, ' C. I
oEPA
             United States
             Environmental Protection
             Agency
             Office of Health and
             Environmental Assessment
             Washington DC 20460
EPA-600/8-S3-033A
August 1983
External Review Draft
             Research and Development
Revised Evaluation of  Review
             Health  Effects
             Associated with
             Carbon Monoxide
             Exposure:

             An Addendum to the
             1979 Air Quality
             Criteria Document for
             Carbon Monoxide
                             Draft
                             (Do Not
                             Cite or Quote)
                          NOTICE

             This document is a preliminary draft. It has not been formally
             released by EPA and should not at this stage be construed to
             represent Agency policy. It is being circulated for comment on its
             technical accuracy and policy implications.

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                                    EPA-600/8-83-033A
                                       August 1983
                                    External Review Draft
Draft
Do Not Quote or Cite
   Revised  Evaluation of  Health
 Effects Associated with Carbon
         Monoxide Exposure:

  An Addendum to the 1979  EPA
 Air Quality Criteria Document for
           Carbon  Monoxide
                     NOTICE

This document is a preliminary draft. It has not been formally released by EPA and should not at this stage be
construed to represent Agency policy. It is being circulated for comment on its technical accuracy and policy
implications.
           U.S. ENVIRONMENTAL PROTECTION AGENCY
             Office of Research and Development
          Office of Health and Environmental Assessment
           Environmental Criteria and Assessment Office
              Research Triangle Park, NC 27711

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                          CONTRIBUTORS AND REVIEWERS


The following authors contributed to the writing of this addendum.

Dr. Lester D. Grant, Environmental Criteria and Assessment Office,
  U.S. Environmental Protection Agency, Research Triangle Park, NC  27711

Dr. James A.  Raub, Environmental Criteria and Assessment Office,
  U.S. Environmental Protection Agency, Research Triangle Park, NC  27711

Dr. Vernon A. Benignus, Neurotoxicology Division, Health Effects Research
  Laboratory, U.S. Environmental Protection Agency, Building 224H, University
  of North Carolina, Chapel Hill, NC  27514.

Dr. David 0.  McKee, Strategies and Air Standards Division, Office of Air
  Quality Planning and Standards, U.S. Environmental Protection Agency,
  Durham, NC  27701


     A working draft of this addendum was circulated for preliminary peer-review
to the individuals listed below, and comments received were taken into account
in preparing the present draft addendum.   The views expressed in the present
addendum should not be taken, however, as representing those of any single
individual or group listed here.

Dr. Richard Ayres
Natural Resources Defense Council
1725 I Street, NW
Suite 600
Washington, DC  20006

Dr. Laurence Fechter
Department of Environmental Health Sciences
School of Hygiene and Public Health
John Hopkins University
615 North Wolfe Street
Baltimore, MD  21205

Dr. George Goldstein,
Clinical Studies Branch, Health
  Effects Research Laboratory
U.S. Environmental Protection Agency
Building 224H, University of
 North Carolina
Chapel Hill,  NC  27514

Dr. Jack Hackney
Environmental Health Service
Rancho Los Amigos Hospital
7601 Imperial Highway
Downey, CA  90242
                                        i i

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                          CONTRIBUTORS AND REVIEWERS
Dr.  Stephen M. Horvath
Institute of Environmental Stress
University of California
Santa Barbara, CA  93106

Dr.  Victor G. Laties
Environmental Health Sciences Center
University of Rochester, School of Medicine
Rochester, NY  14642

Dr.  Pat Mihevic
Institute of Environmental Stress
University of California
Santa Barbara, CA  93106

Dr.  John O'Neil
Clinical Studies Branch, Health
  Effects Research Laboratory
U.S. Environmental Protection Agency
Building 224H, University of
 North Carolina
Chapel Hill, NC  27515

Dr.  David S. Sheps
Department of Cardiology
University of North Carolina
  School of Medicine
Chapel Hill, NC  27514

Dr.  Jaroslav J. Vostal
Biomedical Science Department
General Motors Research Laboratories
Warren, MI,  48090-9055

Dr.  Jeames Wagner
Institute of Environmental Stress
University of California
Santa Barbara, CA  93106
                                       i i i

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                               TABLE OF CONTENTS

                                                                      Page

INTRODUCTION 	    1

MECHANISMS OF ACTION 	    2

HEALTH EFFECTS OF LOW LEVEL CO EXPOSURES 	    6

  CARDIOVASCULAR EFFECTS 	    7
  NEUROBEHAVIORAL EFFECTS 	    11
  EFFECTS OF CO EXPOSURE ON FIBRINOLYSIS 	    14
  PERINATAL CO EFFECTS 	    17

POPULATION AT RISK	    19

SUMMARY AND CONCLUSIONS	    23

REFERENCES 	    27

APPENDIX A 	    A-l

APPENDIX B 	    B-l

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                                  INTRODUCTION

     On April 30, 1971, the Environmental Protection Agency promulgated (36 FR
8186) national ambient air quality standards  (NAAQS) for carbon monoxide  (CO)
under section  109 of  the  Clean Air Act.   Identical primary  and  secondary
standards were set  at  levels of 9 ppm,  8-hour average,  and 35 ppm,  1-hour
average, neither to be exceeded more than once per year.   The scientific bases
for these  standards  are  contained in the document  Air Quality Criteria for
Carbon  Monoxide  (U.S.  Department of Health,  Education,  and Welfare,  March,
1970, AP-62).  The  1971  standards were primarily based on  work by Beard  and
Wertheim (1967)  suggesting  that low-level  CO exposures resulting in carboxy-
hemoglobin (COHb)  levels  of  2 to 3 percent are associated with impairment of
ability to discriminate time intervals, a central nervous system  (CNS) effect.
The revised Air Quality Criteria Document for Carbon Monoxide (U.S.  EPA, 1979)
indicated that this study is no longer considered to provide credible evidence
for such CNS effects occurring at 2-3% COHB and, therefore, does not represent
a  sound scientific  basis  for the standard as discussed in an August 18, 1980
EPA proposal  notice  (45 FR 55066).   However,  medical evidence  published since
1970  indicated at the  time of proposal  that  aggravation of angina and  other
cardiovascular diseases may occur at COHb levels as low as 2.7 to 2.9 percent.
Assessment of this  and other medical evidence  led  EPA to propose, on August
18, 1980, retention of the 8-hour primary standard level of 9 ppm and revision
of the  1-hour standard level from 35 ppm to 25 ppm (45 FR 55066).
     The 1980 proposal  was  based in part on  several health studies conducted
by Dr.  Wilbert Aronow (Aronow et al., 1972; Aronow and Isbell, 1973; Aronow et
al.,  1974; Aronow et al., 1974; Aronow and Cassidy, 1975; Aronow et al., 1977;
Aronow,  1978).   Based  on  evaluation of  these studies  in 1979 by EPA staff,
their  expert consultants, and the Agency's  Science Advisory Board,  it was
concluded  that  these  studies  demonstrate  human  health  effects of carbon
monoxide that  should be considered by the Agency in reconfirming existing or
proposing  new NAAQS  for CO.   The Aronow studies were  an important element in
the  judgment of  what blood  carboxyhemoglobin  (COHb)  levels  represent  a  health
concern for  sensitive  individuals.   This  "critical"  range was defined as
2.7-3.0 percent.  An additional study by Aronow  (1981) later reported findings

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suggesting that aggravation of angina symptoms,  i.e.,  small but  statistically
significant decreases  (~10%)  in time to onset of exercise-induced angina,  may
occur in angina patients at COHb levels as low as 2.0 percent.
     Since the CO  standard was  proposed by  EPA  in  1980, news media reports
appearing in early  1983  indicated that the Food  and  Drug Administration  (FDA)
raised questions regarding the technical  adequacy of several studies conducted
by Dr.  Aronow  on  experimental drugs, leading to FDA rejection of use  of the
drug study data.   While  there was no specific  direct  evidence that similar
problems might exist  for the CO studies  conducted by  Dr. Aronow, EPA  judged
that an independent assessment of these studies was advisable prior to a final
NAAQS decision on  CO.   An expert committee was empaneled by EPA and met with
Dr. Aronow to  discuss his studies and to examine limited available data and
records from his  CO studies.   In their report, the committee (chaired by Dr.
Stephen M. Horvath,  Director of the Institute  of Environmental  Stress,  Uni-
versity of California-Santa Barbara) concluded that EPA  should not rely on Dr.
Aronow1s data  due  to concerns regarding problems associated with the studies
which substantially  limit the validity and usefulness of those study results
(Horvath et al., 1983).
     The main purpose of the present addendum is to re-evaluate the scientific
data base  concerning  health  effects  associated  with  exposure  to  CO at  ambient
or  near ambient exposure  levels,  in light of the diminished value  of the
Aronow  studies  and taking into account any new findings  that have become
available beyond  those reviewed in the revised Air Quality Criteria Document
for CO  (U.S.  EPA, 1979).   This addendum is, accordingly, organized to provide:
(1) a concise  summary of key  health  effects  information  discussed in the 1979
document as  pertinent to characterization of health effects  associated  with
relatively low  level  CO exposures;  and (2)  an  overview of the  limited  new
evidence bearing on the  subject which has become available in the past several
years.
                             MECHANISMS OF ACTION

     The 1979  Criteria Document discussed extensive evidence indicating that
the binding  of CO to  hemoglobin,  producing COHb and  decreased oxygen carrying
capacity, results in decreased oxygen transport  and  uptake in most body tissues.
The resulting hypoxic  state (impairing normal biochemical-physiological cellular

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processes as a  function  of increasing external  CO  exposure  and  consequently
increasing blood COHb  concentrations),  it was concluded, probably represents
the main mechanism  of  action  underlying  the  induction  of toxic effects  by  low
level CO exposures.
     Several important relationships between COHb  levels and other physio-
logical parameters  discussed  in the 1979 Criteria Document have continued to
be the  subject  of evaluation  since  then.  Of much  importance is  the  relation-
ship between external  CO exposure  levels and consequent increases in blood
COHb levels.   Many factors,  discussed in the  1979 Criteria Document,  can
affect  the  rate at  which COHb  increases above pre-existing endogenous levels
of COHb in response to inhalation of exogenous CO.   These include, for example,
the pattern of  external CO exposure, as in the case of acute  short-term exposures
to high CO concentrations versus longer term exposure to  relatively low levels
of  CO.   CO exposure-COHb  concentration  relationships  have been modeled  by
Coburn  (Coburn  et  al. , 1965),  taking  into  account several  pertinent factors
(see Chapter 9  of  the 1979 EPA CO  Criteria Document for discussion  of the
Coburn  model equations).   COHb levels predicted by the  Coburn equations,  as
depicted  in Figure  1, are widely  accepted  as the  currently  best  available
modeled  estimates of  COHb levels likely to  result  from  varying  CO concentra-
tions,  exposure durations and  exercise levels.  It should be noted that some
questions have  been raised regarding the specific mathematical approach employed
by Coburn in solving his equations  to predict COHb  concentration as a function
of  time, considering  appropriate   physiological parameters   (Venkatram and
touch,  1979; Ott and Mage, 1980; Marcus, 1980; Joumard et al., 1981).  However,
the  proposed  alternative approaches yield very  similar  estimated  COHb  levels
to  those projected by Coburn1s approach.   In  addition, actual  blood COHb
concentrations  observed  in response to particular  external  CO exposure  situa-
tions  have  been consistent with those predicted  by  Coburn (Peterson and Stewart,
1975),  although further experimental verification would  be useful  to demonstrate
that the Coburn equation accurately predicts uptake and  excretion  of CO under
widely  varying  conditions.
     The  exact  mechanisms responsible for the  hypoxia induced by  CO are not
known.   The most widely accepted mechanism  of CO toxicity has been attributed
to  the preferential binding  of CO to hemoglobin which  produces hypoxia  by re-
ducing  09  transport by red blood  cells  to  the  tissues  and  impedes the dis-

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                                                                        20 LP« U m CD


                                                                        10 im to PPW co
                                                                         20 tP« 20 PPH CO
                                                                         10 1PM 20 PPH CO
                                                                         20 LPH XO PPM CO
                                                                         10 LPH 10 PPM CO
Figure 1.  Blood COHb  concentrations predicted  by  Coburn equations to occur  as
           a  function  of exposure  duration and ambient carbon monoxide con-
           centrations under  resting (10  LPM),  light exercise  (20 LPM), or
           heavy exercise (50 LPM) conditions.   LPM = liters perjninute  venti-
           lation  rate.   Source:   U.S. EPA  (1979).

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sociation of 0^ from hemoglobin in the capillaries.  However, other mechanisms
have been postulated for  reducing  oxygen  transport.   It  is  possible for  CO  to
bind to  intracellular  hemoproteins such as myoglobin and cytochrome oxidase,
which depends on the relationship of oxygen tension (POp) and CO tension (PCO)
to CO binding  constants (Coburn,  1979).  The  affinity of cytochrome oxidase
for CO  is similar  to that for  oxygen  compared  to  myoglobin  (30-50x) and  hemo-
globin (220x) which would make it less likely to be responsible for impairment
of facilitated  diffusion  of oxygen to the  mitochondria.   However,  if steep
oxygen  tension  gradients exist between the extracellular  and intracellular
environment, then the P02 surrounding the mitochondria! terminal oxidase would
be low  enough  to have  increased binding with CO.   This hypothesis was tested
by Coburn (1979) in studies on isolated vascular  smooth  muscle.   He concluded
that significant CO binding to cytochrome  oxidase was  unlikely to be an i_n
vivo mechanism  of  CO  toxicity in that particular tissue.  Myoglobin was also
unlikely because it is absent or present  in  only small  quantities.   It  is
possible that  CO binds to  hemoproteins other  than hemoglobin,  myoglobin, or
cytochrome  oxidase.  Cytochrome P-450,  tryptophan deoxygenase,  and tryptophan
catalase all have high  enough binding affinities for CO in specific tissues to
be considered as possible candidates (Coburn, 1979).
     The binding of CO to  myoglobin in heart and skeletal  muscle may be high
enough  to  reduce  intracellular oxygen  transport  in  those tissues (Coburn,
1979; Agostoni  et  a!.,  1980).   Using  a  computer simulation  of a three-
compartment  model  (arterial blood, venous  capillary  blood,  and tissue myo-
globin), Agostoni  et  al.  (1980) predicted that conditions would be favorable
for formation  of carboxymyoglobin  at COHb  levels  of  5-10%,  particularly in
areas where the P02 was physiologically low (e.g., in subendocardium) and when
conditions  of  hypoxia,  ischemia, or  increased  metabolic  demands  were present.
This could provide theoretical support for experimental evidence of myocardial
ischemia, such  as  electrocardiographic  irregularities and decrements in work
capacity discussed  later.   However,  it is not known whether binding of CO  to
myoglobin could  cause  health effects (e.g., decreases in maximal oxygen con-
sumption during exercise) occurring at COHb levels as low as 4-5%.  Additional
research is needed before this possibility can be more definitively evaluated.
     Whatever the  specific biochemical-molecular  mechanisms involved in  the
induction of CO toxicity in specific tissues or organ systems, it is thought

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that COHb  concentrations in  the blood  represent  a meaningful and  useful
physiological marker by which to gauge the internal CO dose present at a given
time due to the combined cumulative contributions of:  (1) baseline endogenous
production of  CO  by internal body processes; and (2) added CO body burden(s)
resulting from inhalation exposure to exogenous sources of CO.
                  HEALTH EFFECTS OF LOW-LEVEL CO EXPOSURES

     In  evaluating  CO-induced health effects in  humans,  a crucial question
that must be addressed concerns blood COHb levels demonstrated to be associated
with effects  on specific organ systems. The COHb levels of concern vary with
the  patterns  and concentrations  of external CO  exposure  pertinent to the
objectives of any particular  health risk evaluation.  For example, as discussed
in the 1979 CO  Criteria Document (U.S. EPA, 1979), some occupations inherently
involve  exposure  to high levels of CO, at times including frequent exposures
to CO levels well in excess of 100-200 ppm under certain workplace conditions.
On the  other  hand,  it  is relatively unusual  for members  of the  general  public
to encounter such high CO exposure  levels.
     As  examples of possible  extreme CO exposure situations encountered by the
general  public, the 1979 Criteria  Document noted that the  following scenarios
may  result in exposure to unusually high ambient levels of CO: (1)  On a large
city freeway where traffic has come to a halt,  the ambient CO level may exceed
44 ppm;  (2)  Inside a closed  automobile where cigarettes are being smoked, CO
concentrations  may  exceed 87 ppm;  (3)  In enclosed,  unventilated garages, CO
levels  in  excess of 100 ppm  have  been found;  and (4)  In  a heavily traveled
vehicular tunnel, a 1-hour maximum  of 218 ppm CO was  recorded.  Under relatively
mild exercise  conditions likely to occur in such exposure situations for any
sustained period of time, the Coburn equations  predict COHb blood concentrations
of <10 percent, assuming exposure  durations of less  than 8 hrs.  More often,
the  general  (non-smoking) population  is  exposed to  substantially  lower  CO
levels  (<20-50  ppm) sustained over 1 to 8 hr.  periods, potentially resulting
in maximum COHb levels of 6-7 percent but much  more often  in COHb  levels below
2-3  percent.   The present evaluation  is, therefore,  focused mainly on health
effects  observed at blood  COHb levels below  10 percent.   The latter COHb

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levels are most  pertinent for present objectives,  i.e.,  the development of
criteria for ambient air quality standards.
     Since the writing of the 1979 Criteria Document, several new studies have
been published which contribute to the CO health effects data base.   These new
studies, including both human and animal toxicology data, are concisely reviewed
below within a context of integrating the new information with evidence previou-
sly reviewed in the 1979 Criteria Document.

1.  Cardiovascular Effects

     The most  extensive  studies  on the  cardiovascular effects of  CO  have  been
those involving  maximum  aerobic  capacity  (V0?    ).   Previous data reviewed  in
the revised  CO Criteria  Document (U.  S. EPA, 1979)  demonstrated statistically
significant  decreases  in VOp     when  COHb levels  ranged  from 7-20% under  con-
ditions of short-term  maximal exercise  (Ekblom  and  Huot,  1972; Pirnay  et  al.,
1971; Vogel  and  Gleser,  1972).   In another study (Horvath et al.  , 1975), the
critical  level  at which  COHb marginally influenced (P  <  0.10)  VOp     was
approximately 4.3%.  In this study, work time to exhaustion was also reduced by
4.9 and 7% when COHb levels had attained 3.3 and 4.3%,  -respectively.   Reductions
in VXL    following exhaustive treadmill exercise have since been confirmed at
5% COHb. In a double blind experiment (Stewart et al.,  1978; Klein et al., 1980),
6 physically fit male fire fighters were randomly exposed to either CO or fil-
tered air twice  a week for 3 weeks and exercised to exhaustion.   On exposure
days, the subjects breathed a bolus of 20,000 ppm CO for 47  seconds followed by
30 ppm CO for 4 hours.   This resulted in a sustained elevation of COHb at 5.0-
5.5% saturation for 4 hours.  Similar decrements in maximal exhaustion times were
noted following the acute exposure and at the end of 4 hours.  No adaptation to
this hypoxic stress was observed after 4 hours  of exposure or over the 3 weeks
of testing.   Significant decreases in total exercise time (3.8%)  and VO,    (3%)
were also previously reported by Weiser et al.  (1978) in a project designed to
determine the effect of 5% COHb exposure on healthy young men residing in Denver
at an altitude of 1610m.  Blood  COHb  concentrations  were -quickly  increased  to
5.1% from a  resting  level of 1.0% by adding a  bolus of  100% CO to a closed-
circuit system from which the subjects rebreathed. The decrement in VO-  x was
consistent with those reported above and the authors concluded that changes in

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exercise performance following  CO  exposure at this altitude were similar to,
but not greater than, changes occurring at sea level.
     The effects of lower CO exposure levels have also been investigated under
conditions of  short-term  maximum exercise duration (Drinkwater et al., 1974;
Raven et  al. ,  1974a,b).   In this series of studies, a walking test with pro-
gressively increasing grade was used on subjects continuously breathing 50 ppm
CO at either of two ambient temperatures, 25°C or 35°C, with a relative humidity
of 20%.   The  two  populations consisted of young  (23+  years) and  middle-aged
(48+ years) subjects, both smokers and nonsmokers.  During the duration of the
test,  COHB  levels in nonsmokers increased  from 0.7 to approximately  2.8%,
while  levels  in  smokers  rose from 2.6-3.2%  to  4.1-4.5%.   Control  studies
conducted on  these  subjects while  they breathed  filtered  air  indicated  that
COHb decreased  in both  smokers and nonsmokers in the absence of experimental
CO exposures.   These studies did not find  any  reduction  in maximum aerobic
capacity.  In  fact,  the only statistically significant effect related to  CO
was  a  statistically  significant decrease  (<5%)  in absolute exercise time con-
sistently observed  in the nonsmoking subjects but not in the smokers.  These
observations extend those found earlier by Ekblom and Huot (1972), who reported
a large decrease  (38%) in work time at 7% COHb.
     The  revised  CO Criteria Document (U. S. EPA, 1979) also noted that oxygen
uptake  during  short  exposures  and  submaximal  work was  apparently  not  affected
even at COHb concentrations of  15-20%.  Recently, DeLucia et al.  (1983) reported
that COHb levels  of  7.3%  in nonsmokers  and  9.3% in smokers did not induce  any
effects involving subjective symptoms, pulmonary function, exercise metabolism,
or blood  parameters  in  healthy subjects.  In a controlled experimental study
designed  to test  for potential  synergism between 03 and CO, 24 male and female
volunteers were evaluated while performing moderate aerobic exercise at 50%  of
V02    . After  100 ppm CO exposure for approximately 1  hr., COHb levels in non-
smokers  rose  from 1.0-2.1% to  6.0-9.6% and COHb  levels in smokers rose  from
1.9-5.1%  to 6.6-11.8%.  DeLucia et al. (1983) attributed the lack of CO effects
as possibly being due to large  cardiovascular reserves found in healthy  subjects.
     It  should be noted that healthy young subjects were  used in most of the
above  studies  evaluating  the effects of CO on work capacity.  A  recent  study
by Calverley  et al.  (1981) demonstrated a decrease in walking distance  in 15

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patients with  severe  chronic bronchitis and emphysema at a mean COHb concen-
tration of  12.3%.   They  evaluated 11 men  and 4 women with  severe  reversible
airway obstruction  [FEV1  Q  = 0.56 ± 0.2  (SD)  liters;  FVC = 1.54 ± 0.4 (SD)
liters] who were  hypoxic [Pa02 = 5.2 ± 4.9 (SD)  mm Hg]. All patients were
medically stable  at the  time  of  the study and smokers  were  asked to stop
smoking for 12 hours before each session.  Each subject walked while breathing
air and oxygen before and after exposure  to 200  ppm CO  in  air, which  raised
their COHb concentrations from 1.1-5.4% to 9.6-14.9%.   There was a significant
reduction in walking  distance  when the  patients breathed either air  or oxygen
after exposure to CO.   A significant increase  in walking distance when the
patients breathed oxygen after exercise was abolished by CO exposure.  There
was no relationship to normal smoking habits of the patients.  It is therefore
quite possible that individuals with hypoxia due to bronchitis or emphysema
are more  susceptible  to  CO during submaximal work loads typical of  everyday
exercise.
     Other  cardiovascular effects of CO are thought to  be of greater concern,
i.e., those affecting individuals suffering from  chronic angina.  However, the
precise COHb levels at which such cardiovascular  effects occur in angina patients
are much  less  well defined than COHb concentrations associated with various
health effects discussed  above.  Angina pectoris  is a cardiovascular disease in
which mild exercise or excitement produces  symptoms of pressure and pain in the
chest because  of  insufficient oxygen supply to the  heart muscle.  Angina patients
exposed to  low levels of  CO while resting  have been reported to exhibit statis-
tically significantly reduced time to onset of exercise-induced angina at mean
COHb  levels  of 2.9 (range,  1.3-3.8  percent)  and  4.5 percent (range,  2.8-5.4
percent)  and  to experience significantly increased duration of  angina attacks
during  exercise  at a mean  COHb level of 4.5 percent (Anderson et a!., 1973).
Certain  questions have  been raised  regarding the design and conduct of the
study, the  small  number  (N=10) of subjects  studied, and  the absence of credible
independent  confirmation of  its  findings.   A thorough  reevaluation  of  the
Anderson et al. (1973) study,  addressing major points of concern,  has been con-
ducted  recently  (see  Appendix A),  and found that  the  study, in  fact,  provides
reasonably  good evidence  for the hastening  of angina occurring in  angina patients
at COHb levels of 2.9 to  4.5 percent.   The  Aronow et al.  (1973) and Aronow  (1981)
studies similarly reported  decreased time  to onset of angina  in exercising patients
at COHb levels of 2.0-3.0 percent.   However, these Aronow findings are now most

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appropriately interpreted as providing suggestive evidence for such effects occur-
ring at COHb levels below 3 percent.  More conclusive statements regarding this
issue will not be possible until the results of independent studies attempting to
replicate such findings become available.
     Another cardiovascular  effect  of possible concern is that  of  increased
blood flow  that  occurs as a compensatory  response  to  CO  exposures  (Ayres  et
al., 1969;  Ayres  et  al.,  1970;  1979).  This  response might result  in  coronary
damage or other  vascular effects due to  added stress  on the cardiovascular
system.  However, inconclusive results have been obtained in community epidemi-
ology studies  examining the relationship between CO exposure, mortality from
myocardial  infarction  (heart attack), sudden  death due to arteriosclerotic
heart disease, and  cardiorespiratory complaints (Goldsmith and  Landau, 1968;
Kurt, et  al.,  1978;  Kurt, et al.,  1979).   Hence, the  possibility  of  such  an
association  remains  in question,  and further research  is  also  needed  in  order
to clarify this issue.
     The results  of one controlled  human exposure study reported by Davies and
Smith  (1980)  are  suggestive of  possible  effects on  cardiac function at low to
moderate CO exposure in healthy individuals.   In a  series of replicated experi-
ments, six matched groups of young  human subjects lived in a closed-environment
exposure chamber  for 18 days.  They were exposed continuously to 0, 15, or 50 ppm
of CO in air during the middle 8 days.  Standard 12-lead electrocardiograms were
recorded from each subject during the control,  exposure, and recovery periods.
Unequivocal  P-wave  changes  were seen during the CO  exposure  period in 3  of 15
subjects at  15 ppm CO  (2.4% COHb) and 6 of 15  at 50 ppm (7.1% COHb) compared to
none of 14  at 0 ppm  (0.5% COHb).  The changes  were  evenly distributed among non-
smoking subjects  and subjects who had stopped smoking  3 days  before the  start
of CO exposure.   In  addition, one subject, later identified as having evidence
of myocardial ischemia, showed marked S-T changes at 15 ppm.   In a  separate pilot
study by these investigators with both smokers  and  nonsmokers at 75 ppm CO (10.9%
COHb in nonsmokers;  14.9% COHb  in smokers) significant  EKG changes were demon-
strated in  7 of  10  subjects.   In most cases,  the CO-induced changes  remained
after exposure ceased.   The authors  concluded  that  P-wave abnormalities demon-
strated in  this  study  were  due  to interference of  normal  atria!  pacemaking or
conducting  tissue activity  by CO.   In addition, they  speculate  that  CO has a
specific  toxic  effect  on the myocardium  rather than (or in addition  to)  a
generalized  decrease in 02  transport  to the  tissue.

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     Most animal studies  on  the cardiovascular effects of CO have been con-
ducted at exposure  concentrations  resulting in rather  high  (>15-20 percent)
COHb levels.  Only  two  studies are relevant for present discussion.  Becker
and Haak (1979) exposed 11 adult mongrel dogs to increasing  concentrations of
CO 1 hr. after  coronary artery ligation.  These sequential exposures produced
step-wise increases in the COHb level  from 4.9% to 17.0%.   Myocardial  ischemia,
as indicated by the amount of  S-T  segment elevation  in  epicardial electrocar-
diograms, increased  significantly at  the  lowest COHb  level and increased
further with increasing CO exposure.   These changes occurred in the absence of
altered heart rate,  blood pressure,  left atria! pressure,  cardiac output, or
blood flow  to ischemic myocardium.  Flow to non-ischemic myocardium increased
with CO exposure at a rate approximately double the  increase in  COHb.  They
concluded that  low  level  exposure  to CO can significantly augment ischemia in
acute myocardial infarction,  apparently through a reduction  in oxygen supplied
to the  ischemic tissue.   They  suggested, however, that  the hypoxia induced by
CO was more severe  than could be  accounted for by a reduction in tissue 0«
delivery alone.
     Foster  (1981)  investigated  the  arrhythmogenic effects  of CO during  the
initial minutes of  acute  myocardial  ischemia in 8 mongrel dogs.  Since each
dog served  as its  own control, brief  occlusions of  the coronary  artery were
performed sequentially both before and after the administration of 100 ppm CO
which  raised COHb  levels  to   10.4%.    Bipolar epicardial  electrograms  were
recorded in each  experiment from  the  ischemic  and non-ischemic  myocardial
zones.   An  additional 6  dogs  were used to confirm  the reproducibility  of
ischemic conduction slowing during successive occlusions in the absence of CO.
There was no significant  increase in  ischemic  myocardial conduction slowing
after  CO.   This lack of  arrhythmogenic  effect  of CO was supported  by the
absence of  increased  incidence of spontaneous ventricular tachycardia during
ischemia after  CO  administration.   The author concludes that clinically  en-
countered COHb  levels may not  have sufficient arrhythmogenic effect to be of
significant health importance  during the initial minutes of myocardial  ischemia.

2.  Neurobehavioral Effects

     The 1979 CO Criteria Document noted that statistically significant effects
on central   nervous system (CNS) functions have been most clearly shown to occur

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at COHb levels of 5-17 percent.   This is indicated by studies which demonstra-
ted decrements  in vigilance, visual perception,  manual  dexterity, learning
ability,  and  performance  of complex sensorimotor  tasks such  as  driving
(Bender et a!., 1971; Schutte, 1973; O'Donnell et a!., 1971; McFarland et al.,
1944;   McFarland,  1973;  Putz et al., 1976;  Salvatore,  1974; Wright et al.,
1973;   Rockwell  and Weir,  1975;  Rummo and  Sarlanis,  1974).   An evaluative
review by  Laties  and Merigan (1979) substantially agreed with these conclu-
sions.  Also,  as reviewed in the 1979 Criteria Document, some studies (Horvath
et al., 1971;  Fodor  and Winneke,  1972; Groll-Knapp  et al.,  1972; Putz et  al.,
1976)  have reported significant decrements in vigilance performance (defined as
the ability to detect small changes in one's external environment occurring at
unpredictable times)  to be  associated with  COHb  levels  in the 3.0-7.6% range;
and one study by Beard and Grandstaff (1975) reported that vigilance effects may
occur  at  levels   as  low as 1.8 percent COHb. The lowest COHb levels at which
vigilance  decrements  occur,  however,  are a matter of considerable dispute in
view  of numerous  other  studies  not finding such effects at COHb levels below
5.0 percent  (Haider  et al.,  1975; Winneke,  1974;  Winneke  et  al.,  1976;
Christensen et al., 1977;  Benignus and Otto, 1977).
     Since the writing of the 1979 Criteria Document, several new studies have
been published which contribute to the data base of CO-related neurobehavioral
effects.   In  the  following,  each  of the  several  neurobehavioral endpoints are
re-evaluated by integrating new findings.

Vigilance—Si nee the  1979 document was written, several  new pieces of research
on CO and vigilance have appeared.  In an evaluative review of the CO-vigilance
literature, Benignus  et al.  (1983) concluded that all of the studies (except
one)  cited in  the  1979 document had serious  credibility  flaws due  to (a)  non-
replication of the work,.(b) gross statistical abuse, (c) non-concentration-
related effects or (d) combinations of the above.
     The single study from the  1979 document  which  had  no  serious flaws was
that  of  Putz  et al.   (1976),  which  demonstrated  vigilance decrements at 5%
COHb.   Since  that  time  the same group of  researchers  have  replicated these
results on independent  subjects  (Putz  et al. , 1979) and have reported their
earlier results in peer-reviewed  literature (Putz,  1979).   The fact that the
experimental  design  and details  of the tasks  were  not  the  same in the two
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experiments implies that  the  effects were robust and thus lends further cre-
dibility to these results.  The credibility  of these  findings would  be  appre-
ciably increased if an  independent group  of  researchers  also were  to success-
fully replicate the study.
     Three other articles on CO and vigilance have appeared since 1979  (Benignus
et a!.,  1983,  Davies et al.}  1981, Roche  et  al.,  1981).   All of  them achieved
COHb levels of 5-7%.   None of the studies found significant effects on vigi-
lance.    It  is  noteworthy  that all of them used vigilance paradigms  different
from those of Putz et al (1976).   Quite possibly the parameters and  conditions
under which vigilance was studied are sensitive so that unless the proper con-
ditions exist, the effects of such COHb levels will not be detected.
     It appears safe to conclude that, at least under some conditions,  reliable
but small decrements in vigilance occur at about 5% COHb.  The fact  that 5% and
higher levels of COHb were not observed to produce vigilance decrements in many
studies is probably a reflection of (a) low experimental test sensitivity in the
those cases or (b)  the small  effects of CO at these levels coupled with what
is probably a  rather  low-slope concentration-effects curve in the region of
COHb less than 20%.   It must be emphasized that these explanations for  the many
no-effect studies are conjectural.

Sensory and Time Discrimination—Benignus et al.  (1983)  concluded  that no
highly reliable  evidence  for  time discrimination  decrements exists.   The ele-
gant concentration-related decrements  in  dark adaption beginning  at 5% COHb
demonstrated by McFarland et al.  (1944) remain to be replicated.   The importance
of replication should not be overlooked since the decrements were (a) dose-related
and (b) showed a decrement at the lowest non-zero COHb level.
     Davies et  al.  (1981)  tested visual sensitivity in dark adapted subjects
who had  been exposed continuously to  50 ppm  CO for a  total of 5  days (COHb of
7% by the  end  of each  day).   They reported no effects of  CO.  Luria  and McKay
(1979) reported that untrained observers showed no decrement in a night vision
test, eye movement or visual  evoked potential at COHb levels of 9 percent.   The
fact that  McFarland et al.  (1944) used bolus exposure  methods,  whereas the
above investigators used continuous low level exposure,  is perhaps significant.
McFarland et al. (1944) also used highly trained observers, which had the effect
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of reducing variance and thus increasing the sensitivity of their study.  Cer-
tainly the McFarland et al.  (1944) study cannot be said to have been invalidated
by newer data.
     Some support for visual sensitivity decrements due to CO has been provided
by a  study measuring the  electroretinogram  in  anesthetized cats  (Ingenito  and
Durlacher, 1979).  When cats were exposed to 1000 ppm CO the electroretinogram
was decreased in amplitude by 30 minutes after the start of exposure, at which
time  the  mean COHb  was 7.5%.  Further  decreases were  concentration-related.

Complex Sensorimotor Performance and Driving--The  conclusion  of the  1979
document, that driving-like tasks are impaired at COHb levels of 5% or greater,
has since been substantially strengthened.  Three articles have been published
(Putz et  al., 1976,  1979; Putz, 1979), using variations of the same task and
experimental  design but in two independent groups of subjects.  In all c^ses, it
was reported  that 5% COHb produced decrements in compensatory tracking, a hand-
eye-coordination task.   In -all cases, however, the decrements occurred only during
high task difficulty.   Other tasks such as reciprocal tapping and digit manipula-
tion  were  not affected by COHb  levels  of up to 5%  (Mihevic  et  al.,  1982).

Sleep and Activity—Although there  has  been one new publication in this area
(Groll-Knapp  et al., 1982), the conclusions remain the same.   Marginal increases
in  deep  sleep and  concomitant decreases  in  rapid-eye-movement  sleep were
reported at 8% COHb due to exposure to 100 ppm CO for 8 hrs.  during sleep.   As
before, the  changes  did not reach  statistical  significance  when appropriate
corrections are made (Benignus and Muller, 1982).

Central Nervous System Electrical Activity—No significant changes have occurred
in this  area  of  research since  1979.   Marginal, nonsignificant  effects  have
been  reported by Benignus et  al.  (1983)  in the electroencephalogram  alpha
frequency band and  by  Groll-Knapp et al.  (1982) on  evoked potentials.   Both
groups of investigators produced COHb levels of 5-6 percent.

3.  Effects of CO Exposure on Fibrinolysis

     An area  of  growing interest, which was not extensively discussed in the
1979  Criteria Document,  concerns possible effects  of CO on fibrinolysis.   The

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fibrinolytic system  is  an integral  part of homeostatic mechanisms and it has
been suggested  that  derangement of that system  may  contribute  to  the patho-
genesis of  thrombosis.   The plasminogen activator may  be  released from the
blood vessel wall  by a variety of stimuli, including anoxia, electric shock,
and either  local  or  systemic administration of vasoactive substances such as
epinephrine, acetylcholine,  serotonin,  or  histamine.  The  finding  that  anoxia
can release plasminogen  activator has  suggested to investigators that  the
presence  of COHb  with its  associated anoxia  could also be associated  with
increased plasminogen activator.
     Resting fibrinolytic  activity is often low  and  its measurement may yield
conflicting  results  that  do not readily permit intra-individual comparisons.
The relationship  of  tissue activator to vascular  activator suggests that they
are components of two separate fibrinolytic mechanisms:  (1)  the vascular acti-
vator being part of a humoral system whose main role is maintenance of vascular
patency and  (2) the  basic activator concerned with  tissue repair and wound
healing.

Animal Studies—Fibrinolytic  activity was  studied in 12  rabbits  (6  control
rabbits)  exposed  for 8 weeks  to an ambient concentration of 50  ppm CO (Kalmaz
et al., 1977).   The control animals had COHb levels of approximately 6%, while
the CO-exposed  animals'   COHb,  for  some unexplained  reasons,  continued to
increase, finally  stabilizing at 30.9%.  Significant  increases  in  whole  blood
clotting  time,  serum fibrin/fibrinogen  degradation products, and acceleration
of whole  blood  clot  lysis occurred.   Euglobulin lysis time was significantly
accelerated by the end of the first week of exposure.  Although these fibrino-
lytic activity  changes  are of interest, their relationship to CO exposure is
far from clear.
     In another study,  Kalmaz et  al.  (1978) exposed  rabbits to 50 ppm  for 8
weeks or to 300 ppm for 4 weeks.   A second group of rabbits exposed to 300 ppm
CO were given epsilonaminocaproic acid.   Acceleration of the whole blood clot
lysis and euglobulin lysis times  was observed.   Microscopic  examination of
large vessels showed  endothelial damage  -  a possible  source for a  plasminogen
activator  release.   A more  recent  study by Kalmaz et  al.  (1980)  involved
exposing  rabbits  to  ambient air,  50 ppm CO for 24 hours/day continuously (8
weeks),  and  300 ppm  CO for 24 hours/day  continuously  (4 weeks).  They found a
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consistent change  in circulating platelet  quantity  for CO-exposed rabbits.
However, their  conclusion  that prolonged exposure to  low levels of CO may
influence changes  in  circulating platelet counts and/or  congenital platelet
function disorders in man is yet to be confirmed.
     In a recent in-vitro study by Hartiala et al. (1982) 5-minute exposure to
100% CO was  found to have neither an  effect  on  the  decrease  in  prostacyclin
(PGI2) production  nor a direct effect on ADP-induced  aggregability of  human
platelet rich plasma.  This led the authors to conclude that CO is not respon-
sible  for  the temporary increase in platelet aggregability after cigarette
smoking.

Human Studies—Workers  chronically exposed  to high  levels of carbon monoxide
(approximately  100 ppm  with occasional  levels of 200-400  ppm) were studied by
El-Attar and Sairo (1968).   They found an accelerated clot lysis time suggestive
of an enhancement of  blood fibrinolytic activity.  Levels of COHb present were
only crudely  determined and were not related to any specific individual.   CO
poisoning of  21  workers was suggested  by  the  presence  of  subjective symptoms,
headache, blurred  vision,  etc.   Twenty-eight workers, presumably some of the
first group of 21, were  restudied after one day exposure to ambient CO (levels
not given).  This group  also exhibited accelerated lysis times but to a lesser
degree.  In  15  control  subjects no fibrinolytic  activity could  be detected.
This  study,  although suggestive,  was  too poorly controlled  to  be of real
value.  A  similar suggestive  study was made by Alexieva et al.  (1975) on 100
workers in a coke-chemical  plant.   Some increase in fibrogen was observed  in
these  chronically exposed individuals.   Panchenko  et al. (1977)  have  also
suggested that  a relationship between blood coagulation and CO existed.  The
data presented are far  from conclusive.
     The possibility that exposure  to other  substances  in  addition  to CO
resulted in  alterations of fibrinolytic activity was evaluated by Janzon and
Nilsson (1975).  Smokers and nonsmokers were studied by techniques superior to
those  used by the above investigators.  Smokers  and nonsmokers  had the same
fibrinolytic activity when smokers were studied after 12 hours abstention from
smoking.  Smoking 6 cigarettes during 3 hours was associated with an increased
fibrinolytic activity in blood.  They believed that  this  increase was probably
due to  the  combined   effects of  nicotine  and  carbon  monoxide.    Mansouri  and
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Perry (1982) studied the alteration of platelet aggregation by cigarette smoke
and carbon  monoxide.   Inhalation by healthy adults of CO sufficient to raise
the COHb  level  to  between 4.5% and 11% was found to be responsible for inhi-
bition of platelet  aggregation,  which returned to  normal  after  five hours.
However, there  was  no  consistent correlation  reported  between  COHb  levels  and
alterations in platelet aggregation.
     Brinkhouse (1977) exposed 23 men (15 nonsmokers) for 4 hours to either 0,
50, or 100 ppm CO.   COHb levels on the days of carbon monoxide exposure reached
2.17% (50 ppm) and 4.15% (100 ppm).  Studies on blood coagulation were made by
the best and most sophisticated techniques.  Platelet count, prothrombin time,
partial thromboplastin time, thrombin time, fibrin split products, factor VIII,
and platelet  aggregation were  determined before  and  after the  exposure.
Coagulation parameters were not significantly affected by the CO exposures.  A
review by Haft  (1979)  discusses the role  of  platelets in the etiology and
natural history of coronary artery disease.  It is clear that smoking increases
the activity of platelets and cigarette smokers have shortened platelet survival
time.   Endothelial  injury may be facilitated by serum CO, by levels of circulating
catecholamines, and other factors.
     In conclusion, the effects on fibrinolytic activity of exposure to carbon
monoxide are  far from  clear.  The  studies  on  acute  exposure to CO do  not spe-
cifically implicate this pollutant in the observed alterations in fibrinolytic
activity, and the  studies  on chronic exposure are  too poorly controlled to
confirm any definite effects on the blood coagulation system.

4.  Suggestive Evidence for Perinatal CO Effects

     The  Criteria  Document  (U.S. EPA, 1979)  provides  discussion  of results
from certain  animal  toxicology  studies which point toward the possibility of
CO exerting perinatal effects on the fetus or newborn.   With long-term exposures
of pregnant animals to CO, fetal COHb levels have been shown to be higher than
maternal COHb levels  and fetal  elimination of CO was slower than maternal  CO
elimination.  The ability of CO to decrease the oxygen transport capacity of
maternal  and  fetal  hemoglobin  may result in  interference  in  fetal  tissue
oxygenation during important developmental stages.  Whereas normal adults have
reserve capacity and compensatory responses which enable them to handle moder-
ately high  COHb levels without  irreversible consequences, the  fetus may under

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normal situations be  operating close to critical  levels  in terms of tissue
oxygen supply.  Thus, even moderate CO exposures may have a deleterious effect
on fetal development  (Longo,  1977) but this, too, remains to be demonstrated
along with pertinent  dose-response relationships.   In several animal studies
in which pregnant females  were exposed to  CO,  deleterious  effects were gen-
erally reported in the offspring (e.g., reduced birthweight, increased newborn
mortality,  and  lower  behavioral  activity levels) even when no effects on the
mothers were  detected.   In human studies, similar effects have been reported
in children of mothers who smoked cigarettes during pregnancy, suggesting that
expectant mothers  and their  unborn  children may also represent  population
groups at special risk for CO effects, but this  remains to be more clearly
defined along with any pertinent dose-response relationships.
     Sudden  infant  death  syndrome  (SIDS)  is characterized by the sudden,
normally unexplained  death of an  infant.   Research has suggested numerous
possible etiological  factors  (e.g.,  disease, temperature, maternal  smoking,
and pollutant  levels),  but numerous questions remain regarding which are the
most significant factors involved.  Seasonal incidence of SIDS has been studied
in several epidemiology  studies  (Peterson,  1966; Bergman et a!.,  1972; Bonser
et a!.,  1978).   A pattern which appears to be consistent across countries in
the northern hemisphere is increasing incidence in October, peaking in December
and January,  remaining high until May, and  then declining sharply  in June  and
remaining low until  October.
     CO has  been hypothesized to be associated with  seasonal  variations  in
SIDS incidence  rates, based on certain epidemiologic data.  Hoppenbrouwers et
al. (1981)  have reported that increased seasonal  incidence of SIDS in Los
Angeles County  during winter  may be at least partially  explained by higher
levels of CO,  sulphur dioxide (S02), nitrogen dioxide (N02) and hydrocarbons
(HC).   They  suggest  that higher ambient levels of these pollutants may be
implicated in  chronic  hypoxia which often precedes death from SIDS.   Related
to this  hypothesis, they found that  SIDS cases  in  LA were correlated to daily
mean levels  of  the  above pollutants and peaks in these pollutant levels pre-
ceded seasonal  increases  in  SIDS by seven weeks.   The authors further report
that infants  dying from  SIDS  lived longer  (1) if born  in low rather than high
pollution areas and  (2) if born in months of low versus high pollution.
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Finally, a  direct proportionality was reported between exposure to pollution
for  infants  from conception to two months of age and bimonthly rate of SIDS.
     In an editorial letter assessing the results of the Hoppenbrouwers et al.
study, Goldstein  (1982) commented on the presence of indoor sources of CO, NO-
and  lead.   She further pointed out that  during  colder months infants spend
most of  their time indoors where concentrations  of these  pollutants  can  far
exceed ambient levels.   Thus,  she suggests  that  the relationship  between  SIDS
and  ambient  pollution  levels  may  be only  coincidental  and  the evidence  for it
is at  best  suggestive  and in  need of further  confirmation before any causal
relationships  might be inferred.
     Maternal  smoking has been  related to SIDS in several  studies  (Bergman and
Wiesner, 1976;  Lewak et al., 1979; Peterson, 1981).  Because  CO is only one of
numerous pollutants  found in  cigarette  smoke,  however, it is difficult  to
infer  a  causal relationship between CO and  SIDS.   Other factors  associated
with  SIDS  include passive  smoking,  younger maternal  age, short  intervals
between  pregnancies, gestational  age  of less than  40  weeks,  birth weight of
less than 3000 g., lower socioeconomic status, and  male sex.  Thus, the number
.of potentially confounding factors makes finding an association between CO and
SIDS extremely difficult.

                             POPULATIONS AT RISK

     The 1979 Criteria Document directed attention toward identification of
sensitive population  groups at special risk for CO-induced  health effects.
One  key  concept in defining special  risk  groups for CO effects is the idea
that any preexisting  or concommitant physiological or pathological condition
which  interferes  or interacts with oxygen absorption into  blood or its transport
to  and perfusion  of  body tissues can logically  be expected to exacerbate
CO-induced  health effects  associated  with the hypoxic  effects of CO.   Thus,
certain  large segments  of the  general population  can  be reasonably hypothe-
sized  as likely to be at greater  risk for experiencing CO-induced  health  effects
than healthy,  non-smoking adults.
     These probable risk groups include:   (1) fetuses and young infants;  (2) the
elderly, especially those with  reduced cardiopulmonary functions attributable to
a variety of  factors associated with typical aging  processes;  (3)  other,  younger
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individuals with overt,  severe  cardiac damage or acutely severe respiratory
diseases, e.g., pneumonia; (4) individuals with chronic bronchitis or emphysema;
(5) individuals with symptoms (e.g., angina) indicative of chronic cardiovascular
disease; (6) individuals with hematological diseases, e.g.,  anemia that affect
oxygen carrying capacity or transport in the blood;  and (7)  persons with geneti-
cally unusual  hemoglobin  forms  associated  with decreased oxygen capacity.   In
addition to  the above,  one might  reasonably expect that individuals  under  the
influence of certain drugs, used for recreational or medicinal purposes, may be
at greater risk for CO-induced effects due to interactive effects between CO and
certain pharmacological agents.   Lastly, under high altitude conditions (where
reduced levels of atmospheric oxygen exist), increased vulnerability to CO health
effects of both the above sensitive population groups and otherwise, non-sensitive
healthy individuals might be expected.
     As  noted  in the  1979 Criteria  Document,  relatively little  concrete
experimental or observational  evidence currently exists by which most groups
(or conditions) listed abo.ve have been clearly demonstrated to be associated
with  increased risk  for CO-induced  health  effects.  Nor  have  clear-cut
quantitative lowest-observed-effect levels or dose-response relationships been
delineated  for the  occurrence of CO effects among the above "at risk" groups
or in  conjunction with special  interacting circumstances  (i.e., drug usage or
high altitude  living)  that might exacerbate CO  effects.  Only very limited
discussion,  therefore,  can be  provided  here  regarding CO risk factors  and
sensitive groups likely at special risk for CO effects.
     In regard to the first group, fetuses and young infants, certain evidence
was alluded to earlier from animal toxicology studies indicating that higher
levels of COHb and increased CO excretion  time occur among fetuses in compari-
son to  their mothers  exposed to CO;  and some  deficits  in  postnatal  growth  and
development were noted  in the offspring of dams exposed to CO during pregnancy.
Also,  analogous perinatal  effects were noted  in  human  infants  born to mothers
who smoked  during pregnancy, and associations between CO exposure and SIDS  have
been hypothesized.  However, insufficient  evidence exists at this time by which
to estimate  CO exposure  levels  at which any CO effects on human fetuses or  new-
born  infants may  occur or whether the latter  types  of  effects  seen in smoking
mothers  are due specifically to CO  versus other components  of tobacco smoke
either singly  or in combination.
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     Little  specific  evidence directly demonstrates  the  increased vulnera-
bility of  the  elderly for CO health effects  in  precise quantitative terms.
Given the  increased  vulnerability  of  the aged to many different kinds of
stress,  including thermal  stress  (hot  or cold) which taxes decreased reserve
capacities to  maintain adequate  cardiovascular  delivery  of oxygen to  body
tissues, it  must  be expected that CO  exposure would  render the  elderly more
vulnerable to  the effects of other types of  cardiovascular stresses.   Also,
conversely,  it is reasonable to hypothesize that interactive effects involving
other stress factors  might lead to exacerbation of CO-induced health effects
or their  occurrence at lower external CO exposure  levels than  in younger,
healthy adults.   Similarly, younger individuals with overt,  severe cardiac
damage or insufficiency or severe acute respiratory diseases,  e.g., pneumonia,
can be  expected  to  be more vulnerable to CO (i.e.,  either CO exacerbation of
other disease  effects or, conversely,  increased susceptability  to CO health
effects) due to  reduced  reserve capacities to cope with  stress  generally  or
increased  sensitivity of  already  compromised organs  or tissuos,  e.g.,  heart
muscle,  to the hypoxia induced by CO.
     Turning to  individuals with  chronic  bronchitis  and emphysema, again,
reduced reserve  capacities  for  dealing with cardiovascular stresses and al-
ready reduced  oxygenation of blood should exacerbate  or  hasten  the onset  of
health  effects associated  with  CO-induced  hypoxia.   Analogously, angina
patients or  others with obstructed coronary arteries but not manifesting overt
symptoms such as angina,  should be at greater risk for CO health effects.   Both
the Anderson et  al.  (1973)  and  several Aronow publications on angina patients
reported findings previously  accepted  as demonstrating the increased vulnera-
bility of angina patients to CO in terms of hastening of the onset of exercise-
induced angina.  These papers,  furthermore, appeared  to confidently establish
2-3% blood COHb as the range of COHb values associated with the onset of statis-
tically significant  effects  indicative of CO  exacerbation of angina and, pro-
bably, associated hypoxic effects on cardiac muscle.   It is now clear that the
Anderson findings (as of yet not independently confirmed)  can be appropriately
interpreted  as providing  reasonably  good evidence for exacerbation of angina
symptoms occurring at approximately 2.9 to 4.5 percent COHb; and the possibility
of such effects occurring at lower COHb levels (as hinted at by the Aronow studies)
cannot be ruled out at this time.
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     In regard to individuals with anemia being at special risk for CO  health
effects, the  1979  Criteria Document noted that CO  poisoning is similar to
anemia, wherein  the  oxygen capacity of the  blood  is decreased because the
affinity of hemoglobin (Hb) for binding oxygen is  reduced.   The 02 dissociation
curve for anemics is  similar to that for normals except that  it is shifted to
the right.   However,  when curves from individuals  with 50% reductions in Hb con-
tent are compared with dissociation curves for blood with 50% COHb content, there
are striking  differences.   Consequently,  care must be taken  to avoid overly
simplistic  extrapolations  regarding  the  likely  impact  of  particular  CO
exposures on  anemia  patients  due  to additional (CO-induced) reductions of b*
carrying capacity beyond the  reductions already evident in their blood.  The
soecific CO exposure  levels and associated blood COHb concentrations at which
anemia patients may be at increased risk for specific CO health effects remain
to be  clearly delineated,  but little doubt  exists  regarding the  likelihood
that the effective CO exposure (and COHb)  levels are distinctly lower than for
healthy, non-anemic individuals.
     Another  logically-hypothesized "at risk" group for CO effects are individuals
with unusual  hemoglobin types that result in chronic elevations of COHb blood
levels even in the  absence of external CO exposure.   Normal adult hemoglobin
has a  relative affinity  or equilibrium constant (M) for CO  of about 200 for
most animal species,  but  has  been reported  to  be  as high as 240 to 250 in
humans (Roughton, 1970).   There are approximately 350 human hemoglobin variants,
including those found in the fetus, sickle cell anemics,  and other individuals
with hemoglobinopathy (hemoglobin disorders).  Approximately one fourth of the
hemoglobin variants now known are considered unstable,  i.e., they denature and
precipitate when  red blood cells  or hemolyzates  are exposed to  heat,  red
oxdyes, or isopropanol (Bunn et al.,  1977).   One of these variants,  hemoglobin
Zurich (HbZ)  has been found to  have an  affinity for CO which  is approximately
65 times that of normal  hemoglobin (Zinkham et al., 1980; Giacometti  et al.,
1980; Zinkham et al., 1983).  This results in chronic elevation of endogenous
COHb levels ranging from 3.9 to 6.7% in nonsmoking HbZ individuals.
     As for possible drug-induced  enhancement of CO effects,  whereas  there
exists little specific data directly supporting the idea,  it is  logical  to
suspect that  individuals who use certain drugs would be at increased risk for
experiencing  health  effects associated with  CO exposure.   For example,  drugs
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with primary or secondary CMS depressant effects should be expected to exacer-
bate neurobehavioral  effects  of  CO;  and  drugs  which  have  primary  or  secondary
cardiac stimulant  effects might  worsen CQ-related  cardiac effects.   Any  vaso-
constrictive drugs  would be expected to  reduce 0,,  delivery to  various  organs,
thus also  exacerbating CO effects  on exercise, cardiac  or  neurobehavioral
function.   Further  speculations  about drug-CO  interactions are possible, but
it should be emphasized that these are predictions based  on theoretical grounds
that rely  heavily  on our current understanding of hypoxia being the likely
main mechanism  underlying the induction  of CO-induced health effects.  Unfor-
tunately,  few  data currently  exist  by which  to judge the likely  validity of
such speculations.
     Hypothesized  enhancement  or exacerbation of CO  health effects  under high
altitude conditions,  similarly,  rests heavily  on hypoxia  being the key mechan-
ism of  CO  toxicity.  The interactive effects  of high  altitude hypoxia and CO
exposure,  however,  appear to  be more complex than might be  simplistically
expected (Collier and Goldsmith, 1983).  For example,  the 1979 Criteria Document
notes that adaptation to high altitudes occurs  and alludes to the fact that,
analogously, adaptation  to  CO may alter the  position of  the 02  dissociation
curve as  a function of extensive prior CO  exposure.   Thus, individuals living
in high altitude situations with frequently elevated  ambient air  CO  levels may
adapt to  both  the  high altitude  and CO-induced hypoxia, whereas  other  indivi-
duals newly  entering high altitude  and  elevated ambient  CO conditions might
experience CO  effects at concentrations below those  effective at lower alti-
tudes.

                            SUMMARY  AND  CONCLUSIONS
     As was  stated at the  outset,  the main purpose of the present addendum is
to  re-evaluate  the scientific data  base concerning health effects associated
with  exposure  to  CO at ambient or  near-ambient exposure levels.  The  re-
evaluation  includes  both (1)  summarization  of information contained in  the
revised  EPA  Air Quality Criteria Document  for CO (U.S. EPA,  1979) and  (2) new
information  and  studies that  have become available beyond what was reviewed in
the  1979  document.   The most  important points of information reviewed  and key
conclusions  derived from this  evaluation of the CO health effects data base are
summarized below.
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Mechanisms of Action—The binding  of CO  to  hemoglobin,  producing  COHb  and  de-
creasing the oxygen carrying capacity of blood, appears to be the main mechanism
of action underlying the induction of toxic effects of  low-level CO exposures.
The precise  mechanisms  by  which toxic effects are induced via COHb formation
are not yet fully understood, but likely include the induction of a hypoxic state
in many tissues of diverse organ systems.  Alternative mechanisms of CO-induced
toxicity (besides COHb)  have been  hypothesized, but none  have yet been  demon-
strated to operate at relatively low (near-ambient) CO  exposure levels.  Blood
COHb levels, then, are currently accepted as representing a useful physiological
marker by which to estimate  internal CO  burdens due to  the combined contribu-
tion of  (1)  endogenously derived CO and (2) exogenously derived CO resulting
from exposure  to  external  sources of CO.   COHb levels  likely to  result from
particular patterns  (concentrations, durations, etc.) of  external CO exposure
can be reasonably well estimated from equations developed by Coburn.

CO Exposure Levels—Evaluation  of  human  CO  exposure situations  indicates that
occupational exposures  in  some workplace situations can regularly exceed 100
ppm CO, often leading to COHb levels of 10 percent or more.   In contrast,  such
high exposure levels are much less commonly encountered by the non-occupationally
exposed general public.  More  frequently, exposures to  less than  25-50  ppm CO
for any extended period of time occur among the general  population and, at the
low exercise levels usually engaged in under such circumstances, resulting COHb
levels most typically remain below 2-3 percent among non-smokers.   Those levels
can be compared to the physiologic norm for non-smokers, which is estimated to
be in  the  range  of 0.3 to 0.7 percent COHb.  Baseline  COHb concentrations in
smokers, however, often  greatly exceed 1 percent,  reflecting absorption of CO
from inhaled smoke.

Health Effects of Low Level CO Exposures—Four types of health effects reported
or hypothesized to be associated with CO exposures (especially those producing
COHb levels below 10 percent) were evaluated:   (1) cardiovascular effects;  (2)
neurobehavioral effects; (3) fibrinolysis effects; and  (4) perinatal effects.
In regard  to cardiovascular effects,  decreased  oxygen  uptake capacity and
resultant decreased work capacity  under  maximal exercise  conditions have been
clearly shown  to  occur  in  healthy young adults starting at 5.0 percent COHb;
                                     24

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and one study observed  small  decreases  in work  capacity  at  COHb  levels  as  low
as 3.3 to 4.3%.   These  cardiovascular effects  may  have  health implications
for the general  population in terms of potential curtailment of certain physi-
cally demanding occupational or recreational activities under circumstances of
sufficiently high CO  exposure.   However,  of greater concern at  more typical
ambient CO exposure levels are certain cardiovascular effects (i.e., aggravation
of angina symptoms during exercise) likely to occur in a smaller, but sizeable,
segment of the general population.  This group,  chronic angina patients, is pre-
sently viewed as the most sensitive risk group for CO exposure effects, based on
evidence for aggravation of angina occurring in patients at COHb levels of 2.9
to 4.5 percent  COHb.   Such aggravation of  angina is thought to  represent  an
adverse health effect for several reasons articulated in the 1980 proposal pre-
amble (45 FR  55066),  and the Clean Air Scientific Advisory Committee (CASAC)
concurred with  EPA's  judgment on  this matter  (see Appendix  B).   Dose-response
relationships for cardiovascular  effects  in cororary artery disease patients
remain to be more conclusively defined, and the possibility cannot be ruled out
at this time  that such  effects may occur at levels  below 2.9 percent COHb  (as
hinted at by the results of the now-questioned Aronow studies).
     No reliable evidence demonstrating decrements in neurobehavioral function
in healthy young  adults has been reported  at COHb  levels below  5%.  Much  of
the research  at  5%  COHb did  not  show any effect even when  behaviors similar
to those affected in  other  studies were involved.   However, if any  CO effects
on neurobehavioral functions in fact occur below 5% COHb, then none of the sig-
nificant-effects studies would have found such decrements,  because none of them
used COHb levels below 5%.  Other workers who failed to find CO decrements at 5%
or higher COHb  levels may have employed tests  not  sufficiently  sensitive  to
reliably detect small effects of CO.   From the empirical evidence, then, it can
be said that  the COHb levels  in the 5%  region do produce decrements  in  neuro-
behavioral  function.  However, it cannot be said confidently that COHb  levels
lower than 5% would be  without effect.   One important point made in the 1979
document should be reiterated here.   Only young, healthy adults have been stu-
died using demonstrably sensitive tests and COHb levels of 5% or greater.  The
question of groups  at special risk for CNS effects, therefore,  has  not been
explored.   Of special note are those individuals who are'taking drugs which have
primary or secondary  depressant effects which would be expected  to  exacerbate
CO-related neurobehavioral decrements.   Other groups at possibly increased risk

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                                                                      8/22/83

for CO-induced neurobehavioral effects are the aged and  ill but these groups,
also,  have not been evaluated for such risk.
     In contrast to the data available which demonstrates associations between
cardiovascular and neurobehavioral  effects  and relatively low-level CO expo-
sures, much less clear evidence exists for other types of health effects being
associated with  low-level  CO exposures.   For example, only  relatively weak
evidence points towards possible CO effects on fibrinolytic activity and, then,
generally only at  rather high CO exposure levels.  Similarly,  whereas certain
data are also suggestive of perinatal effects (e.g.  reduced birth weight, slowed
postnatal development,  Sudden Infant  Death Syndrome)  being associated with CO
exposure, insufficient  evidence  presently  exists by which to  either confirm
such associations  qualitatively  or  to establish  any pertinent  exposure-effect
relationships.

Population Groups at Risk for Ambient CO Exposure Effects—Angina patients or
others with  obstructed  coronary  arteries, but not yet manifesting overt  symp-
tomatology of coronary  artery disease,  appear to be  best established as a
sensitive group within  the  general  population that is at increased risk for
experiencing  health effects  (i.e. exacerbation of cardiovascular symptoms) of
concern at ambient or near-ambient CO exposure levels.  Several other probable
risk groups  were  identified,  i.e.:    (1) fetuses and  young  infants;  (2) the
elderly  (especially  those  with  compromised  cardiopulmonary  functions);  (3)
younger individuals with severe cardiac or acutely severe respiratory diseases;
(4) individuals  with  chronic bronchitis or  emphysema; (5)  individuals  with
hematological diseases  (e.g.  anemia)  that affect oxygen carrying capacity or
transport in the blood; (6) individuals with genetically unusual forms of hemo-
globin associated  with  reduced  oxygen carrying capacity; and (7) individuals
using medicinal or recreational  drugs having CNS depressant properties.   However,
little emperical evidence currently is available by which to specify particular
COHb levels at which such individuals are likely to experience specific health
effects associated with ambient or near-ambient CO exposures.   Nor does unambi-
guous evidence yet exist which clearly establishes that  healthy non-sensitive
individuals or those in the above probable risk categories are affected at lower
CO exposure levels under high altitude conditions than CO exposure concentrations
effective at lower altitudes.
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                 APPENDIX A

   EPA HEALTH EFFECTS RESEARCH LABORATORY
REEVALUATION OF ANDERSON ET AL.  (1973) STUDY
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                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           HEALTH EFFECTS RESEARCH LABORATORY
' «o                              RESEARCH TRIANGLE PARK
                                 NORTH CAROLINA 27711
    DATE:   August 19,  1983

 SUBJECT:   Evaluation  of Anderson  et al.  (1973) Study of Carbon Monoxide (CO)
           Effects on  Angina Patients.

    FROM:   John J. O'Neil, Ph.D.,  Chief
           Clinical Research Branch, ITD/HERL

      TO:   Lester D. Grant, Ph.D.
           Director, ECAO (MD-52)
           THRU:   F. Gordon Hueter, Ph.D., Director
                  Health Effects Research Laboratory, RTP (MD-58)
      Thank you for the opportunity to comment on the paper by Einar Anderson
 and his co-workers which is entitled "Effect of Low-Level Carbon Monoxide
 Exposure on Onset and Duration of Angina Pectoris."  I have re-read it,
 have discussed it with several colleagues, especially Dr. Vernon Benignus,
 and would offer the following observations by way of review.

      This is a good paper.  The work appears to be carefully done, the
 data seem reasonable, and the paper is well written.  Critical review
 reveals some flaws in the design and conduct of the research, but this is
 typical of most scientific work and, therefore, significance of these
 comments may be interpreted differently by different readers.

 DESIGN
      1)  ST segment depression reported in this paper is not useful
 and does not constitute any physiological support to the observations
 regarding the onset and duration of angina.  The authors recognize this
 shortcoming.  The important data in the paper are the measurement of time
 to onset of pain and the measurement of the duration of pain.

      2)  The paper would have been considerably strengthened by more
 careful selection of the subject population.  For example, 5 subjects
 were smokers and 5 were non-smokers and one subject was taking digitalis.
 In my opinion, the study would have been strengthened considerably had
 the subject population been more homogeneous.

      3)  It is unclear to me if the study is really double blind.  That
 is, did the investigator who administered the gases also interact with
 the subjects by, for example, placing the mask on the subject.  Such
 interactions would make the study not a true double blind design.

      4)  The number of subjects (n) is very small.  Only ten subjects
 were studied and of these there are three for whom there are missing data
 points.  I have been told anecdotally that this study was intended as
 a pilot study.  It is unfortunate that it was not possible to design
 and complete the proper follow-up study.  Given the situation, this is
 valuable data to have published and should be used to develop our under-
 standing of the response of angina patients to CO.

                                  A-2

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METHODS AND RESULTS

     1)  It is disconcerting that the measured COHb levels appear to be
lower than we would predict on the basis of our knowledge of CO-COHb
kinetics.  Why is this measured value lower than we would expect?

          a)  Measurement of COHb.  The measurements were done in
     triplicate using the Buchwald analysis.  As best as I can determine,
     these estimates of COHb are accurate and there is no reason to doubt
     their validity on the basis of technique or equipment.

          b)  It is also possible that the exposure mask used in this study
     was loose fitting and leaked.  This would reduce the exposure level
     and the final COHb levels.

          c)  Though not reported in the paper, the subjects were apparently
     allowed to rest ad libitum during the study.  This amounted to approxi-
     mately 10-15 minutes out of the hour.  This "rest" period would have
     reduced the exposure time an
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                     Table 2.  Time to Onset of Pain
                               Mean (Range)

           Mon (Air)                          294   (215-480)

           Air (Control)                      325   (220-435)

           50 ppm                             264.5 (65-390)

           100 ppm                            263.5 (85-425)

           Friday (Air)                       300   (185-485)


The exposures on Monday and Friday were included to demonstrate the com-
parison of two air exposures separated by the study itself.  The air
control and the exposures to 50 or 100 ppm CO were randomized on Tuesday
Wednesday and Thursday. The data for Monday and Friday are both considerably
closer to the data for 50 and 100 ppm CO exposure than to that for the air
control.  This is, I believe, associated with the small number of subjects
used in the study.  Dr.  Benignus and his colleagues analyzed the data for
the different air days and did not show any significant differences
between these days.

STATISTICAL ANALYSIS

     Dr. Benignus has developed an analysis of the paper by Anderson et
al. and I have excerpted part of his critique here.
             Critique of the Study by Anderson et a!U  (1973)

                            Vernon A. Benignus
          The statistical tests used in the study were anticonserv-
     ative  (Benignus and Muller, 1982) and thus would have tended
     toward showing a significant effect even if none were present
     in the population.

          The data of Anderson et al. were reanalyzed using one
     multivariate analyses of variance for each of the two measures
     (time to onset of angina and duration of angina).  Multivariate
     tests were used because the data for 0, 50 and 100 ppm exposure
     were collected from the same subjects.  Since two separate
     significance tests were to be run (one for time to onset and
     one for duration) Bonferroni corrections were used to keep
     experimentwo.se a = .05.  Each test would then be evaluated
     at a/2 = .025.
                                    A-4

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            Table A.  Overall Test Results
Variable
Time to Onset
Duration
F
7.72
3.10
df
2,8
2,7
P<
.014
.11
Table A shows the results of the overall tests.  This table
agrees with Anderson et al.  that time to onset of angina
would have been significantly affected by CO exposure but
does not agree with Anderson e_t al. that duration of Angina
is affected by CO exposure.  Stepdown tests of the time to
onset data revealed that the 50 ppm exposure showed a CO
effect, p<.017 and the 100 ppm exposure showed a CO
effect p<.002.
        Table B.  Means of Time to Onset Data

   CO Level	Mean time to onset of Angina

   0 ppm                        310

  50 ppm                        265

 100 ppm                        264
Table B shows  the mean  times  to onset for  the  0,  50,  and
100 ppm exposure days.  While both  the  50  and  100 ppm
exposures produced shorter  times  to onset,  they did not
differ among themselves.   (The fact that the p value  for
the 100 ppm day was  lower than for  the  50  ppm  day was due
to the fact that the data on  the  100 ppm day were more
closely correlated with the 0 ppm values.   Thus Table B
shows a puzzling non-dose-related finding.)

     Inspection of Table 1  in Anderson  e_t  al_.  (1973),
reveals that all COHb values  were related  to  the  exposure
level so that  the non-dose-related  findings in time to
onset remain unexplained.   To be  sure,  the variability;
was high on all days and with the small number of subjects,
such non dose  related findings can  occur even  if  the  effects
                          A-5

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          are dose related in the population.  This is especially
          true since the COHb values were both close to the lower
          limits for CO effects and the general dose-effects curve
          can be plausibly argued to have a rather low slope.


          The tests of signficance employed in this critique are
     quite conservative.  Thus, the fact that significant results
     would have been reported even if appropriate and conservative
     tests had been done, lends credibility to the study.  On the
     other hand, the non dose related findings are mildly disturbing.
     Considering (1) the small number of subjects, (2) the high
     variability of the data, (3) the fact that both doses were
     near the no-effects level and (4) the low p values on the
     significance tests, the data are strongly suggestive of an
     effect but are sorely in need of replication and extension.
     More subjects should be run and a wider dose range
     should be studied to be able adequately to quantify a
     dose-effects curve.

Conclusions

     Several aspects of the study were of above average quality.  The study
was conducted in a double-blind fashion; very commendable, especially by
comparison to the extant literature.  Only a small number of variables
were studied, thus minimizing the chances of finding some spurious variable
which accidentally covaried with CO exposure; another positive quality.

     When compared to an ideal study the study by Anderson et al. has
several flaws in its design and execution and the results have inconsistencies.
However, when compared to the extant literature, the design and execution
of this study is commendable.  None of the inconsistencies are of a major
nature and several plausible explanations exist for them.  The results of
this study suggest that angina is exacerbated by small increases in COHb.

     This study is sorely in need of replication and extension.  More subjects
should be run and a wider dose range should be studied to be able to adequately
quantify the dose response relationships.  Even if no inconsistencies were
present in this study, it would be rash to rely entirely upon one study
with 10 subjects.  It would be equally irresponsible to disregard these
findings.  The greatest imprudence would be to fail to do the studies
sugested by these results.
                                  A-6

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                                           8/22/83
            APPENDIX B

 CASAC LETTER (AUGUST 31, 1982) TO
EPA ADMINISTRATOR CONCERNING ISSUES
INVOLVED IN SETTING OF NAAQS FOR CO
                 B-l

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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON. D.C. 20A60
                           August 31, 1982
                                                          OFFICE OF
                                                       THE ADMINISTRATOR
Mrs. Anne M. Gorsuch
Admini strator
U.S. Environmental Protection Agency
Washington, D.C.  20460

Dear Mrs. Gorsuch:

     The Clean Air Scientific Advisory Committee (CASAC) met
on July 6 to provide its advice on several issues related to
the ambient air quality standard for carbon monoxide.  The
Committee had previously advised the Administrator of the
scientific adequacy of the criteria document and staff paper
in a closure memorandum dated October 9, 1979.

     At its most recent meeting the Committee provided advice
to the Agency on four issues.  These included:  1) setting a
revised eight-hour carbon monoxide standard that includes five
allowable exceedances; 2) the role and significance of the 1981
study published by Dr. Wilbert Aronow; 3) sensitivity analysis
and exposure analysis predictions of carboxyhemoglobin (COHb)
levels and ambient CO concentrations under alternative air
quality standards;. 4) range of scientifically acceptable
alternative standards for CO.

     I would like to briefly summarize for you the Committee's
views on each of these issues.

     1.  Development of a Multiple Exceedance 8-Hour Standard.

     The CASAC reached a consensus that a multiple exceedance
standard has both scientific as well as administrative merit.
From a scientific point of view this approach recognizes the
stochastic or random-like character of meteorological events;
administratively, it reduces the exement of chance in determining
compliance with the standard.  In recommending that you adopt
a multiple exceedance standard, the Committee notes that an
increase in the number of allowable exceedances will, in effect
relax the existing standard if the standard level 'remains
unchanged.  In order to provide protection to the public health
with an adequate margin of safety you should consider the impact
of a multiple exceedance standard upon ambient CO concentrations
and levels of blood COHb.
                             B-2

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     2.  Role of the 1981 Aronow Study.

     CASAC reached no overall consensus on the significance
which the Agency ought to attribute to the Aronow study.  The
study reported a 10 percent reduction in the time to onset of
angina during treadmill exercise at blood carboxyhemoglobin
levels of 2 percent.  CASAC discussed the fact that the response
observed at 2.0% COHb was more subtle than that observed at
higher levels (2.7 - 2.9% COHb) and speculated that even more
subtle responses might be found at COHb levels below 2.0%. - The
Committee concluded that there may be no physiological response
threshold for carbon monoxide.  One CASAC consultant, while
noting that the study data are solid and irrefutable, concluded
that activity and exposure patterns of angina patients are far
different from the general population.  He also observed that
there is no reason to believe that changes in the time of
onset of angina during treadmill exercise are a valid biologic
endpoint for the determination of an adverse health effect.
Another Committee consultant, however, concluded that shortening
of exercise time prior to the onset of an angina attack clearly
is an adverse health effect.

     While reaching no consensus on the role of this study, the
Committee's earlier position as stated in the October 9, 1979
closure memorandum — that.the critical effects level for COHb
occurs between 2.7% - 3.0% and that the onset of angina represents
an -adverse effect — remains as the CASAC consensus on this
issue.

     3.  Scientific and Technical Adequacy of Sensitivity and
         Exposure Analyses.

     The sensitivity and exposure analyses were prepared by the
Agency to compare the relationship between ambient CO concentrations
and various levels of blood COHb.  In addition, the analyses
estimated the number and distribution of individuals who were
projected to experience various COHb levels under alternative
CO standards.

     CASAC has reviewed the exposure and sensitivity analyses
and has concluded that both are scientifically acceptable given
the current etate-of-the-art of the scientific community's
ability to model physiological and other parameters related to
this pollutant.   Specifically, the Committee would draw to your
attention two of its conclusions on these analyses:  1) the
Agency's use of the Haldane constant with a value set at 218 is
a reasonable selection among a variety of physiological parameters
                              B-3

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discussed in the sensitivity analysis? and 2) the draft preamble
states that an Agency objective is to keep 99% of the population
below a COHb level of 2.5%.  Since there may be no threshold
concentration level for carbon monoxide below which no adverse
effects will be experienced by anyone, and since one hundred
percent protection is not feasible, a social policy choice must
be made to limit societal risk from this pollutant.  From a
scientific standpoint the 99% objective is within the realm of
reason, but there may be other than scientific factors you wish
to consider in reaching a decision on this particular issue.

     4.  Scientifically Acceptable Range for the 8-Hour CO
         Standard.

     In commenting upon the staff's proposals for a revised
8-hour CO standard set at 9 parts per million (p. p.m.) with
five exceedances, or 12 p. p.m. with one exceedance, the Committee
made the following consensus observations:

          o  a standard set at 12 p. p.m. with 5 exceedances
     is not scientifically acceptable

          o  a standard established at 12 p. p.m. with 1 exceedance
     would provide a very small margin of safety

          o  the scientific evidence alone cannot identify an
     exact level at which to set a standard for carbon monoxide.
     Given the need to protect sensitive members of the population
     from this pollutant, the Committee advises you to choose a
     standard level and a corresponding number of exceedances that
     will limit COHb below the critical effects level of 2.7 - 3.0%,
     with an adequate margin of safety.

    . The Committee appreciates the opportunity to advise you on
the carbon monoxide standard and hopes that its comments will
be useful as you finalize the standard.  We urge you to proceed
expeditiously in this matter because the criteria document and
staff paper, reviewed by CASAC more than three years ago, will
be increasingly subject to challenge because of any newly published
literature on this pollutant.  In addition, both the private
sector and individual citizens need to know the standard level
for the next five years for planning purposes and for reassurance
that public health is being adequately protected.

                              Sincerely yours,
                              Sheldon K. Friedlander
                              Chairman, Clean Air Scientific
                                Advisory Committee   *
cc:  Dr. John W. Hernandez
     Kathleen Bennett
     Dr. Terry F. Yosie
                               B-4

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