.25 mg/L
arsenic) served as
control.
Elevated urine arsenic demon-
strated.  Statistically
elevated prevalence of derma-
tological signs or other
symptoms was not observed.
Hinckley showed relatively
hi gh total cancer mortali ty
data, but cancer incidence
data was not similarly high
(neither of which had any
bearing on skin cancer).
Very small population
studied (144 total for
Hinckley and Desert;
31 age 60 or older
given physical  exam).
Andelmann and Barnett
(1984) calculated that
the negative findings
were not inconsistent
with the EPA risk model
based on Taiwan data.
Wagner
 et al.
 1979
Case
report
41-year-old woman
who was consuming
well water containing
1.2 ppm arsenic in
Lane County, Oregon.
12 years previously, patient
had been diagnosed as having
acute arsenlsm after drinking
contaminated well water for
6 months.  Authors reported
that she had multiple skin
lesions (43 were removed),
including i^ situ squamous
cell carcinoma and multi-
centric basal cell carcinoma.
                                                                                           (continued on the following page)

-------
                                                   TABLE  A-l.   (continued)
Author
Type of study     Study population
                                  Results
                                   Highlights/deficiencies
United States (continued)
Morton
 et al.,
 1976
Kelynack
 et al.,
 1960
Geographic
correlation
of skin
cancer in-
cidence with
measured
drinking
water
arsenic
levels.
Clinical
observa-
tion and
analysis
of mortal-
ity records.
Lane County,  Oregon,
population:  190,871
in 1965.   Skin cancer
incidence determined
from pathology records;
arsenic levels measured
in 558 water  samples,
8% of which  exceeded
50 ppb.
Beer drinkers exposed
to arsenic  through
contaminated ingredi-
ent.  Chemical  mea-
surements of arsenic
in beer were made
(trace - 4.8 ppm,
average 1.7 ppm in
16 samples).
No relation was found In
correlation between dis-
trict skin cancer and
average arsenic levels.
Physicians noted unusual
excess of patients with
peripheral neuritis mani-
fested in weakness and pains
in limbs and difficulty in
walking.  Patients also
typically had skin disorders:
darkening, thickening, and
deterioration of skin on
hands and feet,  many cases
of "branny" desquamatlzatlon.
Review of mortality records
revealed that deaths attribu-
ted to neuritis or alcoholism
totaled 66 in 4-month period
of poisoning episode, com-
pared with 27 to 39 in pre-
vious whole years.
Age standardization was
accomplished by an indi-
rect regression method.
Andelmann and Barnett
(1984) calculated the
negative findings by
Morton et al. and con-
cluded that they were
not inconsistent with
the EPA risk model based
on Taiwan data.
                                                                                           (continued  on  the  following page)

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                                                  TABLE A-l.  (continued)
Author
Type of study     Study  population
                                                                   Results
                                   Highlights/deficiencies
England

Philipp
 et al.,
 1983
Reynolds
 et al.,
 1901
Geographic      Cancer  registry  data
correlation     on cases  of  malignant
                melanoma  were  obtained
                by district  in south-
                west England.   Popu-
                lation  data  were
                available by census.
                A nationwide survey
                of arsenic levels  in
                stream-bed sediments
                was used  to  classify
                districts into high-
                and low-arsenic
                categories.

Review of       Residents of Manchester
clinical        who consumed beer  con-
experience      taminated with arsenic.
                Chemical  measurements
                revealed  2 to  4 ppm
                arsenic in beer.
A positive correlation
(p <0.05) was found between
district melanoma rates and
arsenic categories in males.
When analysis was restricted
to rural areas, the positive
correlation was again ob-
tained.  No similar cor-
relation was found in
females, who had higher
overall incidence rates
than males.
Author had charge of 500
patients with arsenical
poisoning, of whom 13 died.
Skin lesions were present
in almost all patients.
Skin darkening, keratosis of
hands and feet, herpes zoster,
and presence of tender, Irri-
tated regions were common.
Patients experienced loss of
feeling and weakness in limbs.
Circulatory problems were
noted.  Author estimates at
least 2,000 cases of poison-
Ing occurred In Manchester.
No common trend was seen
in males and females.   The
arsenic measure used may
or may not be reflective
of population arsenic expo-
sure.
                                                                                           (continued  on  the  following  page)

-------
                                                                  TABLE A-l.   (continued)
               Author
 Type  of  study
  Study population
                                                                                   Results
                                    Highlights/deficiencies
               China

               Yue-zhen
                et al.,
                1985
i—•
co
               Japan

               Yamashita
                et al.,
                1972
Clinical
survey  of
conwnuni ty
Study of
teenagers
who were
exposed to
arsenic-
tai nted
mi 1 k in
infancy.
Parental
interviews,
physical
exams, and
psychologic-
al tests were
administered
to assess
state of
health and
development.
359 persons residing
at an industrial
plant consumed water
containing 0.6 mg/L
arsenic.
554 exposed teenagers
were identifed from
a variety of local
sources.   Controls
came from the exposed
students  schools.
Controls  for psycho-
logical tests came
from one  local  school.
No controls were  used
in physicals.
 Among  336  individuals  exam-
 ined,  150  with  skin  lesions
 of  chronic arsenism  were
 found.   All  affected had
 consumed the contaminated
 water  for  6  months to  12
 years.   126  cases of dys-
 pigmentation and 84  keratotic
 lesions  (primarily on  palms
 and  soles) were noted.
 Among  33 patients questioned
 in  depth,  13 noted numbness,
 most commonly on hands and
 feet;  a  variety of other
 symptoms were noted.  The
 authors  reported that ? cases
 of  cutaneous carcinoma had
 been reported in the same
 area;  however, none were
 observed in  this study.
Parents reported that exposed
children had a variety of
physical maladies and learn-
ing/social difficulties.
Many complaints, including
dark spots and white spots
on skin, were well  in
excess of controls.  Medical
exam identified CMS problems,
skin problems (hyperpigmen-
tation, depigmentation, hyper-
keratosis [15%]), low height,
and other symptoms  (no statis-
tics).  Intelligence tests and
other psychological tests showed
markedly poor performance for
exposed group compared with the
local  high school.
Study approaches were not
as refined as are needed
for good statistical com-
parisons.  Study identified
numerous problems which
deserve more attention.
Large Japanese exposed
group is available for
future work.
                                                                                                          (continued  on  the  following  page)

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                                                  TABLE A-l.   (continued)
Author
Type of study     Study  population
                                  Results
                                   Highlights/deficiencies
Arsenical Medicinals
Braun,
 1958
Case
report
Cuzlck et
 al., 1982
Cohort
Falk et al.,
 1981
Case report
18 patients with
skin and/or vis-
ceral  cancers.
478 patients treated
with Fowler's solu-
tion (an arsenical
medicinal) for periods
ranging from 2 weeks
to 12 years between
1945 and 1969.
7 male patients
and 1 female
anglosarcoma
patient.
16 of the patients with skin
and/or visceral cancer were
vintners who had used arsen-
ical pesticides; one patient
with skin and lung cancer had
taken an arsenical medicinal;
another skin cancer patient had
taken an arsenical medicinal.

A statistically significant
association of Ingestlon of
Fowler's solution with deaths
from Internal malignancies was
not found.  A subset of 142
of the 478 In the cohort was
examined In 1969-1970, and 491
were found to show dermal
signs of arsenldsm, Including
skin cancer (11%).
All of the patients had
previously taken Fowler's
solution.
In the subset of 142,  deaths
from Internal malignancies
occurred only in those who
had previously demonstrated
dermal signs of arseniclsm,
leading the authors to con-
clude that perhaps persons
who show signs of arseniclsm
are at a greater risk  of
death from internal malig-
nancies.  Patients with
signs of arsenicism (kera-
tosls, hyperpigmentation,
and skin cancer) had higher
median doses than those
without signs.
                                                                                           (continued on  the  following page]

-------
                                                        TABLE A-l.  (continued)
     Author
                  Type of study
                  Study population
                                  Results
                                   Highlights/deficiencies
     Arsenical Medicinals  (continued)
     Fierz, 1965
                  Cohort
i
ho
O
Hutchinson,
 1888
     Istvan
      et al.
      1984
     Jackson and
      Gainge,
      1975
Case
report
                  Case
                  report
                  Case
                  reports
                262 patients treated
                with Fowler's solu-
                tion by a private
                practitioner.
6 patients being
treated with
arsenical  medici-
nals.
                Individual  who
                received 7-month
                course of arsenic
                therapy for psoriasis.

                Seven individuals
                tested with Fowler's
                solution.  Cases
                selected from
                clinical files.
                           106 of the 262 patients report-
                           ing for physical examination
                           reported hyperkeratosis; 21
                           cases of skin cancer were
                           found.  The response increased
                           with increasing dose.
The 6 patients treated with
arsenical medicinals exhi-
bited the keratotic lesions
associated with arsenical
poisoning.

Angiosarcoma of liver devel-
oped 25 years after therapy.
                           Six cases of basal  cell  car-
                           cinoma,  carcinoma 1n situ,  or
                           squamous cell carcinoma  of  skin
                           were reported.   Two of these
                           patients had systemic cancer
                           (breast  and colon).   All  7
                           patients showed keratosls on
                           palms and soles.
                                   Less than 45% of a group of
                                   1450 to whom invitations to
                                   participate in the study
                                   were sent presented them-
                                   selves for physical exam-
                                   ination, and the author
                                   himself reported that the
                                   patients reporting for exam-
                                   nation were not a represen-
                                   tative sample.  No controls
                                   were used.
                                                                                                (continued on the following page]

-------
                                                   TABLE  A-l.   (continued)
Author
Type of study     Study population
                                  Results
                                   Highlights/deficiencies
Arsenical Medicinals (continued)
Knoth, 1966
Case report
Lander et
 al., 1975

Morris et
 al., 1974
Case report


Case report.
2 male patients,
one with a retlc-
ulosarcoma of the
glans penis and
one with skin can-
cer; one female
patient with both
skin cancer and
mammary cancer.

1 male angiosarcoma
patient.

2 male patients;  one
had skin pigmentation,
skin tumors, carcino-
ma of the larynx, and
a probable bronchial
carcinoma; the other
had skin pigmentation
and keratosis.  Both
had non-cirrhotic
portal hypertension.
All of the patients had pre-
viously been treated with
Fowler's solution.
The patient had previously
taken Fowler's solution.

Both patients had previously
taken Fowler's solution.
                                                                                           (continued on the following page)

-------
                                                              TABLE  A-l.   (continued)
           Author
 Type  of  study
   Study population
                                                                                Results
                                    Highlights/deficiencies
           Arsenical Medicinals  (continued)
           Neubauer,
             1947
           Nurse,  1978
           Popper et
            al., 1978
Case
report
Case
report
Case
report
NJ
ho
           Prystowsky
            et al.,
            1978
           Regelson et
            al., 1968
           Reymann et
            al., 1978
Case
report
Case
report
Cohort
 143 patients with
 epithel ioma.
Male patient with
adenocarcinoma of
the kidney.
4 male and 1
female angio-
sarcoma patients.
Female patient with
nasopharyngeal  can-
cer and with palmar
and plantar keratosis.

Male patient with
hemangi oendothel i al
sarcoma of the live'1.
389 patients treated
with arsenical  medi-
cinals between  1930
and 1939 at a derma-
tology clinic in
Denmark.
 The  patients  had previously
 been treated  with arsenical
 medicinals  for skin  diseases
 and  various internal  dis-
 orders.

 Patient  had taken arsenical
 medicinal approximately  20
 years  previously for psori-
 asis.

 Four of  the patients  had
 previously  taken Fowler's
 solution fo>-  10  to 17 years
 for  psoriasis  or asthma.
 There  was not  enough
 information for  the  fifth
 patient  to  ascertain dura-
 tion of  exposure.

 Patient  had received Fowler's
 solution almost yearly for 20
years  prior to development of
 the  cancer.

The  patient had  previously
 been treated with Fowler's
 solution for psoriasis for
 17 years.

Of 389 persons treated with  -
arsenical medicinals, 41 in-
ternal malignant neoplasms
were found  to occur during
1943 through 1974 versus
44.6 expected.  No increase
in internal  malignant neo-
plasms was  found by dose.
 Patient  treated with a vari-
 ety  of other drugs  before
 developing  kidney cancer.
The end point, "internal
malignant neoplasms," is
not specific.  It is pos-
sible that the risk of
cancer for particular
organ sites was elevated,
but this was not reported
by the authors.
                                                                                                      (continued on the following page)

-------
                                                        TABLE A-l.   (continued)
     Author
Type of study     Study population
                                  Results
                                   Highli ghts/defi ci enci es
     Arsenical Mediclnals (continued)
     Roat et
      al., 1982
     Sowners and
      NcNanus,
      1953
Case
report
Case
report
:>

u>
Hale patient with
anglosarcoma and
skin cancer.

27 cases of skin
cancer; 10 of the
cases also had
visceral cancer.
Patient had previously
Ingested Fowler's solution
for 6 months.

12 of the patients had been
treated with Fowler's solu-
tion for psoriasis, 2 for
epilepsy, and 1 with in-
jected arsenlcals for
syphilis.  2 patients had
occupational exposure to
arsenical sprays and 4
had had possible exposures.
7 had been treated with
arsenic for swollen lymph
nodes, burns, dermatitis,
or chorea.  In 3 patients
the means of exposure were
unknown.  All had the
characteristic keratosls of
the palms and soles.
For the 22 patients for
whom the time from begin-
ning of exposure to onset
of cancer was known, the
latent period ranged from
3 to 50 years.

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                  APPENDIX B







Quantitative Estimate of Risk for Skin Cancer



      Resulting from Arsenic Ingestion

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                                    CONTENTS




List of Tables	      B-iii

List of Figures	      B-iv

  I.  METHODOLOGY	      B-l

 II.  APPLICATION TO TAIWAN EPIDEMIOLOGIC STUDY 	      B-l

III.  USE OF THE MEXICAN DATA TO EVALUATE TAIWAN'S DOSE-RESPONSE
      MODEL	      B-16

 IV.  USE OF THE GERMAN DATA TO EVALUATE TAIWAN'S DOSE-RESPONSE
      MODEL	      B-21

  V.  DISCUSSION ABOUT THE UNCERTAINTIES OF THE RISK ESTIMATES. .  .  .      B-24

 VI.  SUMMARY	      B-28
                                      B-ii

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                                     TABLES
B-l       Estimated distribution of the surveyed male population at
          risk (skin cancer cases) by age group and concentration of
          arsenic in well  water in Taiwan	    B-4

B-2       Estimated distribution of the surveyed female population at
          risk (skin cancer cases) by age group and concentration of
          arsenic in well  water in Taiwan	    B-5

B-3       Conversion of arsenic dose for Taiwanese to equivalent
          arsenic dose for U.S. population	    B-7

B-4       Results of model fitting to Taiwan skin cancer data 	    B-8

B-5       Results of model fitting to Taiwan skin cancer data,
          adjusted for background rate	    B-17

B-6       Lesions counted as skin cancers (ulcerative lesions and
          papular keratosis) in Mexico study, and predictions based
          on Taiwan experience, both genders combined 	    B-18

B-7       Conversion of arsenic dose for Mexicans to equivalent
          arsenic dose for U.S. persons	    B-19

B-8       Skin carcinomas in patients treated with Fowler's
          solution who were in the Fierz follow-up study	    B-22

B-9       Age-specific incidence rates calculated from age-specific
          prevalence with equal and differential mortalities	    B-27
                                     B-iii

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                                   FIGURES
B-l       Observed and predicted skin  cancer prevalence  for Taiwanese
          males at three exposure levels,  by age;  prevalence  predicted
          by use of the model,  linear  in  dose	    B-9

B-2       Observed and predicted skin  cancer prevalence  for Taiwanese
          males at three exposure levels,  by age;  prevalence  predicted
          by use of the model,  linear  and  quadratic  in  dose	    B-10

B-3       Observed and predicted skin  cancer prevalence  for Taiwanese
          females at three exposure levels,  by age;  prevalence predicted
          by use of the model,  linear  in  dose	    B-ll

B-4       Observed and predicted skin  cancer prevalence  for Taiwanese
          females at three exposure levels,  by age;  prevalence predicted
          by use of the model,  linear  and quadratic  in  dose	    B-12

B-5       Lifetime skin cancer risk for a U.S. person,  predicted
          from the Taiwanese male experience.  "Linear"  = estimated by
          use of the model, linear in  dose;  "Quadratic"  = estimated by
          use of the model, linear and quadratic in  dose	    B-14

B-6       Lifetime skin cancer risk for a U.S. person,  predicted from
          the Taiwanese female experience.  "Linear" = estimated by use
          of the model, linear in dose; "Quadratic"  = estimated by use
          of the model, linear and quadratic in dose	     B-15
                                       B-iv

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                                 I.  METHOLOGY

     A generalized multistage model  is  employed to  predict  the  prevalence  of
skin cancer as a function of arsenic concentration  in  drinking  water (d) and
age (t), assuming exposure to a constant dose rate  since  birth.   Let F(t,d)
represent the probability of developing skin cancer by age  t after lifetime
exposure to arsenic concentration d.   The model has the following form:

                           F(t,d) =  1  - exp [-g(d)  H(t)]

where g(d) is a polynomial in dose with non-negative coefficients, and H(t)  is
(t-w)k, where k is any positive real  number, and t  > w for  induction time  w.
The model F(t,d) is a generalization of the multistage in which k can only
assume the value of positive integers.   The multistage model is consistent with
the somatic mutation hypothesis of carcinogenesis (Armitage and Doll, 1954;
Whittemore, 1977; Whittemore and Keller, 1978).  It also results from the
epigenetic hypothesis when reversible  cellular changes occur randomly (Watson,
1977).  Moreover, it can be derived  from the multistage theory of carcinogenesis
(Armitage, 1982).  These authors and many others have used  this model to interpret
and/or estimate potency from human data.  The number of people at risk and the
number with skin cancer at different values of t and d must be known in order
to employ maximum likelihood estimation (MLE).

                 II.  APPLICATION TO TAIWAN EPIDEMIOLOGIC STUDY

      In order to use the model described above and the prevalence data provided by
Tseng et  al.  (1968) and Tseng  (1977),  the following three assumptions must be made:
                                       B-l

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     (1)   The mortality  rate  was  the  same  in  the  diseased  (skin cancer)  persons
          as in the nondiseased persons.
     (2)   The population composition  (with respect  to  the  risk factors of  the
          skin cancer)  remained constant over time.  This  assumption  implies
          that there was no cohort  effect.
     (3)   The skin cancer was not surgically  removed.
     The  first assumption may not be  reasonable because  there  is  reason  to
believe that the mortality rate in  the  diseased  (skin  cancer)  persons was  higher
than in the nondiseased persons.   Tseng et al .  (1968)  reported that 61 skin
cancer patients (out of a total of 428  individuals  with  skin cancer)  had also
incurred  Blackfoot disease which  was  known to have  higher  death rates than the
general population.  The impact of this potential differential mortality will
be investigated in Section V  of this  Appendix.  The second assumption seems
less a problem in view of the fact that the population studied by Tseng  and  his
associates was stable.   However,  the  probability  still exists  that there may be
some cohort effect due to the change  of risk  factors,  such as  the change of  the
arsenic water concentration over time (over 60 years).  The last  assumption  is
reasonable because the studied population  was very poor, and medical  (surgical)
service to the population was almost  nonexistent.
     Tseng et al. (1968) and Tseng (1977)  reported skin cancer prevalence
rates as percentages specific to age  group and arsenic concentration  for each
gender.  The underlying "raw" prevalence  ratios  were calculated  from the percentage
estimates by use of data in Tseng's 1968  publication.   The use of these  ratios
permits use of all the data, including that for controls and the  0 to 19 age
group, which had not been included in EPA's 1984 analysis.  The  procedure  used
for estimating the actual number of persons at risk is presented in  the paragraphs
that follow.
                                      B-2

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     The percentage age distribution  of the population  in  the  endemic  area  by
gender appears in Table 3 of Tseng et al.  (1968).   (Note that  the percentages
for males and females in the endemic  area  do not sum to 100.)   Age group  per-
centages were applied to the male population surveyed (19,269)  to estimate  the
totals at each age.  These were distributed among  the four dose categories
under the assumption that the age distribution of  the surveyed males at each
arsenic exposure category is the same.  This was accomplished  by solving  a  set
of equations.  Table B-l shows the resulting distribution of the male population
at risk.  Furthermore, it was assumed that the distribution of surveyed females
across age and dose categories was the same as that for men (see Table B-2).
The age distribution of the control  population appears  in Table 3 of Tseng  et
al. (1968).  Tables B-l and B-2 also show the number of cancer cases observed
in each age and dose group.
     Next, values of t and d representative of each age and arsenic concentra-
tion interval were determined.  For each interval  a weighted average age was
calculated from the data in Table 3 of Tseng et al . (1968). The resulting
values of t that relate to the skin cancer prevalence rate for males (females)
are 8 (9), 30 (30), 49 (50), and 69 (68).
     From the distribution of arsenic concentrations in well water depicted in
Figure 2 of Tseng et al. (1968), and the fact that the highest arsenic content
in surveyed well water was 1.82 ppm, weighted average arsenic  concentrations
(in ppm) of 0.17, 0.47, and 0.80 were calculated for the low,  medium, and high
concentration groups, respectively.  (This approach does not accommodate the
variation with respect to time of the arsenic concentration in well water noted
by the authors, but for which no data are available.)  These values were then
converted into equivalent doses for the U.S. person in units of ug/kg/day using
the following assumptions:  the "reference" U.S. person weighs 70 kg and consumes
                                      B-3

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   Arsenic
              TABLE B-l.  ESTIMATED DISTRIBUTION OF THE SURVEYED
                 MALE POPULATION AT RISK (SKIN CANCER CASES)
           BY AGE GROUP AND CONCENTRATION OF ARSENIC IN WELL WATER
                                  IN TAIWAN3
                                         Age group  (years)
concentration
(ppm)
Low (0-0.30)
Medium (0.30-0.60)
High (> 0.60)
Unknown
Total
0-19
2,714b
(0)C
1,542
(0)
2,351
(0)
4,933
(0)
11,540
(0)
20-39
935
(1)
531
(2)
810
(18)
1,699
(3)
3,975
(24)
40-59
653
(4)
371
(18)
566
(56)
1,188
(61)
2,778
(139)
>_ 60
236
(11)
134
(22)
204
(52)
429
(64)
1,003
(149)
Total
4,538
(16)
2,578
(42)
3,931
(126)
8,249
(128)
19,296
(312)
aFor the control  group, the number of persons  in  each  of  the  four  age  groups,
 0-19, 20-39, 40-59,  and >_ 60,  respectively are 2,679,  847, 606, and 176.
 No skin cancer was observed in the control population.

^Estimated of number  of persons at risk.

cEstimated number of  skin cancer cases observed.
                                      B-4

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   Arsenic
               TABLE  B-2.   ESTIMATED DISTRIBUTION OF THE SURVEYED
                 FEMALE  POPULATION AT  RISK  (SKIN CANCER CASES)
            BY  AGE  GROUP AND  CONCENTRATION OF ARSENIC  IN WELL WATER
                                  IN  TAIWAN3
                                        Age  group  (years)
concentration
(ppm)
Low (0-0.30)
Medium( 0.30-0. 60)
High (> 0.60)
Unknown
Total
0-19
2,651b
(0)C
1,507
(0)
2,296
(0)
4,819
(0)
11,273
(0)
20-39
1,306
(0)
742
(1)
1,131
(4)
2,373
(2)
5,552
(7)
40-59
792
(3)
450
(9)
686
(33)
1,440
(13)
3,368
(58)
>_ 60
239
(2)
136
(8)
207
(22)
435
(27)
1,017
(59)
Total
4,988
(5)
2,835
(18)
4,320
(59)
9,067
(42)
21,210
(124)
aFor the control  group,  the number of persons in each  of the  four age  groups,
 0-19, 20-39, 40-59,  and _> 60,  are respectively 2,036,  708, 347,  and 101.
 No skin cancer was observed in the control  group.

^Estimated number of persons at risk.

°Estimated number of skin cancer cases observed.
                                      B-5

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consumes 2 L of water daily;  the "reference"  Taiwanese  male weighs  55  kg and
consumes 3.5 L of water daily;  and the "reference"  Taiwanese  female weighs  50 kg.
The resultant arsenic dose rates,  normalized  to  the reference U.S.  person,  are
presented in Table B-3.
     These data were used with  the generalized multistage  model  to  predict
dose- and age-specific skin cancer prevalence rates associated with ingestion
of inorganic arsenic for the reference U.S. person  based on the Taiwanese
experience.  The four dose groups  include control,  low, medium, and high.
     The model was fitted separately to the  skin cancer data  for males and
females.  The g(d) was evaluated as to linear and quadratic function of dose
(i.e., two models were considered; one was linear in dose  and the other was
both linear and quadratic in dose).  The MLEs of g(d),  H(t),  and the log likeli-
hood (In L) estimate are shown  in  Table B-4.   Table B-4 shows the unit risk,
the probability that a U.S. person exposed to dose  d =  1 ug/kg/day  of  arsenic
in drinking water will develop  skin cancer in lifetime.  It is adjusted for the
survivorship of the U.S. population by the life-table analysis.
     For visual inspection of the goodness-of-fit of the model with time,  values
of the observed skin cancer prevalence rates  for Taiwanese males were  given in
Figures B-l and B-2, for linear and quadratic dose, respectively.  Figures  B-3
and B-4 show the analogous plots for females.  While the suitability for a
particular model is not obvious from these plots, there is some evidence
favoring the quadratic  (both linear and quadratic in dose) model.  For each
gender-specific set of models,  a test of the null hypothesis  that the  coefficient
corresponding to d? is zero is rejected at p < 0.01 via the  asymptotic likelihood
ratio test.
                                      B-6

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              TABLE  B-3.   CONVERSION OF ARSENIC DOSE FOR TAIWANESE
                 TO  EQUIVALENT ARSENIC DOSE  FOR U.S. POPULATION3
               Taiwanese                         U.S.  person
                 (ppm)                           (ug/kg/day)
         Males    0.17                              10.8
                  0.47                              29.9
                  0.80                              50.9
       Females    0.17                              6.8
                  0.47                              18.8
                  0.80                              32.0
Assumptions:   A U.S.  person weighs  70  kg  and  drinks  2 L  of water  daily;
 a Taiwanese male weighs  55  kg and drinks  3.5  L  of water  daily; a  Taiwanese
 female weighs 50 kg and  drinks 2 L  of  water daily.
                                      B-7

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        TABLE B-4.   RESULTS OF MODEL  FITTING  TO  TAIWAN  SKIN CANCER DATA
               Linear                                 Quadratic


Males:

             Doses (d):   0,  10.818,  29.909,  50.909  ug/kg/daya


g(d) = (0.302525 x 10-7)d                   g(d)  =  (0.124707  x  10-7)d
                                                   + 0.404871 x  10-9)d2

H(t) = (t - 6.931)2.935                     H(t)  =  (t _  5.373)2.950

In L = -614.551                             In L  =  -610.088

Unit risk (probability of skin cancer       Unit  risk (probability of  skin  cancer
in lifetime due to 1 ug/kg/day              in lifetime  due to  1  ug/kg/day
of arsenic)                                 of arsenic)


= 5.0 x 10-3                                = 2.3 x 10-3


Females:

             Doses (d):   0,  6.8,  18.8,  32.0 ug/kg/daya


g(d) = 0.682262 x 10-8)d                    g(d)  =  (0.157281  x  10-8)d
                                                   + 0.204076 x 10~9)d2

H(t) = (t - 9.0)3.225                       H(t)  =  (t _  9.0)3.231

In L = -348.041                             In L  =  -344.365

Unit risk (probability of skin cancer       Unit  risk (probability of  skin  cancer
in lifetime due to 1 ug/kg/day              in lifetime  due  1 ug/kg/day
of arsenic)                                 of arsenic


= 3.4 x 10-3                                = 1.0 x io-3


aDose estimates for U.S. persons (see Table B-3).

SOURCE: Data from Tseng et al ., 1968.
                                      B-8

-------
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                                                          >*
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-------
    .mt
u
u
z
u
IX
Q.

Q
U
              OBSERVED
              PREVALENCE
H = HIGH DOSE
M = MEDIUM
L = LOW
         te
                                 4*


                                AGE
     Figure B-2. Observed and predicted skin cancer prevalence
     for Taiwanese males at three exposure levels, by age;
     prevalence predicted by use the model, linear and quadratic
     in dose.
                                B-10

-------
.MM
           OBSERVED
           PREVALENCE
               H  =  HIGH  DOSE
               M  =  MEDIUM
                         AGE
   Figure  B-3.  Observed and predicted skin cancer prevalence
   for Taiwanese females at three exposure levels, by age;
   prevalence  predicted by use of the model,  linear in dose.
                           B-ll

-------
   .ISIS
U
u

U
a
a
£-
U
HI
a
u
Oi
04
.orst
                 OBSERVED

                 PREVALENCE
                       HIGH DOSE
                       MEDIUM
                                  AGE
      Figure B-4.   Observed and predicted skin  cancer prevalence for Taiwanese
      females at three  exposure levels, by age; prevalence predicted by use of
      the model, linear and quadratic in dose.
                                 B-12

-------
     The estimated induction period (w),  based on the  experience of  Taiwanese
males, is approximately 6.9 years,  and the estimated power of t is 2.9 (see
Table B-4).   Analogous estimates from Taiwanese females are 9.0 years  and 3.2.
The risk for skin cancer estimated from the quadratic  model (2 x 10-3  and 1 x
10-3 per ug/kg/day) for males and females, respectively,  is smaller  than that
estimated from the linear model  (5 x 10-3 and 3 x 10-3 per ug/kg/day).  With
each model,  the estimated risk for females is slightly less than the corresponding
risk for males.  Two reasons may explain why the risk  estimate calculated on
the basis of data for Taiwanese males is greater than  that calculated on the
basis of data for Taiwanese females: (1)  the daily water consumption by Taiwanese
males (3.5 L/day) in relation to that consumed by females  (2 L/day)  may be
underestimated; and (2)  males, in particular those who were healthy,  were more
likely than females to migrate out of town, and thus were not available at the
time of the survey.
     The current U.S. drinking water standard for arsenic  is 50 ug/L, which is
equivalent to 1.4 ug/kg/day for the reference U.S. person.  Figures B-5 and B-6
are plots of lifetime risk of skin cancer for a U.S. reference person as pre-
dicted from the model using the gender-specific Taiwan data.  At 50 ug/L, the
lifetime risk is estimated to range from  1 x 10-3 (based on data from Taiwanese
females) to 3 x 10-3  (based on data from Taiwanese males)  for a 70-kg person who
drinks 2 L/day of water contaminated with 50 ug/L of arsenic.
     Lastly, age- and gender-specific nonmelanoma skin cancer incidences among
Singapore Chinese  (IARC, 1976) were used  in the risk assessment as estimates of
background skin cancer rates  for Taiwan.  The background rates for the four age
groups, 0 to 19, 20 to 39, 40 to 59, and _> 60 are, respectively, 0, 8.0 x  10~5,
6.7 x lO'4, and 3.6 x 10"3 for males, and 0,  7.0  x 10-5, 5.5 x iQ-4,  an(j| 1.1 x 10-3
for females.  The purpose of  using Singapore  rates was to  address the comment

                                      B-13

-------
  .01
(X
u
u
z
u
u
z:
»—i
e-
u
b.
DOS
                 ENVIRONMENTAL DOSES (ug/kg/day)
   Figure B-5.  Lifetime skin cancer risk for a U.S. person,
   predicted from the Taiwanese male experience. "Linear" =
   estimated by use of the model, linear in dose;  "Quadratic"
   = estimated by use of the model, linear and quadratic in
   dose.
                            B-14

-------
   .004*
en
i—i
K

IX
U
u
z
fr-
U
Ci.
   .0023
                      ENVIRONMENTAL D0325 (ug/kg/day)
      Figure  B-6.  Lifetime skin cancer risk for a U.S. person,
      predicted  from the Taiwanese female experience.  "Linear"
      = estimated  by use of the model, linear in dose; "Quadratic"
      = estimated  by use of the model, linear and quadratic  in  dose.
                               B-15

-------
made by Margolis December 17,  1985 (Letter from Dr.  Stephen  Margolis,  Ph.D.,
Centers for Disease Control, to Mr.  Robert Dupuy,  Director,  Waste  Management
Division, U.S. EPA Region 8) that the lack of skin cancer found  in the comparison
population of 7,500 was anomalous.  All  Chinese populations  for  which  skin
cancer is reported have some incidence of skin cancer.   The  results of model
fitting to the Taiwan skin cancer data,  adjusted for this background rate,
appear in Table B-5.  Comparison of  the unit risk  estimates  in Tables  B-4 and
B-5 shows that this adjustment is inconsequential.  Therefore, the final  risk
estimate used the background rate reported by Tseng et al. (1968).

     III.  USE OF THE MEXICAN DATA TO EVALUATE TAIWAN'S DOSE-RESPONSE MODEL

     Cebrian  et al. (1983)  studied persons residing in two rural Mexican towns,
one with arsenic-contaminated  drinking water.  The prevalence of skin tumors
observed by Cebrian was compared with rates predicted by use of the parameters
estimated  from Taiwanese  data  (see Section II  of this Appendix).  These calcula-
tions  are  discussed below.
     Cebrian  et al . (1983)  published age-specific prevalence rates of ulcerative
lesions  and papular keratosis  among  the  surveyed  groups  (see Table 8-6).  These
prevalence rates,  in  10-year age  categories, were collapsed to  form the age
groups used in  the Taiwan study:  <  19,  20 to  39, 40 to  59, and _> 60 years.
However,  since  the  age  distribution  of persons  over 60 years old  differed
significantly in  the  two  towns,  information  on  the  prevalence of  skin  cancer  in
this  age  group  is not included in this analysis.
      An evaluation of how well the  model,  based on  the Taiwan experience,
 predicts the  prevalence rates  reported by Cebrian et al.  (1983) is  provided  in
Table B-6.  Since the Mexican  prevalence rates are  not  gender-specific,  the

                                       B-16

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        TABLE B-5.   RESULTS OF  MODEL  FITTING  TO  TAIWAN  SKIN  CANCER  DATA,
                        ADJUSTED FOR  BACKGROUND  RATEa»b
               Linear
          Quadratic
Males:
             Doses (d):  0, 10.818,  29.909, 50.909 ug/kg/dayC
g(d) = (0.351576 x 10-7)d


H(t) = (t - 6.934)2.885

In L = -596.744

Unit risk:  4.0 x 1Q-3 (ug/kg/day)'1
g(d) = (0.106619 x 10-7)d
       + (0.558064 x 10-9)d2

H(t) = (t - 6.867)2-903

In L = -590.501

Unit risk:   1.6 x 10-3 (ug/kg/day)-1
Females:
             Doses  (d):  0, 6.8, 18.8, 32.0 ug/kg/dayc
g(d)  =  (0.614891 x 10-8)d

H(t)  =  (t  - 9.0)3.225

In L  =  -317.188

Unit  risk:  3.0 x 10-3  (ug/kg/day)-1
g(d) = (0.238789 x 10~9)d2

H(t) = (t - 9.0)3.233

In L = -309.892

Unit risk:  Not available due to
            nonlinearity
 aBackground rate used is nonmelanoma skin cancer incidence among Singapore
 Chinese  (1968-1977)  (IARC, 1976).

 bData  from Tseng et al., 1968.

 cDose  estimate for U.S. persons  (see Table B-3).
                                      B-17

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                  TABLE B-6.   LESIONS  COUNTED  AS  SKIN  CANCERS
              (ULCERATIVE LESIONS  [UL] AND  PAPULAR  KERATOSIS [PK])
          IN MEXICO  STUDY, AND PREDICTIONS  BASED  ON TAIWAN  EXPERIENCE,
                             BOTH  GENDERS COMBINED
  Arsenic
concentration
   (ppm)
                                               Age group  (years)
     0-19
   20-39
   40-59
> 60
Control town

  UL (observed)
  PK (observed)
   0/20ia (0)b
   0/201  (0)
  0/73 (0)
  0/73 (0)
  0/29 (0)
  0/29 (0)
0/15 (0)
0/15 (0)
Exposed town

 UL (observed)
 PK (observed)
 UL (predicted)
   0/187 (0)
   0/187 (0)
0.08/187 (0.04)
  1/68 (1.5)
  8/68 (11.8)
0.7/68 (1.0)
  2/27 (7.4)
  6/27 (22.2)
1.2/27 (4.4)
1/14 (7.1)
1/14 (7.1)
aData from Cebrian et al., 1983.

^Prevalence in percentages.
                                      B-18

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Taiwan data for both genders were combined,  normalized  to  dose  equivalents

in ug/kg/day for the reference U.S.  person,  and  refitted to  the model.   For  the

same reason, it was necessary to convert the Mexican dose  estimate to that of

the reference U.S.  person.  This was done by assuming that a Mexican male

(female) weighs 60  (55) kg and drinks 3.5 (2.5)  L  of water daily  (Cebrian et

al., 1983).  If there were an equal  number of males and females,  the reference

Mexican person would weigh approximately 57  kg and drink 3 L of water daily.

The equivalent dose of arsenic, normalized to the  reference  U.S.  person, appears

in Table B-7.
              TABLE B-7.  CONVERSION OF ARSENIC DOSE FOR MEXICANS
                   TO EQUIVALENT ARSENIC DOSE FOR U.S.  PERSONS3
               Mexican person                     U.S. person
                   (ppm)                          (ug/kg/day)
                  0.005                              0.26

                  0.411                             21.63
Assumptions:  A U.S. person weighs 70 kg and drinks 2 L of water daily;
 a Mexican person weighs 57 kg and drinks 3 L of water daily.
                                      B-19

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     Cebrian, et al.  (1983)  did  not  report  gender  difference  in  susceptibility
to skin cancer from  arsenic ingestion.   There  was a  significant difference  in
the Taiwan study,  however,  where  the  crude male-to-female  ratio was  2.9:1.  For
this analysis, attempting to ascertain  how well the  model, using the Taiwan
data, might predict  the skin cancer response  in Mexico,  the  Taiwan  response
data for both genders were combined,  normalized to dose  equivalents  for the
reference U.S. person, and refitted to  the model. The model, with  linear and
quadratic terms in dose, provides a significantly better fit than that with
only a linear term (p < 0.01 by the asymptotic likelihood ratio test).   The
parameter estimates  for the combined (i.e.,  sex-blind)  data  are:

                g(d) = (0.564398 x 10~8)d +  (0.435613 x  10'9)d2

and

                             H(t) = (t - 8.0)3.028

This is virtually a three-stage model (k = 3), with induction time of 8 years
(w = 8), and  quadratic in dose.
     Cebrian  et al.  (1983) reported that the estimated total dose and over-
all  prevalence of lesions in the Mexican study were similar to those in the
Taiwan study, except  for skin cancer.  As previously stated, Cebrian et al.
(1983) separately described papular keratosis and ulcerative lesions that were
considered  compatible with a clinical diagnosis of epidermoid or basal cell
carcinomas,  but for which  no histologic examination was available.  The diagnosis
of  ulcerative lesions  in the Mexican study corresponds to the diagnosis of skin
cancer in  the Taiwan  study.
                                      B-20

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     The equation given above,  with 21.63 ug/kg/day as  the  dose  rate for the

reference U.S. person (i.e., the dose equivalent to the dose received by the

exposed Mexican population) (see Table B-7)  predicts the following prevalence

of skin cancers by ages 19, 39, and 59, respectively:   0.04%, 0.9%, 4.4% (see

Table B-6).  The responses observed in the age intervals 0-19, 20-39, and 40-59

in the Mexican study are, respectively:  0.0%, 1.5%, and 7.4%.  The differences

between the values predicted from the Taiwanese data and those observed in

Mexico are negligible in view of the small number at risk in the latter study.

Adjustment for background rate of skin cancer in the Mexican study increases

the predicted prevalence by a negligible amount.



      IV.  USE OF THE GERMAN DATA TO EVALUATE TAIWAN'S DOSE-RESPONSE MODEL



     In 1984, a follow-up study of former patients who had been treated for skin

disorders with Fowler's solution (a solution of arsenic) between 1938 and

1958 was conducted by Fierz (1965).  (See II.A.3. for a description of this

study.)

     The total doses in mL of Fowler's solution and in ug/kg of body weight

(assuming a 70-kg body weight) are shown in Table B-8.  The crude  response is

the number of patients with skin cancer (total 21) out of those examined (total

262) by total dose.

     The "adjusted" response in Table B-8 (adjusted by isotonic regression) is

based on the assumption that the true response rate is monotonically non-

decreasing over total dose of Fowler's solution:  This assumption  is probably

not strictly true, since some variables not reported in the study  (e.g.,

treatment regimen) differ among patients, and these differences are likely to

affect the response.
                                      B-21

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     TABLE  B-8.   SKIN CARCINOMAS  IN PATIENTS TREATED WITH FOWLER'S  SOLUTION
                    WHO  WERE  IN  THE FIERZ  FOLLOW-UP STUDY*
Fowler's solution
(mil li liters)
0 -
50 -
100 -
150 -
200 -
250 -
300 -
350 -
400 -
450 -
500 -
600 -
700 -
1,000 -
1,500
50
100
150
200
250
300
350
400
450
500
600
700
1,000
1,500

Crude
response
0/24 ( 0.0)
2/45 ( 4.4)
2/24 ( 8.3)
1/12 ( 8.3)
1/14 ( 7.1)
1/31 ( 3.2)
1/17 ( 5.9)
2/11 (18.2)
2/11 (18.2)
0/7 ( 0.0)
1/18 ( 5.6)
1/14 ( 7.1)
2/13 (15.4)
4/15 (26.7)
1/5 (20.0)
Adjusted
response**
0/24 ( 0.0)
2/45 ( 4.4)
6/98 (6.1)
6/98 (6.1)
6/98 (6.1)
6/98 (6.1)
6/98 (6.1)
6/61 ( 9.8)
6/61 ( 9.8)
6/61 ( 9.8)
6/61 ( 9.8)
6/61 ( 9.8)
2/13 (15.4)
5/20 (25.0)
5/20 (25.0)
aResponse is given as no. carcinomas/no.  patients at risk,  and,  in parentheses,
 as a percentage.

^Estimate obtained by isotonic regression, assuming true response rates are
 monotonically non-decreasing as total  dose increases.

SOURCE:  Fierz, 1965.
                                      B-22

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     A rough comparison  between  the  response  rates  in  the  study by Fierz  (the
"German"  study)  and the  Taiwan study can  be made  by comparing  response  rates
at equivalent total  doses.   The  total  dose  (in  ug/kg)  in the Taiwan  study  for
each dose rate and exposure combination is  found  by multiplying the  daily  dose
rate by the total  number of exposure days.  Assuming an average body weight of
70 kg and a weight of 7.6 mg arsenic per ml of  Fowler's solution, we multiply
the total dose in  ug/kg  by 9.2 x 10~3 ly to obtain  an  estimated equivalent dose
in ml of Fowler's  solution (FS).  The prevalence  rate  at the  resulting  total
dose in the German study is then read from the  adjusted response  column in
Table B-8.
     Exposures in  the Taiwan study were far greater than those in the German
study.  At 10.8 ug/kg/day for 20 years, the total Taiwan dose  corresponds to
725 ml.  At this dose, the prevalence rate for  the  Taiwan  study  is  less than
2%.  At the equivalent dose in the German study,  the prevalence  rate is estimated
to be 15.4% if 262 persons are considered at  risk (see Table  B-8) and  3.4% if
1,170 are at risk.
     Therefore, the difference in the prevalence rates at  equivalent total doses
estimated from the German study and observed in Taiwan are unknown  but  may be
due to such factors as the difference in dosing regimens  and  media,  the difference
in arsenic species in well water in Taiwan and in Fowler's solution, the mitigating
effect of other chemicals present in well water,  and genetic  cultural  or socio-
economic  differences.
    ug arsenic/kg x 10~3 mg/ug x 70 kg x l/(7.6 mg arsenic/mL FS) = 9.2 x 10~3
    ml FS.
                                      B-23

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          V.   DISCUSSION  ABOUT  THE  UNCERTAINTIES  OF  THE  RISK ESTIMATES

     There are several  factors  that could affect  the risk  estimates  presented  in
the Special  Report.   (Some of  these factors  have  already been  discussed elsewhere
in that document.)  In  this section,  two quantitative issues that  received  the
most comments from peer reviewers  are discussed and  evaluated.
     The first issue concerns  the  use of prevalence  rates  to estimate  the
cumulative incidence rate.  As  discussed previously, for the prevalence data to
be useful for the quantitative  risk assessment, three assumptions  must be made:
     (1)  the mortality rate was the same in the  diseased  (skin cancer)
individuals as in the nondiseased individuals.
     (2)  the population composition (with respect to the  risk factors of the
skin cancer) remained constant over time.
     (3)  the skin cancer was  not surgically removed.
     The appropriateness of these assumptions have been  discussed previously in
this Appendix.  The major concern was that the first assumption may  not be
appropriate and, thus it is of interest to assess the impact  of differential
mortality on the risk estimates.
     To calculate the age-specific skin cancer rate in the age-interval  (x, x+t),
the  following notations are used:
     PQ = the skin cancer prevalence at age x
     P! = the skin cancer prevalence at age x+t
     mg = the mortality rate in the nondiseased persons  in the age-interval
           (x, x+t).
     mi  = the mortality rate in the diseased persons in the age-interval  (x,  x+t),
     h   = the age-specific  skin cancer  rate  in the  age-interval (x, x+t)
     The  time to  death or skin  cancer is  assumed  to follow the independent

                                      B-24

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 exponential distribution with parameters m-j , i = 0, 1, or h.
 The  relationship between the age-specific skin cancer incidence rate, h, and
 the  cumulative incidence, F(t), by time t, is given by
           F(t) = 1 - exp  [-  j  h(x) dx]

      Thus,  it is sufficient to evaluate the effect of differential mortality on
  the  age-specific incidence.
       It  is  shown (Podgor  and Leske, 1986) that the age-specific incidence rate,
  h, satisfies the following equation.
(l-P0)P1exp(-m0-h)  =  p  ev  (.m  ) +  (l-Po)h[exp(-m1) - exp(-mp-h)]
         1-P^                               nig - mj + h
       From  this  equation,  it  is possible to investigate the effect of differential
  mortality  on  the  age-specific skin cancer incidence.
       Recall that  the  risk  estimates are calculated under the assumption that
  those persons with  and without skin cancer had the same mortality rate.  To
  assess  how an increase of  mortality rate in the skin cancer patients can affect
  the  age-specific  incidence rate, the skin cancer prevalence rates observed in
  the  Taiwanese males  (Table B-l) are taken as an example, and the age-specific
  skin cancer incidences in  various age intervals are calculated using the formula
  given above.  Table B-9  gives the estimated age-specific skin cancer incidence
  when the relative mortality  rates between those persons with and without skin
  cancer  are assumed  to be  (a) equal (m\ = mo),  (b) two  (mi = 2mo), and  (c) three
  (mi  = 3mo).
                                       B-25

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     From Table B-9,  it is seen  that  the age-specific  skin  cancer  incidence
assuming differential  mortality  exceeds those assuming equal  mortality,  the
increase ranging from about 2% to  24% when  the relative mortality  rate of  two
(mi = 2mo) is assumed; from about  2%  to 49% when  the  relative mortality  rate
of three (m^ = 3m0)  is assumed.  These observations are consistent with  Or. Lin's
comments that the difference between  the cumulative incidence and  the prevalence
incidence will be higher in the  "high" endemic area than in the "low" endemic
area (Lin, 1987).
     Since the mortality rate in the  diseased (skin cancer) persons  is not
likely to be three times greater than the nondiseased persons, the extent  of
risk underestimation does not appear  to be  of concern.
     The second issue concerns the intake of arsenic  from the sources other
than the drinking water.  Arsenic  intake from sources other than the drinking
water would over-estimate the unit arsenic  risk calcuated above from the Taiwan
study.  Heydorn  (1970) reported  that  the blood arsenic levels were higher  in
the Taiwanese than in persons in Denmark, suggesting  that both the study and
comparison populaton in the Tseng  study may have been exposed to arsenic from
sources other than drinking water.  However, these data are of limited  use
because the sample size is small  (less than 20) and  the sampling protocol  is
not specified.  Since the arsenic-contaminated water  was known to be used  for
vegetable growing and fish farming, the food consumption could have been an
important source of arsenic intake in addition to the drinking water.   There  is
very little information on the arsenic content in food, however, that  can  be
used in the risk calculation.  To provide some insight about how the arsenic
intake  from food consumption can  affect the risk estimate, the consumption of
rice and  sweet  potatoes is taken  as an example.
                                      B-26

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              TABLE  B-9.   AGE-SPECIFIC INCIDENCE RATES CALCULATED FROM
        AGE-SPECIFIC  PREVALENCE  WITH  EQUAL  AND DIFFERENTIAL MORTALITIES

                       SKIN CANCER AGE-SPECIFIC  INCIDENCE3
Exosure
group"
Low-dose
group


Mid-dose
group


Low-dose
Group


Age
20-39
40-59
60-69
20-39
40-49
60-69
20-39
40-59
60-69
Observed
skin cancer
prevalence
1.07x10-3
6.13x10-3
4.66x10-2
3.77x10-3
4.85x10-2
1.64x10-1
2.22x10-2
9.89x10-2
2.54x10-1
Equal
mortality
ml = mO
1.07x10-3
5.94x10-3
4.16x10-2
3.78x10-3
4.59x10-2
1.29x10-1
2.25x10-2
8.17x10-2
1.89x10-1
Differential
m< = 2niQ
1.09x10-3
(2)
6.04x10-3
(2)
4.84x10-2
(16)
3.85x10-3
(2)
5.30x10-2
(2)
1.57x10-1
(22)
2.29x10-2
(2)
8.39x10-2
(3)
2.34x10-1
(24)
mortality0
m^ = 3niQ
1.11x10-3
(4)
7.06x10-3
(2)
5.56x1-2
(34)
3.91x10-3
(3)
6.06x10-2
(3)
1.85x10-1
(43)
2.33x10-2
(4)
8.61x10-2
(5)
2.81x10-1
(49)
3The mortality rates for those without skin cancer are  assumed to be 0.035,
 0.26,  and 0.25 respectively for the age-intervals 20 to 39,  40 to 59,  and 60
 to 69.

bFor the low exposure group,  PQ = 0, Pi  = 1.07xlO~3 for the age-interval
 20 to 39; PQ = 1.07x10-3;  p.  = 6.13xlO-3 for the age-interval 40-59;
 PQ = 6.13xlO-3; Pi  = 4.66x10-2 for tne  age-interval  60+ (assumed to be
 60 to 69).  For other exposure groups,  PQ and PI are similarily defined.

°The parenthesized values are the ratio  (xlOO) of age-specific skin cancer
 incidence rates calculated respectively under the assumptions of the
 differential mortality and equal mortality.
                                      B-27

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     For the studied population,  rice and sweet potatoes were  the  main  staple
and might account for as much as  80% of food intake per meal.   For the  purpose
of discussion we will assume that a  man in the study population ate one cup  of
dry rice and two pounds of potatoes  per day and that the amount of water required
to cook the rice and potatoes was about 1 L.  Under this assumption, the risk
calculated before is overestimated by about 30% (1  L/3.5 L).   This calculation
considers only the water used for cooking; the arsenic content in  the rice and
potatoes that might have been absorbed from soil  arsenic is  not considered
because of the lack of information.   For a realistic adjustment of the  risk
estimates, one would need the information on the arsenic content and the
composition of the diet taken by  the studied population whose  diet content was
certainly different from the population currently living in  the same area.

                                  VI.  SUMMARY

     This section presents a dose-response analysis for skin cancer from expo-
sure to inorganic arsenic in drinking water.  Results based  on the multistage
theory of carcinogenesis have been obtained from the Taiwan  epidemiologic study
and are compared to two studies in other environments (Mexico:  Cebrian et al.,
1983; and Germany:  Fierz, 1965).  Compatibility of results  across studies  (1)
suggests the conclusion that arsenic exposure is the likely  causal factor in
the increased prevalence of skin  cancers in these studies; (2) provides additional
statistical evidence for refinement of statistical  estimates;  and  (3) helps  to
identify potential sources of variability and environmental  factors, or patterns
of exposure, that may be influential.
     None of these studies contains all of the details needed for  an ideal
statistical analysis, such as: ages at times of initial exposure,  termination of
                                       B-28

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exposure,  and first appearance of skin  cancer;  similar  information  on  lesions
that may frequently precede appearance  of skin  cancer;  number of subjects  with
cancer at multiple sites;  locations  of  cancers;  and  prior  disease including
those that lead to the use of Fowler's  solution.   Consequently,  it  is  important
to glean what information is available  from each  study  for purposes of complemen-
tarity as well as comparison.
     Analysis of the Taiwan data required estimation of the number at  risk in
each dose/age category because only  response rates and  marginal  totals by  age
groups are provided.  The estimated  values, which fit the  marginal  data closely,
make possible the estimation of dose-response for the generalized multistage
model by means of maximum likelihood.   The cancer response is well  described by
a quadratic polynomial in dose (with positive linear coefficient) for  both male
and female data.  The minimum tumor  induction time is estimated at 7 and 9
years for males and females, respectively; in both cases,  the cancer response
for time-to-tumor is best described  by time of observation (minus induction
time) to the third power.  The observed data in the Mexican study,  taken at
only one concentration of arsenic in well water,  but collected for different
exposure intervals, are consistent with predictions from the model  using the
Taiwan data.
     The data from the study in Germany consist of the response of former der-
matology patients who had been treated with Fowler's solution (a 0.5% solution
of arsenic trioxide, which is a relatively toxic form).  Patients were treated
for up to 26 years  (many for apparently a much shorter period) in intermittent
dosing patterns specific to the prescribed treatment.  This is in contrast to
exposure to arsenic-contaminated well  water which is likely to be consumed at a
reasonably uniform rate over time.
     The published data do not include much information that could be useful

                                      B-29

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for risk assessment.   Except for a  few specific  cases  cited  here,  the  data were
summarized by response for total dose.   When compared  to predictions  from the
model  for Taiwan with total  dose held fixed at values  equivalent to  total doses
in the German study,  and then varied over a wide range of possible exposure
durations in the Taiwan data, the skin cancer prevalence values in the German
study exceeded the values predicted.
     In conclusion, the lifetime risk of skin cancer for a 70-kg person who
consumes 2 liters per day of water contaminated with 1 ug/L  of arsenic is cal-
culated to range from 3 x 10~5  (on the basis of Taiwanese females) to 7 x 10~5
(on the basis of Taiwanese males);  equivalently, the lifetime risk due to
1  ug/kg/day of arsenic intake from water ranges from 1 x 10-3 to 2 x 10~3.
                                       B-30

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                         APPENDIX  C
Internal  Cancers Induced by  Ingestion  Exposure  to  Arsenic

-------
           INTERNAL CANCERS INDUCED BY INGESTION  EXPOSURE  TO  ARSENIC

     As noted in the Technical  Panel's Special  Report on Ingested Inorganic
Arsenic, arsenic ingestion has  been associated  with  cancer of internal  organs.
Chronic arsenic ingestion has
been reported to be associated  with cancer of the lung (Calnan,  1954;  Robson
and Jellife, 1963;  Fierz, 1965; Chen et al.,  1985,  1986),  bladder (Sommers and
McManus, 1953; Nagy et al., 1980;  Chen et al.,  1985, 1986),  liver (Fierz,  1965;
Regelson et al., 1968; Lander et al.,  1975;  Popper et al., 1978;  Roat  et al.,
1982; Falk et al.,  1981; Chen et al.,  1985,  1986),  nasopharynx (Prystowsky et
al., 1978), kidney  (Chen et al., 1985; Nurse, 1978), and other internal organs
(Rosset, 1958; Reymann et al.,  1978;  Chen et al., 1985).  Many of these references
are case reports,  however, and do not deserve the attention given a well-designed
epidemiologic study.
     The Technical  Panel felt it important to summarize the studies of Chen  et
al. (1985, 1986) since these studies have been  referred to in the text of the
Technical Panel's report, and they are of a design which allows one to give
greater weight to observed associations.  Chen  et al. (1985)  calculated cancer
standardized mortality ratios  (SMRs) for the population of the arsenic endemic
area studied by Tseng et al. (1968).   The authors found the SMRs for cancer  of
the kidney, bladder, skin, lung, liver, and colon to be significantly  elevated
in both males and females.  Chen et al. (1986)  conducted a case-control study
of lung, bladder, and liver cancer mortality cases and randomly sampled controls
from the endemic area.  They found odd ratios that were significantly   (p < 0.05)
elevated, and remained much the same when adjusting for other risk factors
including cigarette smoking.  Chen et al. (1985) indicated a positive  correlation
between the SMRs of those  cancers which were significantly elevated and Blackfoot

                                      C-l

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disease prevalence rates.   Also,  SMRs were  greater  in villages where only
artesian wells were used as the drinking  water  source than  in villages using
shallow wells only.  Chen et al.  (1985) stated  that water from the artesian
wells in the Blackfoot disease endemic  areas  had  been reported to have from
0.35 to 1.14 ppm arsenic with a median  of 0.78  ppm  while the shallow well water
had arsenic content between 0.00 and 0.30 ppm with  a median of 0.04 ppm.  Chen
et al. (1986) found an increased risk  of  lung,  bladder, and liver cancer with
increasing duration of artesian well use.  Thus,  in both studies  (Chen et al.,
1985, 1986), the authors demonstrated a qualitative relationship between arsenic
exposure and internal cancer risk;  however, the data is not sufficient to assess
the dose-response.  For this purpose, it  is necessary to have the  individuals
studied by Chen grouped by well-water arsenic concentration and  age.  These
data quite likely  do  (or did) exist, because they were  available  to Tseng et
al.  (1968) for the skin cancer study.  EPA  is currently trying  to  obtain these
data.
                                       C-2

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                APPENDIX  D
Individual  Peer Review Comments  on  Essentiality

-------
                INDIVIDUAL PEER REVIEW  COMMENTS ON  ESSENTIALITY



     This appendix seeks to clarify some uncertainty in the workshop report of

the Subcommittee on Essentiality.

     The Subcommittee on Essentiality of the December 2-3,  1986  peer review

workshop reported that "information from experimental studies with rats,  chicks,

minipigs, and goats demonstrates the plausibility that arsenic,  at least in

inorganic form, is an essential nutrient.  A mechanism of action has not been

identified and, as with other elements, is required to establish fully arsenic

essentiality." V

     The Subcommittee also described a framework for determination of nutritional

essentiality.  The framework describes the usual approach to establishing

essentiality as including:

     1)  performance of empirical observations  in animal models to establish the
         plausibility of nutritional essentiality;

     2)  establishment of  a reproducible  syndrome through the use of chemically
         defined diets in  animal models;

     3)  definition of biochemical  lesions to characterize the specificity of
         the  lesions;

     4)  establishment of  specific  biochemical  functions absolutely  dependent on
         the  factor being  investigated.

     The Subcommittee's statement  on the  animal studies clearly addresses

 points  1 and 4  in  the framework, but the written report does not explicitly

 address points  2 and 3 for the  animal  studies.  Furthermore, Agency

 participants and some Subcommittee members contacted by telephone differed

 somewhat in  their  recollection  of  the  Subcommittee's opinion on the extent to

 which  points 2  and 3 in the  above  hierarchy had been experimentally achieved.
]_/   Report  of  the  EPA Risk Assessment Forum Peer Review Workshop on  Arsenic,
     December 2-3,  1986.

                                    D-l

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Some selected peer reviewers'  comments  and  observers'  notes  are  summarized

below to explain the Technical  Panel's  position  on  this  issue.   The  summary

report of the Risk Assessment Forum Peer Review  Workshop on  Arsenic  (U.S. EPA,

1987) presents all of the post-workshop comments in full.



        I.  COMMENTS ON PLAUSIBILITY OF ARSENIC  ESSENTIALITY IN  ANIMALS
A.  POST-WORKSHOP COMMENTS ON ESSENTIALITY  (page numbers refer to the Risk

    Assessment report on the Forum Peer Review Workshop on Arsenic.)

    Menzel :   The section [in the peer review draft] on [essentiality] of
             arsenic should be rewritten with a more positive emphasis on the
             probable [essentiality] of arsenic. .  . (p. E-17).

    Mushak:   . . .the overall conclusion would seem to be that it is premature
             to conclude that essentiality is established (p. E-21).

    Weiler:   It appears that there may be enough experimental evidence to
             suggest that in some animals, diets low in arsenic affect growth
             and fertility.  However, the levels in the arsenic depleted diet
             are about the same as those found in the normal human diet (<_ 50
             ng/g).  Further, the amount of arsenic added as a supplement
             (2 ug/g) are far in excess of what would be found in the normal
             human diet.

             Further, the supplementary arsenic is all inorganic, whereas
             the arsenic in  the human diet is, in all likelihood, almost all
             organic.  Thus, the amount of inorganic arsenic in the human diet
              (excluding drinking water) is really quite small  (perhaps a few
             ug/day), but there are no apparent health effects that have been
             observed in humans.  The relevance of the animal  experiments to
             humans  is therefore not at all clear and it seems unrealistic to
             believe that arsenic is needed in quantities greater than what is
             present in the  normal western diet  (pp. E-43 through E-44).
 B.   ORAL  COMMENTS  DRAWN  FROM  EPA NOTES OF MEETING:

   -  The  absence of  knowledge  of biochemical action for arsenic  and of cof actor
      requirements  renders  a  determination of essentiality  uncertain (methyl
      donors,  vitamin C,  choline, molybdenum, arginine, and histidine were cited
      as possible cofactors.).   [Fox;  Combs; general
 2/  General  discussion.   Individual  attribution  uncertain.

                                       D-2

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    Reproductive experiments are difficult to perform and not always reproduc-
    ible.  Discussants referred again to lack of knowledge of possible co-
    factors.   [Nielsen; Menzel; general]

    Progression of  steps  leading to the establishment of essentiality is
    necessary.  Several participants felt that research is now in an early
    stage  (i.e., step 2,  establishment of a reproducible syndrome).  [Combs;
    general ]

    Some reviewers  emphasized that the steps  in the framework need not all be
    unambiguously established, e.g., identification of a specific biochemical
    lesion and mechanism  would suffice even in the absence of a clear definition
    of a reproducible syndrome,  [general]
         II.   ESTIMATION  OF  A HUMAN  NUTRITIONAL REQUIREMENT FOR ARSENIC
     The Subcommittee's report states
.at this time it is  only possible  to
make a general  approximation of amounts  of arsenic  that  may  have  nutritional

significance for humans." ]_/

A.  POST-WORKSHOP COMMENTS (page numbers refer to the  summary  report for  the

    peer review workshop)

    Menzel:  . . .the development of the estimate for  the human daily
             requirement is quite limited and careful  delineation of the
             limits should be included.  .  .  .uncomfortable about providing a
             single estimate and would encourage the provision of a range of
             values citing the uncertainties in the methods  of estimation and
             the interactions betwen arsenic and methyl  donor. .  .availability
             in the diet  (p. E-17).

    Strayer: I feel that a certain tone could be struck  by the report to  indicate
             that evaluating the question of lower limits for arsenic in  drinking
              water is not so much a matter of direct  proof of essentiality in

              any species.  Rather,  the fact that the  possibility of essentiality
              has been raised by workers in widely disparate species and  settings
              should deter us from setting very low limits even if proof of its
              essentiality in man is not forthcoming (p. E-30).
    Report of the EPA Risk Assessment Forum Peer Review Workshop on Arsenic,
    December 2-3, 1986.

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B.  ORAL COMMENTS DRAWN FROM OBSERVERS  NOTES  OF  MEETING:

  -  Discussants outlined reasons for not providing an  estimate  of  nutritional
     requirements for arsenic at this time:   the fact that  there is no  information
     on speciation of arsenic in the diet;  analytical difficulties;  species-
     comparative problems (e.g., uncertainty  on  whether to  make  direct  weight
     comparisons or to use surface area conversions); lack  of  a  biochemical
     mechanism;  and lack of knowledge of arsenic requirements  as a  function of
     age.  [general]

  -  Discussants reached a consensus that development of an order-of-magnitude
     estimate of intake requirements is possible.   However, they felt that the
     factors influencing the uncertainty of such an assessment (as  listed
     above) should be spelled out.  [general; subcommittee  report I/]
                         III.   USE IN RISK  ASSESSMENTS
    Andelman:   At the workshop it was the consensus  that  the  essentiality  of
               arsenic has not been proven for humans.  .  .  .Nevertheless,  there
               does seem to be some confusion in that  the question  of  essentiality
               has become somewhat intertwined with  that  of the  risk  for skin
               cancer, and this is inappropriate.  The  risk of  skin cancer is
               unlikely to be influenced by the possible  essentiality  of arsenic.
               The use of the risk model  to regulate arsenic  should take into
               account such a possibility, but there does not appear  to  be a
               basis for doing so at this time (p. E-6).

     Menzel:    As a consequence of the agreement of  the workshop participants  on
               the probable essentiality of arsenic, a  new  section  will  have to be
               added to deal  with [the] problem [of  essentiality versus  toxicityl.
               .  . .EPA should face . . .the problem of the no-threshold treatment
               of oncogenesis and the threshold phenomenon  of essentiality.  .  .  .

               I  see no need to abandon the no-threshold  treatment  for oncogenesis
               even though arsenic or other minerals might  be essential.  To not
               face this issue directly will only encourage misunderstanding and
               disagreement with the risk estimate (pp. E-18  through  E-19).

     Mushak:    It is premature to factor essentiality  into  risk  assessment models
               for arsenic exposure in human populations. . . .There  is  no inherent
               limitation on the use of linear extrapolation  models for, e.g.,
               skin cancer, because of any threshold implicit in a  daily required
               intake  (p. E-21).
]j  Report of the EPA Risk Assessment Forum Peer Review Workshop on Arsenic,
    December 2-3, 1986.

                                      D-4

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          I see no need to abandon the no-threshold  treatment  for  oncogenesis
          even though arsenic or other minerals  might be  essential.  To  not
          face this issue directly will  only encourage misunderstanding  and
          disagreement with the risk estimate (pp. E-18 through  E-19).


Mushak:   It is premature to factor essentiality into risk  assessment models
          for arsenic exposure in human populations. . .  .There  is no inherent
          limitation on the use of linear extrapolation models for,  e.g.,
          skin cancer, because of any threshold  implicit  in a  daily  required
          intake (p. E-21).
                                  D-5

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      APPENDIX E
Metabolic Considerations
                         Prepared by:

                            Dr. William Marcus
                            Dr. Amy Rispin

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                               TABLE OF CONTENTS



List of Tables	E-iii

List of Figures	E-iii

  I.  INTRODUCTION	E-l

 II.  EXPOSURE LEVELS OF ARSENIC; CHEMICAL FORMS
      AND AVAILABILITY	E-2

      A.  Drinking Water	E-2

      B.  Ambient Air	E-3

      C.  Food	E-4

      D.  Occupational Exposed Groups  	  E-6

      E.  Total Daily Body Burden	E-7

III.  METABOLISM, BIOAVAILABILITY, AND TOXICITY 	  .  	  E-7

      A.  Toxicity of Arsenic Chemical Species	E-7

      B.  Absorption, Distribution, and Elimination  ....  	  E-9

      C.  Detoxification via Methylation	E-12

      D.  Human Metabolism and Enzyme  Kinetics	E-18

  IV.  PHARMACOKINETICS OF ARSENIC METABOLISM
      AND ITS  IMPLICATIONS FOR ONCOGENICITY	E-25
                                        E-ii

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                                  LIST OF TABLES
E-l       Percentage of inorganic arsenic in food
          a preliminary analysis	E-6

E-2       Daily arsenic body burden (ug/day) in the United States . . .  E-8
                                 LIST OF FIGURES
E-l       Reproduction of arsenic III forms by membrane-bound
          lypoic acid	E-14

E-2       Role of s-adenosylmethionine in methylation of arsenic III.  .  E-15

E-3       Urinary concentrations of arsenic and its metabolites ....  E-20

E-4       Excretion of arsenic metabolites following a single oral
          dose of inorganic arsenic; ?4^s radioactivity in urine
          of male volunteer No.5; ingested dose 6.45uCi 	  E-22

E-5       Urinary excretion of arsenic (As) and its metabolites in
          glass workers with prolonged exposure to Arsenic trioxide
          (AS203) after suspension and resumptions	E-24
                                      E-iii

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                                  INTRODUCTION

     The Technical  Panel  has concluded that ingestion  of  inorganic  arsenic  can
produce a dose-related carcinogenic  response in humans.   There  are  many  uncer-
tainties including the mechanism of  action of arsenic  as  a  human  carcinogen.
The Technical  Panel  has explored the bioavailability,  toxicity, and carcinogenic!ty
of the different chemical forms of arsenic which comprise the U.S.  body  burden
and outlined this information in broad overview in this  Appendix.  However, the
Panel expects that EPA program offices will use their  own information developed
for particular conditions of human exposure, along with  the information  presented
in this Appendix, to develop a complete risk assessment  for this  compound.
     This Appendix also delineates the metabolic pathways of absorption  and the
daily ingested amount of arsenic at which excretion and  elimination of arsenic
occur.  The many new studies available on arsenic metabolism may  offer explan-
ations for some of the observations reported in the epidemiologic studies,
provide a basis for speculation about the role of some of these metabolic
factors in the carcinogenesis of arsenic, and suggest avenues for future research.
Although much of the data on pharmacokinetics is derived from acute or short-term
exposures, a number of observations are cited of populations chronically exposed
occupational ly or through drinking water and food.  However, the Panel remains
uncertain about the applicability of this information in toto to carcinogenesis
developing under conditions of chronic exposure.  The Panel believes, however,
that information and analyses of this type will be useful in future assessments
of the  risks associated with human exposure to arsenic.
     Part III of this part  reviews information on sources of arsenic to provide
data on the body burden of  arsenic in the U.S. population.  In Part III  data
relating to the metabolism  and toxicity of arsenic are reviewed as background

                                      E-l

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for the discussion in Part IV  of  metabolic  considerations  that may help elucidate
the mechanism by which arsenic effects carcinogenic  changes  in humans.

        II.  EXPOSURE LEVELS OF ARSENIC;  CHEMICAL  FORMS  AND  AVAILABILITY

     Arsenic is a natural  constituent of certain  rock and  mineral  formations  in
the earth's crust.  Weathering of rocks and minerals appears to  be a  major
source of arsenic found in soils and drinking water  sources. Other causes  of
arsenic in soil are deposition and precipitation  of  airborne particles  from
industrial operations, application of arsenic-containing pesticides,  and  decay
of contaminated plant material.  As a result of its  ubiquitous  nature,  humans
are exposed to arsenic primarily in foodstuffs and drinking water,  and for
certain target groups, from industrial and agricultural  uses (U.S.  EPA, 1985).
Among individuals of  the  general population, the main routes of exposure  to
arsenic are via ingestion of  food and water; lesser exposures occur via inhala-
tion.  Among smokers,  intake  by  inhalation is augmented in  proportion to the
level  of  smoking  because  of background levels of arsenic in tobacco  (Weiler,
1987;  IARC,  1986)

A.   DRINKING WATER
      Drinking  water  contains  arsenic  predominantly  as inorganic salts  in the tri-
valent and pentavalent states.   These inorganic salts are fully available  biolog-
ically and quite  toxic in very high  concentrations.   In chlorinated  drinking water
 supplies, all  arsenic salts have been found to be pentavalent as a result  of oxida-
 tion by free chlorine.
      The results  of  federal surveys  of public water supplies and compliance
 monitoring data developed by the states  are summarized  below  (U.S. EPA,  1984b;
 U.S. EPA, 1985).   Most of the approximately 214  million people  in  the  United
                                       E-2

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States using public  water supplies  are  exposed  to  levels  of  arsenic  below 2.5
ug/L.  Assuming an average daily consumption  of 2  liters  of  water, most of the
U.S. population would thus be exposed to less that 5  ug  of arsenic per day
from drinking water.  However, some U.S.  drinking  water  supplies contain higher
concentrations of arsenic.  Based on the compliance monitoring data  available
through the Federal  Reporting Data  Systems,  one can estimate that approximately
112,000 people are receiving drinking water from public  water supplies with
arsenic levels at or above 50 ug/L, the current Maximum  Contaminant  Level.
These people would be exposed to more than 100  ug  of  arsenic per  day.  These
surveys do not include many wells currently in  use in the United  States.  On
the average, ground water supplies  show higher  levels of arsenic  in  some  of the
western United States.

B.  AMBIENT AIR
     Assuming a daily inhalation rate of 20 m3, and an average national exposure
of 0.006 ug arsenic/m3, the inhalation exposure of the general public  to water-
soluble forms of arsenic  in ambient air can be  estimated as  almost  0.12 ug/day.
Assuming 30% to 85% absorption of inhaled arsenic, depending on the  relative
proportions of vapor and particulate matter  (U.S.  EPA, 1984a; Vahter,  1983),
the  general public would be exposed to a range  of approximately 0.04 to 0.09
ug/day of arsenic by inhalation.
     Persons living near  industrial areas such  as smelters,  glass factories,
chemical plants, or cotton gins may be exposed to ambient air levels between
0.1 and 3.0 ug arsenic/m3  (U.S. EPA, 1984b).  This would result in  as  much  as
45 ug arsenic absorbed per day.
     In the general  environment, airborne arsenic is  available from a  variety
of sources as inorganic salts.  In the vicinity of smelters, these  salts  contain
trivalent arsenic.  The chemical form and the uptake  rate of arsenic in  the
                                      E-3

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vicinity of cotton gins from its use  as  a desiccant  on  cotton  is  not  known.

C.  FOOD
     In the United States,  arsenic  is used as a pesticide  on grapefruit,  grapes,
and cotton.  In addition,  the animal  feed use of cotton,  grapes,  and  grapefruit
byproducts can lead to arsenic residues  in meat and  milk.   Various  organic  forms
of arsenic (arsanilic acid, roxarsone, and carbarsone)  are added  to feed  as
growth enhancers for chickens and swine  (Anderson,  1983).   Finally, many  food-
stuffs contain arsenic from background environmental  contamination.
     Food arsenic values taken from FDA  surveys indicate  an average daily dietary
intake of approximately 50 ug arsenic (Johnson et al.,  1984; Gartrell et  al.,
1985; U.S. EPA, 1984 a,b).   Generally, the meat, fish,  and poultry  composite
group is the predominant source of arsenic intake for adults and  has  been
estimated to account for about 80% of arsenic intake (Gartrell et al.,  1985;
Hummel, 1986; 1987; U.S. EPA, 1984b).  Of this composite  group, fish  and  seafood
consistently contain the highest concentrations of arsenic. The  concentration
of arsenic in fish and seafood (particularly shell  fish and marine  foods) is
generally one to two orders of magnitude higher than that in other foods  (FDA,
1985; Jelinek and Corneliussen, 1977).  The second most concentrated source of
arsenic in these FDA surveys is the grain and cereal  group which  may account
for  about  17% of arsenic.   Following these groups are vegetables, sugars, oils,
fats, and  beverages.   In the average U.S. adult diet, dairy products account
for  26% by weight; meat, fish, and poultry 9%;  grain and cereal products  14%;
potatoes  5%; fruits 11%; and vegetables 6% (Gartrell et al., 1985).
      An  analysis of arsenic species  in  foods sampled by the Canadian government
shows  that most of the arsenic in meats, poultry, dairy products, and cereals is
inorganic  (Weiler, 1987).  Fruits, vegetables,  and fish contain arsenic predomi-
nantly  in  organic forms.   These data, though based on a limited number of
                                      E-4

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samples,  are included here (Table  E-l)  because, until  recently, this  type of
breakdown by arsenic species  has  not been  available.
     Because of the very large  quantities  of  arsenic  in  fish  and  seafood, many
investigators have studied the  chemical  forms of  arsenic in fish  and  their meta-
bolism, excretion, and toxicity in humans.   As noted  in  Table E-l,  arsenic in
seafood is predominantly organic.   A number of researchers have  shown that
these organic forms are trimethylated.   In 1977,  Edmonds et al.  showed that
rock lobster contained 26 ppm of arsenic as arsenobetaine,  (CHg)^ As+CH2  CO^.
Other researchers have shown  that trimethyl arsenic in fish  also  occurs in
other chemical structures, such as arsenocholine.  Yamauchi  and  Yamamura  (1984)
showed that although most of  the trimethyl arsenic compounds  in  prawns were
excreted unchanged, 3% to 5%  is changed to mono-  and  dimethylated forms or to
inorganic arsenic.  Thus, although most of the organic arsenic in seafood is
excreted rapidly and unchanged, some of it may be retained  in the soft tissues,
undergo biotransformation, and be available biologically.

D.  OCCUPATTONALLY EXPOSED GROUPS
     Pesticide applicators and workers in copper, lead,  and  zinc smelters,  glass
manufacturing  plants, chemical  plants, wood preserving plants, and cotton gins
are exposed to high levels of arsenic.  Smelter workers  are  exposed to trivalent
arsenic, workers  in wood  preserving plants are exposed to pentavalent arsenic,
and pesticide  applicators are exposed to various inorganic  salts as well  as
mono-methyl arsenic  (MMA) and cacodylic acid or dimethyl arsenic (DMA).
     The OSHA  standard is 10 ug arsenic/m3 (8-hour time-weighted average) for
industrial  exposure  (OSHA, 1986).  Using the previous assumption for daily ven-
tilation rate  and  lung absorption and assuming an 8-hour workday, an occupation-
ally exposed  person could receive about 80 ug corresponding to 68 ug water-
soluble arsenic absorbed  daily via  inhalation at the OSHA standard.  Because
                                      E-5

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 TABLE E-l.  PERCENTAGE OF INORGANIC ARSENIC IN FOOD:   A PRELIMINARY ANALYSIS3
                                                         Percentage of
Food                                                   Inorganic Arsenic
Milk and dairy products                                      75

Meat - beef and pork                                         75

Poultry                                                      65

Fish - saltwater                                             0
     - freshwater                                            10

Cereals                                                      65

Rice                                                         35

Vegetables                                                   5

Potatoes                                                     10

Fruits                                                       10
aspeciation of the arsenic content of basic food groups based on preliminary
 data from the Ontario Research Foundation and other sources.

SOURCE:  Weiler, 1987.
                                       E-6

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arsenic is poorly absorbed dermally  (approximately  0.1%),  dermal  exposure has
been considered to be negligible as  compared to  inhalation exposure.

E.   TOTAL  DAILY BODY BURDEN
     Table E-2 represents the range  of total  body burden  of arsenic  from all
sources:  dietary, drinking water,  smoking,  ambient air,  and occupational exposure,
in the United States, namely 55.09  to 224 ug/day.  As  noted in this  section,
water and air generally contain arsenic in inorganic and  organic forms.  Using
information about the percentages of inorganic arsenic in various food groups,
combined with FDA surveillance data on the contributions  of these foods to  the
daily arsenic intake, it appears that the diet including  drinking water and
beverages contains about 17 or 18 ug/day of inorganic  arsenic (Table E-2).

                III.  METABOLISM, BIOAVAILABILITY,  AND TOXICITY

A.  TOXICITY OF ARSENIC CHEMICAL SPECIES
     Chronic arsenic intoxication can lead to gastrointestinal disturbances,
hyperpigmentation, and peripheral neuropathy (Goyer, 1986).  Arsenic is also
carcinogenic, and Jacobson-Kram (1986) notes that arsenic is clastogenic and
causes  sister chromatic exchange.
     The toxicity of arsenic is closely related to its chemical form.  Inorganic
salts and acids of arsenic occur predominantly in the tri- and pentavalent oxi-
dation  states.  It is well known from acute exposure studies that trivalent
arsenic is more toxic than pentavalent arsenic (Goyer, 1986).  Recent studies
have shown that at environmental levels, pentavalent arsenic is rapidly converted
to trivalent arsenic in the blood (Marafante et al., 1985).  These two forms
can be  readily interconverted in mammals.  Trivalent and pentavalent arsenic
salts also have different  modes of toxic action.  Cellular mechanisms of arsenic
                                      E-7

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       TABLE  E-2.   DAILY ARSENIC  BODY  BURDEN  (ug/day)  IN THE  UNITED  STATES
     Source             Usual                              Unusual

      Water              5                                  100a
      Air                0.09                                1.5  -  45t»
                                                            68C
      Food               50d                                50
      Smoking                                               2 -  6^

      TOTAL             55.09                                up  to  224

aAt the ODW maximum containment level  (see Part II.A).
bNear industrial  use sites such as smelter or cotton gins  (see  Part II.B),
C0ccupational exposure.
dsee Part II.C.
62 ug arsenic/package  (Weiler, 1987;  IARC, 1986).
                                      E-8

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toxicity have been discussed in several  current reviews  (Goyer,  1986;  Vahter
and Marafante, 1983).   For example,  Vahter and Marafante note  that "Arsenite  is
known to react with SH-groups of proteins and enzymes  while  arsenate may  interfere
with phosphorylation reactions due to its chemical  similarity  with phosphate."
     Methylation of inorganic salts  of arsenic through the trivalent state appears
to be a detoxification pathway in mammals (Vahter,  1983).  The simple methylated
forms of arsenic, namely cacodylic acid and methanearsonate, are less  acutely
toxic than the inorganic salts.  Fairchild et al.  (1977) gives the LDso of arsenic
trioxide as 1.43 mg/kg, of MMA as 50 mg/kg, and of  DMA as 500 mg/kg.  Trimethy-
lated forms of arsenic are not acutely toxic and are rapidly excreted (Vahter,
1983).  Although tested in animals,  the oncogenic potential  of the organic
forms has not been  adequately  characterized.

B.   ABSORPTION, DISTRIBUTION, AND ELIMINATION
     Arsenic  exposure occurs  predominantly through ingestion and  inhalation.
Dermal  absorption  is negligible.  A detailed understanding of the mammalian
distribution,  elimination,  and long-term  deposition patterns following exposure
and  the relationship of these processes  to  the  internal  body burden can provide
insights  into tissue sites  for chronic  target  organ toxicity.
      In smelters,  inhaled arsenic and that  brought to the gastrointestinal tract
by mucociliary  clearance, leads  to  approximately 80%  absorption  (Pershagen and
Vahter, 1979).   Smith et  al.  (1977)  showed  that nonrespirable particulate
forms  of  arsenic  were more  closely  correlated  with excretion  of  arsenic than
respirable  forms.   These  results imply  that ingested  forms  of arsenic  are
better  absorbed and get into the bloodstream more  efficiently than  inhaled
arsenic.  Marafante and Vahter (1987)  compared absorption and tissue  retention
 of arsenic  salts administered orally  and intratracheally in the  hamster.   In
 general,  orally administered arsenic  had a  shorter biological half-life  than
                                       E-9

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that administered intratracheal ly.   Clearance  of  arsenic  compounds  from the
lungs was also closely correlated with  solubility under physiological conditions.
     Brune et al. (1980) collected  autopsy  specimens  from a  group of 21 Swedish
smelter workers employed between 10 and 30  years  in a smelter.   A control  group
consisted of eight individuals from a  region  50 km from the  smelter site.  Arsenic
levels in kidney and liver were comparable  for workers and control  subjects, but
levels of arsenic in lung tissue were  about 6  times higher for  the  smelter
workers than the control group.  Furthermore,  arsenic levels in the lungs  of
workers retired up to 19 years were comparable to those in workers  autopsied
less then 2 years after retirement. However,  if  smoking  is  a factor, the  high
lung levels in some subjects may be a  function of chronic exposure  to arsenic
in tobacco smoke.  For example,  Vahter  (1986)  reports that some smokers in the
1950s may have inhaled as much as 0.1  ug arsenic  each day.   Although the complete
smoking history of these workers is not known  and the duration  of exposure of
the two groups of retirees is not completely  defined, the Brune et  al. study may
indicate that a portion of inhaled  arsenic  binds  irreversibly to lung tissue.
     Valentine et al. (1979) measured  arsenic  levels  in human blood, urine, and
hair in five United States communities  with arsenic concentrations  in drinking
water ranging from 6 ug/L to 393 ug/L.   Their results showed that arsenic
concentrations increased in urine and  hair  samples in proportion to increases
in concentrations in drinking water.  However, this trend was not reflected in
blood until drinking water concentrations exceeded 100 ug/L.
     Various researchers have monitored arsenic  excretion in the urine and the
feces and found that the urinary tract is the major  route of elimination and
accounts  for more than 75% of absorbed arsenic over  time. Animal studies  have
also shown that little, if any, absorbed arsenic  is  exhaled  (WHO,  1981).   Thus,
since the  late 1970s, pharmacokinetic  and metabolism  studies have monitored  the

                                      E-10

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urine alone as an approximate surrogate  for excretion.   When  organic  arsenic is
administered orally,  it is eliminated more rapidly  than  inorganic  forms.   In
addition to urine and feces,  arsenic  is  also eliminated  from  the body via  sweating
and desquamation of the skin.  In humans not excessively exposed to  inorganic
arsenic, the highest tissue concentration of arsenic is  generally  found in skin,
hair, and nails (Liebscher and Smith, 1968).  Kagey et al.  (1977)  also studied
women in the United States and showed that umbilical cord levels of  arsenic
were similar to maternal levels.
     Because of the limitations of human studies of absorption, elimination,  and
tissue  distribution of arsenic, various researchers have used the  recent advances
in arsenic, speciation methods to study the way laboratory animals  handle arsenic.
Lindgren et al.  (1982) injected mice with  radiolabeled  (inorganic) arsenic and
used whole body radiography  to study its distribution and clearance.  Initial
concentrations were highest  in the bile and kidney  for  arsenate,  but clearance
from these tissues was extremely rapid.  After 72 hours, the highest concentrations
were in the epididymus, hair,  skin,  and stomach for arsenite and the skeleton,
stomach, kidneys, and  epididymus for arsenate.  Arsenate was cleared more rapidly
than arsenite  from all  soft  tissues  but the kidneys.  It seems probable that
this pattern  of  uptake  is  related to the  chemical similarities between arsenate
and  phosphate  in  the  apatite crystals in  bone.  One can ascribe the  accumulation
of arsenic  in  skin, hair,  and upper  gastrointestinal  tract to  its binding of
sulfhydryl  groups of  keratin (Goyer,  1986).
     Following intravenous injection of DMA in  rabbits  or mice, excretion was
essentially complete  within  24 hours,  indicating low  affinity  for the  tissues
 in  vivo (Vahter and  Marafante,  1983).   The same  results were obtained  following
 oral  administration  (Vahter  et al.,  1984).  In  addition, the distribution
 showed  a  different pattern from that shown after administration of  inorganic

                                       E-ll

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arsenic, as discussed above.   The  highest initial  concentration  of  arsenic  in
mice was found in the kidneys,  lungs,  gastrointestinal  tract,  and testes.
Tissues showing the longest retention  time were the  lungs,  thyroid,  intestinal
walls, and lens.
     Tissue retention of arsenic  in the marmoset monkey,  which doesn't  methylate
arsenic, was much more pronounced than in species which methylate arsenic
(Vahter and Marafante, 1985).   Seventy-two hours after  injection with inorganic
arsenic, almost 60% was still  bound to the tissues.   The major single binding  site
was liver, with 10% of the original dose.  Arsenic was  also retained in the kidney
and gastrointestinal tract.  To the extent that the  marmoset monkey may be  an
appropriate model of distribution and  tissue retention  in humans when arsenic
levels exceed the normal detoxification capacity, these studies  may enable  us
to predict accumulation of arsenic in  the liver, kidney,  and gastrointestinal
tract from chronic high exposure.
     In sunmary,  systematic animal studies and observations in humans show  that
arsenic is efficiently absorbed through the gastrointestinal tract  and  via
inhalation and eliminated predominantly in the urine.  High levels  of exposure
can lead to deposition in tissues rich in sulfhydryl (SH) groups such as the
lung tissue, gastrointestinal  tract, skin, and hair.  Arsenic also  appears  to
concentrate in the liver and to a lesser extent the  kidney, especially  in the
marmoset monkey which does not methylate arsenic.  As discussed  above,  the
chemical form of arsenic influences its retention time and target tissue sites.

C.  DETOXIFICATION VIA METHYLATION
     Methylation of  inorganic arsenic is generally accepted as a detoxification
mechanism  of mammals.  Vahter (1983) and Vahter et al.  (1984) showed that
methylated arsenic  is excreted more rapidly after ingestion than the inorganic
 forms.   In addition,  cumulative observations of humans acutely exposed to
                                      E-12

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inorganic arsenic  show that,  although  inorganic  arsenic  is  the  predominant
initial  metabolite,  after 9 days,  MMA  and DMA  account  for more  than  95%  of
total  arsenic excreted in the urine (Mahieu  et al.,  1981).   Various  researchers
have shown that methylation of inorganic arsenic occurs  enzymatically  prior  to
elimination in the urine.  The enzymatic pathways  for  arsenic methylation and
detoxification are summarized in this  section.
     Methylation appears to take place through the  trivalent As (+3) state
(Vahter and Envall,  1983).   Based on studies with  model  compounds, Cullen et al.
(1984) hypothesized that methylation of arsenic  III  requires s-adenosylmethionine
in excess, dithiolipoic acid-like structures on  the  membranes,  and/or  a  functional
enzyme system (see Figures  E-l and E-2).
     The major site of methylation appears to  be the liver  (Klaassen,  1974).
Lerman et al. (1985) followed methylation of tri-  and  pentavalent arsenic in
cultures of hepatocytes.  They found that dimethyl  arsenic  acid formed when
arsenite, but not arsenate, was added to the culture medium. No metabolism  of
arsenate was seen, nor was  the arsenate taken  up by  the  liver cells.   The
authors postulated that the differences in in  vitro  cellular uptake  of the two
forms of arsenic may be due to the fact that,  at physiologic pH, arsenite is
not ionized, whereas arsenate is charged.
     In order to understand reaction mechanisms  and  sequences of methylation,
Buchet and Lauwerys (1985)  performed in vitro incubations of inorganic arsenic
with various (rat) tissues.  The methylating capacity  of red blood cells, and
brain, lung, intestine, and kidney homogenates were  insignificant by comparison
to that of the liver.  They found that the cytosol  was the  sole fraction of  the
liver showing methylating activity; and s-adenosylethionine and reduced  glutathione
were required as methyl donors.  The effect  was  further  enhanced by  addition of
vitamin 612 to this system.  Although  MMA was  formed immediately, a  30-minute

                                      E-13

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    Me3AsO   *
M
:E
M

;A
!E
HS^.
OH
• Me As



Figure E-l.  Reproduction  of arsenic III forms by membrane-bound lypoic acid.
SOURCE:  Cullen  et al.,  1984.
                                  E-H

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    S-Adenosytmetfiionine
  S-Adenosythomocysteine
Me As
Figure E-2.  Role  of s-adenosyImethiom'ne in methylation of arsenic  III
SOURCE:  Cullen et al.,  1984.
                                 E-15

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latency period occurred before  DMA was  produced,  suggesting  that  it  is  formed
from MMA.   As cytosol  and subtrate  (As  +3)  concentrations were  varied,  MMA  and
DMA appeared to exhibit different kinetics  of  formation.  At high substrate
concentrations, DMA formation was inhibited, while  MMA  appeared to accumulate
in the system, showing that formation of DMA  is  a rate-limiting step.
     Methyl transferase activity has been shown  to  play a necessary  role  in the
methylation of arsenic in mammals (Marafante  and Vahter,  1984,  1986;  Marafante
et al., 1985).  The effect of dietary deficiencies  and  genetic  variability  on
methylating capacity (shown below)  has  important implications for tissue  distri-
bution and individual  susceptibility to arsenic  toxicity.
     Marafante and Vahter (1984) studied the  effect of  methyl transferase inhi-
bition on the metabolism and tissue retention  of arsenite in mice and rabbits.
Periodate-oxidized adenosine (PAD),  an inhibitor of methyl  transferase, was
injected into mice and rabbits  prior to administration  of the arsenite.  This
led to a marked decrease in production of cacodylic acid,  a  dimethylated  form
of arsenic.  Moreover, impairment of methylation increased the tissue retention
of arsenic.  These results imply that S-adenosyl-methionine  is a  methyl donor
in the methylation of inorganic arsenic in vivo and are consistent with the
conclusions of Buchet and Lauwerys   (1985) regarding the significance of various
cofactors  i_n_  vitro.
      In 1985, Marafante et al.  measured blood as well as urinary  concentrations
of arsenic metabolites following the administration of arsenate.   The reduction
of arsenate to arsenite occurred almost immediately, followed by  the appearance
of DMA in  the  blood plasma after about an hour.   The administration of PAD led
to a  dramatic  decrease in the  appearance of DMA  in the blood and confirmed the
earlier results  in  the laboratory showing the significance  of methyl transferase
activity in  the  methylative metabolism of arsenic.  Urinary excretion of arsenate

                                      E-16

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and its metabolites  paralleled  their  concentrations  in  the  blood.   In light of
these observations,  these authors  postulated that  reduction of  arsenate  to
arsenite is an initial  and independent reaction  in the  biotransformation of
arsenate and probably occurs in the blood.
     In a later study,  Marafante and  Vahter (1986) studied  the  effect of
choline-deficient diets on the  metabolism of arsenic in rabbits.   Shivapurkar
and Poirier (1983) had previously demonstrated that choline- or protein-deficient
diets increase relative hepatic concentrations of  s-adenosylhomocysteine,
leading to inhibition of methyl transferase activity.   In their study, Marafante
and Vahter showed that both the choline-deficient  diets and the administration
of PAD led to decreased excretion of DMA in the urine and higher retention  of
74As in the liver, lungs, and skin.   (As noted above, this pattern is  seen  in  the
marmoset monkey which lacks the genetic capacity to methyl ate arsenic.)   In
addition, choline deficiencies led to an increased concentration of 7^As in
the  liver microsomes.
     These observations demonstrate that methylation as a detoxification pathway
is enzymatic  and  occurs via the trivalent state of arsenic to MMA and subsequently
to DMA.  Furthermore,  decreased methylating capacity caused by chemical  inhibition,
dietary  deprivation, or genetic disposition appears to lead to decreased excretion
of DMA  in the urine, with  retention of arsenic in the lungs, skin, and liver.
In addition,  certain dietary deficiencies lead to concentration of arsenic in
the  liver microsomes.  These results  in animals may be considered to mimic that
segment  of  the  human population described as  poor methylators.  [See the following
section  for  a summary  of  the human studies by Foa et al. (1984) and Buchet et al.
(1982).]  They  may  also  serve  as  models for those populations  consuming protein-
deficient diets while  exposed  to  high levels  of arsenic.   In these populations,
one  can  anticipate  that  decreased methylating capacity can  lead to an increased

                                      E-17

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deposition of arsenic in liver and  lung  cells  as well  as  the  organ  sites of
normal  distribution,  namely skin, hair,  and nails.

0.  HUMAN METABOLISM  AND ENZYME KINETICS
     This section contains summaries of  human  studies  of  the  metabolism and
enzyme kinetics of arsenic.  In these studies,  dosing  or  exposure  levels ranged
from background levels to which the general population is normally exposed,
through levels representing occupational exposure,  up  to  highly toxic  levels.
The dosing patterns include acute,  short-term, and chronic exposure.   Of necess-
ity, many of these studies are limited to single  doses in small numbers of
human  volunteers.  Nonetheless, when seen in the  context  of the enzyme kinetics
of  arsenic methylation described previously, they provide valuable insights
into the way humans can handle, detoxify, and eliminate arsenic at levels  of
concern.
     Buchet  et al. (1981)  performed a series of pharmacokinetic studies of
arsenic metabolism in human volunteers  exposed to levels of arsenic roughly
comparable to  those  in  smelters.   In the first study,  groups of three, four, or
five  adult males  drank  solutions containing 500 ug equivalents of inorganic
arsenic,  MMA,  or  DMA.   After  a  single dose, urine was collected for four days
and analyzed for  inorganic arsenic, MMA, or DMA.  In  four  days, total  or cumulative
arsenic  content  as monitored  by urinary excretion, amounted to about 47% of the
 ingested dose of inorganic arsenic,  78% of ingested MMA,  and 75%  of ingested
DMA,  indicating  much more rapid excretion  of  organic  than  inorganic forms.
After ingestion  of inorganic  arsenic, the  percentage  of  inorganic  arsenic
 excreted in  the  urine fell off extremely rapidly and  was  accompanied by an
 increase of  DMA  excretion.  However,  MMA excretion  initially increased and  then
 at 12 to 24  hours began to decrease.  When MMA was  ingested, MMA  accounted  for
 87.4% and DMA accounted for 12.6% of urinary arsenic  after 4 days indicating
                                       E-18

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some bioconversion of MMA to DMA,  but  no demethylation.   When  DMA was  ingested,
all  urinary arsenic was excreted as  DMA.  These observations,  in  light of  the
relative toxicities of the metabolites,  demonstrate that methylation is an
efficient detoxification pathway for arsenic.
     In a second human study, Buchet et al .  (1982)  studied urinary  metabolites
after repeated oral dosing for 5 days with 125, 250, 500, or 1,000  ug inorganic
arsenic.  In this study, urinary monitoring was performed for 9 days following
the last dose.  Although only one volunteer was tested at each dose, they  were
chosen  in the context of previous studies in the laboratory to have normal
methylation rates.  Above 500 ug the ratio of DMA to MMA decreased  and methyla-
ting capacity appeared to fall off as shown in Figure E-3.  When the percentage
of  each metabolite was plotted against  the log of the ingested dose, the concen-
tration (percentage)  of  inorganic arsenic declined and that of DMA  increased
commensurate with  first-order kinetics.  The rate of conversion to methylated
forms diminished starting at 250 ug, but not until  the dose range exceeded 500
ug  did  the  absolute amount  of DMA decline indicating saturation of methylating
capacity.   In addition,  the  biological  half-life of total recovered arsenic
increased with  increasing dose  (39 h at 125 ug to 59 h at 1000 ug).  The  authors
indicated that  when  they  saw these results, they re-examined the history  of the
high-dose  volunteer,  but confirmed that his excretion pattern  for arsenic was
not out of  line with  the others.  These results  suggest  the hypothesis  that
saturation  of methylating capacity occurs just above 500 ug/day in  healthy
adult  males exposed to repeated  doses  of arsenic in short-term experiments.
However, confirmation of the enzyme saturation pattern would  require  that EPA
obtain the  raw  data from Buchet's experiments.
     These  short-term dose-response curves  are  typical  of enzymatic conversion
processes.  Buchet's studies include  a  dosing  range up  through enzymatic  satu-

                                       E-19

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                                                             T 1408
         a
          188    125
500
             1888
                        Micrograns  As Per Day
Figure  E-3.  Urinary concentrations of  arsenic and its  metabolites.
SOURCE:  Adapted from Buchet et al.,  1982.
                                    E-20

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ration and beyond it.   At about  600  ug/day  the  absolute amount of MMA begins to
plateau,  and the saturation of methylation  occurs  between  doses  of  500  and  1,000
ug/day in people of adequate methylating  capacity  (Figure  E-3).
     In 1985, Lovell and Farmer  monitored urine for  arsenic  metabolites following
ingestion of highly toxic doses  of inorganic  arsenic by people attempting suicide.
In the course of 5 days, a decreasing percentage of  inorganic arsenic was elimi-
nated with a corresponding increasing percentage of  DMA,  implying metabolic
conversion of one to the other.   The amount of MMA in the urine  did not show
any such clear pattern.  A similar pattern of urinary metabolites to that
observed by Lovell and Farmer (1985) as well  as Buchet et al.  (1981) was seen
by Tarn et al . (1979) (Figure E-4).
     From the dose-response experiments and the time course  of elimination, one
can postulate that after the initial rapid excretion of inorganic arsenic
arising from ingestion of  inorganic arsenic,  simple enzymatic  conversion to
DMA, first order in the inorganic arsenic substrate, occurs  in  the  liver.   The
DMA is then  excreted via the kidneys.  However, conversion of  arsenic to MMA as
observed by  urinary excretion does not indicate simple kinetics. Possibly,
this conversion occurs at  the cellular level  throughout the body, or by nonenzy-
matic mechanisms.   In  light of this elimination pattern for short-term experiments,
conversion of inorganic arsenic to DMA appears to be the rate-limiting step in
detoxification  (Buchet and Lauwerys, 1985).
     Foa et  al .  (1984) measured blood and urinary metabolites  of arsenic in 40
glass workers exposed  to high levels of arsenic and in 148 control  subjects drawn
from the general population.  These researchers found a broad range and standard
deviation  for each  metabolite in  the blood and urine.  Perhaps the most significant
finding in  this  study was  that, although many of the subjects were good methyl-
ators, each  group  contained subjects with clearly reduced methylation  capacity

                                      E-21

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                        LSr
                •  Total  arsenic

                $  inorganic  arsenic

                X  monomethylarsenic  compound

                A  dimethyl arsinic acid
Figure E-4.
Excretion of arsenic metabolites following a single oral  dose
of inorganic arsenic.  ^As radioactivitiy in urine of male
volunteer No. 5; ingested dose:   6.45 uCi.
SOURCE:  Tarn et al .,  1979.
                                      E-22

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as seen by the profile of metabolites.   For  the  glass workers,  both  blood and
urine concentrations of total  arsenic  were increased  in  proportion to  the
exposure,  although metabolite  profiles  were  comparable.
     Foa et al.  (1984) also selected a group of  five  glass  workers with  high
urinary arsenic  concentrations and suspended their exposure for one  month.
Urinary concentrations of arsenic and its methylated  metabolites decreased  with
time nearly to that of the control population.   However, when  high exposure was
resumed, only a moderate increase was seen for  inorganic arsenic and its methylated
metabolites.  Two months after exposure resumed, urinary concentrations  of  total
arsenic were still diminished  relative to daily  exposure (Figure E-5).   Further-
more, day-to-day and morning-to-evening sampling showed  only the slightest
variation in concentration of  inorganic arsenic, with no variation in  concentra-
tion of its methylated metabolites.  This appears to  indicate  that full  methyla-
tion capacity for high exposures takes several  months to build up and that  any
accommodation the body had made to very high arsenic  levels is rapidly lost.
Comparing their observations with human studies  in other laboratories,  these
researchers postulated that the time course of  excretion of metabolites  indicates
a saturable mechanism for the  methylation of arsenic.
     In a very recent study, Vahter (1986) compared urinary arsenic  metabolites
in smelter workers having high chronic exposures to those in a general  population
of non-fish eaters in Sweden.   The profile of metabolites was  strikingly similar
(inorganic arsenic:MMA:DMA was 18%:16%:65% and 19%:20%:61%, respectively)  and
implied the occurrence of long-term accommodation to  high levels of  arsenic by
the smelter workers.
     In sumnary, similar patterns of enzymatic  methylation  have been demonstrated
in both animals and humans.  Short-term studies demonstrate that these enzymatic
detoxification pathways are saturable as noted above.  However, the  human  studies

                                      E-23

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       As
        300-
        200-
        100 H
  As exposure

end     resumption

                      -1
                                2    months
Figure E-5.  Urinary excretion of arsenic (As)  and its metabolites  in glass
            workers with prolonged exposure to arsenic trioxide, after suspension
            and resumption of exposure.  Values are means +_ SD of  five subjects.
SOURCE:   Foa et al.,  1984.
                                    E-24

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demonstrate a long-term accommodation  pattern  such  that  occupationally exposed
people eliminate inorganic  arsenic,  MMA,  and DMA  in the  same  relative proportions
as the general  population or lightly exposed worker groups.   Although the
pattern of accommodation is consistent with  traditional  clinical  observations
of arsenic toxicology,  the panel  could not find any research  that would  enable
the mechanism of accommodation to be elucidated.   Finally,  a  number of  researchers
observed that methylation capacities in large  populations  can be  highly  variable.

IV.  PHARMACOKINETICS OF ARSENIC METABOLISM AND ITS IMPLICATIONS  FOR ONCOGENICITY

     Although most forms of arsenic to which people are  commonly  exposed are bio-
logically available, inorganic arsenic is the most toxic.   Inorganic arsenic is
methylated enzymatical ly in the liver prior to its elimination in the urine.
When the methylation capacity of the liver is exceeded,  exposure  to excess
levels of inorganic arsenic can lead to increased and long-term deposition in
certain target  tissues, namely the liver, lung, skin, bladder, and gastrointestinal
tract.
     One can speculate  that the methylation capacity may be exceeded at lower
levels of arsenic exposure in the segments of the human population that are poor
methylators  due to genetic disposition or in groups consuming poor or protein-
deficient  diets.  This  may explain the anomalies noted by Enter!ine in the
manifestation of carcinogenic response in epidemiological  studies of certain
highly exposed  groups  (U.S. EPA, 1987).
     Long-term  accommodation  to arsenic  (on the order of several  months or more)
appears to  take place  in occupationally exposed worker populations as demonstrated
by similar  profiles of  arsenic metabolites in  the  urine over a wide range of
exposures.   However, blood levels from high chronic  exposure to arsenic (in

                                      E-25

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excess of 200 ug/day)  indicate that the  accommodation may not  be  complete.



However,  even if the human body accommodates  to  chronically  elevated  arsenic



levels, the internal tissues are nonetheless  exposed to  much more inorganic



arsenic over long periods of time.   Furthermore, the ability of  the human



organism to handle more than 500 or 600  ug/day may  constitute  a  stress  to  the



body.  An improved understanding of these homeostatic mechanisms  is critical  to



improving the cancer dose-response  assessment.



     Appendix C summarizes data on  elevated rates of  cancer  of the liver,  lung,



and bladder in Taiwan and also notes the occurrence of  internal  tumors  in  the



Fierz  study.  Extrapolating from the studies on  protein-deficient animals, one



would  expect liver cancer to be especially prevalant  in protein-deficient  human



populations.  Future work may show whether the deposition patterns are  matched



by confirmed incidence of internal  cancer.
                                       E-26

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     469-485.

Yeh, S.; How,  S.W.;  Lin, C.S.   (1968)  Arsenical cancer  of skin-histologic
     study with special  reference  to Bowen's  disease.  Cancer 21(2):312-339.

Yue-zhen,  H.;  Xu-chun,  Q.;  Guo-quan, W.;  Bi-yu,  E.; Dun-ding, R.; Zhao-yue, F.;
     Ji-yao, W.; Rong-jiang; X.; Feng-e,  Z.   (1985)  Endemic chronic arsenicism
     in Xinjiang.  Chin. Med.  J. 98(3):219-222.

Zaldivar, R.  (1974)  Arsenic contamination of drinking  water and foodstuffs
     causing endemic chronic poisoning.   Beitr.  Pathol.  151:384-400.

Zalidvar, R.  (1977)  Ecological investigations  on arsenic dietary  intake and
     endemic chronic poisoning in  man:  dose-response curve. Zentralbl.
     Bakteriol.  Parasitenkd.  Infektionskr. Hyg. Abt. 1:  Orig. Reihe B.  164:
     481-484.

Zaldivar, R. ; Guillier,  A.   (1977)  Environmental  and clinical investigation
     on epidemic chronic arsenic poisoning in infants and children.  Zentralbl.
     Bakteriol. Parasitenkd. Infektionskr.  Hyg.  Abt.  1:  Orig. Reihe B.  165:226-
     243.
                                 R-12

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     Reproductive  experiments  are  difficult  to perform and not always reproduc-
     ible.   Discussants  referred again  to  lack of knowledge  of possible co-
     factors.   [Nielsen;  Menzel; general]

     Progression  of steps leading  to  the establishment of essentiality is
     necessary.   Several  participants felt that  research is  now  in  an early
     stage  (i.e.,  step 2, establishment of a reproducible syndrome).  [Combs;
     general ]

     Some reviewers emphasized that the steps in the  framework need not all be
     unambiguously established, e.g., identification  of  a specific  biochemical
     lesion and mechanism would suffice even in  the absence  of a clear definition
     of a reproducible syndrome,   [general]
         II.   ESTIMATION  OF  A HUMAN  NUTRITIONAL  REQUIREMENT  FOR  ARSENIC



     The Subcommittee's report states  ".  .  .at this  time  it  is only  possible  to

make a general  approximation of amounts of  arsenic that may  have nutritional

significance  for humans." ]_/

A.  POST-WORKSHOP COMMENTS (page numbers refer to the  summary report for  the

    peer review workshop)

    Menzel:  .  . .the development of the estimate for  the human  daily
             requirement is  quite limited and careful  delineation of the
             limits should be included. . .  .uncomfortable about providing  a
             single estimate and would encourage the provision  of a  range of
             values citing the uncertainties in the  methods  of  estimation and
             the interactions betwen arsenic and methyl donor.  . .availability
             in the diet (p. E-17).

    Strayer:  I  feel that a certain tone could be struck by the  report to  indicate
             that evaluating the question of lower limits for  arsenic in  drinking
              water is not so much a matter of direct  proof  of  essentiality in

              any species.  Rather,  the fact that the  possibility of essentiality
              has been raised by workers in widely disparate species and  settings
              should deter us from setting very low  limits even  if proof  of its
              essentiality in man is not forthcoming (p.  E-30).
\J  Report of the EPA Risk
    December 2-3, 1986.
Assessment Forum Peer Review Workshop on Arsenic,
                                      D-3

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B.  ORAL COMMENTS DRAWN FROM  OBSERVERS  NOTES  OF MEETING:

  -  Discussants outlined reasons  for not  providing  an  estimate  of  nutritional
     requirements for arsenic at  this time:   the  fact that  there  is no  information
     on speciation of arsenic in  the diet;  analytical difficulties;  species-
     comparative problems (e.g.,  uncertainty  on whether to  make  direct  weight
     comparisons or to use surface area conversions); lack  of  a  biochemical
     mechanism;  and lack of knowledge of arsenic  requirements  as  a  function of
     age.  [general]

  -  Discussants reached a consensus that  development of an order-of-magnitude
     estimate of intake requirements is possible.  However, they  felt  that the
     factors influencing the  uncertainty of such  an  assessment (as  listed
     above) should be spelled out.  [general; subcommittee  report
                         III.   USE IN RISK ASSESSMENTS
    Andelman:  At the workshop it was the consensus that the essentiality  of
               arsenic has not been proven for humans.  . .  .Nevertheless,  there
               does seem to be some confusion in that the question of essentiality
               has become somewhat intertwined with that of the risk  for skin
               cancer, and this is inappropriate.  The  risk of skin cancer is
               unlikely to be influenced by the possible essentiality of arsenic.
               The use of the risk model  to regulate arsenic should take into
               account such a possibility, but there does not appear  to be a
               basis for doing so at this time (p.  E-6).

     Menzel:    As a consequence of the agreement of the workshop participants on
               the probable essentiality of arsenic, a  new section will have to be
               added to deal with [the] problem [of essentiality versus toxicityl.
               .  . .EPA should face  . . .the problem of the no-threshold treatment
               of oncogenesis and the threshold phenomenon of essentiality. . . .

               I  see no need to abandon the no-threshold treatment for oncogenesis
               even though arsenic or other minerals might be essential.  To not
               face this  issue directly will only encourage misunderstanding and
               disagreement with the risk estimate  (pp. E-18 through E-19).

     Mushak:   It is premature to factor essentiality into risk assessment models
               for arsenic exposure  in human populations.  .  .  .There is no inherent
               limitation  on the use of linear extrapolation models for, e.g.,
               skin cancer, because  of any threshold implicit  in a daily required
               intake  (p. E-21).
 V  Report of  the  EPA  Risk Assessment  Forum  Peer Review Workshop on Arsenic,
     December 2-3,  1986.

                                       D-4

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          I  see no need to abandon  the  no-threshold  treatment  for oncogenesis
          even though arsenic or other  minerals  might be  essential.  To  not
          face this issue directly  will  only encourage misunderstanding  and
          disagreement with the risk estimate (pp. E-18 through  E-19).


Mushak:   It is premature to factor essentiality into risk  assessment models
          for arsenic exposure in human populations.  . .  .There  is  no inherent
          limitation on the use of  linear extrapolation models for,  e.g.,
          skin cancer, because of any threshold  implicit  in a  daily  required
          intake  (p. E-21).
                                  D-5

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      APPENDIX E
Metabolic Considerations
                         Prepared by:

                            Dr. William Marcus
                            Dr. Amy Rispin

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                               TABLE OF CONTENTS



List of Tables	E-iii

List of Figures	E-iii

  I.  INTRODUCTION	E-l

 II.  EXPOSURE LEVELS OF ARSENIC; CHEMICAL FORMS
      AND AVAILABILITY	E-2

      A.  Drinking Water	E-2

      B.  Ambient Air	E-3

      C.  Food	E-4

      D.  Occupational Exposed Groups 	  E-6

      E.  Total Daily Body Burden	E-7

III.  METABOLISM, BIOAVAILABILITY, AND TOXICITY 	  E-7

      A.  Toxicity of Arsenic Chemical Species	E-7

      B.  Absorption, Distribution, and Elimination 	  E-9

      C.  Detoxification via Methylation	E-12

      D.  Human Metabolism and Enzyme Kinetics	E-18

 IV.  PHARMACOKINETICS OF ARSENIC METABOLISM
      AND ITS  IMPLICATIONS FOR ONCOGENICITY	E-25
                                        E-ii

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                                  LIST OF TABLES
E-l       Percentage of inorganic arsenic in food
          a preliminary analysis	E-6

E-2       Daily arsenic body burden (ug/day) in the United States .  .  .  E-8
                                 LIST OF FIGURES
E-l       Reproduction of arsenic III forms by membrane-bound
          lypoic acid	E-14

E-2       Role of s-adenosylmethionine in methylation of arsenic III. .  E-15

E-3       Urinary concentrations of arsenic and its metabolites ....  E-20

E-4       Excretion of arsenic metabolites following a single oral
          dose of inorganic arsenic; 74/\s radioactivity in urine
          of male volunteer No.5; ingested dose 6.45uCi	E-22

E-5       Urinary excretion of arsenic (As) and its metabolites in
          glass workers with prolonged exposure to Arsenic trioxide
          (AS203) after suspension and resumptions	E-24
                                      E-iii

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                                  INTRODUCTION







     The Technical  Panel  has concluded that  ingestion  of  inorganic  arsenic  can



produce a dose-related carcinogenic  response in humans.   There  are  many  uncer-



tainties including the mechanism of  action of arsenic  as  a  human  carcinogen.



The Technical  Panel  has explored the bioavailability,  toxicity, and carcinogenicity



of the different chemical forms of arsenic which comprise the U.S.  body  burden



and outlined this information in broad overview in this  Appendix.   However, the



Panel expects that EPA program offices will  use their  own information developed



for particular conditions of human exposure, along with  the information  presented



in this Appendix, to develop a complete risk assessment  for this  compound.



     This Appendix also delineates the metabolic pathways of absorption  and the



daily ingested amount of arsenic at which excretion and  elimination of arsenic



occur.  The many new studies available on arsenic metabolism may  offer explan-



ations for some of the observations reported in the epidemiologic studies,



provide a basis for speculation about the role of some of these metabolic



factors in the carcinogenesis of arsenic, and suggest  avenues for future research.



Although much of the data on pharmacokinetics is derived from acute or short-term



exposures, a number of observations are cited of populations chronically exposed



occupational ly or through drinking water and food.  However, the Panel remains



uncertain about the applicability of this information  in toto to carcinogenesis



developing under conditions of chronic exposure.  The  Panel believes, however,



that information and analyses of this type will be useful in future assessments



of the risks associated with human exposure to arsenic.



     Part III of this part  reviews information on sources of arsenic to provide



data on the body burden of  arsenic in the U.S. population.  In Part III  data



relating to the metabolism  and toxicity of arsenic are reviewed as background





                                      E-l

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for the discussion  in Part IV  of  metabolic  considerations  that may help elucidate



the mechanism by which arsenic effects  carcinogenic  changes  in humans.








        II.   EXPOSURE LEVELS  OF ARSENIC;  CHEMICAL  FORMS  AND  AVAILABILITY








     Arsenic is a natural  constituent of certain  rock  and  mineral  formations  in



the earth's  crust.   Weathering of rocks and minerals appears to  be a  major



source of arsenic found in soils  and drinking water  sources. Other  causes  of



arsenic in soil are deposition and precipitation  of  airborne particles  from



industrial operations, application of arsenic-containing pesticides,  and  decay



of contaminated plant material.  As a result of its  ubiquitous  nature,  humans



are exposed to arsenic primarily  in foodstuffs and drinking water,  and  for



certain target groups, from industrial  and agricultural  uses (U.S.  EPA,  1985).



Among  individuals of  the  general  population, the main  routes of  exposure  to



arsenic are via ingestion of food and water; lesser exposures occur  via inhala-



tion.  Among smokers, intake by  inhalation is augmented in  proportion tn  the



level  of  smoking because  of background levels of arsenic in tobacco  (Weiler,



1987;  I ARC,  1986)





A.   DRINKING WATER



      Drinking  water  contains  arsenic predominantly  as inorganic salts in the  tri-



valent and  pentavalent  states.   These  inorganic salts are fully available  biolog-



ically and  quite toxic  in very high concentrations.   In chlorinated  drinking  water



supplies, all  arsenic salts have been  found  to be pentavalent as a result  of  oxida-



tion by  free chlorine.



      The results of  federal  surveys  of public water supplies and compliance



monitoring  data developed by  the states  are  summarized  below (U.S. EPA,  1984b;




U.S.  EPA, 1985).   Most of the approximately  214 million people  in the  United



                                       E-2

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States using public  water supplies  are  exposed to  levels of arsenic below 2.5
ug/L.  Assuming an average daily consumption  of  2  liters of water, most of the
U.S. population would thus be exposed to less that 5  ug  of arsenic per day
from drinking water.  However, some U.S.  drinking  water  supplies  contain higher
concentrations of arsenic.  Based on the compliance monitoring data available
through the Federal  Reporting Data  Systems,  one  can estimate  that approximately
112,000 people are receiving drinking water from public  water supplies with
arsenic levels at or above 50 ug/L, the current  Maximum  Contaminant Level.
These people would be exposed to more than 100 ug of  arsenic  per  day.  These
surveys do not include many wells currently in use in the  United  States.   On
the  average, ground water supplies show higher levels of arsenic  in  some  of  the
western United States.

B.   AMBIENT AIR
      Assuming  a daily inhalation rate of 20 m3,  and an average national  exposure
of  0.006 ug arsenic/m3, the  inhalation exposure of the general public to  water-
soluble forms  of  arsenic  in  ambient air can  be estimated as almost 0.12 ug/day.
Assuming 30%  to 85%  absorption  of  inhaled arsenic, depending on the relative
proportions of vapor  and  particulate matter  (U.S. EPA, 1984a; Vahter, 1983),
the general  public would  be  exposed  to a range of  approximately 0.04 to 0.09
ug/day  of  arsenic by  inhalation.
      Persons  living  near  industrial  areas such as  smelters,  glass factories,
chemical plants,  or  cotton  gins may  be  exposed to  ambient air levels between
0.1 and 3.0 ug arsenic/m3 (U.S.  EPA,  1984b).  This would result  in as much  as
45  ug arsenic  absorbed  per  day.
      In the general  environment, airborne arsenic  is  available from a variety
 of  sources as  inorganic salts.   In the  vicinity  of smelters,  these salts contain
 trivalent  arsenic.   The chemical form and  the uptake  rate of arsenic in the
                                       E-3

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vicinity of cotton gins from its use  as  a  desiccant  on  cotton  is  not known.

C.  FOOD
     In the United States,  arsenic  is used as  a  pesticide  on grapefruit,  grapes,
and cotton.  In addition,  the animal  feed  use  of cotton,  grapes,  and  grapefruit
byproducts can lead to arsenic residues  in meat  and  milk.   Various  organic  forms
of arsenic (arsanilic acid, roxarsone, and carbarsone)  are added  to feed as
growth enhancers for chickens and swine  (Anderson,  1983).   Finally, many food-
stuffs contain arsenic from background environmental contamination.
     Food arsenic values taken from FDA  surveys  indicate an average daily dietary
intake of approximately 50 ug arsenic (Johnson et al.,  1984; Gartrell  et al.,
1985; U.S. EPA, 1984 a,b).   Generally, the meat, fish,  and poultry  composite
group is the predominant source of arsenic intake for adults  and  has been
estimated to account for about 80% of arsenic  intake (Gartrell et al.,  1985;
Hummel,  1986;  1987; U.S. EPA, 1984b).  Of this composite group, fish and seafood
consistently contain the highest concentrations  of arsenic.  The  concentration
of arsenic in  fish and seafood  (particularly shell fish and marine foods) is
generally one  to  two orders of magnitude higher than that in other foods (FDA,
1985; Jelinek  and Corneliussen, 1977).  The second most concentrated source of
arsenic  in these  FDA surveys  is the grain and cereal group which  may account
for  about  17%  of  arsenic.  Following  these groups are vegetables, sugars, oils,
fats, and  beverages.   In the  average  U.S. adult diet, dairy products account
for  26%  by weight; meat, fish,  and poultry 9%;  grain and cereal products 14%;
potatoes 5%;  fruits  11%; and  vegetables 6% (Gartrell et al.,  1985),
      An analysis of  arsenic  species  in foods sampled by the Canadian government
shows  that most of  the  arsenic  in meats,  poultry, dairy products, and cereals is
inorganic  (Weiler,  1987).   Fruits, vegetables,  and  fish contain arsenic  predomi-
nantly  in  organic forms.   These data, though based  on a limited number of
                                      E-4

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samples,  are included here (Table  E-l)  because,  until recently, this  type of
breakdown by arsenic species  has  not been  available.
     Because of the very large  quantities  of  arsenic  in  fish  and  seafood, many
investigators have studied the  chemical  forms of arsenic in fish  and  their meta-
bolism, excretion, and toxicity in humans.  As noted  in  Table E-l,  arsenic in
seafood is predominantly organic.   A number of researchers have shown that
these organic forms are trimethylated.   In 1977, Edmonds et al. showed that
rock lobster contained 26 ppm of arsenic as arsenobetaine,  (CH^)^ As+CH2  Ct^.
Other researchers have shown  that trimethyl arsenic in  fish also  occurs in
other chemical  structures, such as arsenocholine.  Yamauchi and Yamamura  (1984)
showed that although most of  the trimethyl arsenic compounds  in  prawns were
excreted unchanged, 3% to 5%  is changed to mono- and  dimethylated forms or to
inorganic arsenic.  Thus, although most of the organic  arsenic in seafood is
excreted rapidly and unchanged, some of it may be retained  in the soft tissues,
undergo biotransformation, and be available biologically.

D.  OCCUPATIONALLY EXPOSED GROUPS
     Pesticide applicators and workers in copper, lead,  and  zinc  smelters,  glass
manufacturing plants, chemical  plants, wood preserving plants, and  cotton gins
are exposed to high levels of arsenic.  Smelter workers  are  exposed to trivalent
arsenic, workers in wood  preserving plants are exposed to pentavalent arsenic,
and pesticide applicators are exposed to various inorganic  salts  as well  as
mono-methyl arsenic  (MMA) and cacodylic acid  or dimethyl arsenic  (DMA).
     The OSHA standard is 10 ug arsenic/m3 (8-hour time-weighted  average) for
industrial exposure  (OSHA, 1986).  Using the  previous assumption for daily ven-
tilation rate and lung absorption and assuming an 8-hour workday, an occupation-
ally exposed person could receive about 80 ug corresponding to 68 ug water-
soluble arsenic absorbed  daily via inhalation at the OSHA standard.  Because
                                      E-5

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 TABLE E-l.   PERCENTAGE OF  INORGANIC  ARSENIC  IN  FOOD:   A PRELIMINARY  ANALYSIS3
                                                         Percentage of
Food                                                   Inorganic Arsenic
Milk and dairy products                                      75

Meat - beef and pork                                         75

Poultry                                                      65

Fish - saltwater                                             0
     - freshwater                                            10

Cereals                                                      65

Rice                                                         35

Vegetables                                                   5

Potatoes                                                     10

Fruits                                                       10
 aSpeciation of  the  arsenic content of basic food groups based on preliminary
  data  from the  Ontario  Research Foundation and other sources.

 SOURCE:   Weiler,  1987.
                                       E-6

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arsenic is poorly absorbed  dermally  (approximately  0.1%),  dermal exposure has



been considered to be negligible as  compared to  inhalation exposure.





E.   TOTAL  DAILY BODY  BURDEN



     Table E-2 represents the range  of  total  body burden  of arsenic  from all



sources:   dietary, drinking water,  smoking,  ambient air,  and occupational exposure,



in the United States, namely 55.09  to 224 ug/day.   As  noted in this  section,



water and air generally contain arsenic in inorganic and  organic forms.  Using



information about the percentages of inorganic arsenic in various  food groups,



combined with FDA surveillance data  on the contributions  of these  foods to  the



daily arsenic intake, it appears that the diet including  drinking  water and



beverages contains about 17 or 18 ug/day of inorganic  arsenic (Table E-2).







                III.   METABOLISM, BIOAVAILABILITY,  AND TOXICITY








A.   TOXICITY OF ARSENIC CHEMICAL SPECIES



     Chronic arsenic  intoxication can lead to gastrointestinal disturbances,



hyperpigmentation, and peripheral neuropathy (Goyer, 1986).  Arsenic is also



carcinogenic, and Jacobson-Kram (1986) notes that arsenic is clastogenic and



causes sister chromatic exchange.



     The toxicity of arsenic is closely related to  its chemical form.  Inorganic



salts and acids of arsenic occur predominantly in the  tri- and pentavalent oxi-



dation states.  It is well  known from acute exposure studies that trivalent



arsenic is more toxic than pentavalent arsenic (Goyer, 1986).  Recent studies



have shown that at environmental levels, pentavalent arsenic is rapidly converted



to trivalent arsenic in the blood (Marafante et al., 1985).  These two forms



can be readily interconverted in mammals.  Trivalent and pentavalent arsenic




salts also have different  modes of toxic  action.  Cellular mechanisms of arsenic




                                      E-7

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       TABLE E-2.  DAILY ARSENIC BODY BURDEN  (ug/day) IN THE UNITED STATES
     Source              Usual                             Unusual
Water
Air

Food
Smoking
5
0.09

50d

lOOa
1.5 - 45b
68C
50
2-6e
      TOTAL             55.09                               up  to 224





aAt the ODW maximum containment level  (see Part II. A).



bNear industrial  use sites such as  smelter or cotton gins  (see  Part II.B)



C0ccupational  exposure.



dSee Part II.C.



^2 ug arsenic/package  (Weiler, 1987;  IARC, 1986).
                                      E-8

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toxicity have been discussed  in several  current  reviews  (Goyer,  1986; Vahter
and Marafante,  1983).   For example,  Vahter  and Marafante note  that  "Arsenite  is
known to react  with SH-groups of proteins  and enzymes while  arsenate may  interfere
with phosphorylation reactions due to its  chemical  similarity  with  phosphate."
     Methylation of inorganic salts  of arsenic  through  the trivalent state  appears
to be a detoxification pathway in mammals  (Vahter,  1983).   The simple methylated
forms of arsenic, namely cacodylic acid and methanearsonate, are less acutely
toxic than the inorganic salts.  Fairchild et al.  (1977) gives the  1050 of  arsenic
trioxide as 1.43 mg/kg, of MMA as 50 mg/kg, and  of  DMA  as 500  mg/kg.  Trimethy-
lated forms of arsenic are not acutely toxic and are rapidly excreted  (Vahter,
1983).  Although tested in animals,  the oncogenic  potential  of the  organic
forms has not been adequately characterized.

B.  ABSORPTION, DISTRIBUTION, AND ELIMINATION
     Arsenic exposure occurs predominantly through ingestion and inhalation.
Dermal  absorption  is negligible.  A detailed understanding of  the mammalian
distribution, elimination, and long-term deposition patterns following exposure
and the relationship of these processes to the  internal body burden can provide
insights into tissue sites for chronic target organ toxicity.
      In smelters,  inhaled arsenic and that brought to the gastrointestinal  tract
by mucociliary clearance, leads to approximately 80% absorption (Pershagen and
Vahter, 1979).  Smith et  al .  (1977) showed that nonrespirable particulate
forms of arsenic were more closely correlated with excretion of arsenic  than
respirable forms.  These  results  imply that  ingested forms of arsenic are
better  absorbed and get into the  bloodstream more efficiently than inhaled
arsenic.  Marafante and Vahter  (1987) compared  absorption and tissue retention
of arsenic salts  administered  orally  and intratracheally  in the hamster.   In
general, orally administered arsenic  had a  shorter biological  half-life  than
                                      E-9

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that administered  intratracheally.   Clearance  of  arsenic compounds from the
lungs was also closely correlated with  solubility under physiological conditions.
     Brune et al.  (1980)  collected  autopsy  specimens  from a group of 21 Swedish
smelter workers employed  between  10 and 30  years  in a  smelter.  A control  group
consisted of eight individuals  from a  region  50 km from the smelter site.  Arsenic
levels in kidney and liver were comparable  for workers and control subjects, but
levels of arsenic  in lung tissue were  about 6  times higher for  the smelter
workers than the control  group. Furthermore,  arsenic  levels  in the lungs  of
workers retired up to 19  years  were comparable to those in workers autopsied
less then 2 years after retirement. However,  if  smoking  is a factor, the  high
lung levels in some subjects may  be a  function of chronic exposure to arsenic
in tobacco smoke.   For example, Vahter (1986)  reports  that  some smokers  in the
1950s may have inhaled as much  as  0.1  ug arsenic  each  day.  Although the complete
smoking history of these workers  is not known and the duration  of  exposure of
the  two groups of retirees is not  completely  defined,  the Brune et al. study may
indicate that a portion of inhaled arsenic  binds  irreversibly to  lung tissue.
     Valentine et al. (1979) measured  arsenic levels  in human blood, urine, and
hair in five United States communities with arsenic  concentrations in drinking
water  ranging from 6 ug/L to 393  ug/L.  Their results showed  that arsenic
concentrations increased in urine and hair samples in proportion  to  increases
in concentrations in drinking water.  However, this  trend was not reflected  in
blood until  drinking water concentrations exceeded 100 ug/L.
     Various  researchers have monitored arsenic excretion in  the urine  and the
feces  and  found that the urinary  tract is the major route of  elimination and
accounts  for more than 75% of  absorbed arsenic over time.  Animal studies  have
also shown  that little,  if any, absorbed arsenic  is exhaled  (WHO, 1981).  Thus,
since  the  late  1970s, pharmacokinetic  and metabolism  studies have monitored the

                                       E-10

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urine alone as an approximate surrogate  for  excretion.  When  organic arsenic is
administered orally,  it is eliminated more  rapidly  than inorganic  forms.   In
addition to urine and feces,  arsenic  is  also eliminated from  the body  via  sweating
and desquamation of the skin.  In humans not excessively  exposed to  inorganic
arsenic, the highest tissue concentration of arsenic  is generally  found  in skin,
hair, and nails (Liebscher and Smith, 1968).  Kagey et  al.  (1977)  also studied
women in the United States and showed that umbilical  cord levels of  arsenic
were similar to maternal levels.
     Because of the limitations of human studies of absorption, elimination, and
tissue  distribution of arsenic, various  researchers have  used the  recent advances
in arsenic, speciation methods to study the way laboratory animals  handle arsenic.
Lindgren et al. (1982) injected mice with radiolabeled  (inorganic) arsenic and
used whole body radiography to study its distribution and clearance.  Initial
concentrations were highest  in the bile and kidney for  arsenate,  but clearance
from these tissues was extremely rapid.   After 72 hours,  the  highest concentrations
were in the epididymus, hair, skin, and stomach for arsenite  and the skeleton,
stomach, kidneys, and epididymus for arsenate.  Arsenate  was  cleared more rapidly
than arsenite  from all  soft  tissues but the kidneys.   It  seems probable that
this pattern of uptake  is  related to the chemical similarities between arsenate
and phosphate  in the apatite crystals in bone.  One can ascribe the accumulation
of arsenic in  skin, hair,  and upper gastrointestinal  tract to its binding of
sulfhydryl groups of keratin  (Goyer, 1986).
     Following intravenous injection of DMA in rabbits or mice, excretion was
essentially complete within  24 hours, indicating low affinity for the tissues
in vivo (Vahter and Marafante, 1983).  The  same results were obtained following
oral administration  (Vahter  et al.,  1984).  In addition,  the distribution
showed  a different pattern from  that shown  after administration of  inorganic

                                      E-ll

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arsenic, as discussed  above.   The  highest  initial  concentration  of  arsenic  in
mice was found in the  kidneys,  lungs,  gastrointestinal  tract,  and testes.
Tissues showing the longest retention  time were the  lungs,  thyroid,  intestinal
walls, and lens.
     Tissue retention  of arsenic  in the marmoset monkey,  which doesn't methylate
arsenic, was much more pronounced than in  species which methylate arsenic
(Vahter and Marafante, 1985).   Seventy-two hours after  injection with inorganic
arsenic, almost 60% was still  bound to the tissues.   The major single binding  site
was liver, with 10% of the original dose.   Arsenic was  also retained in the kidney
and gastrointestinal tract.  To the extent that the marmoset monkey may be an
appropriate model of distribution and tissue retention  in humans when arsenic
levels  exceed  the normal detoxification capacity, these studies may enable us
to predict  accumulation of arsenic in the liver, kidney, and gastrointestinal
tract  from  chronic high exposure.
      In  sunmary, systematic animal studies and observations in humans show that
arsenic  is  efficiently  absorbed through the gastrointestinal tract and via
inhalation  and eliminated predominantly in the urine.  High levels of exposure
can  lead to deposition  in  tissues  rich  in  sulfhydryl (SH)  groups such as the
lung  tissue,  gastrointestinal  tract,  skin, and hair.   Arsenic also appears to
concentrate in the  liver and  to a  lesser  extent  the  kidney, especially in  the
marmoset monkey which  does  not methylate  arsenic.  As  discussed  above, the
 chemical  form of arsenic influences its retention time and target  tissue sites.

 C.   DETOXIFICATION  VIA METHYLATION
      Methylation of inorganic arsenic is  generally accepted as  a detoxification
 mechanism of mammals.   Vahter (1983)  and  Vahter et  al. (1984) showed that
 methylated arsenic is excreted more  rapidly after ingestion than the inorganic
 forms.  In addition,  cumulative  observations  of humans acutely exposed to
                                       E-12

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inorganic arsenic  show that,  although  inorganic  arsenic  is  the  predominant



initial  metabolite,  after 9 days,  MMA  and DMA  account  for more  than  95%  of



total  arsenic excreted in the urine (Mahieu  et al.,  1981).   Various  researchers



have shown that methylation of inorganic arsenic occurs  enzymatically  prior  to



elimination in the urine.  The enzymatic pathways  for  arsenic methylation and



detoxification are summarized in this  section.



     Methylation appears to take place through the trivalent As (+3) state



(Vahter and Envall,  1983).  Based on studies with  model  compounds, Cullen et al .



(1984) hypothesized that methylation of arsenic III  requires s-adenosylmethionine



in excess, dithiolipoic acid-like structures on the  membranes,  and/or  a  functional



enzyme system (see Figures E-l and E-2).



     The major site of methylation appears to be the liver  (Klaassen,  1974).



Lerman et al. (1985) followed methylation of tri- and pentavalent arsenic  in



cultures of  hepatocytes.  They found that dimethyl arsenic  acid formed when



arsenite, but not arsenate, was added to the culture medium.  No metabolism  of



arsenate was seen, nor was the arsenate taken up by the  liver cells.  The



authors  postulated that the differences in in vitro cellular uptake  of the  two



forms of arsenic may be due to the fact that, at physiologic pH, arsenite  is



not ionized, whereas arsenate is charged.



      In  order to understand reaction mechanisms and sequences of methylation,



Buchet and Lauwerys (1985) performed in vitro incubations of inorganic arsenic



with  various  (rat) tissues.  The methylating  capacity of red blood cells,  and



brain, lung, intestine, and kidney homogenates were insignificant by comparison



to  that  of the liver.  They found that the cytosol was the sole fraction of  the



liver showing methylating activity; and s-adenosylethionine and reduced glutathione



were  required as methyl donors.  The effect was further enhanced by  addition of



vitamin  BI?  to this system.  Although MMA was formed immediately, a  30-minute





                                      E-13

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    Me3AsO  *
                      HS
                                                         HS-
Me  As
        \C_
          o
Figure E-l.  Reproduction of arsenic III  forms by membrane-bound lypoic acid.
SOURCE:  Cullen  et al., 1984.
                                E-H

-------
    S-Adenosylmetttionine
  S-Adenosylhomocysteine
Me As
Figure E-2.  Role of s-adenosylmethionine  in methylation of arsenic III
SOURCE:  Cullen et  al.,  1984.
                                 E-15

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latency period occurred before  DMA  was  produced,  suggesting  that  it  is  formed
from MMA.   As cytosol  and subtrate  (As  +3)  concentrations  were varied,  MMA  and
DMA appeared to exhibit different kinetics  of  formation.   At high substrate
concentrations, DMA formation was inhibited, while  MMA  appeared to accumulate
in the system, showing that formation of DMA  is a rate-limiting step.
     Methyl transferase activity has been shown to  play a  necessary  role in the
methylation of arsenic in mammals (Marafante  and Vahter,  1984, 1986;  Marafante
et al., 1985).  The effect of dietary deficiencies  and  genetic variability  on
methylating capacity (shown below)  has important implications for tissue distri-
bution and individual susceptibility to arsenic toxicity.
     Marafante and Vahter  (1984) studied the  effect of  methyl transferase inhi-
bition on the metabolism and tissue retention  of arsenite in mice and rabbits.
Periodate-oxidized adenosine (PAD), an inhibitor of methyl transferase, was
injected into mice and rabbits prior to administration  of the arsenite.  This
led  to a marked decrease in production of cacodylic acid,  a dimethylated form
of arsenic.  Moreover, impairment of methylation increased the tissue retention
of arsenic.   These results imply that  S-adenosyl-methionine is a methyl donor
in the methylation of  inorganic  arsenic  in vivo  and are consistent with the
conclusions  of Buchet  and  Lauwerys  (1985)  regarding the significance of various
cofactors  i_n_ vitro.
      In  1985,  Marafante  et al. measured  blood as well  as  urinary concentrations
of arsenic  metabolites  following the administration of arsenate.  The  reduction
of arsenate to arsenite  occurred almost  immediately, followed  by the appearance
of DMA in  the blood  plasma after about an  hour.  The administration  of  PAD  led
to a dramatic decrease in  the  appearance of DMA  in  the blood  and confirmed  the
 earlier results  in the laboratory  showing  the  significance  of methyl transferase
 activity in the  methylative  metabolism of  arsenic.   Urinary  excretion  of arsenate

                                       E-16

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and its metabolites  paralleled  their  concentrations  in the  blood.   In  light of
these observations,  these authors  postulated that  reduction of  arsenate  to
arsenite is an initial  and independent  reaction  in the biotransformat!on of
arsenate and probably occurs in the blood.
     In a later study,  Marafante and  Vahter (1986) studied  the  effect  of
choline-deficient diets on the  metabolism of arsenic in  rabbits.   Shivapurkar
and Poirier (1983) had previously demonstrated that  choline- or protein-deficient
diets increase relative hepatic concentrations of  s-adenosylhomocysteine,
leading to inhibition of methyl transferase activity.   In  their study, Marafante
and Vahter showed that both the choline-deficient  diets  and the administration
of PAD led to decreased excretion of  DMA in the  urine and  higher retention  of
7fy\s in the liver, lungs, and skin.  (As noted  above, this pattern is  seen  in  the
marmoset monkey which lacks the genetic capacity to  methylate arsenic.)   In
addition, choline deficiencies led to an increased concentration of 7^As in
the liver microsomes.
     These observations demonstrate that methylation as  a  detoxification pathway
is enzymatic and occurs via the trivalent state  of arsenic to MMA and  subsequently
to DMA.  Furthermore, decreased methylating capacity caused by chemical  inhibition,
dietary deprivation, or genetic disposition appears  to lead to decreased excretion
of DMA  in the urine, with retention of arsenic  in the lungs, skin, and liver.
In addition, certain dietary deficiencies lead to concentration of arsenic in
the liver microsomes.  These results in animals  may be considered to mimic that
segment of the human population described as poor methylators.  [See the following
section for a summary of  the human studies by Foa et al. (1984) and Buchet et al.
(1982).]  They may also serve as models for those populations  consuming protein-
deficient diets while exposed to high levels of arsenic.   In these populations,
one can anticipate that  decreased methylating capacity can  lead to an increased

                                      E-17

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deposition of arsenic  in liver  and  Tung  cells  as well  as  the  organ  sites of
normal  distribution,  namely  skin, hair,  and  nails.

D.  HUMAN METABOLISM  AND ENZYME KINETICS
     This section contains summaries  of  human  studies  of  the  metabolism and
enzyme kinetics of arsenic.   In these studies,  dosing  or  exposure levels ranged
from background levels to which the general  population is normally  exposed,
through levels representing  occupational exposure,  up  to  highly  toxic  levels.
The dosing patterns include  acute,  short-term,  and  chronic exposure.   Of necess-
ity, many of these studies are  limited to single  doses in small  numbers of
human volunteers.  Nonetheless, when  seen in the  context  of the  enzyme kinetics
of arsenic methylation described previously, they provide valuable  insights
into the way humans can handle, detoxify, and eliminate arsenic  at  levels  of
concern.
     Buchet et al . (1981) performed a series of pharmacokinetic  studies of
arsenic metabolism in human volunteers exposed to levels  of arsenic roughly
comparable to those in smelters.  In the first study,  groups of  three, four, or
five adult males  drank solutions containing 500 ug equivalents of inorganic
arsenic, MMA, or  DMA.  After a single dose, urine was  collected  for four  days
and analyzed  for  inorganic arsenic, MMA, or DMA.   In four days,  total  or  cumulative
arsenic  content as monitored by urinary excretion,  amounted to about 47%  of  the
ingested  dose  of  inorganic arsenic,  78% of  ingested MMA,  and 75% of ingested
DMA, indicating much more rapid excretion of organic than inorganic forms.
After  ingestion  of inorganic arsenic, the percentage of  inorganic arsenic
excreted  in  the  urine  fell off extremely rapidly and was accompanied by an
 increase of  DMA  excretion.  However, MMA excretion initially increased and then
at 12  to  24  hours began  to decrease.  When  MMA was ingested, MMA accounted for
 87.4% and DMA accounted for  12.6%  of urinary arsenic  after 4 days  indicating
                                      E-18

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some bioconversion of MMA to DMA,  but no demethylation.   When DMA was  ingested,



all urinary arsenic was excreted as DMA.  These observations, in light of the



relative toxicities of the metabolites,  demonstrate that methylation is an



efficient detoxification pathway for arsenic.



     In a second human study, Buchet et al .  (1982)  studied urinary metabolites



after repeated oral dosing for 5 days with 125, 250, 500, or 1,000 ug inorganic



arsenic.  In this study, urinary monitoring  was performed for 9 days following



the last dose.  Although only one volunteer  was tested at each dose, they were



chosen in the context of previous studies in the laboratory to have normal



methylation rates.  Above 500 ug the ratio of DMA to MMA decreased and methyla-



ting capacity appeared to fall off as shown  in Figure E-3.  When the percentage



of each metabolite was plotted against the log of the ingested dose, the concen-



tration (percentage) of inorganic arsenic declined  and that of DMA increased



commensurate with first-order kinetics.   The rate of conversion to methylated



forms diminished starting at 250 ug, but not until  the dose range exceeded 500



ug did the absolute amount of DMA decline indicating saturation of methylating



capacity.   In addition, the biological  half-life of total recovered arsenic



increased with increasing dose (39 h at 125  ug to 59 h at 1000 ug).  The authors



indicated that when they saw these results,  they re-examined the history of the



high-dose volunteer, but confirmed that his  excretion pattern for arsenic was



not out of line with the others.  These results suggest the hypothesis that



saturation of methylating capacity occurs just above 500 ug/day in healthy



adult males exposed to  repeated doses of arsenic in short-term experiments.



However, confirmation of the enzyme saturation pattern would require that EPA



obtain the raw data from Buchet's experiments.



     These short-term dose-response curves are typical of enzymatic conversion



processes.  Buchet's studies include a  dosing  range up through enzymatic  satu-





                                      E-19

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                                                             T 1489
         e
         188
       250            500


Micrograms As  Per Day
1888
Figure  E-3.  Urinary concentrations of arsenic and its metabolites.
SOURCE:   Adapted from Buchet et al.,  1982.
                                    E-20

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ration and beyond it.   At about 600  ug/day  the  absolute amount of MMA begins to
plateau,  and the saturation of methylation  occurs  between  doses  of  500  and  1,000
ug/day in people of adequate methylating  capacity  (Figure  E-3).
     In 1985,  Lovell and Farmer monitored urine for  arsenic  metabolites following
ingestion of highly toxic doses of inorganic  arsenic by people attempting suicide.
In the course of 5 days, a decreasing percentage of  inorganic arsenic was elimi-
nated with a corresponding increasing percentage of  DMA,  implying  metabolic
conversion of one to the other.  The amount of MMA in the urine  did not show
any such clear pattern.  A similar pattern of urinary metabolites  to that
observed by Lovell and Farmer  (1985) as well  as Buchet et al.  (1981) was seen
by Tarn et al. (1979) (Figure E-4).
     From the dose-response experiments and the time course  of elimination, one
can postulate that after the initial rapid excretion of inorganic  arsenic
arising from ingestion of  inorganic arsenic,  simple enzymatic  conversion to
DMA, first  order in the inorganic arsenic substrate, occurs  in  the liver.   The
DMA is then excreted via the kidneys.  However, conversion of  arsenic to MMA  as
observed by urinary excretion  does not indicate simple kinetics.  Possibly,
this conversion occurs at  the  cellular level  throughout the body,  or by nonenzy-
matic mechanisms.   In  light of this elimination pattern for short-term experiments,
conversion  of inorganic  arsenic to DMA appears  to be the rate-limiting step in
detoxification  (Buchet and Lauwerys, 1985).
     Foa et al.  (1984) measured blood and urinary metabolites of arsenic in 40
glass workers exposed  to high  levels of  arsenic and  in 148  control  subjects drawn
from the general population.   These researchers found a broad range and standard
deviation  for each  metabolite  in  the blood and  urine.  Perhaps the  most significant
finding in  this  study was  that, although many of  the subjects were  good methyl-
ators, each  group  contained  subjects with clearly reduced methylation  capacity

                                      E-21

-------
                •  Total  arsenic
                $  inorganic  arsenic
                X  monomethylarsenic  compound
                A  dimethylarsinic acid
Figure E-4.
Excretion of arsenic metabolites following a single oral  dose
of inorganic arsenic.  ?^As radioactivitiy in urine of male
volunteer No. 5; ingested dose:  6.45 uCi.
SOURCE:  Tarn et al ., 1979.
                                      E-22

-------
as seen by the profile of  metabolites.   For  the  glass workers,  both blood and
urine concentrations of total  arsenic  were increased  in  proportion  to  the
exposure, although metabolite  profiles were  comparable.
     Foa et al.  (1984) also selected a group of  five  glass workers  with  high
urinary arsenic concentrations and suspended their exposure for one month.
Urinary concentrations of arsenic and its methylated  metabolites decreased  with
time nearly to that of the control population.  However, when high  exposure was
resumed,  only a moderate increase was seen for inorganic arsenic and  its methylated
metabolites.  Two months after exposure resumed, urinary concentrations  of  total
arsenic were  still  diminished relative to daily exposure  (Figure E-5).  Further-
more,  day-to-day and  morning-to-evening sampling showed only the slightest
variation in  concentration of inorganic arsenic, with no  variation in concentra-
tion of  its methylated metabolites.  This appears to indicate that full  methyla-
tion capacity for  high exposures  takes  several  months to  build up and that any
accommodation the  body had made  to  very high  arsenic levels  is rapidly lost.
Comparing their  observations  with human studies in other  laboratories, these
researchers  postulated that the  time  course  of  excretion  of  metabolites indicates
a saturable  mechanism for  the methylation of arsenic.
      In a very  recent study,  Vahter (1986)  compared  urinary  arsenic metabolites
 in smelter workers having high  chronic exposures  to  those in a  general  population
 of non-fish  eaters in Sweden.  The  profile  of metabolites was strikingly similar
 (inorganic arsenic:MMA:DMA was  18%:16%:65%  and  19%:20%:6U,  respectively)  and
 implied the occurrence of long-term accommodation to high levels of  arsenic  by
 the smelter workers.
      In  sumnary, similar patterns of  enzymatic  methylation have been demonstrated
 in both animals and humans.   Short-term studies demonstrate that these  enzymatic
 detoxification pathways are saturable as noted  above.   However, the  human  studies

                                       E-23

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       As
        300-
        200-
        100-1
  As exposure

end     resumption
                      -1
                                2    months
Figure E-5.  Urinary excretion  of arsenic (As)  and  its metabolites in  glass
            workers with prolonged exposure to arsenic trioxide, after suspension
            and resumption of  exposure.  Values are means + SO of five subjects.
SOURCE:   Foa et al., 1984.
                                    F.-24

-------
demonstrate a long-term accommodation  pattern such  that occupationally exposed
people eliminate inorganic arsenic,  MMA,  and DMA  in the same  relative proportions
as the general  population or lightly exposed worker groups.   Although the
pattern of accommodation is consistent with traditional clinical  observations
of arsenic toxicology, the panel  could not find any research  that would  enable
the mechanism of accommodation to be elucidated.   Finally,  a  number of  researchers
observed that methylation capacities in large populations can be  highly  variable.

IV.  PHARMACOKINETICS OF ARSENIC METABOLISM AND ITS IMPLICATIONS  FOR ONCOGENTCITY

     Although most forms of arsenic to which people are  commonly  exposed are bio-
logically available,  inorganic arsenic is the most toxic.   Inorganic arsenic is
methylated enzymatical ly in the liver prior to its elimination in the urine.
When the methylation  capacity of the liver is exceeded,  exposure  to excess
levels of inorganic arsenic can lead to increased and long-term deposition in
certain target  tissues, namely the liver, lung, skin, bladder, and gastrointestinal
tract.
     One can speculate  that the methylation capacity may be exceeded at lower
levels of arsenic exposure  in the segments of the human population that are poor
methylators  due to genetic  disposition or  in groups consuming poor or protein-
deficient diets.  This  may  explain  the anomalies noted by Enterline in the
manifestation of carcinogenic response in  epidemiological  studies of certain
highly exposed  groups (U.S. EPA, 1987).
     Long-term  accommodation  to arsenic  (on  the order of several  months or more)
appears to  take place in  occupationally exposed worker populations as demonstrated
by  similar  profiles of  arsenic metabolites  in  the urine over a wide range of
exposures.   However,  blood  levels from high  chronic  exposure to arsenic (in

                                      E-25

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excess of 200 ug/day)  indicate that the  accommodation  may  not  be  complete.



However, even if the human body accommodates  to  chronically  elevated  arsenic



levels, the internal  tissues are nonetheless  exposed to  much more inorganic



arsenic over long periods of time.   Furthermore, the ability of the human



organism to handle more than 500 or 600  ug/day may  constitute  a stress  to  the



body.  An improved understanding of these homeostatic  mechanisms  is critical  to



improving the cancer dose-response  assessment.



     Appendix C summarizes data on  elevated rates of cancer  of the liver,  lung,



and bladder in Taiwan and also notes the occurrence of internal tumors  in  the



Fierz  study.  Extrapolating from the studies  on  protein-deficient animals,  one



would  expect liver cancer to be especially prevalant  in  protein-deficient  human



populations.  Future work may show whether the deposition patterns are  matched



by confirmed incidence of internal  cancer.
                                       E-26

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