vvEPA
           United States
           Environmental Protection
           Agency
           Environmental Criteria and
           Assessment Office
           Cincinnati OH 45268
EPA-600/9-84-014a
June 1984
           Research and Development
Selected Approaches to
Risk Assessment for
Multiple Chemical
Exposures:

Progress Report on
Guideline Development at
ECAO-Cincinnati

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                                            EPA-600/9-84-014a
                                            June 1984
       SELECTED APPROACHES TO  RISK ASSESSMENT
           FOR MULTIPLE  CHEMICAL EXPOSURES
Progress  Report on Guideline Development at  ECAO-C1ndnnat1
             Or.  Jerry F. Stara, Director,  ECAO
                          Editor
        Environmental Criteria and Assessment  Office
                 Cincinnati, Ohio  45268
                  Dr. Linda S. Erdrelch
                     Technical Editor
        Environmental Criteria and Assessment Office
                 Cincinnati, Ohio  45268
       Environmental Criteria and  Assessment Office
      Office of Health and Environmental Assessment
            Office of Research and Development
           U.S. Environmental Protection Agency
                  Cincinnati, OH   45268

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                                    NOTICE

    This document  has been  reviewed 1n  accordance  with U.S.  Environmental
Protection Agency  policy  and  approved  for publication.   Mention of  trade
names or commercial  products  does not constitute endorsement  or  recommenda-
tion for use.

    The appendix to  this document,  consisting  of  post meeting comments  and
selected references, will be available only from National  Technical  Informa-
tion  Service,   U.S.   Department   of  Commerce,   Springfield,  VA   22161,  as
"Selected  Approaches  to  Risk Assessment  for  Multiple Chemical  Exposures:
Appendix,- EPA-600/9-84-014b.
                                       11

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                                   FOREWORD

    Methods must be  developed  for  assessing the potential  risks  of  simulta-
neous or sequential  exposure to multiple chemicals  1n  order to prepare valid
assessments of  risks posed  by environmental contamination.   Many real-life
exposures  have  dynamic and  chronic patterns  that have  no counterparts  1n
laboratory studies.  This workshop  and others 1n  this  series are Intended to
develop  such  methods,  to promote  discussion on alternative approaches,  and
to stimulate research Into developing areas 1n risk assessment.

    The  need  for  risk assessment  1s driven by  the presence of  or threat of
environmental contamination and the absence of  sufficient  data for the human
health effects of  these chemicals.  The  twenty-five peer  reviewers listed 1n
this  report  were  selected  for their  scientific expertise and  Interest  1n
this  pressing  problem.  The presentations and subsequent  scientific Inter-
change among Agency  and non-Agency scientists,  and  the summary statements of
the  reviewers  after the  meeting  are presented  1n this document  to reflect
the  dynamic  nature of  this  contemporary problem.   The  document  represents a
second  progress  report on  the development of  risk assessment methodologies
and  guidelines  which  are  1n   progress  at  the  Environmental Criteria  and
Assessment Office, Cincinnati.
                                                 Jerry F. Stara, DVM, OS
                                                 Director
                                     111

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                                   ABSTRACT

    This report summarizes a  workshop  that addressed methods and  Issues  for
the assessment  of  human health  risks  from  exposure to multiple  chemicals.
The  meeting was  sponsored  by  the Environmental   Criteria  and  Assessment
Office of  the  U.S.  Environmental  Protection  Agency and was  held  1n Cincin-
nati, Ohio, on  July  12-13,  1983.  The methods and  Issues  were  selected from
those presented at  a previous workshop  held 1n September  1982,  "Approaches
to  Risk Assessment  for  Multiple  Chemical  Mixtures."   Approaches  1n  five
areas were discussed  with  the  Intention  of  Identifying  valid  methods  of
mult1chem1cal  risk assessment  that could be Implemented 1n  the  near future.
Consensus  was  reached  among  the  participants  on  approaches  to  the Inter-
species conversion of  dose  and duration of  exposure (use  one-third power of
body  weight and  lifetime  proportionality  factors),  the assessment  of  risk
for  less  than  lifetime exposure  to toxicants (consider dose,  duration,  and
no-effect  levels  for all available data), and multiple  chemical  assessment
(an  add1t1v1ty  model  was  considered  adequate  1n  the  Interim).   The  other
topics proposed for  consensus  concerned  the assessment  of  risk  for  less than
lifetime  exposure  to  carcinogens,  the  determination  of acceptable  dally
Intakes  based   on  quantal,  continuous,  or  graded   data,  and  the   pharmaco-
klnetlc approach to route-to-route conversions.

    Brief  presentations  were made by  several  participants on  approaches
using structure-activity  relationships,  reproductive effects as endpolnts 1n
risk  assessment,  and  use  and   biological  justification  of  mathematical
models.   Four   working  groups  were  also  convened  to consider  approaches
proposed  1n four  additional  areas:   consideration of  high  risk  subgroups,
assessment  of  multiple  routes  of  exposure,  the  ranking  of  the  severity of
the  effects,  and  the  use  of exposure  and monitoring  data 1n  health risk
assessment.   A  statement  Including  recommendations  was  produced  by  each
group as  a guide for  future  discussions.   The  results of this workshop will
provide  a  basis for developing  guidelines  for  risk assessment  from multiple
chemical  exposures.   This  effort 1n guidelines development will culminate 1n
a  symposium 1n  the summer of  1984.
                                       1v

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                              TABLE  OF  CONTENTS

                                                                        Page
 1.   INTRODUCTION - MEETING OBJECTIVES AND STRUCTURE 	     1

 2.   CONSENSUS TOPICS (Session I)	     4

     2.1.    INTERSPECIES CONVERSION OF DOSE AND DURATION OF
            EXPOSURE — NONCARCINOGENIC TOXICANTS	     4
     2.2.    HEALTH RISK ASSESSMENT FOR LESS THAN LIFETIME
            EXPOSURE — TOXICANTS  AND CARCINOGENS	     9
     2.3.    ADIs BASED ON QUANTAL, CONTINUOUS,  OR GRADED DATA	    24
     2.4.    PHARMACOKINETIC APPROACH FOR ROUTE-TO-ROUTE CONVERSION .  .    34
     2.5.    MULTIPLE CHEMICAL ASSESSMENT 	    44

 3.   PRESENTATION OF NEW TOPICS (Session II)	    55

     3.1.    APPROACHES USING STRUCTURE-ACTIVITY RELATIONSHIPS	    55
     3.2.    USE OF REPRODUCTIVE EFFECTS AS ENDPOINTS IN RISK
            ASSESSMENT	    60
     3.3.    USE AND BIOLOGICAL JUSTIFICATION OF MATHEMATICAL MODELS.  .    63

 4.   WORKSHOPS (Session III)	    72

     4.1.    CONSIDERATION OF HIGH  RISK (SENSITIVE) SUBGROUPS IN
            HEALTH RISK ASSESSMENT 	    72
     4.2.    ASSESSMENT OF MULTIPLE ROUTE EXPOSURE	    81
     4.3.    RANKING THE SEVERITY OF EFFECTS	    87
     4.4.    USE OF EXPOSURE DATA IN ASSESSING HEALTH RISK	    94

REFERENCES	101

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                               LIST OF TABLES
No.                               Title                                Page
2-1     Various Effect Levels and Their Definitions 	   10
2-2     Constant Dose Rates Corresponding to Given Levels of
        Extra Risk	   21
2-3     Doses of 1-Week Duration that Correspond to Given Levels
        of Extra Risk	   22
2-4     Quantal Data Used To Illustrate Quantitative Dose Response
        Methodology	   29
2-5     Summary of Fits of Models to Quantal Data 1n Table 2-4. ...   30
2-6     Doses Corresponding to Given Levels of Extra Risk for
        Quantal ETU Data	   31
2-7     Comparison of Benchmark Doses with NOELs for Quantal Data .  .   32
2-8     Magnitude of Rate Coefficients (t1/2) 	   42
3-1     Performance of SAR Equations	   57
3-2     Predicted Clearance of Benzo(a)pyrene 1n Rats 	   66
4-1     Biological Factors Predisposing Individuals to Hyper-
        suscept1b1Hty to Pollutants	   76
4-2     Rating Values for NOELs, LOAELs and FELs for the
        Determination of RVe	   90
4-3     Relationship of Composite Score to RQ	   91
                                     v1

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                              LIST OF FIGURES
No.                               Title                                Page
2-1     Methoxychlor Oral Tox1c1ty Data	   11
2-2     Methoxychlor Oral Toxldty Data - Option 1	   13
2-3     Methoxychlor Oral Toxldty Data - Option 2	   14
2-4     Male Rats Exposed to EDB by Gavage	   18
2-5     Comparison of Estimates from Arm1tage-Doll Model with
        Kaplan-Meier Estimates	   19
2-6     Comparison of Estimates from ArmHage-Doll Model with
        Kaplan-Meier Estimates Excluding Tumors Found at Sacrifice.  .   20
2-7     Hypothetical Blood Concentrations for Three Exposure
        Conditions	   36
2-8     Hypothetical Blood Concentrations for Intermediate
        Elimination Rates 	   37
2-9     Hypothetical Blood Concentrations for Long Elimination
        Rates	   38
2-10    Dose Addition	   46
2-11    Response Addition 	   47
2-12    Isobole Diagram for Quanta! Response Data 	   48
2-13    Example of Dose and Response Addition	   49
2-14    Models for Interaction	   51
3-1     The Relationship Between a Measure of Internal Dose, the
        Area Under the Concentration, Time Curve, and Either Oral
        or Intravenous Metoprolol 1n Five Male Human Subjects ....   69
3-2     Mean Plasma Concentrations of Nortr1ptyl1ne and Us Major
        Metabolite, I0-Hydroxynortr1ptyl1ne  	   70
4-1     Information Flow and Methodology Use 1n Conducting Site-
        Specific MultUhemlcal Health Risk Assessment	   75
4-2     Rating Values for Doses	   89

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                             LIST OF  PARTICIPANTS
ECAO-C1n AUTHORS AND REVIEWERS

Jerry F. Stara
Tox1colog1st (Director)

Linda S. Erdrelch
Epidemiologist

Randall J.F. Bruins
Environmental Scientist

Michael L. Dourson
Tox1colog1st

Richard C. Hertzberg
Blomathematlclan

William Pepelko
Tox1colog1st
EXTERNAL PEER REVIEWERS

Roy E. Albert
Institute of Environmental Medicine
Tuxedo, New York

Julian B. Andelman
University of Pittsburgh
Graduate School of Public Health
Pittsburgh, Pennsylvania

Eula Blngham
Ketterlng Laboratory
College of Medicine
University of Cincinnati
Cincinnati, Ohio

Edward J. Calabrese
Division of Public Health
University of Massachusetts
Amherst, Massachusetts

Thomas W. Clarkson
Division of Toxicology
School of Medicine and Dentistry
University of Rochester, New York
Herbert H. Cornish
School of Public Health
University of Michigan
Ann Arbor, Michigan

Kenny S. Crump
Science Research Systems, Inc.
Ruston, Louisiana

Patrick R. Durkln
Syracuse Research Corporation
Syracuse, New York

Kurt Ensleln
Health Design, Inc.
Rochester, New York

Rolf Hartung
School of Public Health
University of Michigan
Ann Arbor, Michigan

Dale Hattls
Center for Policy Alternatives
Massachusetts Institute of Technology
Cambridge, Massachusetts

Marvin Legator
University of Texas Medical School
Dept. of Preventive Medicine and
  Community Health
Galveston, Texas

Jeanne M. Manson
Dept. of Obstetrics and Gynecology
University of Cincinnati
Cincinnati, Ohio

Myron Mehlman
Mobil 011 Corporation
Princeton, New Jersey

Norton Nelson
New York University Medical Center
New York, New York

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EXTERNAL PEER REVIEWERS  (cont.)
William J. Nicholson
Department of Environmental Health
Mt. S1na1 Hospital
New York, New York

Ian C. T. Nlsbet
Clement Associates
Arlington, Virginia

Ellen J. O'Flaherty
Institute of Environmental Health
Ketterlng Laboratory
University of Cincinnati
Cincinnati, Ohio

Magnus Plscator
Karollnska Institute
Stockholm, Sweden

Marvin A. Schnelderman
Clement Associates
Arlington, Virginia

Ellen K. Sllbergeld
Environmental Defense Fund
Washington, DC

James R. WUhey
Food Directorate
Bureau of Chemical Safety
Ottawa, Canada

Ronald E. Wyzga
Electric Power Research Institute
Palo Alto, California
OTHER GOVERNMENT SCIENTISTS AND
  PARTICIPANTS

Irwln Baumel
U.S. EPA
Washington, DC

Judith Bellln
U.S. EPA
Washington, DC

Josephine Brecher
U.S. EPA
Washington, DC
Steven BrodeMus
U.S. EPA
Duluth, Minnesota

Robert Bruce
Procter & Gamble Company
Cincinnati, Ohio

C1pr1ano Cueto
Dynamac Corporation
Rockvllle, Maryland

Margaret Chu
U.S. EPA
Washington, DC

Chris Dlppel
Dynamac Corporation
Rockvllle, Maryland

Alan M. Ehrllch
U.S. EPA
Washington, DC

Len1 Field
Procter & Gamble Company
Cincinnati, Ohio

Gregory Kew
U.S. EPA
Washington, DC

Arnold Kuzmack
U.S. EPA
Washington, DC

William Lappenbusch
U.S. EPA
Washington, DC

Robert McGaughy
U.S. EPA
Washington, DC

Susan Moskowltz
U.S. EPA
Washington, DC

Edward Ohanlan
U.S. EPA
Washington, DC
                                     1x

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OTHER GOVERNMENT SCIENTISTS AND
  PARTICIPANTS (cont.)
Jean C. Parker
U.S. EPA
Washington, DC

Orvllle E. Paynter
U.S. EPA
Washington, DC

David J. Relsman
U.S. EPA
Cincinnati, Ohio

Rosemarle Russo
U.S. EPA
Duluth, Minnesota

Paul Seybold
Wright State University
Dayton, Ohio

Maryrose K. Smith
U.S. EPA
Cincinnati, Ohio
Janet Springer
U.S. EPA
Washington, DC

Glenn W. Suter, II
Oak Ridge National Laboratory
Oak Ridge, Tennessee

William W. Sutton
U.S. EPA
Las Vegas, Nevada

Deborah Taylor
U.S. EPA
Washington, DC

Todd Thorslund
U.S. EPA
Washington, DC
                            DOCUMENT DEVELOPMENT

    The  Initial  draft  was  reviewed  by  the  following  personnel  of  the
Environmental  Criteria  and Assessment  Office:   Jerry  F.  Stara (Director),
Randall  J.F.   Bruins,  Michael   L.  Dourson,  Linda  S.  Erdrelch, Richard  C.
Hertzberg and William Pepelko.

    The  ECAO  Technical Support Staff  Included  Judith  Olsen,  Erma Durden,
Bette Zwayer, Patricia Daunt and Karen Mann.

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                               1.  INTRODUCTION
                 MEETING OBJECTIVES AND STRUCTURE (J. Stara)

    The  U.S.  EPA's  Environmental  Criteria and  Assessment Office  (ECAO)  1n
Cincinnati  sponsored  three  major  workshops  that  brought together  expert
scientists  to  review and  discuss  guidelines for  health risk  assessment  of
chemical mixtures.   The  purpose of  these  meetings was  to  revise  and  add  to
the  previously  published  health  assessment guidelines  (Federal  Register,
1980) for assessing  the chronic  (or  lifetime) health risk of  single contami-
nants so that  the more complex  questions associated with exposures to chemi-
cal mixtures could be addressed.

    The  Agency's  Interest  1n the development of  risk  assessment methodology
for multiple chemicals stems from recognition of  the  nature  of actual expo-
sures.  The Agency has already  regulated public  exposure to several mixtures
Including coke-oven  emissions  and  auto  and dlesel  exhaust.   Now,  with  the
Implementation of Superfund, the Agency must  develop methods  for determining
the  risks  posed  by  what may be thousands  of  unregulated  sites In order  to
prioritize and direct cleanup efforts.  In  addition, the Agency must respond
to  Imminent  hazards  posed by  chemical spills,  and, toward that  goal,  ECAO
has developed  a  rapid  response  assessment  system.   Toxldty data  are stored
1n  a  computer  and used to make  an  assessment  within 48  hours  that can  then
be  provided  to state or  regional officials.  Mult1chem1cal assessments  also
have a  role  1n enforcement,  I.e.,  determining the  reduction  1n risk after a
site's cleanup.  More  broadly,  all  Agency  program  offices  realize that  they
are dealing with mixtures,  not only single  pollutants.
1871A                                -1-                             04/11/84

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    The primary  objective  of this meeting,  therefore,  was the  Injection  of
scientific  stimulus  Into  the  development  of  the  mult1chem1cal  assessment
methodologies.   To provide  structure  to  this  stimulus,  this  meeting  was
divided Into three sessions.

    In  Session  I, specific  selected methodologlc  approaches were  proposed
for those  subjects that had  been  discussed at length  1n previous meetings.
Discussion  was  focused  on  whether  or  not  the approach was acceptable  as
stated.   If  not,  an  attempt  was  made  to  amend  the  approach  to  achieve
consensus  or  to clearly  Identify  remaining problems or  disagreements.   The
following  topics  were presented  for  consensus:  Interspedes  conversion of
dose  and  duration of  exposure;   calculation of  risk   for  partial-lifetime
exposure  to  carcinogens  or   toxicants;   calculation  of  acceptable  dally
Intakes  (ADIs)  based  on  quantal,   continuous,  or  graded  response  data;
pharmacoklnetlc  approaches  that  can be  used  for  conversion  among  various
exposure routes; and methods for multlchemlcal assessment.

    In  Session  II, several new topics were  presented that had not been dis-
cussed  or  were only  touched upon  1n  previous meetings.  One or two  speakers
were  asked  to present  a brief outline of  the Issues, followed by  a period of
discussion.   The goal  of  this  session was  to elicit comments from reviewers
about the  direction   toward  which these  Issues should be  developed.   New
topics  Included the  use of  structure-activity relationships, special methods
for  reproductive  endpolnts,  and  use and biological  justification of mathe-
matical  models.
 1871A                                -2-                              03/21/84

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    Issues Introduced at  previous  meetings,  but  needing further development,
were the  subject  of  four  workgroups 1n Session  III.   Invited scientists and
ECAO staff discussed  the  strengths  and  limitations  of alternative approaches
1n order  to  develop  the  guidelines 1n these  areas.   The objectives  of the
workgroups were  to  eventually develop a  scientifically defensible consensus
reflecting current knowledge  and  to Identify the options  that  could be best
developed  Into  a consensus approach.   The following  topics  were discussed:
methods  to account  for  sensitive  subgroups,  methods  to  assess  effects  of
multlroute exposures,  methods for  ranking the severity of  various  effects,
and the use of exposure data In assessing  health risk.
1871A                                -3-                             03/21/84

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                       2.   CONSENSUS TOPICS (SESSION I)
2.1.   INTERSPECIES CONVERSION OF DOSE  AND DURATION OF EXPOSURE  -  NONCARCI-
       NOGENIC TOXICANTS
2.1.1.   Presentation  (R.  Htrtibtrg,  T.  Clarkson).   The  goal   of   this
session was to choose a method for determining  how  dose-response  Information
from animal studies  could  be  used to estimate  human  dose-response  relation-
ships  for  noncardnogenlc  toxicants.   The  primary  limitation  1s   that  for
most chemicals, Insufficient data on  absorption,  metabolism,  and  elimination
are  available  to accurately  extrapolate  the dose-duration-effect  relation-
ship from  studies  of animals to  humans.   Several methods, or  options,  were
proposed for accomplishing these  1nterspec1es conversions.  To  deal  with the
duration  question,   a  proposed  method  was  to  assume  that  equally  toxic
effects  1n humans  will  result  from exposures  where duration  1s   the  same
fraction of the total lifetime as for  the exposed animals.   This  approach 1s
currently  used  1n   assessing  the  risk  posed   by  carcinogens  and  may  be
applicable to  most  noncardnogenlc  toxicants.   However,  1t  1s probably not
applicable to certain types of effects, certainly not acute effects  and most
likely  not teratogenlc  effects  that  result from exposures during  a  unique
susceptible period.

    To  deal with  the question of equltoxlc dose rates, a  number of conver-
sion methods were proposed:
    1.   Expression  of  dose  as  a  function  of  body  weight,  I.e.,
         mg/kg/day
    2.   Expression of  dose  as  a function of metabolism  or  some surro-
         gate, I.e., mg/cm2 body surface area
1871A                                -4-                             03/21/84

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    3.   Use  of  a mg/kg  brain  weight  per day  conversion  when extrapo-
         lating central nervous system effects
    4.   Use  of  Options  1 or 2 when 1t 1s known  that  the substance 1s
         detoxified  or  activated,  respectively,  1n a  manner  that  1s
         similar  1n the experimental species and humans
    5.   Use  of   Options  1  or  2 depending on  the  best fit  of  either
         relationship  to  the available toxldty data.
    None  of  these  options  1s  an  obvious  choice  as  the  best  conversion
method.   Expression  of dose on  a  straight surface area basis  1s  said to be
more  "protective"  than the  body weight-based conversion,  because  for doses
derived 1n  studies with the jjsual  test  species,  rodents, 1t results 1n lower
equltoxlc doses.   Options 4  and  5  are substance-specific:   Option 4 requires
metabolic data  and Option  5 depends  on  the  shape of  the dose-response curve
derived from  toxldty data.   However,  curve-fitting  requires  both substan-
tial data and the selection of a Justifiable model for the curve-fit.

2.2.2.   Discussion.   Dr.   Clarkson  Initiated  the  discussion  of  duration
conversion  by  stating that  the most frequently  used approach  1s  to  set  a
proportion  between  the fraction of the lifetime  of  the test  species  for  a
given  effect  and  the  fraction of  a human  lifetime  expected to  produce an
effect, but  that  the  approach 1s   not  applicable to  some  types  of effects,
I.e.,  acute or  teratogenlc  effects.   Dr.   Hartung   pointed out   that  the
question  of  the validity  of  the  use  of  proportionality   1s  susceptible to
experimental resolution  and  that  consideration   of  all  three axes  (dose,
duration,  and  response)  should  be  made.   Dr.   Nelson  Indicated   that,  1n
general,  the  dividing line  to  be  considered 1s  between  acute effects  and
delayed effects, and that knowledge  of  the pharmacoklnetlcs of  the substance
1s  needed.   Dr. Clarkson  responded  that  pharmacoklnetlc  data are usually


1871A                                _5-                             03/21/84

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lacking and  concluded  that  there  seemed to  be  general agreement among  the
participants  that  EPA should  continue  to  use  the  lifetime  proportionality
approach limited by  Us  applicability  to only chronic  types  of  effects.   He
stated  that,  at  this  time,  this  approach  1s  a  "best  guess"  that  needs
experimental resolution.

    In  the  discussion  of dose  conversion approaches,  Dr.   Clarkson  stated
that body weight,  which  1s proportional to volume,  1s  the preferred conver-
sion and  that the rationale for  using surface  area (because 1t  Is  an Index
of metabolic  rate) 1s now believed  to be spurious.  Dr.  WHhey  pointed  out
that  the  Important  factor  to  determine 1s  the  "effective dose,"  I.e.,  the
dose at the  physiological  level  that  1s producing  an effect,  and that In his
published  papers  J1m Gillette  has  proposed  a  conversion  approach  using
effective  dose.   Dr.  Schnelderman  pointed out  that a conversion  could  be
related to  liver weight  because  the  liver  1s  the main site of activation and
detoxification;  Dr.  Clarkson supported the use  of  a target  tissue relation-
ship.   Dr.  Hattls  cited work  by Boxenbaum  (1982)  that  demonstrated how many
energy-consuming  functions display Interspecific  relations   that  are  a 0.75
power  of  body  weight  and therefore  the turnover  time of the  average body
constituent  1s
        (body we1ght)V(body weight)0'75 =  (body weight)0'25  (Hattls).
Dr.  Clarkson stated that  elimination  time 1s Important.   He presented data
on the elimination  rates  for  methyl  mercury  1n  a  number  of  species  and
showed that the variation between the rates  was reduced by a body weight  to
 the  one-third adjustment.   Several  speakers  noted  that the  overall  metabo-
 lism of a  substance (whether  1t attains a steady  state 1n  the  blood) would
 Influence  any   conversion  methods   based  on   elimination   rates   (Hartung,

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Nelson, and  Nicholson).   Dr.  Plscator  pointed out  that when  dose 1s  ex-
pressed as parts  per  million  of  diet, conversions may  not  be needed because
food  consumption  1s  proportional  to body  weight.    Difficulties   1n  using
dietary concentration alone  are  that   laboratory  animals  and  humans  have
diets with different  composition  (low water  and fat  vs.  high water and fat,
respectively),  and  that  1n some  studies the  test  material  Influences  food
consumption (Nlsbet).

    A  proposal  for  research  Into  the question was  made  by  Dr. Hartung  who
suggested   using  a  wide range  of  dose-duration-effect  data  from  different
species 1n  an  optimization program to  determine the  best-fitting  exponent.
Dr.  Ensleln  suggested  using  structural  parameters   as  covarlants,  and  Dr.
Crump  proposed  analyzing  the  data with  the  type  of  effect as the common
denominator rather than the chemical.

    In  their  postmeetlng  memoranda,  several  participants  provided sugges-
tions  for  Improving  Interspedes  conversions.   Dr.  Hattls  stated  that  more
sophistication  could  be used  1n  determining  a general  scaling factor  for
cases  1n  which the  application  of  Option   4  (pharmacoklnetlc  approach)  or
Option  5  (goodness-of-f1t   for  toxldty data)  were   limited  by  Insufficient
data.   He  suggested  using  the  current  data  base  or conducting research  to
discern patterns  1n   1) which  kinds  of chemicals   scale   with larger  vs.
smaller body weight  exponents,  and  2) which  kinds   of  chemicals   appear  to
give rise to anomalous human data  (1n which  direction are the data  anomalous
and what 1s the magnitude  of  the  anomaly).   In the  absence of other Informa-
tion,  Dr.  Hattls  advocated a one-fourth  exponent  as opposed to one-third.
1871A                                -7-                             03/21/84

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He also suggested placing  the  Hfespan  scaling for duration conversion  on  a
firmer basis  by making some comparisons  of the  "time x dose-rate  tradeoff"
for a  few  defined toxic endpolnts  for  several species with different  life-
spans.  Dr. Schnelderman suggested  (as did  Drs. Hartung and  Crump)  determin-
ing  the  dose-conversion  factor  on  the  basis  of a single  toxic  effect,
possibly  using  for  an extrapolation  the  factor  for a  "crucial"  or  "key"
toxldty.    In  their postmeetlng  memoranda, other  participants  pointed  out
additional   considerations  1n  Interspedes   conversions.   Dr.   O'Flaherty
stated that  sufficient data were  available for  a more systematic  approach
than  that  used  by EPA  thus far and  raised  two questions:   1)  Should conver-
sions  for  short-term  (nonsteady-state) exposures  be  different  from conver-
sions  for  chronic conditions?  and  2) how  does  one perform conversions  for
compounds  that  are  activated?   Dr.  Nicholson  wrote that the  current under-
standing of 1nterspec1es  dose conversion  for some  endpolnts,  for  example
cancer,  1s Insufficient  for  a general  policy.   He  pointed out  the strong
Influence  of metabolism  on  such conversions and  cited as an example the 1-4
times  higher observed  risk  1n  rats  than  1n  humans for hemanglosarcoma of the
liver  caused  by exposure to vinyl  chloride.   Dr.  WHhey  also  expressed con-
cern  that  some  species have metabolic deficiencies that  alter  the metabolism
of  some  classes  of  compounds  such as  hexabarbHol  and  phenols   or  have
different  detoxification  "priorities";  for example,  rodents use glutathlone
as  the primary  detoxifying substrate while primates  use water  and epoxlde
hydrase before  glutathlone.

2.1.3.   Consensus.   For Interspedes conversion  of  exposure duration,  the
consensus  was  that the  lifetime  proportionality approach should  be used
giving consideration  to the  type  of  effect   being  examined, and  that the


1871A                                -8-                              03/21/84

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 validity  of  this  approach  could  be  determined  by  experimentation.   For
 Interspedes  conversion of  dose,  the participants decided  that the conver-
 sion  should  be  based on mg/body weight to the two-thirds power  when  Insuffi-
 cient  data were available  to determine a more precise factor; they generally
 acknowledged  that  the  Ideal  approach  would  Involve  optimization of  the
 exponent  1n  an equation  relating  dose,  species, effect,  and  body weight
 (chemical-specific)  or  dose,  species,  chemical, and  body  weight   (effect-
 specific).
 2.2.   HEALTH  RISK ASSESSMENT  FOR  LESS THAN  LIFETIME EXPOSURE  - TOXICANTS
       AND CARCINOGENS
2.2.1.   Presentation  - Toxicants  (M.  Dour son).   The  goal  of  this  subses-
slon was  to  choose an  approach  to  estimating  ADIs  for Individual substances
such as 1) exposure  durations  less  than lifetime  when subsequent exposure 1s
assumed  to  be  zero,  and  2)  exposure  duration  of  any  length  after  known
previous exposure.   Two options  were proposed and Illustrated  using  data on
methoxychlor and mlrex.   In  both options,  all  the available data are plotted
on  a  graph  of  dose  vs.  duration.   The dose  1s  expressed on  a  mg/kg  basis
adjusted by  the dose  (mg)  per  surface area conversion  for  species  differ-
ences; the duration  1s the equivalent  fraction of human  llfespan,  I.e..  the
exposure period  of  the study 1n days  divided by  the assumed  or  published
animal Hfespan  times  70 years.  The  results  from the study are assigned  a
code corresponding to  severity (Table 2-1),  which 1s  based on currently used
EPA methodology.   The  data  for   methoxychlor  are presented  1n  Figure  2-1.
The "RP,"  "GR,"  "SP,"  and  "LV"  notations  Indicate effects on  reproduction,
growth, spleen, and  liver,  respectively.  The  size  of the symbol  Indicates
the relative quality of  the  study.   In  Option  1,  these data are divided Into

1871A                                 -9-                            03/21/84

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                                  TABLE  2-1

                 Various  Effect  Levels and Their  Definitions
Effect Level     Symbol
                              Definition
   AEL
   PEL
   NOAEL
o
   NOEL
   NOFEL
o
 A
Adverse-Effect  Level.    That  exposure  level   at
which  there  are  statistically  or  biologically
significant Increases 1n  frequency  or  severity of
adverse  effects  between  the  exposed  population
and Us appropriate control.

Frank-Effect  Level.   That   exposure  level  that
produces  unmistakable   adverse  effects,  such  as
Irreversible  functional  Impairment  or  mortality,
at  a  statistically or  biologically  significant
Increase  1n  frequency  or   severity  between  an
exposed population and  Us appropriate control.

No-Observed-Adverse-Effect  Level.   That  exposure
level  at  which  there  are no  statistically  or
biologically  significant  Increases 1n  frequency
or   severity   of  adverse   effects  between  the
exposed  population and  Us appropriate  control.
Effects are  produced  at this level,  but  they are
not considered to be adverse.

No-Observed-Effect  Level.   That  exposure  level at
which  there  are no statistically  or biologically
significant Increases 1n  frequency or severity of
effects  between  the  exposed  population  and  Us
appropriate control.

No-Observed-Frank-Effect  Level.    That   exposure
level  at  which  there   are no  statistically  or
biologically  significant  Increases  1n  frequency
or  severity of  frank  effects  between  an exposed
population  and  Us appropriate  control.   Experi-
menters  may  or  may  not  have  looked for  other
adverse effects.
 1871A
                     -10-
                                          03/21/84

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CD
                      100,000
                       10,000
           I
      1,000

Equivalent

Human

Dose

(mg/d)
        100
-------
four areas  corresponding to  different durations:   acute,  short-term,  sub-
chronic and chronic  (Figure  2-2).   Highest  no-observed-adverse-effect levels
(NOAELs) are  chosen  1n each category  (Indicated  by arrows 1n  the figures),
and ADIs  are estimated  using  U.S. EPA  methods currently  1n  use  (Stara  et
al., 1981).  ADIs for  subsequent exposures  are  estimated  using  the estimated
length (duration) of the exposure.

    In  Option  2, an  estimate of  the visually  best-fitting,   highest  NOAEL
line  1s  made and  a corresponding  ADI line  1s  drawn.   Figure  2-3 presents
this option as  applied to the methoxychlor data.   ADIs  for future exposures
are determined  using  the  time-weighted  average of  the  previous  and subse-
quent  exposure  levels.   The primary  assumptions  1n developing  these  plots
are that  equivalent  exposure durations for studies  of different species are
adequately  described by  conversion to  fractions  of expected  Hfespans and
that equivalent  doses  for experimental animals and  humans  are  derived using
a dose equivalence based on  surface area.

    The advantage  of the first option Is  that  1t  1s similar  to current U.S.
EPA  procedures  and  1s  consistent  with  the methods used  to  estimate health
advisories  by the Office of Drinking Water.    The  main  disadvantage 1s that
this  option does not estimate ADIs using  previous  exposure Information when
H  1s  known,  a distinct  disadvantage  when  the  previous  exposure  exceeds  the
ADI  for  the  current duration.  Option  2   provides  more  flexibility 1n that
ADIs  can  be  estimated  for  any duration once the  NOAEL  line 1s established,
and  thus  ADIs for .future exposures can  be estimated when  previous  exposures
are known.
 1871A                                -12-                             03/21/84

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 QO
00
 I
                           I
                   100,000
                    10,000
                     1,000
              Equivalent
              Human
              Dose
              Ong/d)
                        10
                                 A
                                 A

ADI
                                ACUTE
                           0.07
  O
ADI
                                                                O
            SHORT TERM
                                                                                CA
                                         ADI
 O
SUBCHRONIC

                                                                                            O
                         CHRONIC
         0.7                     7.0

               Fraction of Lifespan  (Yr)
                               70
o
co
                                                      FIGURE 2-2

                                      Methoxychlor  Oral  Toxlclty Data - Option 1

-------
CO
~J

3»
                   100,000
                   10,000
                    1,000
               Equivalent
               Human
               Dose
               (mg/d)
                                                                NOAEL
                      100,1 —
                       10
                         o
                    o         o
                                                                                                __  ADI
                                                I
                          0.07
         0.7                    7.0

               Fraction of Lifespan (Yr)
70
o
03
CO
                FIGURE 2-3

Methoxychlor Oral  Toxldty Data - Option 2

-------
2.2.2.   Discussion  -  Toxicants.   In   the  discussion,   Dr.   Schnelderman
pointed out  that  neither  option uses all of  the  available data, rather only
the  NOAEL  points  are  used  1n  estimating  the  ADIs.   Dr.  Hertzberg replied
that  these options  use  more data than the  current  approach and allow one to
exercise more  judgment,  although a  statistical method of  drawing  the NOAEL
and ADI lines 1s preferred.

    Several  participants  provided additional comments 1n  their postmeetlng
memoranda.   Dr. Hattls noted that, although both  options  are similar, Option
2 1s  preferable  because  any division or  grouping of  data  leads to  a loss of
Information.    Dr.  Sllbergeld  suggested  that   for  some  toxic  endpolnts,
physiologically similar life stages, such as  pregnancy or  lactation, be used
1n Option 1  to group the  data  rather than just  the duration of exposure as a
fraction of  Hfespan.   Dr. Schnelderman wrote that neither option  considers
the  dose-response  relationships  observed 1n  the  Individual experiments,  and
that  a  weakness  of  the  approach  1s that  the  Identification  of a  NOEL 1s
highly dependent  on  the  sample  size, with  the  smaller sample  sizes leading
to higher NOELs.

2.2.3.   Consensus  -  Toxicants.   In general,  the consensus   was   that  the
approach 1s  acceptable;   neither option  was Identified as  being preferable.
The  main  reservations  were  that the  approach  tended  to  be  subjective  and
that some weighting procedure was needed  1n drawing the ADI lines to account
for the quality of the  data.
1871A                                -15-                            04/11/84

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2.2.4.   Presentation - Carcinogens  (K.  Crump).   The goal of  the  subsesslon
on carcinogens  was  to  Identify  a method  to  estimate human  lifetime  cancer
risk  from exposures  of  any duration  regardless  of age  at  the start  of
exposure.  The method should also be able  to  adjust for  carcinogens known to
act at  specific stages of  the  multistage  process  now being used  by  EPA to
model  cardnogenesls.  Three options were suggested:
    1.   Base  all  lifetime  cancer  risk  estimates  for  durations  less
         than  lifetime  on a  ratio of total  dose based on  exposure  to
         the  total   dose  associated  with  a  g1ve_n  carcinogen  potency
             ) and lifetime cancer level  (e.g., 10~s).
    2.   Use  the  concept  of  the  "Druckrey effect"  (I.e.,  that  lower
         dose rates  are  more effective  than  higher  dose rates  1n pro-
         ducing cancer,  at a  given total  dose)  In  establishing  total
         doses associated  with  different  dose  rates and  durations  for
         estimating  the  lifetime  cancer  risk  for  durations  less than
         lifetime.
    3.   Modify the  currently  used multistage model  to  allow for  esti-
         mates of risk from partial lifetime exposure.
Option  1  1s  currently  used by  EPA but  does  not  account for  the  Druckrey
effect, the  age  of  Initiation  of  exposure, or  the  stage at which  a carcino-
gen may  act.  Option 2 accounts for  the Druckrey effect but  not  the age of
Initiation or  the carcinogen stage.   Option  3 would Incorporate  all three.
A  method  to  Implement  Option  3 was  developed under  a contract with ECAO
(Crump and Howe,  1983).

    In his presentation,  Dr. Crump pointed out that the basis for his proce-
dure  1s  the Arm1tage-Doll  multistage  model of carclnogenesls  as  refined by
Whlttemore and Keller  (1978) and Day and Brown (1980) to account  for noncon-
tlnuous  exposure  and carcinogens  that act  on  different stages.   The primary
difficulties 1n   the  application of his  procedure  are  the selection of  the
number  of stages and the selection  of  the  stage  at   which  the  carcinogen

1871A                               -16-                             03/21/84

-------
acts.   Animal  studies  have  provided  few data  to  Identify  the  number  of
stages  1n cardnogenesls,  and  their  applicability  to human  cancer  1s  1n
question.  Selection  of the  stage  at  which a carcinogen acts may be based on
the  apparent  mechanism,  I.e.,  whether  1t  acts  as  an  Initiator  or  as  a
promoter.

    Or.  Crump  Illustrated  his method using data  from the  NCI bloassay  {NCI,
1978)  of ethylene  dlbromlde (EDB).   The study  Involved  a pattern  of high
mortality and  tumor  Incidence and  an  Interrupted pattern  of  dosing  (Figure
2-4).   Upon  fitting  the model  using  different numbers  of stages and  stages
of  action,  1t appeared  that the  best  fit to  the  data (the  fit giving the
largest  likelihood)  had the  assumption of  six  stages with  the  first  stage
being dose-related.   A comparison  of  the  probability of death from carcinoma
of  the  forestomach (the primary tumor  found)  as predicted  by  the  model and
the  Kaplan-Meier  estimates   found  good  agreement  using   all  of  the  data
(Figure  2-5) and using  the data  excluding tumors  found at  terminal  sacrifice
(Figure  2-6),  because 1t  1s  questionable whether the tumors found  at termi-
nal sacrifice  should  be  used 1n predicting the probability of cancer death.
Table  2-2  Illustrates the effect  of assuming  different stages  to  be dose-
related.  The  effect  on  the  doses  1s slight,  suggesting that  risk  estimates
from constant  dose rates are not  extremely sensitive  to  the stage  that  1s
assumed  to be  dose-related.   Table 2-3 shows  the effect of  a  single  week  of
dosing at either week 1,  14, or 30.  A  dose  given at week  14  must be twice
as large as the dose  given the  first  week to have the same carcinogenic risk
by week 105,  and a  dose given during week 30 must  be about  5 times as  large.
1871A                                -17-                            03/21/84

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         u, 10-1
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          40-
      ui
           151
           5-
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      IO
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     UJ
       J  0
                     High  Dose  Animals
                     Low Dose  Animals
                    10     20     30

                            Weeks
             40    50
                          FIGURE 2-4


                 Male Rats Exposed to EDB by Gavage
1871A
-18-
03/21/84

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                                                         Kaplan-Meier
                                                                             Low  Dose:


                                                                          rmitage - Doll

                                                                         Kaplan- Meier
                                                                                    40
                                       FIGURE  2-5


       Comparison of  Estimates from Arm1tage-Doll Model with Kaplan-Meier  Estimates
                      (assumed six stages;  first stage dose related)
                                                                                             50

-------
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                                                      FIGURE 2-6


                      Comparison  of Estimates from Armltage-Doll Model with Kaplan-Meier Estimates
                                         Excluding Tumors Found at Sacrifice
                (assumed six stages; first stage dose  related; tumors discovered during week 49 omitted)

-------
                                  TABLE 2-2
       Constant Dose Rates Corresponding to Given Levels of Extra Risk
Level of Extra
Model
Probability of death from tumor by
week 49; 6 stages; stage 1 dose
related
Probability of death from tumor by
week 49; 6 stages; stage 3 dose
related
Probability of death from tumor by
week 49; 6 stages; stage 1 dose
related; tumors found during last
week of study omitted
Probability of tumor by week 49;
6 stages; stage 1 dose related
Probability of death from tumor by
week 105; 6 stages; stage 1 dose
related; tumors found during last
week of study disregarded
10'1
3.3
(2.7)
2.5
(2.1)
4.7
(3.8)
0.91
(0.70)
0.048
(0.037)
10~2
0.31
(0.26)
0.24
(0.20)
0.45
(0.36)
0.086
(0.067)
0.0046
(0.0035)
Risk*
10""
0.0031
(0.0026)
0.0024
(0.0020)
0.0045
(0.0036)
0.00086
(0.00066)
4.6 x 10~5
(3.5 x 10~5)
*Max1mum likelihood estimates;  95X lower confidence limits 1n parentheses
1871A
-21-
03/21/84

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                                  TABLE  2-3

    Dose of 1-week Duration that Correspond to Given Levels of Extra R1ska
Beginning
of Exposure
Week 1
Week 14
Week 30

10'1
0.91b
(0.69)
1.8
(1.4)
4.7
(3.7)
Levels of Extra R1skb
10~2
0.087
(0.065)
0.17
(0.13)
0.45
(0.35)

10~«
0.00087
(0.00065)
0.0017
(0.0013)
0.0045
(0.0035)
aExtra probability  of  death  from  cancer by  105  weeks; tumors  found  during
 last week of study disregarded;  6  stages assumed  with stage 1  dose-related.

^Maximum likelihood estimates; 95%  lower confidence limits  1n parentheses.
1871A                                -22-                            03/21/84

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 2.2.5.    Discussion  -  Carcinogens.   Dr.   Kuzmack   suggested   that  for  the
 Crump  approach  to  be  more  practical  1t  should be  simplified,  possibly  by
 reducing  1t  to a table by making a set of  plausible  assumptions  about  likely
 exposure  conditions.   Or. Nlsbet  pointed  out this  1s  feasible because most
 exposed  populations  will  have  both  age  extremes,  and  so Identification  of
 the  carcinogen  as  early  or late  stage-acting may  not  be  critical.   Drs.
 Thorslund  and  Andelman noted that  the  multistage  model  does not fit all the
 sets  of  data  on human cancer,  for  Instance,  leukemia.   Dr.  Crump acknowl-
 edged  that the multistage model 1s most  applicable to solid tumors, and not
 leukemlas, and that  Incorporation  of  pharmacoklnetlc Information would be  an
 Improvement  In his  approach.  Dr.   Nlsbet  pointed  out that 1f  the assumption
 Is  made   that  most  carcinogens  act  at  the first  stage,  then  the  risk for
 promoters  with  late  life exposures  will  be seriously  underestimated.  Dr.
 Nicholson  also noted  a  problem 1n using  animal  data to  develop models for
 estimating human risk 1n  that  animal studies are  not  designed to determine
 the  effect  of  promoters  1n the   same  environment  of  Initiators  1n  which
 humans  live.   He  suggested  that   animal   studies  of  a  suspected  promoter
 should be conducted with concurrent exposure to Initiators.

    Additional  discussion  was  provided by  participants  1n their postmeetlng
memoranda.   Dr.  Hartung believes that the  multistage model for  cancer  Induc-
 tion has  been  accepted without  sufficient  scrutiny  of  Its scientific basis.
Dr. Hattls stated  that he believes the Crump-Howe  approach  1s  preferable to
the other  two  options  because  at least 1t  1s based on  a hypothesized mecha-
nism of action.   Dr.  Andelman  asked  1f the  concentration  (dose)  term 1n the
model  can  be effectively dealt with  when  1t Is not  a  first  order  variable,
I.e.,  concentration  to  the  1.2 power,  which he  felt was  not  an  uncommon
situation.

1871A                                 -23-                            03/21/84

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    Dr.  Schnelderman made  both  general and  specific  comments on  the  Crump-
Howe approach  1n  his memorandum.  In  general,  he noted  that  animal  experi-
ments have thus far  been capable of Identifying  only  two stages {Initiation
and  promotion)  and recommended  that  both EPA  and  NTP should  design  animal
models capable of  distinguishing more  stages and  at  which stage a carcinogen
may  be  acting.   He also  stated  the  Crump-Howe report should  be modified to
show the effects  of  a  "remaining  lifetime"  exposure  resulting from modifying
a dose, rather  than  showing  a  fixed  number  of  years  of exposure.  This would
more closely  follow  the exposure pattern 1n which the U.S.  EPA Is Interest-
ed,  where exposures  are  to  be  reduced.   He  also  suggested  constructing
tables  from  data   on carcinogens  that  appear to act at more  than one stage.
Dr.  Schnelderman  made  some  specific  points  about the  Crump-Howe paper  (see
Appendix  to   this  report) concerning  the expression  of  cumulative  dose 1n
some  tables,  the  100-fold difference  1n week 49 stage 1  dose and week 105 1n
Table 2-2, and  the Importance of clarifying  reasons for nonllnearHy.

2.2.6.    Consensus - Carcinogens.   Dr.  Crump's  approach was  considered to
be  acceptable 1n  principle with some reservations about  Us applicability to
cancers  for  which the  multistage model  of  cancer  may not apply.   Childhood
 leukemia  was given as  an  example.   For these cancers, 1t was  suggested  that
an  ad hoc model be developed based on  the available  human data.

 2.3.   ADIs  BASED ON QUANTAL,  CONTINUOUS, OR GRADED  DATA

 2.3.1.    Presentation (M. Dourson, K.  Crump).   The  goal  of  this  session was
 to  choose a method  for estimating ADIs or risk  levels for  toxicants  from
 1871A                                -24-                            04/11/84

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quantal or continuous toxldty data.   EPA's  current  methodology for estimat-
ing ADIs  1s  recommended for use  with  graded toxldty data.   Definitions  of
these three classes of  effects data are  as  follows:   graded (or ranked) data
are 1n the form of severity of adverse  effects  (e.g., fatty  Infiltration  of
the liver, single  cell  liver necrosis,  liver  necrosis,  liver  flbrosls)  vs.
dose without  reference  to the percentage of animals with  the  given effect.
The data  are  often considered to  be  biologically significant  by  a patholo-
gist,  but cannot always be statistically tested.   Graded data are  frequently
reported  1n  the literature.   Contlnous  data are 1n  the form of an Increase
or decrease 1n  a measured biological parameter  (I.e.,  body  weight) vs.  dose.
The data  may be  expressed  only  as  an overall  average  of the experimental
animals  within  a  dose  group.    Quantal  effects  data are 1n  the form  of
percentage of animals with a specific  endpolnt  (I.e., death) vs. dose.

    Two methods were  proposed  for using quantal or  continuous  toxldty data
for estimating  ADIs.   The  first  option 1s  to  fit  a mathematical  model  to
dose  response  data  and, using  statistical confidence  limits,  extrapolate
downward  to doses  appropriately safe to  humans  (I.e.,  doses corresponding  to
risks of  10~5 or  less).  The advantage  of  this approach 1s  that  1t rewards
good  experimentation 1n  that  experiments   with  larger numbers   of  animals
(larger number  of  quantal or  continuous data  points)  tend  to produce more
narrow  confidence  limits and  consequently higher  values  for   the  lower
confidence limits  of  safe doses.   It  also explicitly  takes Into  account the
shape of  the  dose-response  curve  because a mathematical model  1s  fit  to all
of the dose-response  data.   It provides estimates  of risk corresponding  to
any dose, along  with  associated  confidence  limits,  and   therefore can  be
1871A                                -25-                            04/11/84

-------
conveniently used  1n  rlsk-benefU  analyses.  The  method  does not,  1n  prin-
ciple, rule out thresholds because a model  that  Incorporates  a threshold can
be used for the extrapolation.

    The chief  disadvantage of  an  extrapolation  approach  1s  related to the
selection of  the  models;  different models  that  fit the observed  data  about
equally well  can  yield vastly  different  results when extrapolated  to  doses
corresponding  to  very  small  risks.   When used 1n estimating  carcinogenic
risks, Information  on  the nature  of  the carcinogenic process has  been used
1n the selection  of a model.   Most Information  has  Indicated that the  dose-
response  curve  1s  apt  to be nonthreshold and  approximately linear at low
doses whenever a  chemical  Initiates  cancer through a  change  In  the DNA of a
single cell, or whenever  background cardnogenesls 1s  present.  However, for
nongenotoxlc  events,   a   linear  nonthreshold  dose   response   seems   more
unlikely.   Although a  linear model  still  would define upper bounds  to low
dose  risks,  these  upper  bounds might  overestimate the  true risk  by   large
amounts  1n  some  Instances.   Thus, the uncertainty as to  the true  shape of
the  dose-response curve 1n the  low  dose range  for  nongenotoxlc effects and
the  fact  that  different models  can give  vastly  different  results constitute
a  disadvantage  to the  model  extrapolation approach for nongenotoxlc effects.
A  second disadvantage  to the  extrapolation  approach 1s  that  toxlcologlcal
experiments are frequently not  designed  or  reported 1n a manner that facili-
tates  the use of  model-fitting methods.  Frequently,  the  doses  are selected
too  far  apart to  adequately  describe the dose-response  curve;  sometimes the
response  data  necessary for   fitting a model  are not  reported.  However, the
experimental  design and  reporting of  data 1n  future toxlcologlcal experi-
ments  could be  Improved 1f a  model-fitting  approach were adopted.


1871A                                -26-                           03/21/84

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    The  second  option 1s  to  fit  a mathematical  model  to dose-response data
and,  using  statistical  confidence  limits,  calculate a lower confidence limit
for  the  dose  corresponding to a  preset  risk of  10"1  or  10~2;  then apply
a  safety or uncertainty  factor to this  dose that reflects  the  severity of
the  toxic effect,  the thoroughness of  the  toxlcologlcal  study,  and possibly
the mechanism of action.   This  approach combines  features of the current EPA
methodology and Option  1.   It  shares  some of their advantages while avoiding
some  of  their  disadvantages.   Like Option  1,  but unlike  EPA methodology, 1t
takes  the   shape  of  the  dose-response  curve explicitly  Into account.   It
would  reward  good  experimentation 1n  that larger,  better  designed experi-
ments  should yield  higher  levels  at  the  lower  confidence limits  and thereby
higher allowable human  exposures.   Also, 1t would  reduce  the problem of the
selection of  the  mathematical model  because the  estimates  from  the various
models diverge  less  If  extrapolated  only  down  to a  risk of 10"1  or 10~2.
The  disadvantages  of  this  approach  are that selection  of a safety  factor
could  be considered  arbitrary  and,  like Option  1,  Its  experimental  design
and reporting are often Inadequate.

    Dr. Crump presented a  summary  of  work  he has  done on  refining the Option
2  approach.   He pointed  out  that  the  traditional  method of determining  a
NOAEL  to which  safety  factors  were applied  to estimate  an ADI  has several
limitations:  1} a NOAEL 1s an  experimental  dose  that results  from the study
design and  does  not  reflect   the  entire  dose-response   relationship;  2)  a
smaller sample size,  I.e.,  a  less  reliable  experiment, makes  1t  more  likely
to  find  a  NOAEL;  3) Identifying  a   NOAEL  1s   difficult,  especially  with
continuous   data;  and 4) some  studies  are  adequately conducted  but do  not
have a NOEL and therefore are not  used.   In his approach,  Dr.  Crump proposed


1871A                                -27-                            03/21/84

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applying  one  or  more models  to experimentally  derived dose-response  data
(either quantal  or  continuous)  to Identify  a "benchmark" dose.   The  bench-
mark was defined as a  lower  statistical  confidence  limit for the dose corre-
sponding  to  a  specified  Increase 1n  the  level  of  health  effects  over  the
background level.   To Illustrate this approach,  four models  (quantal  linear
regression, quantal polynomial  regression,  quantal  Welbull,  and log-normal)
were applied  to five sets of  quantal data (Table 2-4).  The  results  (Table
2-5) Indicated  good fits  (p-value close  to 1) for  the models with the excep-
tion of  quantal  Welbull  and log-normal  as  applied  to the botullnus  toxin
data,  Implying  that  the  mechanism of action  of  the  toxin  Involves a thresh-
old.   When maximum  likelihood  estimates  (MLE)  and   lower confidence  limits
were calculated  for the  different models and  levels  of  risk  for one data set
(Table 2-6),  1t  can be seen  that  these estimates diverge at  the lower levels
of  risk  and  yield  similar  results  at  the higher  levels.   Dr.  Crump  stated
that  he  has  applied  the  approach  to continuous   data  with  satisfactory
results but did  not have  time  to  present them.  As  a summary,  he displayed a
comparison of benchmark  doses and NOELs  for the five  data  sets (Table 2-7)
and  pointed out that  for four sets  the  NOEL  was between the estimated doses
corresponding  to 1%  and 5% extra  risk  and  that,  for  the  fifth  set,  his
procedure  determined a benchmark dose when no NOEL had been Identified.

2.3.2.   Discussion.   Dr.  Hartung commented  that for any approach  to fully
utilize all the data and be applicable  to all types  of responses 1t must be
multidimensional.  As an  example  of  data for which  the proposed approach may
underestimate risk,  he selected  a  continuous response, such  as a change 1n
blood  pressure,  1n  which  a  small  proportion of the  population responded at a
low  dose   of  a  chemical  with  severe effects.   Other participants also were


1871A                                 -28-                            03/21/84

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                                  TABLE 2-4

    Quantal Data Used to Illustrate Quantitative Dose Response Methodology




Ethylenethlourea (ETU) (Khera. 1973)

                          	Fetal Anomalies 1n Rats
Doses (mg/kg):           0        5        10       20       40         80
No. affected/total no.:  0/167    0/132    1/138    14/81    142/178    24/24


2.3.7.8-Tetrach1orod1benzo-p-d1ox1n (TCDD) (Khera and Ruddlck. 1973)

                            	Intestinal Anomalies 1n Rat Fetuses
Doses (ug/kg):              0          0.125       0.25       0.5        1.0
No. affected/total no.:     0/24       0/38        1/33       3/31       3/10
2.3.7.8-Tetrachlorod1benzo-p-d1ox1n (TCDD) (Hurray, et al. 1979)

                                    	Rats Dead at Birth
Doses (ug/kg/day):                 0                 0.001             0.01
No. affected/total no.:            22/318            16/224            17/100


Hexachlorobenzene (HCB) (Khera. 1974)

                               	14th R1b Anomaly 1n Rat Fetuses	
Doses (mg/kg):                 0         10        20        40         60
No. affected/total no.:        0/80      4/79      8/91       15/87      25/96


Botullnus toxin - Type A (Food Research Institute.  Univ.  of Wisconsin;
see Food Safety Council. 1978)

                                      Death Due to  Botullnus
Doses (ng):
No. dead/total no.:
Doses (ng):
No. dead/total no.:
0.01
0/30
0.034
11/30
0.015
0/30
0.037
10/30
0.020
0/30
0.040
16/30
0.024
0/30
0.045
26/30
0.027
0/30
0.050
26/30
0.030
4/30


1871A                                -29-                             03/21/84

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                                 TABLE 2-5



           Summary of Fits of Models to Quantal  Data  1n  Table  2-4
Data
ETU



TCDD



TCDD



HCB



Botullnus toxin



*QLR = Quantal linear
Model*
QLR
QPR
QW
LN
QLR
QPR
QW
LN
QLR
QPR
QW
LN
QLR
QPR
QW
LN
QLR
QPR
QW
LN
regression (w1
QPR = Quantal polynomial regression
QW = Quantal Welbul
LN = Log-normal (w1
Ch1-square
17
0.0
1.3
0.46
0.17
0.014
0.32
0.23
0

0
0
0.11
0.09
0.11
0.31
7.0
4.4
162
159
th a threshold)
(with a threshold)
d.f.
3
2
2
2
2
1
3
3




2
1
2
2
8
7
8
8


p-value
0.0007
1.0
0.73
0.93
0.92
0.91
0.85
0.89




0.95
0.76
0.95
0.86
0.54
0.73
0.00001
0.00001


1 (without a threshold)
thout a threshold)
1871A
-30-
03/21/84

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                                  TABLE 2-6
    Doses Corresponding to Given Levels of Extra Risk for Quantal ETU Data
Model Extra Risk
QLR 0.1
QPR
QW
LN
QLR 0.05
QPR
QW
LN
QLR 0.01
QPR
QW
LN
QLR 1 x 10~6
QPR
QW
LN

MLEa
12.2
16.4
17.9
17.1
11.0
13.2
14.5
14.8
10.1
10.2
8.9
11.2
9.9
9.4
5.9-1
4.2
Doses (mg/kq)
95X Lower
11.8
13.9
15.7
15.3
10.6
11.6
12.2
13.0
9.7
7.2
7.0
9.5
9.5
4.0-1
2.9-1
3.1

99% Lower
11.6
13.2
14.7
14.6
10.4
11.0
11.3
12.2
9.5
6.0
6.2
8.8
9.2
1.5-3&
2.1-1
4.7
aMax1mum likelihood estimates
b1.5 x 10"3
1871A
-31-
03/21/84

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                                  TABLE  2-7
          Comparison of  Benchmark Doses  with NOELs  for  Quantal Data
Benchmark Doses*
Corresponding to Extra Risk of
Data Set
ETU
TCDD
TCDD
HCB
Botullnus toxin
Units
mg/kg
ug/kg
ug/kg/day
mg/kg
ng
NOEL
5
0.125
1.0-3
ND
0.027
10%
13.9
0.32
5.3-3
17.4
0.029
5%
11.6
0.22
2.6-3
8.5
0.027
1%
7.2
0.049
5.1-4
1.7
0.025
*95X lower limits derived from QPR model
ND = Not determined
1871A
-32-
03/21/84

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concerned  that the  approach may  Imply the  existence  of  a  threshold below
which no effect would  be expected,  especially considering the wide variation
1n  Individual  thresholds 1n the human  population  (Kuzmack, Nelson, Hattls).
Dr.  Crump  responded that  the models  he  used  Incorporating  thresholds were
found  to  fit some data  sets  the  best, and that his  method was not designed
to  determine a  threshold but a  dose that  corresponds to a  low  level of risk.
Dr.  Sllbergeld and others  (Nlsbet,  O'Flaherty)  felt that more discussion was
needed on  the  application  of the  model to continuous data and on the conver-
sion of one  type  of  data to another, I.e., continuous to quantal.  Or. Stara
suggested  that Dr.  Crump's  complete  paper  be distributed  by ECAO  to  the
participants to provide  the details of the applicability  of  the approach to
quantal and continuous data.

    Some  of  the  participants  provided  written  comments  on   the  proposed
approach  1n  their postmeetlng  memoranda.  Dr.  Schnelderman noted  that  the
benchmark approach (Option  2) has  the  same difficulties  as those of modeling
cardnogenesls  data,   for  example,   how  to choose  a  model  that  accurately
reflects the  data Including the presence  or  absence of  an observed thresh-
old.   Dr.  Sllbergeld  also  cited  difficulties with  the  proposed  benchmark
approach 1n that  the wide  variation  1n the severity of  effects  would compli-
cate the  selection  of  the  safety  factors  that are applied  to  the benchmark
values.   Dr. Nlsbet wrote  that  for  "truly QCG  [quanta!,  continuous,  graded]
data" derivation  of  an ADI  1s  Inappropriate  because such  data  can  often be
fitted  to a nonthreshold model.

    Dr.  Hattls  pointed out  1n  his  memorandum  that  a major problem  1s  that
the steepness of  the dose-response curve depends on  the  genetic diversity of


1871A                                -33-                             03/21/84

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the exposed  population and  therefore animal  data are  likely  to produce  a
steeper curve  than  that expected for  humans  and  lead  to  an  underestimation
of risk.  He also proposed modifying  Option 2  by the  use of different safety
factors  for   different effects  depending  on   the  likely  distribution  of
susceptibility 1n the exposed human population and on  policy  judgments about
the  severity  and   socially  desirable   protective  posture   for  different
effects.  Dr.  O'Flaherty also  suggested  a modification  to  make  the  approach
relatively model  Independent.  When  working with  quantal  data,  she  proposed
the calculation of  a confidence  limit on the  dose corresponding  to  a speci-
fied  low  risk   (I.e.,  10~2)   and   then   the  application  of   appropriate
uncertainty  factors.   She  also  pointed  out that  1n  the  application  of  the
approach  to   quantal  data,  which  vary   from  0  to  1.0,   selection  of  the
uncertainty factors should  take this  variability Into account.

2.3.3.   Consensus.  The consensus of the participants  was  that  Dr. Crump's
benchmark approach was  conceptually acceptable but that no decision  could be
made on how  to go from a benchmark dose  to an ADI, which would be certain to
provide adequate  protection  for all  members  of a human  population.   Addi-
tional consideration of the applicability of  the approach  to continuous data
was also Indicated.

2.4.   PHARNACOKINETIC APPROACH FOR ROUTE-TO-ROUTE CONVERSION

2.4.1.   Presentation  (W.  Pepelko,  J.  WUhey).   Dr.   Pepelko proposed that
consensus  be  sought  1n  three  areas.   First,  that   the  primary routes  of
concern for  human exposure are  Inhalation and  oral and  that data from animal
studies  using  different  routes  be   used when  such  factors as absorption


1871A                                 -34-                            03/21/84

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efficiency, dose frequency, and  hepatic  metabolism are known and  taken  Into
consideration.   Second,  that  extrapolation,  especially from oral  to  Inhala-
tion and vice  versa,  1s  feasible under the following  conditions:   1)  1f  the
portal of  entry  1s  not the target organ, 2) 1f  the  toxicant chemical  1s  not
totally Inactivated  before  reaching  the  target organ, and  3)  1f  elimination
rates  are  sufficiently  slow  that  blood  levels  do  not  fluctuate  greatly
during periodic dosing.  Third,  that  the extrapolation procedure  account  for
any  factor that  affects the  concentration  of  the toxicant  at   the  target
organ and  1s different for  different  routes,  Including absorption efficiency
and  the  degree  of   activation  or deactlvatlon  before  reaching   the  target
organ.  Dr.  Pepelko stated that  the  primary  considerations  are  the  condi-
tions under which the  results  from one route  of  exposure can  be converted to
another and how that conversion 1s to  be  accomplished.

    In his presentation, Dr.  WHhey  reviewed graphical  comparisons  of  the
dose  levels  1n blood achieved by  Inhalation  exposure, 4 oral  doses,  and 20
oral doses 1n  a one-compartment  pharmacoklnetlc  model  1n  which  total  uptakes
for each exposure were equal.   In the first case,  where  a  short  elimination
time  1s assumed  (Figure 2-7), 1t was  evident  that the four oral  doses  lead
to much higher blood  levels, which could greatly affect  the type  or severity
of  the effects  observed.   In  the two  other cases,  1n which  Intermediate
elimination rates (Figure  2-8)  and  very  long elimination rates  (Figure  2-9)
were  assumed,  the blood  levels  for   the  three  administrations were  seen to
converge.   From  these data,  Dr.  WHhey  concluded  that  Increasing  the  fre-
quency of  the  dose  gives  a closer approximation  of oral uptake  to  steady-
state  Inhalation  systemic  levels,  and fast  elimination rates (short t    )
give larger fluctuations about the steady-state level.
1871A                                -35-                            04/11/84

-------
                                            Dose Interval
00
I
CO
                                                                                            Case 1
                                                           TIME (hr)
o
CO

ro


oo
                          FIGURE 2-7


Hypothetical  Blood Concentrations for Three Exposure Conditions:

          Inhalation, 4 Oral Doses, and 20 Oral Doses

-------
CD
I
CO
                                  Dose Interval
I
3>
               30
             §M
             DC
             Z
             Ul
             o
/"\
1 \
1
1
1
m


\
\

f
 !\
l\
                                                                                 Case 2
                                                      Dose
                                                     Interval
            8
            CD
1
) 2
1
4
1
6
1
8
1
10
I
12
14
                                                    TIME (hr)
o
CO
00
                                   FIGURE 2-8


          Hypothetical Blood Concentrations for Intermediate Elimination Rates

-------
                           -8C-
                                     VU81
                       BLOOD CONCENTRATION kg/ml)
DO
o
o.
o
o
                 (Jl
o
=3
I/I
O
3
(O
m
   I
   vO
                 on
TO
Oi
                 <*»
                 o

-------
    In the text  of  his  presentation,  Or. WUhey also  stated:   "It  1s  worth-
while to point out  that, where  a  compound  1s  absorbed  relatively rapidly and
eliminated  slowly,   the  dose   Interval  and  regimen   do  not  Influence  the
systemic concentration or  their temporal relationship,  as  shown 1n case  3.
In such circumstances 1t  1s  the amount  rather  than the  kinetics of systemic
uptake  and  elimination  that would  be  expected  to  Influence   the  systemic
toxldty.   In these cases, provided that the  Inhalation  TLV 1s  soundly based
(I.e., there  1s  little  Involvement of  first  pass  effects,  organohepatlc  or
site  of uptake  effects  are  not the  Index  of toxldty,  etc.) and absorption
coefficients   are known,  there  would  appear  to be  no  reason  why  the  oral
equivalent could not be  calculated using the Stoklnger-Woodward  approach."

    Or.  Wlthey pointed out  that at the  previous meeting,  Or. O'Flaherty had
discussed   an  Important  consideration  1n   route-to-route  conversions:   the
special  case  of  the  deposition of  aerosols  and  partlculates   1n  the  lung.
Deposition varies with particle size but, once  deposition  occurs, uptake (at
least of aerosols)  1s remarkably  similar,  regardless  of particle size.   The
amounts  cleared   from  the  lung are  not  proportional   to  lung  deposition.
These considerations  are Important  1n  the  assessment of  certain   kinds  of
pulmonary  uptake and 1n  addressing special  mechanisms  associated with route.

    Dr.  Wlthey   also  mentioned  the  Importance  of  the  first-pass  effect
because  1t  1s very  much dependent  on  route.   "Substances Injected  Intra-
venously or absorbed via the lung  are carried,  and  distributed,  more or  less
equally  to  the  vessel-rich organs  of  the  body.   Substances  administered
orally pass from the  gastrointestinal   tract  via  the  portal system  and  Into
the  liver.    Thus,  for   substances that  are subject  to  extensive  hepatic


1871A                                -39-                            03/21/84

-------
metabolism, the  effective  dose  reaching the systemic circulation  1s  consid-
erably reduced  (1n  the  case  of  Udocalne, for example, 100% of an  oral  dose
1s metabolized on first pass through the  liver)."   Similarly,  compounds  that
are  activated  by  the  liver  may have  exposure route-specific  patterns  of
toxldty because of the first-pass  effect.

    Dr.  WHhey  reviewed   the  need  for  route-to-route  conversion  methods.
"First, the absence or  lack of adequate studies  for  the  route  of  Interest  1n
humans may necessitate  the use  of  pharmacoklnetlc  principles  for  an  estima-
tion of  toxic  Insult.  This will  Include experiments that have  been poorly
designed or executed,  1n  terms  of  dose,  duration,  numbers, etc.,  or  practi-
cal  considerations  like   low  aqueous   solubility,  which  preclude  toxldty
studies 1n drinking water, the  use  of  an Inappropriate dosing vehicle,  for
example, vegetable  or mineral oil as opposed  to  water,  and animal data where
the  pharmacoklnetlc  rates  and  mechanisms  are  species-,  sex-,  or  strain-
dependent  and  extrapolation  1s  precluded."  Second,  potentially  useful  data
may  be available from  human  or  animal  studies  1n  which  the  route  has  been
Intravenous,   subcutaneous,  Intramuscular, IntrapeHtoneal, etc.   He pointed
out  that  the  data  from such  studies may  be acceptable 1n  every  other sense
and,  1f there  1s   no  reason  to suppose  that metabolic  processes  or  other
factors are affecting the  blood  levels,  the  data should be extrapolated to a
more  conventional   route.   However,  he  noted  that  enormous amounts  of  data
may  be needed  1n order  to  derive a defensible estimate.
 1871A                                 -40-                            04/11/84

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    Dr.   WHhey  also  cited  the  following  as  Information  requirements  for
undertaking the  application of any  route extrapolation methodology:
     1.  Nature of the pharmacoklnetic model.
         (one-, two-, or muIt1compartment,  M1chael1s-Menten)
     2.  Nature of exposure.
         (Dose and dose Interval/duration)
     3.  Absorption efficiency.
     4.  Hybrid rate coefficients for  absorption  and  elimination  and
         their variation with dose.
     5.  First-pass effect (magnitude).
     6.  Are metabolites the active  toxicant?
     7.  Are metabolic pathways the  same?
     8.  Are metabolic rates the same?
     9.  Is systemic concentration proportional to toxic effect?
    10.  Potent1at1on/antagon1sm on  repeated dosing.
    Dr. WHhey pointed out  that  1n  his  three  original  examples where he made
fairly realistic  assumptions  (100% uptake, uptake  the same for  all  routes,
absorption rate  equal  to 10  times  the  elimination rate),  the acceptability
of  route  extrapolation would  be  poor,  questionable,   and  excellent,  respec-
tively (Table 2-8).  Much would  depend,  however,  on the specifics of partic-
ular  exposure patterns,  physlcochemlcal  properties,  etc.   He  stated  that
"route extrapolation  may thus  be reduced from  a generalized  to a case-by-
case  consideration,  particularly where  mechanisms, species  differences, and
other  parameters,  like those considered  above,  are Involved.   It  would,  at
this  stage,  be  unfair and  Inappropriate  to  put  precisely  defined  limits  on
the  application   of   pharmacoklnetic  principles  to  the  question  of  route
extrapolation."

1871A                                -41-                            04/11/84

-------
                                  TABLE 2-8
                    Magnitude of Rate Coefficients (t-|/2)
                  Absorption
                       minutes
                     Elimination
                    (t]/2)  minutes
                    Extrapolation
                       Ability
Case 1
Case 2
Case 3
  0.9
  6.9
144.0
   9.0
  69.0
1440.0
Poor
Questionable
Excellent
 1871A
                 -42-
                         03/21/84

-------
    Dr.  WHhey displayed  the  equation he  uses  to calculate blood  levels  1n
his one-compartment model and  pointed  out  that the critical factor  1s  know-
Ing the absorption  efficiency, which  In turn  requires  a great deal  of  data
to  determine.   He  said,  "It  has been  suggested  that,  where  the  site  of
uptake,  or  portal  of  entry, 1s  the  primary target tissue  (as H  Is  1n  the
case of pulmonary  damage arising from  the Inhalation of manganese  or  chro-
mium),  the  application  of either pharmacoklnetlcs or route  extrapolation  1s
precluded.  In the  case  where  the target  organ 1s  the  same  for  both Inhala-
tion  and   systemic  [gastrointestinal]  uptake,  as  1t   1s   1n  the  case  of
paraquat,  a  special consideration of  the  relative  Insult  arising  from  the
administration of equivalent doses would be a  rewarding  test of  the strength
and  the   value  of  pharmacoklnetlcs  as  a  predictive  tool."   Finally,  Dr.
WHhey pointed  out  that the  choice  of  the  pharmacoklnetlc  model  1s  also
Important;  the  addition  of  compartments  to  the  model  or an  Increase  1n
elimination rate can greatly alter the  blood  profiles.   Another  complicating
factor 1s  that  the pharmacoklnetlcs  may  be  changed  by the test  substance;
for example, the steady  state  blood  levels Increase or  decrease  considerably
1n  the  simple model  when  the elimination rate  1s Increased or  decreased,
respectively, during the administration.

2.4.2.   Discussion.  Dr. Stara  pointed  out  that  the assessment  of exposure
to  partlculates 1s  complicated by the  observation that  Inhaled materials are
often cleared  from the   lungs and  swallowed,  resulting  1n  gastrointestinal
absorption, but that the  Stoklnger-Woodward approach  should  work for Inhaled
solvents.    Dr. WHhey noted that  this  approach  may not  apply to highly vola-
tile solvents  and   that  the Important  factor  1s  the  absorption  efficiency.
1871A                                -43-                            03/21/84

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Or.  Plscator stated that the Stoklnger-Woodward approach  should  be  used  with
caution 1n  determining  ADIs because  H  1s  based  on threshold  limit  values
(TLVs) and  not  directly on  the  data  from which  the TLVs are derived.   Dr.
Stara agreed that  some  values  have limited documentation.  Dr.  Hartung  made
the point  that  although 1t  1s Important  to  know 1f the  substance  1s  having
an effect at the portal of  entry,  these  data are usually not  collected.   Dr.
O'Flaherty noted that Dr. WHhey's analysis  of  the  variation  1n  blood levels
from  different   routes  also Indicated  that  different  levels  result  from
Intermittent dosing of different  frequency within the same route.

2.4.3.   Consensus.   No consensus  was  sought  at   this  point.    Additional
discussion  and  an  attempt  to  achieve  consensus occurred  1n  the workshop on
Multiple Route Exposure, which 1s summarized 1n Section 4.2.

2.5.   MULTIPLE CHEMICAL ASSESSMENT

2.5.1.   Presentation  (R.  Hertzberg,  P. Durkln).   The  goal  of  this session
was  to  choose  an  approach  to  evaluate  health  risks  from exposure  to  a
mixture  of  chemicals  1n the absence of  Information on  their possible Inter-
action.   Two  options  were  presented for discussion.   In the first, the  risk
assessment  1s  based  on  a  single  chemical,  the  marker chemical,  which 1s
believed  to present  the greatest hazard as determined by Us toxldty and by
the  ratio of the actual exposure  to  the current regulatory  criterion value.
When  no criterion  has been  established, the lifetime threshold  concentration
 (the  level considered  acceptable  for  lifetime exposure) or  the  10~s  risk-
specific  concentration 1s  used.   In  this option,  the  assessment 1s a  rough
estimate  of  risk  and  1s  unlikely  to  be overlnterpreted;  however,  only  a
 small  part  of  the  available data 1s actually used  1n the assessment.

 1871A                                -44-                             03/21/84

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    The second  option  and  Us  background was  presented  by Or.  Durkln,  who
stated at  the  outset that  this  approach  1s  a  "default position,"  I.e.,  one
that he  proposes  1n the  absence of  data on how  chemicals Interact  at  low
doses.   He  pointed  out that  there  are  two  general approaches  to  assessing
the effects of  mixtures of  chemicals:  dose addition and  response  addition.
In  dose  addition,  the assumption  1s, 1f  the  dose-response relationship  1s
known for  the  substances, then one can  be treated as a dilution or  concen-
tration of  the  other depending on Its relative potency, which  1s a ratio of
equltoxlc doses.  Figure  2-10 shows  how  the doses of two  chemicals  (y  and
y  )  are  combined  Into a  single expression  utilizing potency.   In response
addition, the  expected response  1s  assumed  to  depend on  the response caused
by  toxicants  1  and  2  alone and on the  degree  of  correlation  of  the toler-
ances  to  the  two  chemicals  within   the  exposed  population.  Hence,  1f  the
animals that are  sensitive  to 1 are  also sensitive to  2  [I.e., the correla-
tion  r  1s  1  and  the  proportion of  the  animals   responding  to 1   alone 1s
greater   than   the  response  to  2   (P.  > PJ],  then  the   response   to  the
combined  exposure  1s  equal   to  the  response  of  1  (Pg = P^  Equation 1,
Figure  2-11).   If  the  correlation 1s  zero,  equation  3  1s  used, and 1f there
1s  a  perfect   negative correlation   of  equltoxlc  doses  of  tolerances,  the
proportion  responding  1s  equal  to   the  sum  of  the  Individual  responses
(Equation 4,  Figure  2-11).   These relationships can be displayed graphically
on an  Isobole  diagram  (Figure  2-12).

     As  an example  of how  the different assumptions of dose  or  response addl-
tlvlty  can  produce  different  expected responses,  Dr. Durkln gave the  example
1n Figure  2-13,  1n  which  the  proportion of the  population responding to  a
mixture  of  equltoxlc doses  of toxicants 1 and  2 ranged from 20-53X.   He  also
 1871A                                -45-                             04/11/84

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                y1 = an  + B log z1
                V2 " a2  + B '°9 *2

                Y = a1 + B log (z1 + pz2)

                p = POTENCY  : RATIO OF EQUITOXIC DOSES
                logp = (a2  - an) + B
                                FIGURE  2-10
                               Dose  Addition
1871A                               -46-                            03/21/84

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            1)  P3 = P1                     IFr = 1 AND?! > P2




            2)  P3 = P2                     IFr = 1 ANDP2 > P,




            3)  P3 = P1  +  P2(1 - P^       IFr = 0




            4)  P3 = P1  +  P2  < 1           IFr = -1
                                 FIGURE  2-11



                              Response Addition
1871A                                 -47-                             03/21/84

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CD
                                                                 DOSE OF TOXICANT A
                                                                      o        p        p
                                                                      8        §        8
                                                             I     .     I     ,     I     j	L
             co
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             c
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CD

fu

Q.
                  V)
                  O
                  cr
                  o

                  (D
                  OJ
                  3
C
ft)
                   TO
                   (0
                   I/)
                   (0
                   Cu
                   r+
                   fu
                        CT>
                        I

                        PO
                                                   RESPONSE ADDITION (r = 1!
                                                           \
                                                             \
                                                              «
                                                               \
                                                                                     \
                                                                                                    k







                                                                                                         \»
                                                                                                                          O
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                                                                   ro
                                                                   O
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-------
              YI = 0.3 + 3 log 19.3




              y2 = 1.2 + 3 log 9.7







                                      EXPECTED RESPONSE




              DOSE ADDITION              53%




              RESPONSE ADDITION         20% (r  = 1)




                                          36% (r  = 0)




                                          40% (r  = -1)
                               FIGURE 2-13



                   Example  of  Dose and Response  Addition
1871A                               -49-                           03/21/84

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pointed  out  that  as  the  expected responses  get  smaller,  the  differences
between the predictions also become less with  the  exception  that,  as long as
equltoxlc  doses  are  used,  a  completely negative  correlation of  responses
will always produce a combined  response  two  times  the  combined response of a
completely positive correlation.

    Dr. Durkln also  reviewed models of  Interactions  he had presented  at an
earlier meeting  (Figure  2-14).   Equation 1  1s a rearrangement of  the  model
for  dose  addition and  does not  show  any Interaction.   In  Equation 2,  the
Interaction of the two chemicals  1s accounted  for  by  the K coefficient  which
1s  a  constant,   p   1s   the  relative   potency,   and   ir1   and  »_  are  the
proportions of  toxicants  1  and  2  1n  the mixture.  Equation 3 was  developed
by Or. Durkln to model  Interactions 1n  which the Interaction may change with
dose  and  therefore   has   two   Interaction   coefficients.   Dr.  Durkln  also
pointed out that  the  use  of these models 1s limited  by the lack  of data to
determine  the  Individual  toxicant's dose-response  relations  and  the Inter-
action of  the toxicants.   He   stated  that  his  survey  of  the  literature on
chronic  effects  found  very little data on Interactions  and  that  this  was
clearly not the approach to use.

    The  approach  recommended by Dr. Durkln  (Option 2)  consists  of separate
procedures  for   noncardnogens  and   carcinogens.    For  noncarclnogens,  a
"hazard  Index"  (HI)   1s  estimated  for  each   chemical  by  the  sum of  the
exposure  levels  (E)  for  each  route  (0 = oral,  I  =  Inhalation,  D = dermal)
weighted  by  the  Inverse of  the respective  lifetime threshold  concentrations
(Th):
                        HI . E0/ThQ + Ej/Thj + ED/ThQ

 1871A                                -50-                            03/21/84

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              1) y  =  a1  + BloglTr.,  + p7T2 ) +  B log z

              2) y  =  a1  + B log [TTI  + pn2  +  K (prr., 7r2)°-5 ]  +  B log z
              3) y  =  a1  + B log [TTI
                     K2 7r2 (p?r1 7r2)°-5]+  B logX
                                    FIGURE  2-14
                               Models for  Interaction
1871A                                   -51-                               03/21/84

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The  total  hazard  Index  (HIT)  1s  estimated  by  the  sum  of the  Individual
chemical Indices and, when greater than one,  1s  considered  to be a cause for
concern:
                    HI,. = HI, + ...  + HI  for n chemicals
For  carcinogens,   the  procedure  1s  a  generalized  additive response  model
assuming a zero correlation of  tolerances,  I.e.,  that  the risks are Indepen-
dent.   For  each chemical,  the  proportion  of  responders  1n a  population  1s
determined by adding the  risks  from  each  route of exposure.  Then, the total
risk for a mixture of n chemicals Is  as follows:
                                      n
                            R T= 1 -  *  (1 - Ri)
                                     1=1
where  R  1s  the  risk by  all  routes  for  1.   The  merits of  this  option for
both  carcinogens  and noncardnogens are  that  all  routes and chemicals con-
tribute  to  the risk estimate and hence more data  are used  than 1n Option 1.
The assumptions of  Independence  of  action and  addltlvHy of effect, however,
probably  oversimplify the  actual  situation.   In addition,  Or.  Durkln noted
that  1t 1s  not certain  that  the types  of Interaction mechanisms observed at
high  doses  are applicable  to  low doses,  and  thus,  much more Information 1s
needed to verify  this approach.

2.5.2.   Discussion.   The primary points  of  discussion were  1)  whether all
effects could be considered equivalent,  since  values of HI  based  on  differ-
ent   effects  are  summed  to   derive  HI   (Sllbergeld,   Lappenbusch),  and
 1871A                                -52-                             04/11/84

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2) whether   subthreshold   effects  of   different   chemicals  are   additive
(Hartung, Plscator).   Dr.  Plscator made  the point  that  1f  sufficient  data
were available to  predict  Interactions,  then enough data would  be  available
to do  a  chem1cal-by-chem1cal  assessment and  a  possibly misleading  total  1s
not needed.   Other  participants noted that,  1n  general terms,  1t  1s  likely
that  the  total  effect  of  a  mult1chem1cal  exposure  will  be   the  sum  of
Individual effects  (Schnelderman)  and that Individuals 1n  a  population  will
display  different   susceptibilities   to  chemicals   (Nelson).   Or.   Andelman
expressed concern that for the  noncardnogens 1n  the additive model,  a total
of 1 or  more  was cause  for concern while lower  values were not and  suggested
that the approach be  used as  a  relative  ranking  of risks.   Dr. Hartung stat-
ed that  the approach should be termed "the best  speculation" at this time.

    In  their  postmeetlng memoranda,  several  participants  expressed  support
for the  add1t1v1ty approach as  the "least  unreasonable" or  "most defensible"
method,  especially  1f H  1s  used to establish  a relative ranking  of  risks
for  a   number   of   sites   (Hattls,   O'Flaherty,   Clarkson,  Durkln).    Drs.
O'Flaherty and  Durkln pointed out  that  this approach  1s  the most  conserva-
tive 1n  that  1t  yields  the  largest estimated risk.   Dr. Schnelderman accept-
ed  the  add1t1v1ty  approach  as  an Interim  solution  and suggested  that  for
cancer  effects  the summation be  limited to cancers  at the  same site  or 1n
tissues  that have  a  similar  embryonic  origin.   Other participants  cited
Inadequacies  of  using an  additive method  Including  Its failure to  account
for possibly  large Interactive effects  (WHhey)  and  multiple tumors  result-
Ing from exposures  to  carcinogens (Blngham, Suter).   Dr.  Hartung  advocated
more research into Interactions  between chemicals  at  low  doses  and  chronic
exposures, and Dr.  Sllbergeld  suggested  that  the  Agency may be better off in
some Instances by basing the assessment on a single chemical, I.e.,  dioxin.

1871A                                 -53-                            03/21/84

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2.5.3.   Consensus.   No  consensus  was  clearly  articulated  on  this  topic,

although a  number of  participants felt  that the  addltlvlty method was  an

adequate Interim approach.   Two recommendations were made to the  Agency:
    1.    Collect more data  on  chemical  Interactions, especially  at  low
         doses and  chronic  exposures,  to  better define  the  addltlvlty
         model.

    2.    Consider that the  application  of  the hazard Index approach  be
         limited only  to chemicals  or  classes  of  chemicals  causing  a
         similar effect.
1871A                                -54-                            03/21/84

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                 3.   PRESENTATION OF NEW TOPICS (Session II)

3.1.   APPROACHES USING STRUCTURE-ACTIVITY RELATIONSHIPS

3.1.1.    Presentation (R.  Bruins,  K.  Ensleln, S.  BrodeMus).   Current  U.S.
EPA methods for  estimating toxicant effect levels 1n humans depend  upon the
availability of  data, however  limited,  on  mammalian  toxldty.   The principle
of analogy, where  untested members of  a chemical class are treated Identi-
cally to tested  members, has also  been  used  but  has  been criticized as over-
simplified.   In  this  session,  the use of  structure-activity  relationships
(SARs) to estimate effect  levels  (I.e.,  NOAELs)  and  endpolnts  (I.e., cancer)
for  untested  chemicals  was  discussed.    Presentations  described  the  use  of
equations  based  on  substructural  fragment descriptors  1n the  prediction  of
various effects  and  the  use  of physlocochemlcal  properties to  predict aquat-
ic  toxldty.   Participants were asked  to  consider  the  potential applicabil-
ity of these  approaches  to the overall  risk  assessment  methodology.  Aspects
of  particular  Importance are  the  amount of   Information needed  to  Implement
such  an  approach, and  the  reliability of the  result  1n  terms  of accuracy
(how well  1t works)  and biological  rationale  (why 1t works).

    Dr.  Ensleln  presented  an overview  of  the development  and  application of
SARs  to  risk  assessment.    He defined  the   approach as  an attempt  through
statistical modeling to  explain or model biological  responses  with  equations
using  parameters that describe known  structures  and their  biologic  activity.
Historically,  SAR  has  been  used to  optimize  desired  characteristics  of
Pharmaceuticals  and  pesticides  or  to elucidate  mechanisms   of  action  of
closely  related chemicals.   Two  general  approaches are  used  1n  SAR.  The


1871A                                 -55-                             04/11/84

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first uses  molecular  orbital calculations  to  precisely describe  the  struc-
ture of the  chemicals;  1n  the second, empirical equations  are  derived using
parameters that generally describe a  substance's chemical  and  physical prop-
erties.   In the second approach,  the usual  equation has the following form:
Biological  response  =  Constant  +   (Coefficient   x  Parameter  )  *  (Coeffi-
cient,, x Parameter-)  ... + (Coefficient  x Parameter )
The  parameters are  octanol/water  partition  coefficients,  electronic  con-
stants,  Indicator  variables,  substructures,  and other  physical  parameters.
Ideally, one would wish  to develop equations  for a  series  of  related chemi-
cals;  however,  few series  have  sufficient data, one  of which Is  the poly-
aromatic hydrocarbons.   Dr.  Ensleln  also cited  some data on  the  performance
of the equations he has  developed  for  Identifying mutagens, carcinogens, and
teratogens (Table  3-1).   He pointed out that  the performance  tests were not
conducted with  Independent  data;  I.e., some or  all  of  the  data were used 1n
the development of the equations.   He  also noted that  the effect of the size
of  the database on  equation  performance  was  tested  for  the   rat  oral  LO
equation;  Increasing  the  database  from  1500  to   2000 chemicals  did  not
Improve  the  equation's performance.   Finally,  Dr. Ensleln reviewed disadvan-
tages  1n the  SAR  approach.   The  toxlcologlcal  activity for  only  60-90% of
compounds  can  be  estimated because  the  remainder have unique  nondescrlbable
structures  or   do  not have  sufficient data  on  the parameters used  1n the
equations.   In  addition,  all  discriminant  analyses  have a gray area In which
no   conclusion  can   be   made  from  the  discriminant  value  (Dr.   Ensleln
arbitrarily  Identifies  values of 0.3-0.7  as  Indeterminate).   Also,  SAR 1s
not  currently  applicable to mixtures and needs more verification to Increase
Us  credibility.

1871A                                -56-                            03/21/84

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                                  TABLE 3-1

                         Performance of SAR  Equations
                       Number of           False         False
loxlc Endpolnt      Compounds Tested     Positive      Negatives     Accuracy
                                            (X)            (X)           (X)


Mutagenldty              472                5             5            90

Cardnogenlcity           334                6             4            90

Teratogenlclty            430                5             7            89
1871A                                -57-                            03/21/84

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    The second  presentation was  made  by  Dr.  Broderlus,  who  discussed  the
development of SAR at the EPA Environmental Research Laboratory  (Ouluth)  and
his  research  Into  the  joint  action  of  multiple  organic  toxicants.   The
Initial SAR  work  Involved  the  calculation  of  bloconcentratlon factors  1n
aquatic animals for a variety of  organic chemicals  from  one  parameter, log P
(the octanol/water partition coefficient).  The  results,  from  -120  compounds
tested 1n  trout,  showed a  linear  relationship  between log P  and  bloconcen-
tratlon;  however,  predictions  made  for  compounds  not used  1n  the  Initial
modeling were accurate only within 1  order  of  magnitude.

    A  second  phase  of  the work  was  to  develop  models  to  predict  acute
toxldty of Industrial compounds  to aquatic organisms  based  primarily on two
parameters,  log P and  water  solubility.   Approximately 200-300  compounds
Including  organic  solvents, ethers,  and  chlorinated  benzenes were  used to
construct  and verify  the  models.   The results were  that  these  compounds
could  be   grouped  Into  three  classes  that   could  be  modeled  with  varying
success.   Compounds  of  low toxldty, which  were also  termed  "nonspecific"
toxicants  because  their  primary  effect was narcosis ("a  reversible state of
arrested activity  of various protoplasmic structures"),  fit  the model well,
showing  good  correlation  between   toxldty   and   log P  and   solubility.
Compounds  of  moderate  toxldty showed  some correlation,  and  highly toxic and
specific  compounds  had  toxldtles  that   showed  little   relationship  to the
modeling parameters.

     Dr.  Broderlus 'also  presented  his  research Into the  joint   action of
multiple  toxicants  1n  aquatic  species,   primarily  the   fathead minnow.   He
stated  he  has  limited  his   study  to  strictly  additive  joint   action as


1871A                                -58-                             03/21/84

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Initially described  by  Bliss  and others.  Using  various  binary combinations
of  ketones,  such  as 2-octanone  and acetophenone,  and  alkyl  alcohols,  he
found  that  these   compounds   displayed   concentration   addition  in  their
effects.    Other  compounds,  such as  2,4-pentanedione, 2-chloroethanol,  and
benzaldehyde, did not show additive effects  when  tested  in  combination with
previously  tested  chemicals,  and  thus   1t  was proposed  they  had  different
modes of  acutely toxic action.

3.1.3.   Discussion.  Dr.  Hartung  noted  that although  SAR  can  be  useful,
some compounds are  not  suitable  for  the  SAR  approach and  cited as an example
the fluoro acids, which  interfere with  intermediate  metabolism.  In general,
he  felt  that SAR  1s not  applicable  to  compounds that  are  similar  to bio-
logically  active  materials,  I.e.,  compounds  that play  a  role  In  cellular
physiology.  Dr. Enslein  responded  that  once a mechanism of  action is known
for a  toxicant,  an  SAR  evaluation can be  developed.   Dr. Stara stated that,
if  a  mechanism of  action were  known,  SAR would  probably  not be  needed to
conduct a risk assessment.

    Three  participants   commented   on   the   presentations   of   Enslein  and
Broderius  in  their  postmeeting memoranda.   Drs.  Durkin and  Sllbergeld noted
that  the  research  presented by  Dr.  Broderius indicated  that  his SAR models
worked best  for  compounds of  low  toxiclty and that  these  compounds  were of
least  interest  for   regulation  and  human risk assessment.   Dr. Schnelderman
1871A                                -59-                            03/21/84

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stated that SAR holds promise and  raised  the  following  questions and sugges-

tions 1n regard to the Ensleln SAR approach:


    1.   In the discriminant  equation,  what  parameters contribute  most
         to  separating   materials   later   labeled  as  carcinogens  from
         those labeled  noncardnogens?   Are  these parameters  different
         for different classes of chemicals?  If so,  how  are  classes of
         chemicals defined,  or determined  1n  advance?

    2.   What kind of  self-learning process  1s  built Into the  Ensleln
         procedure?   How have  the parameters  changed  with  additional
         data?  How are  missing data handled?

    3.   If comparisons   of  Ensleln  equations with other  SAR  approaches
         and  with such  testing  procedures  as  short-term mutagenesls
         tests were made, these comparisons would  {or should)  Include a
         proposal   for   stepwlse   testing  (evaluation)  of   potential
         carcinogens.   Can  the Ensleln  process  be  set  up with  cutoff
         points to Identify  compounds  that we can be sure will  not be
         carcinogens?   Dr.  Schnelderman noted  that, 1f  this could  be
         done, a  great deal  of testing might  be  eliminated.

    4.   Is there  some  way  of  adding  electrophlle  Information  to  the
         existing  Ensleln   equations?   If  done,  does  1t  Improve  the
         discrimination?
3.2.   USE OF REPRODUCTIVE EFFECTS AS ENDPOINTS IN RISK ASSESSMENT



3.2.1.   Presentation (J. Stara,  J.  Hanson).  ECAO  Is  faced with  the  ques-

tion  of  how appropriately  to  use fetotoxlc,  teratogenlc,  and,  In  general,

reproductive effect  data  1n  human  health  risk  assessment.  Although  such

data are limited, they need to be  evaluated  and  considered  1n the estimation

of  potential  hazard.  Much  additional  basic  and applied  research must  be

done  to  provide  a satisfactory data  base  for these  purposes.   Furthermore,

the extrapolation process  using  reproductive effects  1s  complicated  because

of  species  differences   that  may   Include  different  placentae,  placental

transfer  rates,   neonatal  developmental  stages,  and  lengths  of  pregnancy

among others.




1871A                                -60-                             03/21/84

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    Dr.  Hanson  Introduced  her  presentation  by  stating  that,  at  present,
there 1s little experimentally based guidance for  the  use of reproductive or
prenatal toxldty  endpolnts  1n  risk assessment.   In  addition,  she  said  a
wide range  of  endpolnts 1s possible as  a result  of  a single exposure  to  a
teratogen during development.  To  Illustrate her  points,  Dr. Manson present-
ed data  on  two teratogens  that  act through very  different  mechanisms.   The
first,  methyl-N-n1tro-N-n1troguan1d1ne,  1s  a direct-acting  alkylatlng agent
that specifically  kills S-phase,  or  rapidly proliferating  cells  and,  as  a
result, Induces 11mb malformation.  Her  research  found  that  this  agent has  a
very narrow range  of   doses  that  will  produce  a doubling or  tripling  of
effect  and  hence manifests  a  sharp  demarcation  between  doses causing malfor-
mation  and  those  causing  fetal  death.   In  addition,  the unique  pattern  of
11mb deformation  caused by the  chemical was  found to  be  a  consequence  of
slightly different  rates  of cell  proliferation  1n the limbs  of one side of
the  fetus and  that there  was  a  very small "window" (~3  hours)  during which
exposure would  cause  the   pattern  of  11mb  malformation.   Furthermore,  the
distribution of the compound 1n  the  fetus  had  relatively little  to do  with
the  ultimate malformation  or  Initial cellular toxldty.   Dr. Manson conclud-
ed that  for this  type  of direct-acting  chemical,  which  1s typical of almost
all  research drugs  that have  been  studied  1n  teratology, the final pattern
of malformation depends  more  on  the specific location  of susceptible sites,
I.e., the sites of the cellular replication,  than on the chemical Itself.

    The  second  teratogen  presented as an  example was  nltrofen, a herbicide
that has  little  toxldty  1n  the  adult  animal.    Dr. Hanson's  research found
that,  unlike  methyl-N-n1tro-N-n1troguan1d1ne,   nltrofen  has  a unique mecha-
nism of  action  1n  that  H acts  as a  thyroid  hormone analog.   In addition,


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she  pointed  out  that  although  the kidneys  of the  exposed offspring  were
grossly malformed,  kidney function was  normal  up to  100 days of  age,  thus
raising the  question of  how to choose  an endpolnt  1n  risk assessment  for
teratogens.   Her conclusion  was  that  1t  1s unlikely  that  a general approach
to the  assessment  of risk  for  teratogens could  be  developed and  that  each
compound should  be assessed  Individually.   In  addition,  she said  her  work
Indicated   the   Importance of  performing  thorough qualitative  studies  and
Identifying  an  appropriate  toxic  endpolnt   before  attempting  quantitative
extrapolation to humans.

3.2.2.   Discussion.  Dr.  Manson  began  the   discussion  by  stating  that  1n
her  opinion  teratogens  are  a very  rare  type  of  toxicant.  Dr.  Sllbergeld
suggested  that 1t was possible that more  chemicals may be considered terato-
gens  1f one  studied  subtle detrimental effects  on  the central nervous system
(CNS) resulting from prenatal exposure.   Dr.  Manson  said that there  Is prob-
ably  no chemical that acts only  on the CNS.   Dr.  Legator proposed that 1t 1s
possible  that  the  wide   divergence  1n gross  morphologic  effects  resulting
from teratogens  1n  different  species may  actually  stem from a common mode of
action  that  occurs  1n  the  very  early  stages  of development.    Dr. Nelson
agreed  with  this suggestion  and asked Dr.  Manson what  teratogenlc effects
may  occur at very low exposure  levels.   She  said that  there 1s  no easy way
to Identify such effects.

     Dr. Calabrese  raised  the question of using  rodents  for test  species,
since studies  have  Indicated  that  they are more sensitive to teratogens than
are  humans.   Dr. Clarkson  stated  that for  methyl mercury,  humans  were the
most   sensitive.   Dr. Calabrese  said  the  difference  between methyl mercury


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and  other  teratogens  may be  due  to  difference  1n  b1oact1vat1on and  then
asked  Or.  Hanson 1f  teratogens,  1n general,  had thresholds below which  no
effect  occurred.   She  replied  that  there  were  Insufficient  data  for  a
conclusion but  that 1t was  her  belief that  teratogens  had  thresholds.   Or.
WUhey noted  that his  studies  of the  pharmacoklnetlcs  of  teratogens  led him
to  question  the term  "dose" 1n  teratology  because he  had  found  that  some
I1p1d-soluble compounds,  which  one would suspect  would cross  the  placenta
easily, did  not.  Dr.  Hartung  also noted that  the exposure  patterns  used 1n
teratology studies  rarely duplicate human exposure.

    In their  postmeetlng memoranda, Drs.  Schnelderman  and  Sllbergeld  noted
the  need  for the consideration  of a  broader  range of  effects  than  terato-
genldty  1n  the development of  a  policy  1n this much-neglected  area.   Or.
Sllbergeld cited fetotoxlns  and  gonadal  toxins  as candidates for regulation,
and  Dr.  Schnelderman  mentioned  pregnancy wastage  and reduced  fertility  as
possible endpolnts.   He  also cited three  steps that  are  currently  possible
1n the development  of a policy:

    1.   Establishment of a minimum number of endpolnts to be studied.
    2.   Creation of a database on spontaneous abortions 1n humans.
    3.   Promotion   of  studies  of  effects  of  some  toxicants   on  germ
         cells 1n whole animals.

3.3.   USE AND BIOLOGICAL JUSTIFICATION OF MATHEMATICAL MODELS

3.3.1.   Presentation  (R.  Hertzberg,  E. O'Flaherty).  Several  models  and
calculation  schemes  have  been  adopted  or   proposed  for  use  1n  predictive
health  risk   assessment.   Among  these  are  add1t1v1ty of  risk  and  dose,

1871A                                -63-                            03/21/84

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species conversion by dose  per  body weight, time-weighted averaging  for  any
dose  rate,   and  route   equivalence  using  the  Stoklnger-Woodward  formula.
These  calculation  methods  must  be evaluated  for possible  errors based  on
known biological mechanisms, behavior,  or numerical  methods.

    In  his   presentation,   Dr.  Hertzberg  discussed   the  general  principles
underlying the  development  of a mathematical  model  of a  biological  process
and  pointed  out  that  most models  used 1n  toxlcologlc  risk  assessment  may
benefit from a  reexamlnatlon  of  their  assumptions and validity.   He  divided
the model building process  Into  three  steps:   1)  development of a mathemati-
cal  and  theoretical  description  of a  given  biological  system  or  process,
2) calibration  of the  model  with a  broad range  of  applicable data,  and
3) verification and  validation  of the  model with a second  set  of data.   He
also stated  that  1t  1s  Important  to  carry  through the model's assumptions to
the  final  calculation   to  prevent  overlnterpretatlon of  the model's  predic-
tions.  As an example of  this process,  Dr.  Hertzberg proposed a simple model
to  justify  the surface  area  approach  to  Interspedes dose conversion.   He
outlined  three  assumptions:  the  dose at  the target tissue  determines  the
toxic  effects;  the  function and anatomy of organs  are similar for mammalian
species;  and,   1n  this  case,  metabolism detoxifies  the  toxicant.   He also
discussed  the   Implications of  these assumptions for  the final  form of  the
model.   As  a second example,  Dr.  Hertzberg described an approach for esti-
mating  a  cleanup  level  based on known  prior  exposures.   He pointed out that
the  Initial  curve  used by the  ECAO,   an  ADI  line  based on  the  results of
laboratory  experiments   utilizing  continuous  exposures,  does  not represent
the  exposure pattern of  humans  1n which exposures  decrease after a site Is
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cleaned up.  Hence, the question  1s whether  the  total  human exposure consti-
tutes an acceptable level:  how can one  choose a post-cleanup level that, 1n
light of previous  exposures,  will be  safe?  One  approach  1s  to require that
the time-weighted average for any  time after cleanup  be acceptable, that Is,
assure that the average human exposure duplicates the laboratory situation.


    Dr. O'Flaherty focused her talk on one aspect of  route-to-route extrapo-
lation, first-pass effects.   The text  of  her  talk follows.
    "The  purpose  of  this  presentation was  to Illustrate  several  Important
features of first-pass metabolism  that must  be taken  Into account by pharma-
coklnetlc or  tox1cok1net1c  models.  These features have  direct  relevance to
Issues surrounding route-to-route extrapolation.

    "The  first  point  made was  that  the  lung should not  be  too  readily dis-
missed as a metabolizing  organ.  Although 1t  1s  true  that the total metabo-
lizing capacity of  the lung 1s much  less  than that of the  liver,  there are
circumstances  under which metabolism 1n  the lung may  be  a significant frac-
tion of  total  metabolism.  An  example  1s  shown 1n the Table 3-2 taken from a
paper  by Roth  and  Wlersma   (1979).   It  shows  the  predicted clearance  of
benzo(a)pyrene  (BP)  In the  lung and  liver of  control  ("basal")  rats  and of
rats  pretreated  with  3-methylcholanthrene  [3-MC]  to  Induce  BP  metabolism.
The predictions were  made by  Incorporating experimentally measured metabolic
capacities and physiologically  reasonable  blood flow  rates Into  a simple and
generally accepted model of  organ clearance.

    "It  1s apparent  from  the  table that although pulmonary  metabolism of BP
1n  non-pretreated  rats 1s only 0.4 percent  of  hepatic  metabolism,  1n 3-MC
treated  rats   the  predicted  BP metabolizing  activity   of  the  lung   1s  60
percent  that  of the  liver.   The reason 1s  not differential  Induction, since
metabolizing  capacity was Induced  to  the  same extent 1n both  organs.  The
explanation for the  Increased  relative Importance of  the lung 1n metabolism
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                                  TABLE  3-2



                Predicted Clearance of Benzo(a)pyrene In Rats*
Predicted Clearance (mi/minutes)
Organ
Lungs
Liver
Lungs/liver
Blood Flow
(ml/minutes)
44.8
11.2
4.0
Basal
0.027
6.08
0.004
3-MC Induced
6.64
11.0
0.60
*Source:  Roth and Wlersma, 1979
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of BP  1n 3-MC  treated  rats 1s  that  liver  metabolism has  become  perfuslon-
rate-Hmlted  while   lung  metabolism  remains  capacity-limited,  so that  the
full  effect of Induction 1s observable 1n the lung but not the liver.

    "This distinction between  perfus1on-!1m1ted  and  capacity-limited  metabo-
lism 1s  fundamental  to  an  understanding  of  first-pass  metabolism.   The total
metabolic capacity  of  an organ  1s  related  to a  useful  parameter, Intrinsic
clearance  or  CL, ., which  1s expressed  1n  units  of ml/m1n  and, thus,  1s
the  counterpart  of organ  perfuslon  rate,  0-   The  first-pass  metabolic
behavior of a  compound  presented to the liver  1s  determined  by the relative
magnitudes  of  Cl. . .   and  Q.  where  the subscript  L designates  the  liver.
Either  perfuslon  rate   Q    or   Intrinsic  clearance  CL       can  be  rate-
                          L                              I n 191_
limiting.

    "If  CL       1s  much  less than  Q ,  metabolism  1s  rate-limiting  at  all
           I M L f L                       L
or nearly all  doses.   Saturation of hepatic metabolizing enzymes  will occur
at low  doses.   First-pass  metabolism will  be Insignificant,  and  dose  depen-
dence of first-pass metabolism undetectable.  But  because of  the  small value
of  CL.  . . ,  systemic   half-life  t,/2  will  be  dose  dependent.   Dlphenyl-
hydantoln 1s an  example of  a  compound  1n this class.   It 1s at least  98 per-
cent bloavallable at all  doses (Jusko et al.,  1976).   However, Its systemic
t,/? 1s dose dependent  even at doses within  the therapeutic  range.

    "Induction  of  metabolism  of  compounds   for  which Cl       1s  much  less
than  0,  will  shorten   the  systemic  t     but  have  an  Insignificant  effect
on b1oava1labH1ty.

    "If  CL       1s  much  greater   than  Q ,  perfuslon  1s   rate-limiting.
B1oava1lab1l1ty  from an  oral  dose will be  low,  and  1n  fact may be 0  at  low
doses.   But  because  virtually all  of  an 1ntest1nally absorbed  dose  reaches
the liver  on  the first pass,  the rate of presentation  of  absorbed compound
to liver  enzymes may exceed  the  maximum rate at  which  the compound  can  be
metabolized, even at Intermediate doses  and certainly at high  doses.   Thus,
the magnitude  of the first-pass  effect  will be  both large and  dose  depen-
dent.    On  the other hand,  because  of the  large value of  Cl,  .  .,  systemic
t,._  will  not  be dose  dependent.   Phenacetln  1s one  such  compound.   Its
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b1oava1lab1lHy from a 250-mg dose was zero  1n  six  human  subjects  and from a

1-g dose  was 0-49  percent  1n four  human subjects.   But  Us systemic  t,/2
was 37-74 minutes 1n all subjects, Independent  of dose (Raaflaub and Dubach,

1975).


    "Induction of metabolism  of  compounds for  which  CL      1s much  great-
                                                        1 n t , H
er  than  Q  will  reduce  bloavallabUHy  further but  will  have no effect  on
systemic t   .


    "These examples  represent the extremes.   There  1s a  range of  Interme-

diate  relationships  of  QL   to  CL^nt L  1n   which  both  systemic  t1/2  and
b1oava1lab1!1ty  may  be  affected  by  dose and  by the  animal's  status  with

regard to enzyme Induction.


    "Five consequences of first-pass metabolism were  pointed out.   These are:


    1.   First-pass metabolism alters  the relationship  between  applied
         dose and Internal dose.   Figure 3-1  Illustrates this point.

    2.   First-pass  metabolism  leads  to  the  earlier  appearance   of
         larger  amounts  of metabolite 1n the circulation,  so  that  both
         metabolite peak  height  and  total  exposure  to metabolite  are
         Increased.  Figure 3-2 Illustrates  this point.

    3.   If the  metabolite  1s active, plasma  levels  of  the  parent  asso-
         ciated  with  a given magnitude  of  effect will  be  lower  after
         oral than after Inhalation exposure.

    4.   If  metabolites  are  associated  with  a  spectrum  of  effects
         different from the effects  associated  with  the  parent,  dose
         dependence of  first-pass  metabolism  could  be  responsible  for
         dose dependence  of  the  nature  as well as the  magnitude  of  the
         effect.

    5.   Provided that metabolism  1s  a  major  route of  elimination,  com-
         pounds  for which Cl^t^L  1s large  will  have a  short systemic
         t]/2  and will  undergo* a  large  first-pass  effect.   On  both
         these   counts,  they  are   poor  candidates  for  route-to-route
         extrapolation  procedures.   Compounds  for   which  CL^nj-  L   ^
         small  will have a long systemic  t]/2 and will  undergo  only a
         small  first-pass  effect.   On both these counts,  they are  good
         candidates for route-to-route extrapolation  procedures."
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                 AUC.ng-h/nJ
                 600
                 400'
                 200
                          20     40     60     80     TOO
                               Dose mctoprotol, mg
                                   FIGURE  3-1

    The relationship  between a measure of  Internal dose,  the  area under the
concentration,  time  curve   (AUC),  and either  oral  (•)  or Intravenous (0)
metoprolol dose  1n  five male human subjects.   Note that the metoprolol  1s 0%
bloavallable from low oral  doses

Source: Johnsson et al.,  1975
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                    0   6  12  18 24  30  36  42  48  54  60  66  72
                                  FIGURE  3-2

    Mean  plasma  concentrations  of  nortrlptyllne  (solid
major metabolite,  I0-hydroxynortr1ptyl1ne  (open  symbols),
and Intramuscular (A,A) administration to six patients

Source:  Alvan et al., 1977
                       symbols)  and  Its
                       after oral  (0,i)
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3.3.2.    Discussion.   Several   participants  commented  on  Dr.   Hertzberg's
presentation,  noting  that  the  Initial  assumptions  1n  the dose  conversion
example may  not  be completely  accurate or  comprehensive  (Nelson,  Clarkson).
Dr.  Hartung  said  that  at  a  higher  level  of  sophistication,  the  model
suggests that  organ weight  should  be considered 1n  the  conversion;  however,
Dr.  Sllbergeld  noted  that  the  organ with  the  highest level of  toxicant  1s
not  necessarily  the most  affected  organ.   Dr. WHhey  also commented on this
approach by  pointing  out  that  Gillette  (1976)  has  developed a  procedure  1n
which  the  rate  processes  for each  metabolite are evaluated to  find  the con-
centration of  the  active molecule  at  the  target  site.  Dr. Andelman comment-
ed  on  the  example  for  estimating  ADIs for people  near  sites that  had been
cleaned up  and stated that  1t  1s  Important to know  the  age distribution  of
the  exposed  population  to  determine 1n what way ending  exposures at differ-
ent ages may Influence the estimated ADIs.

     In  her  postmeetlng  memorandum, Dr. Sllbergeld noted  that  the model pre-
sented  by  Dr.  Hertzberg could be  Improved by  the consideration of M1chael1s-
Menten  type  kinetics  and  suggested that  a model  for  procardnogens  (Hoel,
1983)  be reviewed as  a useful  example.   Dr.  Schnelderman noted  the need for
developing  models  of  diseases other  than  cancer.    He  also  wrote  that
response models  as well as  dose  models  need  to be  considered  and  that,  1n
general,  the  effects of  peak  doses  vs.  the   effect  of  cumulative  doses,
population  variability, and tissue-specif1c1ty  problems  (I.e.,  first-pass
effects) need  to  be considered  1n  constructing biologically  based models.
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                         4.  WORKSHOPS (Session III)



    The participants were  assigned  to four workshop groups as  listed below.

The charge  to each  workshop  was to  discuss  the  topic, develop  a  statement

describing the state of  the art, and  recommend a  course of action that could

be taken at this time.



WORKSHOP TOPIC

    Al  Sensitive Subgroups

        Blngham (Chairperson)   Legator                Plscator
        Calabrese              Hanson                 Schnelderman
        Ensleln                Nicholson              Sllbergeld
        Hattls                 Nlsbet

    Bl  Multiple Route  Exposure

        Albert                 Crump                  Nelson (Chairperson)
        Andelman               Durkln                 O'Flaherty
        Clarkson               Hartung                WHhey
        Cornish                Mehlman                Wyzga

    A2  Ranking Severity of Effects

        Albert (Chairperson)   Hartung                Nelson
        Blngham                Hattls                 Nicholson
        Calabrese              Legator                Plscator
        Durkln                 Hanson                 Schnelderman

    B2  Use of Exposure Data 1n Assessing Health Risk

        Andelman               Ensleln                Sllbergeld
        Clarkson               Hehlman (Chairperson)   WUhey
        Cornish                Nlsbet                 Wyzga
        Crump                  O'Flaherty
4.1.   CONSIDERATION  OF  HIGH  RISK  (SENSITIVE)  SUBGROUPS  IN  HEALTH  RISK
       ASSESSHENT

4.1.1.   Presentation  (L.S.  Erdrelch,  D.  Hattls).    The  present  U.S.  EPA

guidelines  for  calculating an ADI  Include a  10-fold uncertainty  factor  to

account for  1ntraspec1es  variability.   This  10-fold  factor has traditionally



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been assumed  to  account  for the "sensitive  Individual."   This  theoretically
encompasses both  1nter1nd1v1dual  variations  of a normal  healthy  adult popu-
lation and  high  risk  subgroups.   Some scientists  believe that  this  factor
will prove  Inadequate  to  protect  high risk  subgroups  1n  the  population who,
because of predisposing factors, will  be more  sensitive to specific chemical
Insults.   Predisposing factors Include but are  not  limited to the following:
developmental  processes,   age,  nutritional   deficiencies,  disease  states,
genetic   conditions,   behavioral   factors,   and  previous   or   concomitant
exposures.  It was the purpose of  this workshop to  consider this problem and
to  evaluate  and  devise methods that would allow  for  better Incorporation of
these  uncertainties  and differences  Into  the risk assessment  process.  Two
topics of discussion  were  presented:  the  first was  an  evaluation  of the
data needed  to assess  the variation  1n a  population's response to toxicants,
and  the   second  was  a rating  scheme that  would,  at  least  qualitatively,
weight risk assessments with regard to consideration of sensitive subgroups.

    The  Initial  discussion was  centered  around  the  data available  for an
assessment  of  the magnitude  of  the  differences  1n  Individual  responses to
toxicants.   Data  from pharmacogenetlc studies  were presented and  their use
1n  such  an assessment  was  discussed.  The  significant  advantages  1n  using
such  data  Include   the  following:   1)  they  are  from  studies  of  humans,
2)  they  describe  the  response   to   xenoblotlcs  that   have  been  given  1n
measured  doses to a  group of  Individuals,  and 3) 1n some  Instances, they are
collected  under   conditions  1n  which  1nter1nd1v1dual  variability  1s con-
trolled  (I.e.,  monozygotlc  twins).   Disadvantages  1n  the use  of  pharmaco-
genetlc  data  are that they  generally show  differences  1n a  pharmacoklnetic
parameter  Instead  of an adverse  effect  and  they are derived primarily from
studies of drugs rather than environmental toxicants.

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    Dr. Erdrelch  pointed  out that there  was  a fairly large body  of  litera-
ture on studies  that measure 1nter1nd1v1dual  differences  1n a wide  variety
of  parameters  ranging  from  lung plutonlum concentrations  to  the  clearance
and  metabolism  of  a number  of drugs.   She   suggested  that collection  and
analysis  of  these  data might  be relevant  for estimating  the variance  1n
response.   A general  consensus  on this  approach  was reached and  additional
sources of  Information were  suggested  (Schnelderman,  Sllbergeld),  such  as
registries of  special  diseases  or  conditions,  the  Pels Research  Institute
longitudinal  study,  special  exposure  groups   (Industrial,  Love Canal),  and
perhaps retirement  populations  (the residents  of  Leisure World).  The  sug-
gestion was also  made that chemical-specific  lists  (cross  Indexed  by effect
and sensitive group) should also be  established.

    The second  topic of  this  workshop considered an  Interim  approach  pro-
posed  by  ECAO to  address  the problem of  sensitive subgroups.   This qualita-
tive approach adjusts the number exposed  to  reflect the proportion  of  high
risk (HR)  Individuals  and  weights  the total hazard  Index by  the  size of the
exposed  population.   The  Interim  approach  also provides  Information  for
comparing hazards among exposed populations.

    The first  steps  of this  procedure would  be  Included  as  a part  of the
toxldty  assessment  (Figure  4-1) which  summarizes the  overall  mult1chem1cal
risk assessment  process.   The rating  scheme  Itself  1s  part  of the Integra-
tion  of  the  toxldty  and  exposure  assessments.   The Initial   steps  for
considering sensitive subgroups are  as follows:

    1.    Identify appropriate HR  groups  for the  chemicals  1n question.
          These subgroups are to  be selected from  the general categories
          1n Table 4-1, but  are  limited  to well-defined  HR groups  of
          relatively high prevalence
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oo
                Monitoring, physical, demo-
                graphic and historical data
  SITE
   OF
 HAZARD
                Identity nf
                Toxlcltv Information
  WORLD
LITERATURE
en
i
                                                     EXPOSURE ASSESSMENT
                                                                                Exposure levels,  durations,
                                                                                and  routes for all chemicals.
                                                                                Size and characteristics of
                                                                                exposed population	
                                                      TOXICITY ASSESSMENT
                                              Goal; For each chemical, estimate the
                                              minimum effective dose for endpolnts of
                                              various severities, or the cancer risk,
                                              for all dose rates, durations and
                                              exposure routes.
                                              Methodology Used;
                                              Equivalence Calculations
                                              •  Interspecles conversion of dose
                                                   and duration
                                              •  Route-to-route conversion
                                              Endpoint Interpretation
                                              •  Special methods for fetotoxlc
                                                   endpolnts
                                              Risk or ADI Calculations
                                              •  Ranking severity of effects
                                              •  ADIs based on quanta1, contin-
                                                   uous or graded data
                                              •  Less-than-lifetime exposure
                                              •  Use and biological justification
                                                   of math models
                                              •  Sensitive subgroups in U.S.
                                                   population
                                              Alternative Methods Where Information
                                                Is Lacking
                                              •  Structure-activity approaches
                                                                                       ADIs or Risk Levels
                                                                                       for single chemicals
                                                                                                                         INTEGRATION
                                                                                                                 Coal;  Report numbers of people ex-
                                                                                                                 posed above ADI, LOAEL, FEL,  etc.
                                                                                                                 (for noncarcinogens) or above a
                                                                                                                 given risk level (for carcinogens)
                                                                                                                 for the chemical mixture. Report
                                                                                                                 "safe" or "low-risk" levels which
                                                                                                                 could serve as remedial goals.
                                                                                                                 Methodology Used (and exposure data
                                                                                                                   regul
                                                                                                                     Mixture assessment (requires
                                                                                                                       data on relative proportions of
                                                                                                                       chemicals In mixture)
                                                                                                                     Multiple route assessment (re-
                                                                                                                       quires data on exposure routes)
                                                                                                                     Sensitive subgroups In exposed
                                                                                                                       population (requires data on
                                                                                                                       exposed population character-
                                                                                                                       istics)
o
\
r\>
v>
CO
                                                                    FIGURE 4-1

           Information  flow and methodology  use  1n  conducting site-specific  mult1chem1cal  health risk  assessment,
      showing use of  each  methodology  component under  development  by ECAO-C1ndnnat1

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                                 TABLE 4-1

                Biological  Factors Predisposing  Individuals  to
                      Hypersuscept1b1l1ty  to Pollutants*
               Factors
                 Rationale
  I   Developmental  Processes
     Examples:   Pre-  and  Neonatal

                Young children

 II   Genetic  Disorders
     Examples:   G-6 PD deficiency
               Sickle-cell  trait

III  Nutritional  Deficiencies
     Examples:   Vitamin C deficiency
                Protein deficiency

 IV  Existing Disease
     Examples:   Heart
                Lung
  V  Behavioral Factors
     Examples:  Smoking
                Alcohol
                Dietary patterns
    Immature    enzyme   detoxification
    systems
    Higher rate of GI absorption
    Hemolysls  1n  presence  of  certain
    chemicals

    Predisposes  toward hemolytlc anemia
    Potentiates effects of pollutants
    Affects metabolism of Insecticides
     Increased  mortality   In   pollution
     episodes  demonstrated 1n  epldemlo-
     loglc  studies

     Existing  conditions are aggravated
     by  respiratory  Irritants
     Increases  exposures  and  therefore
     risk:     Interferes    with   normal
     cleansing  mechanisms  of  lung

     Liver  damage,  synerglsm with  other
     chemicals

     Increases   exposures:    deficiency
     states  Increase  risk
 VI  Previous or concomitant exposures
     Examples:  Occupational exposures
                Drugs
     Increases    exposure   level   and,
     therefore,   risk.    Effects  may  be
     synerglstlc  or  antagonistic  with
     environmental exposures

     Possibility of Interactions
 *Source: Adapted  from Calabrese, 1978
 1871A
-76-
03/21/84

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    2.   Determine  the  prevalence  of  the  HR  groups   1n  the  general
         United  States   population   or   approximate  subgroups  (I.e.,
         racial groups for certain genetic factors).

    3.   Incorporate  this Information  Into  the rating  scheme of  the
         Integrated risk assessment.
    This Interim approach was  not  too  well  received.   Many of the criticisms

leveled  at  1t were  summarized 1n  the  second presentation of  the workshop,

made by Dr. Hattls.  His criticism was grouped Into three areas:


    1.   The  proposed  approach   assumes   a   discontinuous  population
         subgroup  model  of  "hypersuscept1bH1ty";  however much  of  the
         variability  between Individuals 1n  susceptibility  may  appear
         as continuous because of  a  host  of factors  acting as quantita-
         tive  characters,   and   not  based  on   obviously  discernible
         membership of people 1n discrete, countable subgroups.

    2.   The  proposed  approach appears  to  Implicitly  assume  that  the
         average hypersusceptlble  person  1s  only  about  twice  as suscep-
         tible  as  the  average   nonhypersusceptlble  person.   (If  the
         difference was actually  this  small,  1t wouldn't be significant
         amid the other uncertainties of quantitative risk assessment.)

    3.   The proposed restriction  to hypersusceptlble  groups  constitut-
         ing  at  least 1%  of the  population,  while  H  flows naturally
         from the  proposed  calculating method, 1s arbitrary  and  poten-
         tially  seriously  misleading.   Consider, for  example,  a  case
         where there exists  a  0.1% subgroup that  1s  ten thousand times
         as susceptible  to  a toxin  as  the  average Individual.   Quanti-
         fying  the  size  of  the  population  that  1s   very  much  more
         susceptible than average  1s  the  essence  of  a quantitative risk
         assessment  for  a  threshold  character   with  widely   varying
         sensitivity.


    Dr.  Hattls  suggested  that,   Instead  of  the  proposed   approach  that

evaluates sensitive  subpopulatlons  on  a  chem1cal-by-chem1cal  basis,  a better

approach would be  to analyze the  sources  of variation 1n sensitivity, define

acceptable methods for estimating  the  variability contributed by  each source

and then  Incorporate  these estimates  Into  a  stochastic simulation  model  to

compute the overall distribution of  population sensitivity for  the chemical.
1871A                                -77-                            03/21/84

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He proposed three sources  of  variability:


    1.    Exposure 1s effectively more  for  a subgroup because  of  either
         biology or  behavior.

    2.    Parameters  determining normal/abnormal  function are  closer  to
         (or even beyond)  the  boundary of  abnormality for  the subgroup
         (these groups have  less  "reserve  capacity" so  smaller  Insults
         would be required to exceed their  ability to handle Insults).

    3.    There  are  more  parameter  changes  per  unit   of  dose  for  a
         particular  subgroup because  of biological differences  either
         1n  pharmacoklnetlc  parameters  (I.e.,   faster  rate of  absorp-
         tion)  the  fraction of a   chemical  metabolized  by   "safe"  or
         "dangerous" pathways or differences  1n  the quality or quantity
         of receptors.


He further suggested that these three sources could be analyzed as follows:


    1.   Have  a  reasonably  standardized analysis  of  susceptibility for
         the  exposure-related  factors, depending  only on  the  routes of
         anticipated exposure of the target population.

    2.   Do a  series  of  standard analyses  of population variability for
         different  well-characterized  physiological functions  that are
         affected  by  toxic  agents  (I.e.,  oxygen transport  and nerve
         conduction).  For  substances  that affect  unknown  physiological
         parameters,  use  a  "typical"  variability profile   borrowed from
         one  of  the  well-characterized functions for  "best  estimate"
         calculations, and  some more  extreme  assumption of variability
         for  "conservative"  or  "worst  case"  projections.

    3.   To the extent possible,  analyze  pharmacoklnetlc  and receptor-
         related  variability   chemical  by  chemical.    Where  chemical-
         specific data are  not available,   1t  may often be necessary  to
         adopt some  general  rules  based   on  previous  experience with
         specific   chemical  classes   or   chemicals affecting  specific
         receptors.


    The results from  such  an  analysis could  be entered Into the  stochastic

 model  and  used to  estimate the overall  susceptibility of  a population  to

 each   chemical,  with  default   values  being  used  1n  the   absence  of actual

 Information.   The  computer  would  then construct  a  synthetic population  of
 1871A                                -78-                            04/11/84

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whatever size was  desired  and,  according  to  the distribution of susceptibil-
ities  1n  these  three  categories, would  simulate  the size  and  extent  of
susceptibility.

4.1.2.   Discussion.   The  discussion  was  opened  by  Dr.  Blngham  who  asked
the  question,  "Is  1t worth  the  effort  to  get  something  better  than  the
10-fold  factor and,  1f so,  then  how do we  go about 1t?"   One response was
that,  before  a  different  approach  could be  derived,   the  question  of  the
types  of  effects  to be considered Important had  to be addressed  because 1t
might  not  be  necessary to have  a 10-fold factor  for all  effects.   Some may
require  a  100-fold  factor,  others   a  2-fold  factor.    Dr.  Nicholson  then
suggested  that the utility of  a  10-fold  factor could  be  checked  by looking
at  the range  of   problt  slopes  for  dose-response curves  occurring  1n  the
population.

    Dr.  Dourson  then  briefly discussed the  current agency policy,  which 1s
to pick  the "critical" effect  (the adverse effect  which occurs  at  the lowest
dose),  find  the  NOAEL  for 1t,  and  apply a  10-fold  factor.   The  rationale
behind  such  an approach  1s   that  protecting  against  the "critical"  effect
should  protect  against all  adverse   effects.   Unfortunately,   this approach
does  not   take  Into  consideration the  situation   1n  which  the log  problt
slopes  for  different  effects  are  not parallel, such  that  an  effect  with  a
higher  dose has  a  more shallow  slope and results  1n  a lower  ADI  than  that
based  on  the  critical  effect.   This approach  1s  predicated   on  threshold
effects; H may not matter which effect  1s used as long as  the ADI Is below
the  threshold  for   all  adverse  effects.   Dr.  Legator  then  Indicated  that
1871A                                -79-                            03/21/84

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thresholds for  Individuals  have  to be distinguished  from  population thresh-
olds, and the question was  raised  by  Or.  Calabrese  of how super1mpos1t1on of
effects Influences a 10-fold factor.

    Dr.  Nlsbet   pointed  out  some  clear  differences  between  children  and
adults who  are  exposed  to  toxic  chemicals.  Children (under 9)  spend  4-8
times  more  time outdoors;   they breathe  3-5  times more air per  unit of body
weight (bw);  and they take  1n  3-4 times more  food per unit of  bw, 5 times
more  fluid,  and  6  times  more dairy products;  breast-fed  Infants receive
10-20  times more  I1p1d-soluble chemicals.  Also,  because children spend more
time  In   contact  with  the  soil  and  their  skin  1s  more  permeable,  H  1s
estimated that  they receive 5- to 10-fold more exposure  than their parents.
These  differences  are 1n  addition  to those  differences  that might be shown
by pharmacogenetlc  Information.   Dr.  Ensleln also pointed out that  there are
also  several  large  studies  on populations  with  various  disease  states  and
that  these might provide Information as to variability.

     Dr.  Blngham closed the discussion by querying,  "Should EPA come up with
chemical  specific  lists  of high  risk groups?"   Dr.  Nlsbet  suggested  that
these be drawn  up  by groups  of  people  and types of  effects.   The general
consensus was  that the scheme presented  was Inappropriate, and that evalua-
tion of   sensitive  subgroups should  be  part of  an ADI determination  rather
than the calculation  of  the hazard  Index.
 1871A                                -80-                            04/11/84

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4.1.3.   Workshop Statement.   Dr.  Schnelderman  prepared a  statement  on  the

conclusions  reached  by  the  workshop participants.   He grouped  the  conclu-

sions Into the following three areas:


    1.   "One  'safety-factor'  number  (I.e.,  division  by  10 or  100)  1s
         Inadequate to  take  Into account  the  variability  1n  the human
         population.   Safety  factors  developed  for adults  are Inappro-
         priate  for  use with  children.   Action:   Develop needed  data
         relating  to   safety  factors  for  different   segments  of  the
         population.    In  the  Interim use  current  factors,   setting  a
         deadline as  to when they should  be reconsidered.

    2.   "For future changes  1n  safety factors, base  safety  factors  on
         the following data:

         a.   Slope of  the dose-response curves  (the more shallow  the
              slope,  the larger the factor required).

         b.   The specific  toxldty  and  Its severity  (the greater  the
              need  to  protect against  the  toxldty, the larger  the
              safety  factor   needs  to be.   A  lifetime  of Illness  or
              reduced functional ability  1s  usually more  Important than
              a short-term, reversible Incident).

    3.   "For  noncancer  effects,  remain  with   the  ADI concept,  rather
         than  a   'hazard Index.1   While  the public-health consequences
         are greater when  more people become 111  (hazard  Index), 1t  1s
         Individuals who become  111,  and  even a small number  of persons
         are to be protected against serious consequences."


4.2.   ASSESSMENT OF MULTIPLE  ROUTE EXPOSURE
4.2.1.   Presentation  (W.  Pepelko,  R.  Hartung).   Under  certain  conditions

humans  are exposed  to environmental  pollutants  by  more  than one  route of

exposure.  The  three major  portals  of  entry Include the lungs, GI tract, and

skin.   While  1t Is possible  to  be exposed by other  routes  such  as Intrave-

nous  or  Intramuscular  Injection,  the use  of these routes 1s generally limit-

ed  to treatment with  therapeutic  drugs or other  nonenvlronmental  exposures.
 1871A                                -81-                            04/11/84

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Such routes were therefore not emphasized  1n  the  discussion.   The skin has a

much smaller  surface  area  than  the lungs and  1s  generally  less  permeable to

environmental pollutants.   Under  normal conditions  of exposure  to  environ-

mental pollutants,  1n which the concentrations  are  very low, entry through

the  skin  will  add  very  little  to body  burdens.  Thus,  1n  most cases,  H

should be  necessary  to consider  only two  routes  of  exposure,  Inhalation and

IntragastMc.



    The major Issue  to  be resolved was whether  exposures  by more  than one

route  should  be summed, and  1f  so,  how?  It was  proposed  that  summation 1s

not valid  under the following conditions:


    1.   A  significant  amount  of  pollutant   1s  absorbed  by only  one
         route.

    2.   The  pollutant  chemical  1s  completely  removed  or  Inactivated
         before  reaching the target organ  (I.e.,  first-pass  effect for
         liver), except  for one route.

    3.   The  portal  of entry 1s the primary  target  organ.   This brings
         up  two questions  to be  considered.  If  the target  organ  1s
         different  for each route of exposure,  should the  situation  be
         treated as  two different  chemicals with two  separate AOIs?   In
         such cases  will   exposure  by  one  route (at  above threshold
         levels) affect  the  threshold for  exposure by  another  route?


     If none  of  the  conditions  listed above  1s  present,  then 1t 1s proposed

 that  summation  of  the exposures by more than one route can be done.   At  the

 previous meeting, a  mathematical approach  was proposed for  this  summation:
                          dn  =  Vl  *d2r2  *  "•  Vl
 where d   =  total  dose,  d.  =  the  various  exposure  routes,  and  r.  =  the
        n                   1                                          I

 absorption fraction  for  each exposure  route;  d   1s  then compared with  the

 ADI.


 1871A                                -82-                            04/11/84

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    The previous equation 1s simple, straightforward, and easy  to  apply.   It
should be  possible  to apply  this  equation  successfully  1n cases where  the
target tissue 1s  the  same  for  each route of exposure,  where  the elimination
half-time 1s sufficiently long so  that  the route  of  exposure  will  not affect
temporal  target organ  concentration  relationships, and where  the  absorption
coefficient 1s known for  each route of  exposure.

    The more difficult cases and the ones that were  to  be emphasized at this
workshop are those  1n  which  a  straightforward   summation  of  d  r   1s  not
possible.  These Include  the following  examples:
    1.   The  target  organs  are generally  different  for  two  exposure
         routes but not exclusively so.
    2.   Partial removal  of  an absorbed dose occurs  following exposure
         by one route but not another.
    3.   As  a  result  of  short  elimination,  the  half-time  target  organ
         concentrations  fluctuate  during  Intermittent  oral   dosing as
         compared with constant levels  during Inhalation exposure.

Under  these conditions,  can  absorbed   doses  by  different  routes be summed
with any degree of accuracy, and 1f so, how?

    Dr.  Hartung summarized his  presentation 1n  his  postmeetlng memorandum.
The portion  revelant to  this workshop  1s as follows:

    "Multiple-Route  Exposure:   The  evaluation of multiple  route  exposures
was analyzed  as a  special  case of  route:route extrapolation,  and  1n  the case
when  exposures  by different routes  produced different effects  as a special
case  of  mult1chem1cal exposure.   The  simplistic  additive approach  suggested
earlier, and as summarized 1n  the premeetlng  Information,  was considered to
be  Inadequate.

1871A                                -83-                             04/11/84

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    "The  approach  taken to  the problem was  to consider  first  those condi-
tions under which a multlroute  exposure  evaluation  could be made with confi-
dence.   In  order  to  keep  the  problem  tractable,  the  problem  analysis was
considered for  a  single species only.  An  evaluation  with confidence can be
made 1f and only 1f all of the following conditions are met:

    "1.  The dose-duration  of  exposure patterns  are  Identical  for  all
         routes of exposure;
    "2.  The systemic effects are Identical for all routes of exposure;
    "3.  No route-specific effects are found at the portal of entry;
    "4.  There are no first-pass effects; and
    "5.  The  dose-duration   of  exposure-response  surface  1s  known  In
         terms  of  absorbed  dose (or,  the  relationships  between  applied
         dose and absorbed dose are known for each route).

    "Points  1  and 4  are likely  to  become unimportant  1f  the chemical  1s
cleared very slowly from the body.

    "If all of  these  conditions are met,  then  the  total absorbed  dose could
be estimated,  and  subsequently  the  systemic response  1n terms of  absorbed
dose could be evaluated.

    "It was recognized  that  these  preconditions would only  rarely,  1f ever,
be met  for a  specific  compound.   It was  also pointed  out,  that  as  these
various preconditions  are  violated,  then  the  ability  to  predict  the conse-
quences of  exposures  by  various routes  deteriorates  In  ways  that  are not
easily predictable.

    "If  there  were   route-specific   effects,   then  a   simple   summation  of
absorbed  doses  would   probably  be  misleading,  since   Interactions  between

1871A                                -84-                            03/21/84

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effects would  not  be  taken  Into account  appropriately.   Under  such  condi-
tions  (1f  dose/response  relationships  were known  for each  route of  expo-
sure),  the  problem could be  treated  as a  special  case of the  simple  joint
action  add1t1v1ty  model  as  postulated  by  Bliss  (1939).  Such  a model  could
readily be formulated 1n terms of external dose,  rather than absorbed dose.

    "Since exposures by multiple  routes  appear to  be common,  and since dose/
response  Information  1s often  Imperfectly known for  the various  routes  of
exposure, H 1s  tempting  to attempt estimations  of  the effects of multlroute
exposures on the basis  of mixtures  of  chronic  and  acute data or on the basis
of  chronic   data  alone.   Such  estimates  may be  very  unreliable and  mis-
leading."

4.2.2.   Discussion.   Several  participants commented  on  the  limitations  to
the general  approach  outlined by Dr.  Hartung, Including  the  likelihood that
some   chemicals   produce  overlapping   effects   through   different   routes
(Albert),  that  environmental  exposures  are  at  low  doses  and  effects  are
likely  to  be  subtle  (Nelson), and that the largest  database  for preparing
dose-response  curves   1s  for   acute  exposures  (Durkln).   Dr.  Nelson  stated
that,  1n addition  to  the  proposed  approach,  the  risk  assessor  should  be
aware  of  the  limitations In  the data and  proposed  a  four-tier system, with
the  highest tier  corresponding  to  the highest  level of confidence  1n  the
assessment  and the  lowest  tier,  to  the lowest level of confidence.  The four
tiers are as follows:
    1.   All of  the  necessary  Information 1s available, Including dose/
         response/time curves for all three routes.
    2.   Information  1s  available   on  two  routes,  and  the  remaining
         Information  1s  available  through  experimentation to determine
         absorption coefficients, Internal doses, and body burden data.
 1871A                                -85-                            03/21/84

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    3.    Acute data  are available  for  all  three  routes,  and  chronic
         data are available for  one.

    4.    Acute (and chronic) data are available for  only one route.


    As  a practical approach, for a single  situation  one could  Identify which

of Dr.  Hartung's preconditions were met  or were  not  pertinent  and then gauge

the level of  confidence  1n the  assessment (Nelson).  Dr. Albert  pointed  out

that the  assessment  of multiple  exposures 1s  sufficiently complex  that  no

one simplistic approach 1s  adequate, and  recommended  a  case-by-case approach

using the available data.   Dr. Durkln  noted that  specifying a  minimum amount

of data without which an assessment would not  be performed 1s a necessity.



    In  her  postmeetlng  memorandum,  Dr. O'Flaherty noted  that  the character-

istics   of  few  compounds   will  be known  1n  sufficient detail  to meet  Dr.

Hartung's five criteria for an Ideal candidate  and  to allow summation across

routes.  Therefore, she proposed  the following  generalizations  on the extent

to which some compounds may meet  the criteria:


    "1.  Internal  dose-duration   patterns  are  likely  not  to  differ
         significantly across routes  of  exposure 1f  the  chemical  has a
         long  t-|/2-    Concentration  cycling   around  the  mean  steady-
         state blood concentration 1s  damped 1f  the  compound has  a long
         t]/2»  so  *nat  f°r  such  compounds   the   difference  between
         dose-duration  patterns   for   Intermittent-exposure  routes  and
         for  continuous  exposure  routes  1s minimized.   Alternatively,
         even  for  compounds with  short  t^/2»  ^ patterns  of  exposure
         are  roughly comparable  the  Internal  dose-duration  patterns may
         also  be  roughly   comparable.   For example,   exposure  through
         water,  although   discontinuous,  would  fall  somewhere  between
         continuous  exposure  by  Inhalation and  administration  of the
         same total dally dose to an animal by single gavage.

    "2.  Although  situations  1n  which systemic  effects  are  different
         for   different    routes   of   administration   can   readily  be
         Imagined, we  were unable  to  Identify any compounds  for which
         this  1s  true.   It may  be possible to  Infer  that few chemicals
         do not meet this criterion.
1871A                                -86-                            04/11/84

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    "3.   Highly chemically  reactive  compounds, or  compounds with  long
         residence times 1n the tissue of entry,  should  be  suspect  with
         regard to their potential for causing portal-of-entry  effects.
         However,   1t  cannot  be  assumed  that  compounds  that  are  not
         highly reactive or have  short residence  times 1n  the  tissue of
         entry will not  cause portal-of-entry effects.

    "4.   Compounds with  long  t]/2are 1ess  likely to undergo  signifi-
         cant  first-pass  effects  than are  compounds  with  short  t]/2-
         Thus, as  a  result of both  considerations  1  and 4, 1t  appears
         that  compounds  with  long t1/2 "^Y  be suitable candidates  for
         summation across exposure routes."


4.2.3.   Workshop  Statement.   The  essential  points  of  the  workshop  were

agreed  upon   by  Drs.  Nelson,  Clarkson,  and  Pepelko.   Or.  Harlung's  five

conditions  for  conducting  an  assessment  of  a  multlroute  exposure  were

considered a  valid starting point against which  other approaches  should  be

evaluated.   The  limitations 1n  the  available  data are  likely to  preclude

meaningful assessments at  the present time, although some  gauge  of  the level

of confidence 1n an assessment 1s  possible and desirable.



4.3.   RANKING THE SEVERITY OF EFFECTS



4.3.1.   Presentation (M.  Dourson,  P.  Durkln).   In  this workshop,  a scheme

was presented  for ranking  potential  adverse  effects from  chronic  exposures,

which 1s  to  be used  for Identifying reportable quantities  (RQs)  as required

by  CERCLA.   This   act stipulates  that once a spill occurs  resulting 1n the

release of a  hazardous  material In a quantity greater  than the RQ,  the spill

must  be reported  to  the Agency.  Under Section 102(b) of  the  act,  the RQ of

any hazardous  substance 1s  1  pound, unless  a different RQ has  been estab-

lished; statutory  RQs  can be  set at 1,   10,  100, 1000  or  5000  pounds.  The

current regulatory approach  uses six primary criteria for setting  an RQ:

aquatic  toxldty,  mammalian  toxldty  (acute),   1gn1tab1l1ty,  reactivity,
1871A                                -87-                            04/11/84

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other toxic  effects  (chronic), and cardnogenlcHy.   For  each criterion,  a
f1ve-t1ered rating  scale  1s  set  up  corresponding with  the  RQ values of  1,
10,  100,  1000  and  5000  pounds.   There  are also  three secondary  criteria
(b1odegradab1!1ty, hydrolysis, and photolysis)  that  may adjust the  RQ up  by
one level.

    In the  scheme presented at the workshop,  determination of a  reportable
quantity  based  on chronic  toxic  effects  requires a  composite score  (CS),
which 1s  the product  of  a rating value  for dose  (RV ) and a rating  value
for  effect  (RV ).  Each  RV  can  vary  from  1   to  10;   hence,  the  CS  varies
from 1 to 100.  The higher the CS, the lower  the RQ.

    The  following  1s  a  brief  description  of  the  calculation   of an  RQ.
First, an RV.  1s  derived as  follows  for each  route  of exposure  for  which
there are data:
    1.    Identify subchronlc or chronic NOAELs,  LOAELs or FELs.
    2.    Convert above dose to units  of mg/kg/day.
    3.    If above dose 1s based on subchronlc exposure, divide by 10.
    4.    Estimate a minimum effect  dose  (MED)  for  humans  by converting
          above  dose using surface area conversion.
    5.    Assign a rating  value to MED as shown  1n  Figure  4-2.  This 1s
          the  RVd.
    The   RV    that  1s  associated with  the MED  1s   derived  as   shown   1n
           e
Table 4-2.
     The  RQ  1s  then  assigned  on the  basis  of  the  following relationship
 (Table  4-3)  using  the  highest  composite  score  (the  product  of  RV.  and
 RV  for each  route  of exposure).

 1871A                                -88-                             03/21/84

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CO
I
oo
VO
I
           •o

           oc

           UJ
          CO
          o
          O
10-


 9


 8



 7


 6


 5-


 4.



 3-


 2


 1 •


 0-
                            T
                            3
                      -2
                                                        RVd  = 10 IF log MED <  -3



                                                        RVd  = -1.5 log MED  + 5.5  IF-3  < log MED < 3


                                                        RVd  = 1  IF log MED > 3
^          \          \	r
 -1012
       log HUMAN MED (mg/day)
1

 4
00
                                      FIGURE 4-2


                               Rating Values for Doses

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                                                     TABLE 4-2

                          Rating Values  for NOELs,  LOAELs and FELs for the Determination of  RVe



               RATING                                     EFFECT

                 1     ENZYME INDUCTION OR OTHER BIOCHEMICAL CHANGE WITH NO PATHOLOGIC CHANGES AND NO
                      CHANGE IN ORGAN WEIGHTS.

                 2     ENZYME INDUCTION AND SUBCELLULAR PROLIFERATION OR OTHER CHANGES IN ORGANELLES
                      BUT NO OTHER APPARENT EFFECTS.

                 3     HYPERPLASIA, HYPERTROPHY OR ATROPHY BUT NO CHANGE IN ORGAN WEIGHTS.

                 4     HYPERPLASIA. HYPERTROPHY, OR ATROPHY WITH CHANGES IN ORGAN WEIGHTS.

                 5     REVERSIBLE CELLULAR CHANGES: CLOUDY SWELLING, HYDROPIC CHANGE, OR FATTY CHANGES.
                 6    NECROSIS, OR METAPLASIA WITH NO APPARENT DECREMENT OF ORGAN FUNCTION. ANY
                      NEUROPATHY WITHOUT APPARENT BEHAVIORAL, SENSORY, OR PHYSIOLOGIC CHANGES.

                 7    NECROSIS, ATROPHY, HYPERTROPHY, OR METAPLASIA WITH A DETECTABLE DECREMENT OF
                      ORGAN FUNCTIONS. ANY NEUROPATHY WITH A MEASURABLE CHANGE IN BEHAVIORAL,
                      SENSORY, OR PHYSIOLOGIC ACTIVITY.

                 8    NECROSIS, ATROPHY, HYPERTROPHY, OR METAPLASIA WITH DEFINITIVE ORGAN DYSFUNCTION,
                      ANY NEUROPATHY WITH GROSS CHANGES IN BEHAVIOR, SENSORY, OR MOTOR PERFORMANCE.
                      ANY DECREASE IN REPRODUCTIVE CAPACITY. ANY EVIDENCE OF FETOTOXICITY.

                 9    PRONOUNCED PATHOLOGIC CHANGES WITH SEVERE ORGAN DYSFUNCTION. ANY NEUROPATHY
                      WITH LOSS OF BEHAVIORAL OR MOTOR CONTROL OR LOSS OF SENSORY ABILITY. REPRODUCTIVE
                      DYSFUNCTION.  ANY TERATOGENIC EFFECT WITH MATERNAL TOXICITY.

££               10    DEATH OR PRONOUNCED LIFE SHORTENING. ANY TERATOGENIC EFFECT WITHOUT SIGNS OF
¥                     MATERNAL TOXICITY.
oo

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                                 TABLE 4-3



                   Relationship of Composite Score to RQ
                       Composite Score          RQ
                           81-100                 1



                           41-80                 10



                           21-40                100



                            6-20               1000



                            1-5                5000
1871A                                -91-                             03/21/84

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4.3.2.   Discussion.  Several  Issues  were raised during  the discussion  and
1n  postmeetlng  memoranda.    Or.  Albert  defined  three  questions  that  he
thought the participants should address relative to the proposed schemes:
    1.   Do  the  participants  agree  with the  rating  for   toxldty  1n
         Table 4-2?
    2.   Do  the  participants  agree with  the rating proposed  for  dose,
         and 1f so, should 1t essentially be a log function?
    3.   Do  participants  agree  with  the multiplicative  approach  for
         combining the two rating schemes?

    With  regard  to  the  first question,  Dr. Stara  asked  1f  the  group (or
possibly  the National  Academy of  Sciences) should  be asked  to  develop  a
catalog of effects  to better  define the  toxldty rating and to provide  Input
as to where  FELs,  LOAELs, and NOAELs  fall 1n the rating scheme.  Dr. Hartung
suggested  that  perhaps  criteria  should be developed  to  grade  particular
effects.   In particular  he  suggested  that  the question  of  reversible or
Irreversible effects be addressed and also  that public perception of effects
should  be  taken  Into account.  Dr. Schnelderman  Indicated  a similar concern
with  the question of 1rrevers1b1l1ty.

    With  regard  to question  3, several  Individuals  Indicated that multipli-
cation  of  what were Implicitly  log functions  to derive  the CS was probably
Inappropriate  and  that  perhaps  an  additive scheme  would  be  better.    They
also  noted  that  this would probably  greatly change  the outcome of the  rank-
Ing procedures presented by Dr. Durkln.
 1871A                                -92-                            03/21/84

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    Two   participants   made   additional   comments   1n  their   postmeetlng
memoranda.  Dr.  Sllbergeld  stated that the  ranking  of effects presented  In
Table  4-2 was  biased   toward  pathological   findings  (I.e.,  hyperplasla  and
necrosis) and that some statements were so unqualified  as  to  be unlnterpret-
able  (I.e.,  "any decrease  1n  reproductive   capacity").  She  also cited  the
lack  of  distinction between  "death" and  "pronounced  life-shortening,"  the
lack of  a  rationale  for why teratogenldty  without  signs  of  maternal  toxlc-
1ty was  considered  more  serious  than with  signs  of maternal  toxUHy,  and
the absence  of  consideration  of  revers1b1Hty/1rrevers1b1lHy.   Or.  Manson
made  similar  points and  stated  that  a distinction  should  be made  between
decreases  1n reproductive capacity that occur  with  general  systemic  toxldty
and  decreases  occurring  1n the  absence  of other   types  of   toxldty.   Dr.
Schnelderman  also  noted  the  lack  of consideration  of reversibility,  germ
plasm  effects,  and  effects  occurring over  a  lifetime  (I.e., reduction  1n
functional ability  and  reduced IQ),   and  stated that the  use  of  logarithmic
scales  for effect  and  dose required  substantially  more  justification.   He
concluded  that  the  process   1s  "far  from  ready to be  used  for extrapolation
to NOELs."

4.3.3.   Workshop  Statement.   A  workshop  statement  was  written  by  Dr.
Albert.   In addition to summarizing  the presentation,  the  statement Included
the following conclusion.

    "The  primary objective  of the  panel was  to critique  the  approach  to
rating the toxic effects.  Three conclusions  were reached by the panel:

    "1.  There was  general   endorsement of   the  principles  used  1n  the
         approach to developing the composite score.

1871A                                -93-                             03/21/84

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    "2.   There were reservations about the scheme presented  for  ranking
         the  toxic  effects;  for example,  tentative  suggestions  were
         made that the minimal effects be lumped Into a  single  category
         and other suggestions concerned different approaches  to giving
         weights  to the various  kinds  of  effects than were  done by Dr.
         Durkln.    Other  possibilities  Included  assigning  weighting
         factors   to   the  quality  of  evidence  used  1n  defining  the
         composite score.

    "3.   There was concurrence  on  the fact  that the subject  1s highly
         complex  and one or  two  days  would be required  to  evaluate all
         four aspects of defining a composite  score  and  assigning these
         scores to  reportable quantities  of  spilled toxic  substances.
         The  possibility of  turning this  problem  over   to  the  National
         Academy  was  discussed with  mixed  response."
4.4.   USE OF EXPOSURE DATA IN ASSESSING HEALTH RISK



4.4.1.   Presentation  (R.  Bruins,  G.  Kew).   A  site-specific  health  risk

assessment  1s  accomplished 1n three  phases  Including a  toxiclty  assessment

and  an  exposure  assessment,  which  may  be  conducted  concurrently,  and  an

Integration step  to  combine  these two (see Figure  4-1).   The  goal  or output

of  a  health risk assessment  1s  to report the  numbers  of people who are at

risk  of  experiencing  adverse  effects as  a result  of  a  given  circumstance

(such  as  uncontrolled  waste site  or untreated  Industrial effluent).   For

noncardnogens,  the  output would  be  the number  of people  subject  to expo-

sures above an ADI,  a LOAEL, a  FEL,  etc.,  and the  duration or  frequency of

exposure.   For carcinogens the result  can be  expressed  as numbers exposed to

a  given  risk  level, or  as  a predicted  number  of  cancer cases.   The  risk

assessment  should also  be  capable  of   estimating  environmental   levels  or

exposure concentrations that can serve as goals for   remedial measures.
 1871A                                -94-                            04/11/84

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    The risk  assessment  methodology  being developed by  ECAO  focuses  primar-
ily on  the toxldty  assessment  phase (ADI  and  risk level calculations  for
single chemicals) and also on methods  used  1n  the Integration phase (assess-
ment  of  chemical  mixtures,  multiple  exposure of  routes, and response  of
sensitive subgroups).  The goal of this workshop  was  to  discuss the Informa-
tion  an  exposure  assessment  can provide  and  how  1t should  be  used.   The
Intent was not  to  recommend  how an exposure assessment  should be  performed.
Some  of  the   questions with  which we  were  concerned Include  the  following:
How will  the  availability or  quality of key exposure  Information  affect the
assessment procedure?  What 1s  the most appropriate endpolnt  (I.e., exposure
concentration  or absorbed  dose)  of  an  exposure assessment?   What  special
problems arise when more  than one chemical 1s Involved?

    4.4.1.1.   DATA   AVAILABILITY   AND  QUALITY  — An   exposure  assessment
examines  the  Identity of  chemicals  of concern,   their movements and concen-
trations  1n  various  environmental media,  and the  demographics of  potentially
affected  populations.  The types  of Information  useful  In conducting a risk
assessment are  chemical  exposure  levels,  numbers  and kinds of people exposed
at  each  level, and exposure durations.

    The  exposure level  1s likely  to be a critically Important  factor, but  1s
very   difficult   to   precisely  ascertain.   It   1s   therefore   Important   to
consider  the  effect  of exposure uncertainty upon the overall outcome of  the
risk  assessment.  Site assessments could conceivably  be requested where  the
exposure  level  1s unknown.  Consider, for  example,  a situation 1n which  the
Identity  of   chemicals at a  site Is known and release  1s verified, but lack
of  time,  funds,  or data   has precluded an exposure assessment.   Or consider  a


 1871A                                -95-                             04/11/84

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situation where  release seems  Imminent  but  has  not  yet  occurred.  We  may
readily  conclude  that  without   the  needed  data,  no  risk  assessment  Is
possible.  But consider a similar situation,  1n which  an  exposure assessment
has been conducted, but limited Information has required  that  a large number
of  assumptions  be made  to  the  extent  that  the  uncertainty  around  the
exposure level 1s  extremely  large,  I.e., several  orders of  magnitude.   This
exposure estimate could 1n effect  be as  useless  as no assessment at all.

    Thus, 1n  terms  of  associated  variability, the data may  fall  anywhere on
a continuum from very  poor  to highly accurate  (I.e.,  where  extensive target
monitoring  has  been  conducted).    Questions  to  be  considered  Include  the
following:  What  level  of  precision can  be expected  from  a  typical exposure
assessment?   Should our  methodology provide  guidance  as  to what  1s  accept-
able?   How  should  exposure  uncertainty  be  treated  when  exposure estimates
are Integrated with toxldty estimates?

    Other types  of  data  may also be unavailable  or  of variable quality.  If
exposure  levels  are given  but no  Information 1s  provided on the  size or
composition of the  exposed  population,  1t may  still  be  possible to complete
a  health risk assessment.   However,  the  result  could be expressed  only In
terms  of effects  and  would  be  lacking 1n  the population  dimension.   This
would  allow a qualitative  judgment as   to whether  or not a hazard existed,
but would not permit  an estimate of the associated  societal cost.  The lack
of  Information about  the characteristics  of  people  exposed raises  an  Issue
of  whether  the population should  be  assumed to  be  "average"  or  "sensitive"
with respect  to  physiological, behavioral, or genetic  traits that may affect
 esponse.   Thus,  this   topic  1s  related   to  the  topic  of  the  "sensitive
subgroups" workshop.

"»871A                                -96-                            03/21/84

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    As  to exposure  duration,  the  assumption  of   lifetime  exposure  may  be
sufficient to  Indicate  whether the situation 1s acceptable  1n perpetuity or
whether remedial measures  need to  be  taken.   However,  more specific Informa-
tion on exposure  duration, I.e.,  duration of past  exposure  and likely dura-
tion before remedial measures  are  completed,  could  be  needed 1n decisions to
relocate  people,  change  water source,  etc.   What  are  the  Impacts  1f this
Information 1s unavailable, and 1s  this  an  Issue that  our guidelines need to
address?

    4.4.1.2.    ENDPOINT  OF EXPOSURE ASSESSMENT --  The  endpolnt of  an  expo-
sure assessment  may vary according  to  the  purpose,  the substance,  or  the
type of monitoring  done.   If   the substance has  been monitored 1n air, food,
soil,  or  water,  exposure may  be  expressed  as  the concentration  or  amount
reaching human exchange membranes.  If absorption factors  are  known or esti-
mated,  exposure  may be  expressed  as  a  whole-body  absorbed dose.   If human
tissues or  excreta  are  monitored, knowledge  of pharmacoklnetlcs  1s  needed
for  back-calculating  to  either a  body  dose  or an  environmental  concentra-
tion.  Where multiple routes  of exposure may  contribute to systemic effects,
whole-body dose  may be  the  best  Indicator of  effects.   On the  other hand,
where  effects  may  be  route-specific,   exchange-membrane  concentrations  or
amounts could  be  most  useful.  Therefore,  1t  1s   Important to  consider  the
significance  of  the exposure  endpolnt  1n  determining  health  risk,  and  to
evaluate whether  our guidelines should address this  Issue.
1871A                                -97-                            03/21/84

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    4.4.1.3.   MULTIPLE CHEMICAL  EXPOSURE — The  preceding questions  apply
to single-toxicant exposures.  What additional questions  are  faced by health
risk assessors 1n  Interpreting the  results  of  mult1chem1cal exposure assess-
ments?  For example,  consider  a  site vicinity where  exposure  to each of two
chemicals  varies  over a  wide  range.   If both were transported  by  the same
route(s),  then  their  respective  exposure  levels  should  be  directly corre-
lated, and  some  Individuals  might be exposed  to  the  highest  observed levels
of both.   Alternatively,  1f  routes differ,  the  highest  exposures  may occur
to different  Individuals; this would affect  the outcome of  the health risk
assessment.  Thus,  1t would  not  be sufficient for  an exposure assessment to
simply provide ranges  of  chemical  levels  over  a  given area, but correlations
among  chemicals  or  routes may also be  needed.   Guidance  on  this  and other
points 1s needed.

    Many  other  questions  are  likely to  arise 1n  any attempt  to  conduct a
risk  assessment  using  this  methodology.   Hence  there 1s  a  need to conduct
trial  assessments  1n  order  to detect  remaining  problems.    Another  goal of
this  session  1s  to Identify  available  exposure assessment  data  that  would be
suited  to this  purpose.  Assessments Including data  on more than one  chemi-
cal  and  on  the  exposed  population  would be  most  useful.   Participants are
requested to provide suggestions  and/or  exposure  data of  which  they are
aware.

4.4.2.    Discussion.   Dr. Wyzga  of  the Electric  Power  Research  Institute
 (EPRI)  briefly  discussed EPRI's   current approach to  assessing exposure  to
atmospheric  emissions.  From Information on transport  and  transformation,  an
estimate of  the atmospheric  concentration of a  given  pollutant 1s  made.


 1871A                               -98-                            04/11/84

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These data  are  combined with  a  demographic  model of  the  exposed population
that  Includes   health  status  and  activity  levels  as covarlants.   Similar
approaches  are  used  for  estimating  the  contribution  of  the   other  media
(I.e., water  and food)  to the  total  exposure;  that  1s,  whatever  data  are
available  are   used   1n  models  of  the  movement  of  pollutants  within  and
between the media to determine exposure.

    Dr.  Nlsbet  stated that  1n  his  experience  the  modeling  approach was of no
use  1n  gauging  exposures  resulting  from  hazardous  waste  sites  because
exposure conditions  are  site-specific  and therefore  do not fit  the models.
The  monitoring  data  tend  to  show wide  variability  in space  and  time  and
that, although  a  log-normal  distribution is  desired,  such  a distribution is
rare.   Or.   Silbergeld   pointed  out  that  an   Important   factor  missing  1n
exposure assessments  is  the environment-human  Interface,  I.e.,  how people's
behavior influences  their  exposure to  toxic  substances.   She  also expressed
the concern  that, because  little information is  available  on  the background
rate  of  various diseases  in  the population, the health  status  of  a poten-
tially exposed  population  is  not considered  1n exposure  assessments.  Other
participants also commented  that both  behavioral  and  health status  data  are
needed (Andelmann, Mehlman, Hattis).

4.4.3.   Workshop Statement.   Dr.  Mehlman,  chairman  of  the workshop,  sub-
mitted the following summary statement:

    "We  assume  that  the  type and  amount  of waste  will  be  reasonably  well
characterized (but may be deficient in  some cases).
1871A                                -99-                            03/21/84

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    "Exposure assessments  are  resource limited  and  data-limited, and  expo-
sures are variable  1n  space  and time;  therefore, exposure  cannot  be  charac-
terized by a single number.

    "The following  data are  desirable  for  characterizing  exposure:   monitor-
Ing data from air,  water  (surface and  ground),  foodstuffs  (especially fish),
and soil must be  determined  to adequately establish the  level  of  substances
present.  Tissue/excreta  monitoring  1n humans  or  animals  from the  area  1s
extremely valuable 1n assessing exposure.

    "Human  behavioral  observations  1n the area should  be made  to  Identify
exposure routes  or sensitive Individuals.

    "Attention should be given to proper  locations  of monitoring wells.

    "The  output  should  be explicit  as  to  the  variability  associated  with
exposure, both 1n space and time.

    "Monitoring data  and  exposure assessments  come from  a  wide  variety  of
sources  within  and without  U.S.  EPA.    Close  communication  between  those
responsible  for each  phase must be encouraged,  especially 1f a second phase
of monitoring can be done.

     "We  recommend  that  the Agency  commission a  paper discussing the  Integra-
tion  of  environmental  monitoring  data,  exposure  data,  and  health  data,
Including the role  of epidemiology of  exposure."
 1871A                                -100-                           03/21/84

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