c/EPA
                United States
                Environmental Protection
                Agency
                Office of Water
                Regulations and Standards
                Criteria and Standards Division
                Washington DC 20460
EPA 440, 5-80-023
October 1980
Ambient
Water  Quality
Criteria  for
Benzidine

-------
      AMBIENT WATER QUALITY CRITERIA FOR

                BENZIDINE
                 Prepared By
    U.S. ENVIRONMENTAL PROTECTION AGENCY

  Office of Water Regulations and Standards
       Criteria and Standards Division
              Washington, D.C.

    Office of Research and Development
Environmental Criteria and Assessment Office
              Cincinnati, Ohio

        Carcinogen Assessment Group
             Washington, D.C.

    Environmental Research Laboratories
             Corvalis, Oregon
             Duluth, Minnesota
           Gulf Breeze, Florida
        Narragansett, Rhode Island

-------
                              DISCLAIMER
      This  report  has been reviewed by the  Environmental  Criteria and
Assessment Office, U.S.  Environmental  Protection  Agency,  and approved
for publication.  Mention of trade names or commercial products does not
constitute endorsement or recommendation for use.
                          AVAILABILITY  NOTICE
      This  document is available  to  the public  through  the National
Technical Information Service, (NTIS), Springfield, Virginia  22161.
                                    11

-------
                               FOREWORD

    Section 304  (a)(l)  of the Clean Water Act  of  1977 (P.L.  95-217),
requires the Administrator  of the Environmental Protection Agency to
publish criteria  for water  quality accurately reflecting  the  latest
scientific knowledge on the  kind  and extent of all identifiable effects
on  health  and  welfare which  may  be  expected from  the presence  of
pollutants in  any  body of water, including ground water.  Proposed water
quality criteria  for the  65  toxic  pollutants  listed  under section 307
(a)(l) of  the  Clean Water  Act  were developed  and  a notice  of  their
availability was published for public comment on March 15, 1979 (44 FR
15926), July 25, 1979 (44  FR 43660), and October 1,  1979 (44 FR 56628).
This  document  is  a revision  of  those  proposed criteria  based  upon a
consideration of  comments received  from  other  Federal  Agencies,  State
agencies,   special  interest  groups,  and  individual  scientists.    The
criteria contained in this document replace any previously published EPA
criteria  for  the  65  pollutants.    This  criterion  document  is  also
published  in satisifaction of paragraph 11 of the Settlement Agreement
in  Natural  Resources  Defense Council,  et.  al.  vs. Train,  8  ERC 2120
(D.D.C. 1976), modified, 12 ERC 1833 (D.D.C. 1979).

    The term "water  quality criteria"  is used  in  two  sections  of the
Clean Water Act, section 304  (a)(l)  and section 303 (c)(2).  The term has
a different program  impact  in  each  section.   In section 304,  the term
represents a non-regulatory,  scientific  assessment of  ecological  ef-
fects. The criteria  presented  in  this  publication  are such scientific
assessments.   Such water  quality  criteria  associated with  specific
stream uses when adopted as  State water quality  standards under section
303 become  enforceable maximum  acceptable  levels  of  a  pollutant  in
ambient waters.  The water quality criteria adopted in the State water
quality standards could have the same numerical limits as the  criteria
developed  under section  304.  However, in many situations States may want
to adjust  water quality criteria  developed under section 304 to reflect
local  environmental  conditions  and  human  exposure  patterns  before
incorporation  into  water  quality  standards.    It  is  not  until  their
adoption as part of the State water  quality standards that the criteria
become regulatory.

    Guidelines  to assist  the  States  in  the modification  of  criteria
presented   in  this  document,  in  the  development  of  water  quality
standards, and  in  other water-related programs of this Agency, are being
developed  by EPA.
                                    STEVEN SCHATZOW
                                    Deputy Assistant Administrator
                                    Office of Water Regulations and Standards
                                   111

-------
                                ACKNOWLEDGEMENTS


Aquatic Life Toxicology

   William A. Brungs,  ERL-Narragansett        John  H.  Gentile,  ERL-Narragansett
   U.S.  Environmental  Protection  Agency       U.S.  Environmental  Protection Agency

Mammalian Toxicology and Human Health Effects:

   Thomas J. Haley  (author)                  Ahmed Ahmed
   National Center  For Toxicological         University of Texas Medical  Branch
      Research

   Steven D. Lutkenhoff (doc. mgr.)          Roy  E. Albert *
   ECAO-Cin                                  Carcinogen Assessment Group
   U.S. Environmental Proteciton Agency      U.S.  Environmental  Protection Agency

   Richard A. Carchmann                      Herbert Cornish
   Medical College  of Virginia               University of Michigan School of
                                               Public Health

   Patrick Durkin                            Karl  Gabriel
   Syracuse Research Corporation             Medical  College of  Pennsylvania

   Charalingayya Hiremath                    Roman Kuchuda
   U.S. Environmental Protection Agency      U.S.  Environmental  Protection Agency

   J.F. Stara, ECAO-Cin                      William W. Sutton,  EMSL-LV
   U.S. Environmental Protection Agency      U.S.  Environmental  Protection Agency


Technical Support  Services  Staff:   D.J. Reisman,  M.A. Garlough,  B.L. Zwayer,
P.A. Daunt, K.S. Edwards, T.A. Scandura, A.T. Pressley, C.A. Cooper,
M.M. Denessen.

Clerical  Staff:  C.A. Haynes, S.J.  Faehr, L.A. Wade, D. Jones, B.J. Bordicks,
B.J. Quesnell, B.  Gray, B.  Gardiner.
*CAG Participating Members:  Elizabeth L. Anderson, Larry Anderson, Dolph Arnicar,
   Steven Bayard, David L. Bayliss, Chao W. Chen, John R. Fowle III, Bernard
   Haberman, Charalingayya Hiremath, Chang S. Lao, Robert McGaughy, Jeffery Rosenblatt
   Dharm V. Singh, and Todd W. Thorslund.
                                        iv

-------
                            TABLE OF CONTENTS


Criteria Summary

Introduction                                                A-l

Aquatic Life Toxicology                                     B-l
   Introduction                                             B-l
   Effects                                                  B-l
       Acute Toxicity                                       B-l
       Residues                                             B-l
       Summary                                              B-2
   Criteria                                                 B-2
   References                                               6-6

Mammalian Toxicology and Human Health Effects               C-l
   Introduction                                             C-l
   Exposure                                                 C-l
       Ingestion from Water                                 C-l
       Ingestion from Food                                  C-l
       Inhalation                                           C-3
       Dermal                                               C-3
   Pharmacokinetics                                         C-4
       Absorption and Distribution                          C-4
       Metabolism and Excretion                             C-4
   Effects                                                  C-12
       Acute, Subacute and Chronic Toxicity                 C-12
       Synergism and/or Antagonism                          C-14
       Teratogenicity                                       C-14
       Mutagenicity                                         C-14
       Carcinogenicity                                      C-15
   Criterion Formulation                                    C-26
       Existing Guidelines and Standards                    C=26
       Special Groups at Risk                               C-28
       Basis and Derivation of Criteria                     C-2S
   References                                               C-33

Appendix I                                                  C-48
   Summary and Conclusions Regarding the Carcinogenicity
     of Benzidine                                           C-48
   Summary of Pertinent Data                                C-53

-------
                               CRITERIA  DOCUMENT
                                   BENZIDINE
CRITERIA
                                 Aquatic Life
    The available  data  for benzidine indicate that acute  toxicity to fresh-
water aquatic  life occurs at  concentrations  as  low as 2,500  ug/1  and would
occur at  lower  concentrations among species  that are  more  sensitive  than
those tested.  No  data  are available concerning  the chronic toxicity of ben-
zidine to sensitive freshwater aquatic life.
    No saltwater organisms have  been tested with benzidine  and  no statement
can be made concerning acute and chronic toxicity.
                                 Humai
    For  the   maximum  protection  of   human   health  from   the   potential
carcinogenic  effects  due  to  exposure  of  benzidine  through  ingestion  of
contaminated  water   and  contaminated aquatic  organisms,  the  ambient  water
concentrations should be  zero based  on  the non-threshold  assumption for this
chemical.  However,  zero level  may  not be  attainable  at the present  time.
Therefore,  the levels which  may  result  in  incremental  increase  of  cancer
risk  over   the  lifetime  are  estimated  at  10~5,  10"6,  and   10~7.    The
corresponding  recommended  criteria are  1.2  ng/1,  0.12  ng/1, and  0.01  ng/1,
respectively.   If  the above  estimates  are  made  for consumption  of  aquatic
organisms  only,  excluding  consumption  of  water,  the  levels  are  5.3  ng/1,
0.53 ng/1,  and 0.05 ng/1, respectively.
                                      VI

-------
                                 INTRODUCTION

    Benzidine  (4,4'-diaminobiphenyl)  is  an aromatic amine.   A proven  human
carcinogen,  its primary  site  of tumor induction is the  urinary bladder.   It
is also mutagenic.
    The  incidence of  bladder  tumors  in  humans resulting from occupational
exposure to  aromatic  amines (benzidine) was  first  researched in Germany  in
1895.  The first  cases of  this  condition  in  the United  States were  diagnosed
in 1931 and reported in 1934.
    Several  studies  implicating the high  risk  of  bladder tumors in  workers
exposed to benzidine and other aromatic amines are  well  documented.
    Adversary  proceedings  under section  307(a)  of  the  Federal Water  Pollu-
tion Control Act  resulted  in  the promulgation of a toxic  pollutant  effluent
standard for benzidine.  The ambient  water criterion upon  which the standard
was based was 0.1 ug/1 (42 FR 2617).
    Benzidine  is  an aromatic amine with a  molecular weight of 184.24 (Weast,
1972).   Existing  as  a  grayish-yellow,  white,  or  reddish-gray  crystalline
powder  (melting  point,  128°C;  boiling point,  400°C) (Standen,  1972),  benzi-
dine's  solubility increases as water  temperature  rises.   The solubility  of
benzidine  in  12°C  water  is  400  mg/1  (Verschueren,  1977).   Solubility  is
greatly  enhanced  with  dissolution  into  organic solvents  (Stecher,  1968).
Its  log  octanol/water  partition coefficient  is  1.81 (Radding, et al.  1977).
Benzidine is easily converted to and from its salt  (Morrison and  Boyd, 1972).
    Diazotization reactions involving benzidine will  result  in colored com-
pounds  (color  will  vary  with  molecular structure).  Because  of their color,
azo  compounds  are important as  dyes for  industrial use  (Morrison  and Boyd,
1972).  The pKa values for  the  amino  groups  in  benzidine were reported to  be
3.57 and 4.66  (Weast, 1972).

-------
    Oxidation by  metal  cations appears to  be an important route  for  benzi-
dine degradation  in  the  aquatic environment  (Lahav and  Raziel,  1971).   Ben-
zidine is  not  bioaccumulated to  a  significant  extent by  aquatic  organisms,
and  it  is apparently not  easily degraded  by the  microorganisms  in  sewage
plant sludge (Howard and Saxena, 1976).
                                     A-2

-------
                                  REFERENCES

Howard,  P.M.  and  J.  Saxena.   1976.   Persistence and degradability testing of
benzidine  and other  carcinogenic  compounds.   EPA  560/5-76-005.   Off.  Toxic
Subst.,  U.S.  Environ. Prot. Agency, Washginton, D.C.

Lahav,  N.   and  S.  Raziel.   1971.   Interaction  between  montmorillonite  and
benzidine  in  aqueous  solutions.   II. A general kinetic  study.   Israel  Jour.
Chem.  9: 691.

Morrison, R.T. and  R.M.  Boyd.   1972.   Organic Chemistry.  2nd ed.  Allyn and
Bacon, Inc.,  Boston.

Radding, S.B.,  et al.   1977.  Review of the  environmental  fate  of selected
chemicals.    EPA  560/5-77-003.   Off.  Toxic  Subst.,  U.S.  Environ.  Prot.
Agency, Washington, D.C.

Standen, A.   (ed.)  1972.  Kirk-Othmer  Encyclopedia  of  Chemical  Technology.
Interscience  Publishers, John Wiley and Sons, Inc., New York.

Stecher, P.G.  (ed.)   1968.   The Merck Index.  8th  ed.   Merck and Co.,  Inc.,
Rahway, New Jersey.

Verschueren,  K.   1977.   Handbook of  Environmental  Data  on Organic Compounds.
Van Nostrand Reinhold, New York.

Weast, R.C.  (ed.)   1972.   Handbook  of Chemistry and  Physics.   53rd ed.   CRC
Press, Cleveland,  Ohio.

                                     A-3

-------
 Aquatic Life Toxicology*

                                  INTRODUCTION

     Static,  acute tests  have  been conducted with  five  freshwater fish  spe-

 cies and  a  scud and  bioconcentration  factors range  from 38 to  2,620.    No

 data are available  for saltwater  species.

                                    EFFECTS

 Acute Toxicity

     The 96-hour  LCrn  values  for  rainbow  and lake  trout, red  shiner,  and

 flagfish range  from  2,500 to 16,200 ug/1  (Table 1).

     Comparable  tests conducted with the  fathead  minnow  and a scud, Gammarus

 pseudolimnaeus,  resulted in no observed  mortality at the  highest test con-

 centration of 20,000 yg/1  (Table  3).

 Residues

     The bluegill has- been  exposed to    C-benzidine  under flow-through con-

 ditions  for  42  days  (EG  and G  Bionomics, 1975).   The edible  portion  of  the

 fish  bioconcentrated    C-residues  by 38  to 44  times (Table 2).   The com-

 parable  bioconcentration factor for the  non-edible portion  (viscera)  of  the

 bluegill  ranged from  about 12  to about 43 times that amount  present  in  the

edible  portion.  The  half-life  of    C-residues in  the fish  was about  7

days.

Miscellaneous

    Lu,  et al.  (1977)  studied  the behavior  of  benzidine  in a model ecosystem

for  3  days and  observed  bioconcentration factors in  algae,  snails,  mosqui-
*The reader  is  referred  to the Guidelines for  Deriving  Water  Quality Crite-
ria for  the  Protection  of Aquatic Life and  Its  Uses  in  order to  better  un-
derstand the  following  discussion and recommendation.   The  following tables
contain the  appropriate  data  that were found  in  the  literature, and  at  the
bottom of  each  table are  the  calculations  for deriving various  measures  of
toxicity as described in the Guidelines.
                                      B-J

-------
tos, and the mosquitofish of  between  55 to 2,620 times.  The result with the
mosquitofish  (55x)  is  consistent with   that  discussed  earlier  with  the
bluegill.
Summary
    One  freshwater  invertebrate and five  fish  species have been  exposed to
benzidine under  static acute test  conditions.   The 96-hour LC50  values for
four fish  species  ranged  from 2,500  to  16,200  wg/1.   The LC5Q  values for
the other  species were greater than  20,000 ug/1.   Bioconcentration  factors
for  the bluegill  ranged  from  38  to 44  and,  in  a model  ecosystem  after  3
days, bioconcentration factors ranged from 55 for fish to 2,620 for an alga.
    No saltwater organism has been tested with benzidine.
                                   CRITERIA
    The  available  data for  benzidine indicate that  acute  toxicity to fresh-
water aquatic  life  occurs  at concentrations as  low as 2,500  ug/1  and would
occur  at lower  concentrations  among  species  that  are more  sensitive  than
those tested.  No data are  available  concerning  the chronic toxicity of ben-
zidine to sensitive freshwater aquatic  life.
    No  saltwater  organisms  have been tested with  benzidine  and  no statement
can be made concerning acute or chronic toxicity.
                                     8-2

-------
      Table 1.  Acute values for benzldlne (U.S. EPA, 1980)


                                        LC50/EC50     Species Acute
Species                     Method*      (ug/l)       Value (ug/l)
FRESHWATER SPECIES
Rainbow trout, S, U 7,400
Salmo galrdner!
Lake trout. S» U 4,350
Sa 1 ve 1 1 nus namaycush
Red shiner, S, U 2,500
Notrools lutrensls
Flagflsh, S, U 16,200
Jordanel la f lorldae

7,400
4.350
2,500
16,200
* S = static, U = unmeasured

  No Final Acute Value Is calculable since the minimum data base
  requirements are not met.

-------
       Table 2.  Residues for banzldlne (EG i 6 Bionomics.  1975)
                                            Bloconcentratlon     Duration
Species                        Tissue            Factor           (days)
                            FRESHWATER SPECIES
8/ueglll,                  edible portion      38  to 44»           42
Leporols mncrochlrus
• Results based on 14C-resldue content.

                                 B-4

-------
                             Table 3.  Other data for beruldlne
Species
Alga,
OedogonI urn card Iacum
Snail,
Physa sp

Scud,
Gamroarus pseudolImnaeus

Mosquito (larva),
Culex pip lens
Fathead minnow,
Plmephales promelas

Mosqultofish,
Gambusla atfinis
Duration          Effect

         FRESHWATER SPECIES
 Result
 (yg/i)
 3 days      Model ecosystem,
             bloconcentrat Ion
             factor = 2,620

 3 days      Bloconcentrat Ion
             factor = 645

96 hrs       LC50
 3 days      Model ecosystem
             b loconcentrat Ion
             factor =456

96 hrs       LC50
 3 days      Model ecosystem,
             bloconcentrat Ion
             factor = 55
>20,000
Reference



Lu, et al. 1977



Lu, et al. 1977


U.S. EPA, 1980


Lu, et al. 1977
>20,000     U.S. EPA, 1980
            Lu, et al. 1977
                                            B-5

-------
                                  REFERENCES

                                                     14
EG  and  G Bionomics.   1975.   Exposure  of  fish  to   C-benzidine:  accumula-
tion, distribution, and elimination of  14-C  residues.   Res.  Report  to Allied
Chemical Corp.

Lu,  P-Y,  et al.   1977.   The  environmental  fate of three  carcinogens:  ben-
zo(a)pyrene, benzidine,  and vinyl chloride  in  laboratory  model  ecosystems.
Arch. Environ. Contain. Toxicol.  6: 129.

U.S. EPA.   1980.   Unpublished  laboratory  data Environmental  Research Labora-
tory, Duluth.
                                     8-6

-------
Mammalian Toxicology and Human Health Effects



                           INTRODUCTION



     In general, exposure to benzidine compounds occurs in factor-



ies that synthesize benzidine and its  congeners  and convert them to



dyes.   It  is  also  probable that  some  exposure occurs  when the



closed system used in synthesis  is cleaned  (Haley/ 1975).  Exposure



also occurs from breathing contaminated air,  ingesting contaminated



food,  and wearing  contaminated  clothing  (Meigs,  et  al.  1951).



Pointing  of  brushes  by Japanese  kimono  painters results  in the



ingestion of benzidine dyes  (Yoshida and Miyakawa, 1973), although



ingestion is not generally an important source  of exposure.



                             EXPOSURE



Ingestion from Water



     Water could be contaminated with  benzidine  and its derivatives



and dyes if plant water is discharged  into  water supplies  serving  a



residential community.  However, as of this time no reports of such



contamination have appeared  in  the  literature.



Ingestion from Food



     While  it  is  possible  for  food  to become contaminated  with



benzidine and its derivatives under poor  industrial hygienic condi-



tions,  ingestion of  contaminated  food is not  a  real contributor to



the overall problem  of benzidine  toxicity.



     A bioconcentration factor  (BCF) relates the concentration of  a



chemical  in  aquatic  animals  to  the concentration  in  the water in



which  they  live.   The  steady-state BCFs  for a  lipid-soluble  com-



pound  in  the tissues of various  aquatic animals seem  to be propor-



tional  to the  percent lipid  in the tissue.   Thus  the per capita





                                C-l

-------
ingestion of a lipid-soluble chemical can be estimated  from the per
capita consumption of fish and  shellfish,  the weighted  average per-
cent lipids of consumed fish and shellfish, and a steady-state BCF
for the chemical.
     Data from a recent survey on fish and shellfish consumption  in
the United  States was  analyzed by  SRI   International  (U.S.  EPA,
1980).   These data were  used  to estimate that the per capita con-
sumption of  freshwater and  estuarine fish  and  shellfish  in the
United  States  is 6.5  g/day  (Stephan, 1980).   In addition,  these
data were used with data on the fat content of the edible portion  of
the same  species  to estimate  that  the  weighted  average  percent
lipids for consumed  freshwater and estuarine fish and  shellfish  is
3.0 percent.
     A measured  steady-state  BCF of  41 was obtained for  benzidine
using the edible portion of bluegills  (EG & G Bionomics,  1975).  A
higher BCF was found for the nonedible portion, but percent lipids
were not reported  for  either portion  and  the  relative weights  of
the two  portions were not  reported.   However,  for 3,3'-dichloro-
benzidine the BCF for whole body was about  3.5 times that  for edi-
ble flesh (Appleton  and Sikka, 1980).  Thus, the steady-state bio-
concentration factor for benzidine in  the whole body of the tested
bluegills can be estimated to be 140.  Similar bluegills  contained
an average of 4.8  percent lipids  (Johnson,  1980).   An adjustment
factor of 3.0/4.8  =  0.625 can be  used  to adjust  the measured BCF
from the  4.8  percent  lipids  of the  bluegill  to the  3.0  percent
lipids  that  is  the  weighted  average  for  consumed   fish  and
shellfish.   Thus, the weighted average bioconcentration factor for
                               C-2

-------
benzidine  and  the edible portion  of all freshwater and  estuarine
aquatic  organisms  consumed  by  Americans   is   calculated   to  be
140 x 0.625 =  87.5.
Inhalation
     In  the  early phases of  the  chemical and dye industries,  the
lack of good industrial hygienic practices and the use  of  open  sys-
tems made inhalation one of the principal routes of entry  of  benzi-
dine and  its derivatives  into the body.   Similar  inhalation expo-
sures can occur at the present time unless workers wear  respirators
and protective clothing while  cleaning the equipment  (Haley, 1975).
Dermal
     Skin absorption  is the most important path of entry into  the
body.  Intact  skin is readily  penetrated  by benzidine  and 3,3'-di-
methylbenzidine  (Meigs,  et  al.  1951).    3,3'-Dichlorobenzidine,
because of its  nonvolatility and large particle  size, presents  less
of  an  inhalation  and  skin  penetration  hazard than  benzidine
(Gerarde and Gerarde, 1974; Rye,  et al.   1970).   It is the  light,
fluffy, powdery nature of benzidine base  that poses the  tumorigenic
hazard  to  benzidine  workers   from  skin   absorption  (Barsotti   and
Vigliani, 1952).  The ease  of  skin  penetration  determines the  fol-
lowing order of decreasing  toxicity from these  chemicals:   benzi-
dine, 3,3'-dimethoxybenzidine,  and  3,3'-dichlorobenzidine (Rye,  et
al. 1970).
     Environmental conditions  of high air temperature  and humidity
increase  skin  absorption  of  benzidine,  3,3'-dimethoxybenzidine,
3,3'-dichlorobenzidine,  and  3,3'-dimethylbenzidine.   Higher  a-
mounts of benzidine are found  in  the  urine of workers  who perspire
                               C-3

-------
freely and have a wet skin (Meigs,  et  al.  1954).  Urinary benzidine
measurements  indicate  that benzidine  does  not  accumulate  in body
tissues, but  no  direct human tissue determinations have been per-
formed to absolutely establish this concept  (Meigs, et al.  1951).
                         PHARMACOKINETICS
Absorption and Distribution
     Benzidine  is  rapidly  absorbed  into  rats  after intravenous
injection.  Maximum concentrations of free  and bound  benzidine are
found  at  two  and three  hours,  respectively.   The highest concen-
trations  were  found   in  the  blood,  followed  by  liver,  kidney,
spleen, heart, and  lung  (Soloimskaya, 1968).  Body distribution of
benzidine in various tissues and urine 4  and 12 hours after intra-
peritoneal injection of  100 mg/kg was as  follows:  high concentra-
tions  in  the  stomach,  stomach contents,  and  small  intestine  at  4
hours;  and  in  the  small  intestine and   its contents at  12 hours
(Baker and Deighton, 1953).  The amine content of the erythrocytes
was low at both time intervals.  Conjugated material,  indicative of
metabolites, was  high  in  tissues and  urine  at 12 hours.  Benzidine
concentrations in the liver, the target organ for  toxicity  in rats,
were  relatively  high  and constant over  the  12-hour  period.   When
rats were given 20 mg of 3,3'-dimethylbenzidine  subcutaneously once
a week for eight  weeks,  the  highest amine content was found in the
Zymbal's gland  followed by the kidney, omentum, spleen, and liver
(Pliss and Zabezhinsky,  1970).
Metabolism and Excretion
     A  pharmacokinetic study  of  benzidine uniformly labeled with
14
  C and dichlorobenzidine labeled  in  the 3,3' positions  indicated
                               C-4

-------
that substitution  in  the 3,3'  positions of the benzidine molecule
significantly affects the routes of metabolism and excretion.  The
blood half-life for benzidine was 68 hours in the rat and 88 hours
in the dog.  The weekly  excretions  of  a dose  of 0.2 mg/kg of ben-
zidine in  the rat, dog,  and monkey were 97, 96, and 83 percent re-
spectively.  The  excretion  values for  the dichloro compound were
98, 97, and 88.5 percent, respectively.  Biliary excretion appears
to be the  main  route  of  excretion of the dichloro compound in all
three species.   The dog  and monkey excrete free benzidine with the
urine,  while the rat  uses the  biliary  route.   The urinary bladder
of the  dog had  a high  content of  benzidine, suggesting that this  is
the reason for urinary bladder cancer  in this species (Kellner,  et
al. 1973).
     The various metabolites reported for benzidine  and its congen-
ers are given in Table 1. It can be  seen that various species han-
dle these  chemicals in different ways  and that the animal metabo-
lites differ considerably from those excreted  by  humans.   The im-
provements  in  analytical techniques have made  identification  of
differences more  positive.   Of  greatest  interest  are  the  human
studies which will now be discussed.
     A single oral dose  of 100 mg of benzidine to a human resulted
in the excretion of free benzidine  and its mono-  and diacetylated
conversion  products  in  the  urine.   The  entire dose was  not re-
covered indicating  that  fecal  excretion probably  occurred.   This
cannot be  proven  because the  feces  were  not  analyzed (Engelbertz
and Babel,  1953).   People ingesting 200 mg of  benzidine excreted
free benzidine  and N-hydroxyacetylamino  benzidine  in their urine
                               C-5

-------
                             TABLE 1

     Metabolites  Formed  by Biotransformation  of  Benzidine  and
                 Benzidine Derivatives  in Animals
Compound
Species
Metabolites
Reference
Benzidine
Human

Human

Human
                 Human
                 Human
                 Monkey


                 Dog

                 Dog

                 Dog


                 Dog


                 Dog

                 Dog



                 Guinea pig

                 Guinea pig


                 Guinea pig

                 Guinea pig

                 Guinea pig
Acetyl N-hydroxy
   compound
N-Hydroxy acetyla-
   minobenzidine
Monoacetylbenzidine
   and diacetyl-
   benzidine
3-Hydroxybenzidine
3,3'-Dihydroxy-
   benzidine

Monoace tylbenz id i ne
             3-Hydroxybenzidine
                and glucuronide
             3-Hydroxybenzidine
                hydrogen sulfate
             3-Hydroxybenzidine
             4,4'-Diamino-3-
                diphenyl hydro-
                gen sulfate
             4-Amino-4-hydroxy-
                biphenyl
             Monoacetylbenzidine
                and diacetyl-
                bendizine

             4'-Acetamido-4-
                aminodiphenyl
             4'-Acetamido-4-
                amino-3-diphenyl
                hydrogen sulfate
             4'-Amino-4-diphenyl
                sulfamic acid
             N-Glucuronides

             4'-Acetamido-4-
                diphenyl sul-
                famic acid
Troll, et al.
  1963
Haley, 1975

Haley, 1975
                                    Haley, 1975
                                    Haley, 1975
Rinde and
  Troll, 1975

Troll and
  Nelson, 1958
Sciarini and
  Meigs, 1958
Bradshaw and
  Clayson, 1955
Sciarini, 1957
Clayson, et al.
  1959

Haley,1975

Haley, 1975
                       Clayson, et al.
                         1959
                       Clayson, et al.
                         1959

                       Clayson, et al.
                         1959
                       Clayson, et al.
                         1959
                       Clayson, et al.
                         1959
                                 C-6

-------
                           TABLE 1 (Continued)
Compound
Species
Metabolites
Reference
Benzidine
Rabbit


Rabbit

Rabbit

Rabbit


Rabbit

Rabbit


Rabbit


Rat

Rat



Rat


Rat

Rat


Rat


Rat

Rat



Mouse


Mouse
3-Hydroxybenzidine
   sulfate and
   glucuronide
4'-Acetamido-4-
   aminodiphenyl
3-Hydroxybenzidine

4'-Acetamido-4-amino-
   3-diphenylyl
   hydrogen sulfate
4'-Amino-4-diphenylyl
   sulfamic acid
4'-Acetamido-4-di-
   phenylyl sulfamic
   acid
N-Glucuronides
                              3,3'-Dihydroxy-
                                 benzidine
                              N-Glucuronides
                              4'-Acetamido-4-
                                 Aminod iphenyl

                              3-Hydroxybenzidine

                              4,4'-Diamino-3-di-
                                 phenyl hydrogen
                                 sulfate
                              4'-Acetamido-4-amino-
                                 3-diphenylyl hy-
                                 drogen sulfate
                              4'-Amino-4-diphenylyl
                                 sulfamic acid
                              4'-Acetamido-4-di-
                                 phenylyl sulfamic
                                 acid

                              Monoacetylbenzidine
                                 and diacetylben-
                                 zidine
                              Monoacetylated 3-
                                 hydroxybenzidine
                                 glucuronide and/or
                                 ethereal sulfate
Troll and
  Nelson, 1958

Clayson, et al.
  1959
Clayson, et al.
  1959
Clayson, et al.
  1959

Clayson, et al.
  1959
Clayson, et al.
  1959

Clayson, et al.
  1959

Haley, 1975

Elson, et al.
  1958
Clayson, et al.
  1959
Clayson, et al.
  1959

Clayson, et al.
  1959
Clayson, et al.
  1959

Clayson, et al.
  1959

Clayson, et al.
  1959
Clayson, et al.
  1959
                       Sciarini and
                         Meigs, 1961a

                       Sciarini and
                         Meigs, 1961a
                                 C-7

-------
                           TABLE 1 (Continued)
Compound
Benzidine













3,3'-dimethyl-
benzidine
(orthotolidine)


3,3'-Dimethoxy-
benzidine
Species
Mouse

Mouse

Mouse

Mouse


Mouse


Mouse

Human
Human
Human
Dog

Dog

Metabolites
N-Hydrogen sulfate
and/or glucuronide
3-Hydroxybenz id ine
glucuronide
4' -Acetamido-4-amino-
diphenyl
4, 4 '-Di ami no- 3-d i-
phenyl hydrogen
sulfate
41 -Acetamido-4-amino-
3-diphenylyl hy-
drogen sulfate
N-Glucuronides

Diacetyl-o-tolidine
5-Hydroxy-o-tolidine
Monoacetyl-o-tolidine
5-Ethereal sulfate
of o-tolidine
Unidentified diamine
metabolite
Reference
Sciarini and
Meigs, 1961a
Sciarini and
Meigs, 1961a
Clayson, et al.
1959
Clayson, et al.
1959

Clayson, et al.
1959

Clayson, et al.
1959
Dieteren, 1966
Dieteren, 1966
Dieteren, 1966
Sciarini and
Meigs, 1961b
Sciarini and
Meigs, 1961b
(dianisidine)

3-Methoxyben-
  zidine (mono-
  substituted
  dianisidine)
Rat
4-Amino-4'-acetamido-
  S-methoxybi-
  phenyl
Laham, 1971
                                 C-8

-------
(Troll, et  al.   1963).   In the  urine  of  plant workers exposed to
benzidine  in  unknown quantities,  free benzidine,  its  mono- and
diacetylated derivatives,  and  3-hydroxybenzidine were identified.
The latter  compound  comprised  78.5  to  89.7 percent  of  the  total
(Sciarini and Meigs,  1961a).  This work was a repeat of an earlier
study by Meigs, et al. (1954)  and confirmed the previous findings.
It has been suggested that an 8-hour exposure to an air concentra-
tion of 0.018 mg/m  of benzidine would  result  in a urinary excre-
tion of not more than  0.026 mg/1 of diamines. Thus,  an air exposure
to 0.02 mg/m   or less of  benzidine  would be safe  (Meigs,  et al.
1954).
     Dyestuff  factory workers  exposed  to  benzidine excreted free
benzidine, 4-amino-4-oxybiphenyl, and monoacetylbenzidine in  their
urine (Vigliani and Barsotti,  1962).
     Exposure  to  3,3'-dimethylbenzidine results in urinary excre-
tion of free 3,3'-dimethylbenzidine,  its  diacetyl derivative, and
5-hydroxy-3,3'-dimethylbenzidine.    Although   the  monoacetylated
derivative was  not detected, there is  a probability of its forma-
tion because 3,3'-dimethylbenzidine appears to  be metabolized  simi-
larly to benzidine (Dieteren,  1966).
     3,3'-Dichlorobenzidine has  been  identified  in  the  urine  of
workers handling  benzidine yellow.   This  establishes  the weakness
of the azo linkage in dyes made from this compound  (Akiyama,  1970).
     It is  questionable  how comparable animal data  are  to  human
data,  and whether the former allow predictions  to be made concern-
ing the metabolic conversion of chemicals  in various species.  This
is  taken  into   consideration  in the  following discussion  of the
                               C-9

-------
animal data in Table 1 and their relevance to the human situation.
Intraperitoneal  injection  of  100  mg/kg of benzidine  in mice pro-
duced free benzidine, mono- and diacetylated  derivatives as well as
the  ethereal  sulfates  and  glucuronates  of  3-hydroxybenzidine
(Sciarini  and  Meigs,  1961a).   The  same  dose  of benzidine in dogs
caused the excretion of  free benzidine  and conjugates of 3-hydroxy-
benzidine but no acetylated derivatives,  because the dog lacks this
biotransformation mechanism (Sciarini,  1957).  The ethereal sulfate
of 3-hydroxy-benzidine  has been identified  in  dog  urine and con-
stitutes  25 to  50 percent of the  administered  dose (Sciarini and
Meigs, 1958).   The  ethereal  sulfate and  glucuronide were the only
metabolites found in dogs  given 1  g of benzidine or rabbits given
100 to 300 mg of  this chemical (Troll  and Nelson, 1958).
     The differences in  the biotransformation  of benzidine  by the
rat, mouse, rabbit,  guinea pig, and dog are related  to  the presence
or absence of  specific  enzymatic  pathways.   For  example,  the dog
cannot acetylate  benzidine.   The  rat, rabbit,  and  guinea pig can
produce  4'-amino-  and  4'-acetamido-4-diphenylyl  sulfamic  acid
whereas the mouse and dog cannot.   Other  metabolites found were 4'-
acetamido-4-aminodiphenyl,  3-hydroxybenzidine,  4,4'-diamino-3-di-
phenylyl  hydrogen sulfate,  and  4'-acetamido-4-amino-3-diphenylyl
hydrogen  sulfate in  the  rat; and 4'-acetamido-4-aminodiphenyl,
4,4'-diamino-3-diphenyl   hydrogen   sulfate,   and   4'-acetamido-4-
amino-3-diphenylyl hydrogen sulfate  in the mouse.   4,4'-Diamino-3-
diphenylyl hydrogen  sulfate  was  absent from  rabbit and guinea pig
urine, although the other metabolites  were present.  3-Hydroxyben-
zidine and 4,4'-diamino-3-diphenylyl hydrogen sulfate were present
                               C-10

-------
in dog urine.  In all cases, N-glucuronides were present  (Clayson,
et al. 1959).  Metabolite  differences  occur  when different routes
of elimination  are  considered.   Dogs  excrete  the  same benzidine
metabolites  in urine  and  bile but their  feces  have  no 3-hydroxy-
benzidine or N-glucuronides (Clayson, et al.  1959).  Comparison of
routes of  excretion of benzidine  and  its dichloro  derivative in
rats, dogs,  and  monkeys showed  that the  rat eliminated both com-
pounds  in  greater  quantities  in  the  feces than  in  the  urine,
whereas the  dog  eliminated the dichloro  compound to a greater ex-
tent in the  feces.  Neither  route  was  decisive  in the monkey, but
more of  both compounds did  appear in  the urine  (Kellner,  et al.
1973).  Previously, it  had been shown  that dog  fecal excretion of
dichlorobenzidine  was  10  times  greater  than   urinary  excretion
(Sciarini and Meigs, 1961b), while  the  opposite  was true for benzi-
dine (Sciarini and Meigs,   1958).
     When benzidine-based  azo  dyes were  fed  to  monkeys, benzidine
and monoacetylbenzidine were  found  in their urine  (Rinde and Troll,
1975).   This  shows that  the  monkey,   like  man,  can reductively
cleave the azo linkage  (Akiyama, 1970).
     Intraperitoneal  injection  of dimethylbenzidine,  dimethoxy-
benzidine,  and dichlorobenzidine in dogs  resulted  in recovery of
part of these chemicals in nonmetabolized form.   The dichloro com-
pound was not metabolized, whereas the other two  derivatives of ben-
zidine were  recovered  from urine as unidentified conjugated ether-
eal sulfates (Sciarini and Meigs, 1961b).
                               C-ll

-------
                             EFFECTS
Acute, Subacute, and Chronic Toxicity
     Iji  vitro  studies have  shown that  benzidine,  3,3' -dimethyl-
benzidine,  and  3,3'-dimethoxybenzidine  are  moderate  reducers  of
cytochrome c.   3,3'-Diaminobenzidine  is  a strong reducer, whereas
3,3'-dichlorobenzidine is an ineffective reducer.  It  has  been sug-
gested that there is a relationship between carcinogenic potential
and the reduction of cytochrorae c (Hirai  and Yasuhira,  1972; Canuner
and Moore, 1973).
     There  is  a significant  increase  in  urinary B-glucuronidase
activity  in workers exposed  to  benzidine.   The elevated activity,
although decreased by removal from benzidine exposure,  does not re-
turn  to  normal  levels  (Kleinbauer,  et  al.  1969; Popler,  et al.
1964).
     While  3,3'-dimethylbenzidine administered  subcutaneously  to
rabbits had no  effect on blood  phenolase  activity,  benzidine de-
creased the activity of this enzyme (Nakajima,  1955).   Rats inject-
ed with  benzidine  showed reduced catalase and peroxidase activity
as well  as a  reduction  in  erythrocytes and   thrombocytes  and  an
increase  in leucocytes  (Soloimskaya,  1968).    An intraperitoneal
dose of 12.7 mg/kg  of  benzidine  in rats  increased liver  glutathione
from 182 mg/100 g to 272 rag/100  g  in 24  hours  (Neish,  1967).
     Dermatitis has been reported  in workers in  the benzidine dye-
stuff  industry,  involving  both benzidine and   its dimethyl deriva-
tive.  Individual sensitivity plays a  prominent role in this condi-
tion  (Schwartz, et al. 1947).
     Glomerulonephritis  and  nephrotic  syndrome have been produced
in Sprague-Dawley  rats  fed  0.043 percent N,N'-diacetylbenzidine.
                                C-12

-------
Both sexes developed proteinuria in 3  to  4 weeks.  After two months
the females were excreting 0.1 g of protein per 24 hours.  The fe-
males developed severe anemia, which was rarely seen in the males.
The former also had  a  hypoproteinemia,  hyperlipemia,  and general-
ized edema.  Glomerular lesions in the females consisted of florid
epithelial crescents, progressive sclerosis, and glomerular oblit-
eration.   In  the males,  the  lesions were slower in developing and
less extensive, but  all males  showing  the  nephrotic syndrome also
developed testicular atrophy.  There were morphological similarities
between  the  human  nephrotic  syndrome and  that induced  by N,N'-
diacetylbenzidine in rats, including extracapillary cell prolifer-
ation, formation of  luxuriant  crescents  in  80  percent  of the glo-
meruli,  intact  glomerular tufts,  and  the  presence  of  normal glo-
meruli  in the  advanced   stages of the  syndrome  (Barman,  et  al.
1952; Harman, 1971).
     Rats  fed  N,N'-diacetylbenzidine  or 4 ,4 ,4',4'-tetramethylben-
zidine developed glomerular  lesions with fat-filled spaces in the
glomerular tuft  from 2 to  4.5 months of  treatment  (Dunn,  et al.
1956).  Severe glomerulonephritis developed  in  rats receiving N,N'-
diacetylbenzidine by subcutaneous  (100 mg) or  intraperitoneal (100
or  200 mg)  injections.    These  lesions  were dose-related  (Bremner
and Tange, 1966).  A similar low grade glomerulonephritis has been
produced  in rats fed benzidine  (Christopher and Jairam, 1970).
     Mice  fed  0.01  and  0.08 percent benzidine dihydrochloride de-
veloped  the  following  toxic symptoms:   decreased  carcass, liver,
and  kidney weights; increased  spleen and  thymus  weights; cloudy
swelling of the liver; vacuolar degeneration of the renal tubules;
and hyperplasia of  the myeloid elements in the bone marrow and of

                               C-13

-------
the lyraphoid  cells  in the spleen and  thymic  cortex.   There was a
dose-dependent body weight  loss  of  20  percent in males and 7 per-
cent  in  females.  Moreover,  male mice  were more sensitive to ben-
zidine than  female  mice (Rao, et al.  1971).   This disagrees with
Barman's (1971) findings in rats, but it may only be a  species dif-
ference  in response.
Synergism and/or Antagonism
     Pertinent data could  not be located in the available litera-
ture.
Teratogenicity
     Embryonic mouse  kidney  cultures  have an  increased survival
time but show  hyperplastic  epithelial  changes  in  the  presence of
3,3'-dimethylbenzidine  (Golub, 1969; Shabad, et al. 1972).  Admini-
stration of 8 to  10  mg of  3,3'-dimethylbenzidine  to mice during the
last week of pregnancy  resulted  in lung adenomas and mammary gland
tumors in  their  progeny.   These tumors could  have  resulted from
transplacental transmission of the chemical or from its presence in
the milk  (Golub,  et  al.  1974).  No teratogenic effects  of benzidine
derivatives in humans have been  reported.
Mutagenicity
     The results  of  the  Ames assay on the mutagenicity  of benzidine
are positive  (Ames, et  al.  1973; McCann, et  al.  1975; Garner,  et
al. 1975).   With  metabolic activation,  benzidine  causes an increase
in the recovery of  histidine  revertants in Salmonella typhimurium
strain TA 1537 and TA 1538, both sensitive to frameshift mutagens.
The greatest increase was seen with TA 1538.
                               C-14

-------
     Another  more recently  developed assay,  used  to  screen  for
putative mutagenic/carcinogenic  compounds/ has been  used to  test
benzidine.   This  assay detects the inhibition of DNA synthesis  by
test compounds in HeLa cells  (Painter and  Howard, 1978).  The  con-
centration of a compound  that  is  required  to  inhibit DNA  synthesis
by 40 percent corresponds with its mutagenic  effects in Salmonella
typhimurium.  Benzidine  has  been shown  to be positive in this  DNA
synthesis inhibition test (Painter and Howard, 1978).
     Results of a salmonella mutagenesis  assay indicate  that  ben-
zidine  causes  a  significant  increase in  the reversion  index  of
tester strains TA 98 and TA 1538  when the  compound  is activated  by
the addition of human liver microsomes (U.S.  EPA, 1978).
Carcinogenicity
     Benzidine and its derivatives are carcinogenic in both experi-
mental animals and humans.  In the latter  these chemicals  have  been
shown  to  produce  bladder  cancer after  a long period  of latency
(Clayson, 1976).   Additionally, these  compounds produce dermatitis,
cystitis, and  hematuria  in humans,  indicating  an early attack  on
the urinary  bladder and  presenting  a  sign that  unless exposure  is
stopped, cancer may  result (Haley, 1975).   Table 2 gives various
animal species and the type of cancer induced in  them by benzidine
and its congeners.  It should be noted  that only the dog develops
urinary bladder cancer similar to that seen in  humans after expo-
sure to benzidine.  The animal cancers, in general,  differ signifi-
cantly in their locations.  This may  be  related  to differences  in
specific target tissues  or  to differences in excretory pathways.
                               C-15

-------
                             TABLE 2

       Effects  of  Benzidine,  Its  Congeners,  and Metabolites
                    On  Various  Animal  Species*
Species
       Carcinogen
          Effect
Mouse
Rat
Hamster
Rabbit
Dog
Monkey
Human
Benzidine

3,3'-Dihydroxybenzidine



Benzidine and its sulfate
           3,3'-Dihydroxybenzidine
Dianisidine

o-Ditoluidine


3,3'-Benzidinedioxyacetic
  acid
3,3'-Dichlorobenzidine
N,N'-Diacetylbenzidine

Benzidine

o-Ditoluidine

Benzidine
Benzidine
Benzidine
Benzidine
Hepatoma, lymphoma, bile duct
  proliferation
Hepatoma, lymphoma, bile duct
  proliferation, benign blad-
  der papilloma

Cirrhosis of liver, hepato-
  mas, carcinoma of Zymbal's
  gland, adenomacarcinoma, de-
  generation of bile ducts,
  sarcoma, mammary gland car-
  cinoma
Hepatoma, adenocarcinoma of
  colon, carcinoma of fore-
  stomach, Zymbal's gland car-
  cinoma, bladder carcinoma
Zymbal's gland carcinoma,
  ovarian tumor
Papilloma of stomach, Zymbal's
  gland carcinoma, mammary
  tumor, leukemia
Papilloma of bladder, hepatic
  sarcoma
Extensive cancer
Chronic glomerulonephritis

Hepatoma, liver carcinoma,
  cholangiomas
Bladder cancer

Proteinuria, hematuria, liver
  cirrhosis, myocardial atro-
  phy, bladder tumor, gall
  bladder tumor

Recurrent cystitis, bladder
  tumor, convulsions, liver
  cirrhosis, hematuria

No pathological changes  (Dura-
  tion of study too short)

Bladder  tumor, papilloma,
  chronic cystitis, hematuria
*Source:  Haley, 1975

a3,3'-Dimethoxybenzidine.

b3,3'-Dimethylbenzidine.

-------
In some  cases,  excessive dosage may  cause  death due to toxicity,
thus preventing the development of bladder cancer  (Haley, 1975).
     Benzidine  and  many other aromatic  amines  attack the urinary
bladder and other organs (Hueper, 1954).  However, it is the met.a-
bolites of these compounds that are considered to  be  the proximate
carcinogens  (Clayson,  1969).   These aromatic amines  are ring hy-
droxylated,  converted  to N-hydroxylated, acylated and  deacylated
derivatives,  and  conjugated  with sulfate and  glucuronide (Haley,
1975).   It has been suggested  that  the conjugated N-hydroxy com-
pounds are the active carcinogens in vivo.  Bladder cancer has been
induced  in  rabbits  and dogs  fed benzidine,  but these findings are
controversial  (Haley,  1975).   Spitz,  et al.  (1950) induced papil-
lary carcinoma  in 1 of 7 dogs fed benzidine  for  five years, but the
cancer only appeared 7.5 years  after  the beginning of the experi-
ment.  Orally administered benzidine did not produce  urinary blad-
der cancer in dogs (Marhold,  et al.  1967).  No tumors  were found  in
female beagle dogs  fed 1 mg/kg  five days per week for three years
(Deichmann, et al. 1965).   In these  last two  studies,  the lack of a
carcinogenic effect in dogs  is probably  related  to the known, long
latency  for  benzidine  cancer induction  and  the  shortness of both
studies.
     Extensive  bile  duct proliferations and  cysts appeared along
with cholangiofibrosis, hepatomas,  and liver  cell  carcinoma, but  no
urinary bladder tumors were  found in hamsters fed  benzidine at 0.1
percent of the diet throughout their life spans  (Saffiotti, et al.
1967).
                               C-17

-------
     Benzidine administered subcutaneously to rats at a rate of 15
mg/week  produced  liver  injury,  cirrhosis,  hepatomas,  sebaceous
gland carcinomas, and adenocarcinomas of the  rectum,  but no bladder
tumors (Spitz, et al. 1950).  Rats fed 0.125 percent of dihydroxy-
benzidine in the diet developed liver cirrhosis, hepatomas, adeno-
carcinomas of  the colon,  Zymbal's  gland carcinoma,  and  squamous
cell carcinomas  of  the  stomach.   One  sessile  papilloma  and two
keratinized squamous cell carcinomas  were  found  in the bladder wall
(Baker, 1953).  Intraperitoneal or subcutaneous  injection of N,N'-
diacetylbenzidine  in Wistar rats  induced  tumors of  Zymbal's gland
and of the mammary glands 6 to  15  months later.  Glomerulonephritis
was also reported and appeared  to  be  dose-related.  Female Sprague-
Dawley rats given  oral  doses of 12  to 50 mg/rat developed mammary
gland carcinomas (Griswold, et al. 1968).
     Early cirrhosis occurred  in rats given benzidine by subcutane-
ous injection  for  six  months  (Pliss, 1963).    Injection  site sar-
comas, hepatomas,  and Zymbal's gland  tumors were also  found and
constituted 70 percent of  the  tumors in these  rats  (Pliss, 1964).
Benzidine was more toxic to the females.  Tumors of Zymbal's gland
and  the  liver  were  induced  by  3,3'-benzidine-dicarboxylic  acid
within one  year  (Pliss,  1969).   Benzidine,  in  5 mg  weekly doses,
produced intestinal tumors  in  rats (Pliss, et al. 1973).  A cumula-
tive dose of 0.75 mg/kg of  benzidine  for  15 days produced tumors in
20 of 22  rats,  including  19 hepatomas, 18 cholangiomas, 7 intestin-
al tumors,  and  4 sebaceous gland  carcinomas.   Subcutaneous tetra-
methylbenzidine  doses  of  from  4.15  to  8.3  g/kg produced benign
tumors at the injection  site (Holland, et al. 1974).
                              C-18

-------
     Female Wistar rats given a single intraperitoneal  injection of
100 or  200  rag of N,N'-diacetylbenzidine  subcutaneously developed
Zymbal's gland and mammary gland tumors after 6 to 15 months.  The
100 rag  intraperitoneal  injection produced tumors in 11  out of 18
rats  while  the  200  mg  dose gave  no tumors  (Breraner  and Tange,
1966).
     Hepatomas,  bile duct  proliferation,  and benign papillomas of
the urinary bladder were found  in  Oelph  albino mice injected sub-
cutaneously with  300 mg of benzidine or  dihydroxybenzidine.  Only
the latter chemical caused the bladder changes  (Baker, 1950).
     Benzidine  or  3,3-dihydroxybenzidine administered  subcutan-
eously at 6 mg weekly for 52 weeks produced tumors in exposed mice
in 70 weeks.   Benzidine induced hepatomas and lymphomas while the
3,3-dihydroxy  derivative  induced lymphomas  and benign  intestinal
polyps.   The significance of the lymphomas is obscure because one-
third  of  the  controls developed   this  condition  spontaneously
(Bonser, et  al.  1956).   Subcutaneous administration of 3,3-dihy-
droxybenzidine  in mice  caused   tumors of the  liver  and   mammary
glands as well  as leucosis  (Pliss.  1961).  Inner organ  tumors de-
veloped after skin application of the chemical.  Subcutaneous week-
ly doses of 6 mg  of benzidine to C3HA mice induced hepatomas in 31
of 46 animals after 15 to 16 months.  One  animal  developed a  pulmon-
ary adenocarcinoma (Prokofjeva,  1971).
     3,3-Dimethylbenzidine in a  cumulative dose  of 5.4 g/kg  for 241
days induced 11 gastrointestinal tract tumors,  7 hepatoiaas, 7 bone
tumors,  and 4 Zyntbal's gland carcinomas in rats.  Total  oral doses
of 500 ing in Sprague-Dawley rats produced  4 mammary  carcinomas  in 9
                               C-19

-------
months in 3 of 16 surviving animals (Griswold, et al. 1968).  Sub-
cutaneous injection of  3,3'-dimethylbenzidine  in rats caused skin
tumors, large  sebaceous gland  tumors,  and mammary tumors in 60 to
70 percent of  the  animals.  When 20 mg of  the chemical was implanted
subcutaneously,  hepatocellular carcinomas  and  subcutaneous sar-
comas were produced (Pliss and Zabezhinsky, 1970).
     3,3'-Dimethoxybenzidine given  subcutaneously to rats  induced
Zymbal's gland  tumors  in two  animals  and an ovarian  tumor and a
fibroadenoma  of  the mammary gland  in  another one  (Pliss,   1963).
Both male and  female  Fischer  strain rats developed  tumors  of  the
gastrointestinal  tract, skin, breast, and ear duct after receiving
260 oral  10  mg doses  of  3,3'-dimethoxybenzidine.   The  period of
latency was 293 days (Weisburger, et al.  1967).
     Subcutaneous administration of 3,31-dichlorobenzidine  to rats
induced tumors in 74 percent of the animals (Pliss, 1963).   Tumors
appeared  in  the   skin,  sebaceous  and  mammary  glands,  intestines,
bones, and urinary  bladder.   Dichlorobenzidine given by ingestion
or  injection  into  the underlying  fat produced  sarcomas  at   the
injection site, an  adenocarcinoma in  the intestine,  papillomas in
the urinary bladder, and tumors in the  sebaceous  and mammary glands
(Pliss, 1959).    Total doses  of  300  mg/rat  orally  of  dichloro-
benzidine produced  no  tumors  (Griswold,  et  al.   1968).   Rats  fed
1,000  mg/kg  in the  diet developed mammary  gland tumors   in both
sexes and Zymbal's gland and hematopoietic tumors in males  (Stula,
et  al.  1971,  Stula, et  al.  1975).   Progeny of  BALB/c mice given
total subcutaneous  doses of 8  to  10 mg of dichlorobenzidine had a
significant increase in tumor  incidence.   Tumors  developed  in 13 of
                               C-20

-------
24 mice, with 4 adenocarcinomas of the  mammary  gland,  5 lung adeno-
mas, and 7 cases of lymphatic leukemia (Golub, et al. 1974).
     The carcinogencity risk for workers  exposed  to  benzidine  is 14
times higher than for  the  unexposed  population  (Case,  et al. 1954).
In  the  American  dyestuff  industry,  24  cases of bladder carcinomas
were found  in  workers exposed to aromatic  amines,  including ben-
zidine.  The  latency  for  tumor development was 12 years (Gehrman,
1936).   In England the tumor induction time averaged  16 years, but
one case occurred in two years (Case, et  al.  1954).   In 30 cases of
bladder tumors the induction period  varied  from 8  to  32 years, with
an  average  of  15.9  years.  The  concentration  of  benzidine in the
exposure appeared to  be the main factor  in early  tumor induction.
Benzidine manufacturing was associated  with 14  papillomas, 7 carci-
nomas,  and two cases  in which  the papillomas were  converted to car-
cinomas (Scott, 1952).  Only a few weeks of exposure  followed by a
latent  period  of  several  years  can   produce   bladder  tumors
(Deichmann and Gerarde, 1969),   A latent period  of 18,6 years has
also been  reported  (Hamblin,  1963)=   Initial  exposure concentra-
tion, exposure duration,  and  years  of  survival following exposure
as  well as  work  habits and  personal  hygiene are  involved  in the
development of carcinomas where  benzidine 'appears to  be implicated
(Rye, et al. 197Q).   There is little doubt that benzidine exposure
is  associated with an  increase in the occurrence  of bladder cancer
(International Agency  for Research on Cancsr (IARC),  1972; Riches,
1972; Sax, 1975).  However,  there is a lack of information on the
exact  concentrations   of  benzidine  to  which workers have  been
exposed.
                               C-21

-------
     Long exposure  to  benzidine  produced bladder tumors in 13 out
of 25 men (Zavon, et al. 1973).  Comparison of  the two groups showed
that the tumor group was exposed to benzidine for an average of 13
years while the nontumor group was  exposed for  an  average of less
than 9 years.   Observations  were carried out for approximately 12
years  following exposure.    Ambient  air  benzidine  in  the  plant
varied from 0.005  to  0.415 mg/m  with one  area  giving a value of
17.6 mg/m   (Wendel,  et al.  1974).   Death records of  171 workers
showed  that  18 were  due   to  bladder  and  kidney cancers  and that
there was a higher  rate of neoplasms  of  the digestive system.  It
appeared that  there could  have  been  a synergistic effect between
benzidine and^-naphthylamine, since these workers were exposed to
both chemicals  (Mancuso and El-Attar,  1966, 1967).
     When benzidine  dyestuff manufacturing begins  in  any country
the  incidence  of  bladder   tumors among exposed  workers increases.
Table 3 shows  the  times of  discovery of aromatic  amine  bladder can-
cer in a number of countries. Urinary  system  tumors occurred  in 17
percent of the workers in one benzidine plant.  The highest rate of
tumors was in the group exposed  for  6  to  10 years (Kuzelova, et al.
1969).   Men working  in a French  aromatic amine  plant developed
bladder tumors.  One Normandy factory  had  54 cases, with 17 occur-
ring prior to  1947 and 34 subsequent to 1947.  Symptoms of hematur-
ia and stranguria were  found  in 18 cases  (Billiard-Duchesne,  1960).
     In  Italy,  24  cancers  were  found  in  workers  exposed  to ben-
zidine   or  benzidine-^-naphthylamine  (Vigliani   and  Barsotti,
1962).   Italian benzidine  workers were found  to have  developed 47
cases of bladder cancer during the  period from 1931  to  1960.  There
                               C-22

-------
                  TABLE 3

    Time of Discovery of Aromatic Amine
         Bladder  Cancer  by  Country*
Country                             Year


Germany                             1895

Switzerland                         1905

United Kingdom                      1918

U.S.S.R.                            1926

United States                       1931

Austria                             1932

Italy                               1936

Japan                               1940

France                              1946


*Source:  Haley, 1975
                    C-23

-------
were 21 carcinomas and 16 papillomas.  During the period from 1931
to 1948, 13  of  83 workers developed bladder  carcinomas  from ben-
zidine (Barsotti and Vigliani,  1952).   The  greatest exposure occur-
red in workers in filtration, pressing, drying, and milling of ben-
zidine.  Maximum latency for  benzidine  tumors  was  16 years from the
cessation of  exposure.   Ten  papillomas and  seven carcinomas were
found in a cohort of 858 benzidine dyestuff workers (Forni, et al.
1972).
     Studies  in dyestuff plants in Japan showed 100 cases of blad-
der cancer during  the  period 1949 to  1970.   Benzidine production
workers  accounted for  11.25  percent  of  the cases  and  benzidine
users for 1.45 percent.  Eight cases developed cancer of the upper
urinary tract and not  the bladder.  There was a long latent period
of 16.25 years (Tsuchiya, et al.  1975).   The silk kimono painters
are  the  highest risk  bladder  cancer group  in Japan  because they
point their brushes, thereby ingesting benzidine dyes  (Yoshida and
Miyakawa, 1973).
     There was  a high incidence  of  bladder  tumors (21.3 percent)
in benzidine workers in a coal tar dye factory.  The latent period
was 18.4 years  for  papillomas  and 18.7 for carcinomas (Goldwater,
et al. 1965).  A further  study  showed that  the combined exposure to
benzidine plus ^-naphthylamine  increased  the bladder cancer rate
to 45.5  percent  (Kleinfeld,  et  al.  1966).   Occupational bladder
cancers are  morphologically  similar  to spontaneous bladder tumors
found  in  the general  population.   Both  have a  tendency  for high
recurrence after  treatment.
                               C-24

-------
     At the  present  time  there  is no evidence that 3,3'-dimethy1-
benzidine, 3,31-dimethyoxybenzidine, or 3,3'-dichlorobenzidine are
human  bladder  carcinogens  (Rye,  et al.  1970).    However,  future
epidemiological study may show them to be carcinogenic agents.  No
bladder neoplasms  related  to  exposure  to  3,3'-dichlorobenzidine
over a 35-year  period were  found.  However, the following neoplasms
were reported in 17 workers:   2 lung  cancers,  1 bone marrow cancer,
6  lipomas,  3  rectal papillomas,  2 sigmoid  colon carcinomas,  1
prostate carcinoma,  1 breast  muscle myoblastoma,  and  1 basal cell
epithelioma  (Gerarde  and Gerarde,  1974).   No  bladder  tumors were
found  in  British  workers  handling  this  chemical but  the  worker
exposure time of less than  16 years  could account for these find-
ings (Maclntyre, 1975).  It is possible that  the latent period for
bladder tumors is longer for 3,31-dichlorobenzidine, since workers
exposed to benzidine  plus dichlorobenzidine developed such tumors,
while  those exposed  to  the  latter  compound  alone  did  not (Gadian,
1975).
                               C-25

-------
                      CRITERION FORMULATION



Existing Guidelines and Standards



     In 1973 the U.S.  EPA proposed,  but did  not  promulgate, a toxic



pollutant standard for benzidine (30 FR 35388).



     The industrial standards instituted by  the  Occupational Safety



and Health Administration  (OSHA)  in 1974  excluded from regulation



any compounds  containing less than  0.1  percent benzidine.   These



standards did not recognize a safe level of water contamination and



provided no provisions for environmental monitoring.



     New standards for benzidine discharges have been proposed (41



PR 27012) based upon information on  the toxicological and environ-



mental effects  and  the  fate of benzidine.   These standards,  pro-



mulgated in  1977,  established an  ambient water criterion for ben-



zidine of 0.1 ug/1.  Effluent standards were set at 10 ug/1 (daily



average) with a maximum for  any single day of 50 ug/1.  Based on a



monthly average, daily  loading  was  limited to  0.13  kg/1000  kg of



benzidine produced.  The standards set for users of benzidine-based



dyes were the  same except  that  the  maximum daily effluent concen-



tration of benzidine was limited to  25 ug/1 (42 FR 2617).



Current Levels of Exposure



     It is essential  that  consideration be given to the manner in



which benzidine  and  its  congeners and the  dyes derived from them



contaminate  water  supplies.   In most  cases these chemicals are a



hazard only  in the vicinity  of dye  and pigment  plants where wastes



escape  or  are  discharged.   A  field survey  of  the  Buffalo  and



Niagara  River   areas  using  the   chloramine-T  method,  with  a
                               C-26

-------
sensitivity of 0.2 ug/1, showed no benzidine  in  the samples.  How-
ever, this method  of analysis is photosensitive  and  leads to low
estimates of benzidine.  Moreover, the samples may have been below
the level of detectability, or oxidative degradation may have con-
verted  the benzidine compounds to materials not detectable by the
analytical method used  (Howard and Saxena, 1976).  A Japanese sur-
vey of  the Sumida River area detected 0.082,  0.140, and 0.233 mg/1
of benzidine in the water.   The authors believed  that the benzidine
came from azo dyes by H-S  or SO2 reduction  (Takemura, et al. 1965).
     Information  on  3,3'-dimethylbenzidine,  3,3'-dimethoxybenzi-
dine, and 3,3'-dichlorobenzidine and their dye derivatives  as water
contaminants is nonexistent, and  research  should be  instituted to
correct this deficiency.
     It has  been  stated that  benzidine  resists  physical and bio-
logical degradation (Lutin, et  al.  1965; Malaney,  et al. 1967; Rad-
ding, et al.  1975).  Benzidine in water is oxidatively degraded by
free radical,  enzymatic,  or photochemical  processes  (Radding,  et
al. 1975).   Its half-life  in  water  has been estimated  to be 100
days.   Air oxidation of benzidine  in water seems to  occur readily
(Howard and Saxena,  1976).
     Humic material  seems  to  bind  3,3'-dichlorobenzidine tightly
and its degradation  appears to be slower  than  benzidine,  but the
half-lives of  the  two compounds  are the  same   (Radding,  et  al.
1975).    There  is  no  information  available  on   the dimethyl  and
dimethoxy derivatives.  This deficiency must  be corrected.
     Benzidine  is  converted to a chloramine  type compound during
water chlorination  processes  (Jenkins and  Baird, 1975).   Soil and
                               C-27

-------
intestinal  bacteria reduce  benzidine  azo dyes  to  free benzidine
(Yoshida and Miyakawa, 1973), and although aquatic organisms might
also cause this same transformation, no data  are  available  to prove
this point.   It should  be  remembered  that  the  hydrochlorides of
benzidine are much  more  soluble  in  water than the free amines and
are more resistant  to  degradation than the latter (Bowman, et al.
1976).
Special Groups at Risk
     A  potential  health hazard  exists in the production  of  ben-
zidine  and  its congeners and their  conversion to azo dyes.  There
is no maximum permissible level  of  contamination  in  the industrial
environment, although  there  are  specific  regulations governing the
manufacture  of  benzidine and  its  congeners   (39  FR  3756).  These
standards have reduced the risks to benzidine workers.
     The use of benzidine and its congeners  poses a  potential  risk
to workers in biochemical,  chemical, and microbiological laborator-
ies where these chemicals are used  as  analytical  reagents (Collier,
1974; Veys,  1972; Wood and  Spencer, 1972).  The  greatest  risk oc-
curs in laboratories working with known carcinogens  when good  lab-
oratory practices are not enforced.  No epidemiological evidence is
available to determine the exact extent of the problem.
     The risk to the general  population from  benzidine,  its congen-
ers, and  their dyes  is  unknown, but  contamination  of water  sup-
plies,  which  is  known to occur  in  Japan  (Takemura,  et al. 1965),
poses a yet  to be determined risk.  There also is a  potential  risk
for workers in the garment,  leather, and homecraft industries where
the benzidine dyes  are used.
                               C-28

-------
Basis and Derivation of Criteria
     The available data concerning the  carcinogenicity of benzidine
in experimental animals are severely limited.   It  is extremely dif-
ficult to extrapolate the experimental  results to  man because, with
the possible exception of the dog  and the  rabbit,  the target organs
are different.   Moreover,  the metabolites produced by the various
species, in  general,  differ significantly  from  those  produced by
man (Haley, 1975), although  3-hydroxybenzidine and its conjugation
products are common to both man and  animals.
     Despite  the limitations  of  the available data,  a suggested
criterion for benzidine was calculated using a relative risk model
described in the appendix.  The calculation assumes a risk of 1 in
100,000 of developing cancer as a result of daily consumption of 2
liters of benzidine-contaminated water  and the daily consumption of
6.5 g of benzidine-contaminated aquatic organisms.  Based  on the
data of  Zavon,  et  al.  (1973),  a benzidine criterion of 1.2 x 10~
jug/1 is suggested to be adequate to  protect the population consum-
ing the water.
     Epidemiological  data  indicate  that  exposure to  benzidine is
associated with  an increase  in bladder  cancer in  man.   The possi-
bility  that  benzidine may be  found  in  wastewater may  also pose a
problem.  In order to  determine the extent of the potential prob-
lem, measurements must be made of wastewater, not only for benzidine,
but also for  its congeners.   Moreover,  further evaluation must be
made on these chemicals and  their azo dye derivatives to determine
their stability  to microbiological  degradation.   It  is essential
that studies  of their carcinogenicity  in  experimental  animals be
                               C-29

-------
made at doses which  produce  a bare  minimum of liver pathology.  A
detailed pharmacokinetic  study should be  undertaken  to establish
routes  of  absorption, body  transport,  storage,  and  excretion of
benzidine,  its congeners, and  the azo dyes synthetized from them.
Programs covering  both industrial  hygienic  and epidemiologic as-
pects of exposure  to  benzidine  and  its  congeners to establish the
degree of dermal and  pulmonary absorption  are a  necessity  if we are
to prevent this chemically induced cancer  from occurring.
     Under the  Consent Decree  in NRDC  v. Train,  criteria are to
state  "recommended maximum  permissible  concentrations (including
where appropriate, zero) consistent with  the protection of aquatic
organisms,  human health,  and recreational activities."  Benzidine
is  suspected  of being  a human  carcinogen.   Because  there  is no
recognized safe  concentration for a  human carcinogen, the recom-
mended  concentration  of  benzidine  in water for maximum protection
of human health is zero.
     Because attaining a zero concentration level may  be infeasible
in some cases and  in  order  to assist the  Agency and states in the
possible future development  of water  quality regulations,  the con-
centrations of benzidine corresponding to  several  incremental life-
time cancer risk  levels  have been estimated.  A cancer risk level
provides an estimate  of the  additional incidence of  cancer  that may
be expected in an  exposed population.  A  risk of  10"   for  example,
indicates a probability of one additional  case of cancer for every
100,000  people  exposed,  a  risk  of  10~   indicates  one additional
case of cancer for every million people exposed,  and  so forth.
                               C-30

-------
     In  the  Federal Register notice of  availability of draft am-

bient water quality criteria, the  U.S. EPA stated that it is con-

sidering setting criteria at an interim target risk level of 10~  ,

10~  or 10~  as shown in the table below.
Exposure Assumptions                 Risk Levels          ,,.
   (daily intake)	   	and Corresponding Criteria^	

                           10"7           10"6            10"5

2 1 of drinking         1.2 x 10"5     1.2 x 10"4     1.2 x 10"3
water and consumption      jug/1           wg/1           jug/1
of 6.5 g of fish
and shellfish (2)

Consumption of fish     5.3 x 10"5     5.3 x 10~4     5.3 x 10"3
and shellfish only.        ug/1           jug/1           ug/1
(1)  Calculated from the relative risk model  for epidemiology stud-

     ies as described in the Human Health Methodology Appendices to

     the October  1980  Federal  Register notice which announced the

     availability of this document and in Appendix 1.  Appropriate

     data  used  in the  calculation  of the  model are also presented

     in Appendix I.   Since  the  extrapolation  model  is linear at low

     doses, the additional  lifetime  risk  is  directly proportional

     to the water concentration.   Therefore, water concentrations

     corresponding to other risk levels can be derived by multiply-

     ing or dividing one of  the risk  levels and corresponding water

     concentrations shown in the table by factors such as 10, 100,

     1,000, and so forth.

(2)  Approximately  22  percent  of benzidine  exposure results from

     the consumption of aquatic organisms which exhibit an average
                               C-31

-------
     bioconcentration  potential  of  87.5-fold.   The  remaining 78
     percent of benzidine exposure results from drinking water.
     Concentration levels were derived assuming  a lifetime exposure
to various amounts of  benzidine,  (1)  occurring from the consumption
of both drinking  water  and  aquatic life grown in water containing
the corresponding benzidine  concentrations  and,  (2) occurring sole-
ly from  the  consumption of aquatic  life grown  in  the waters con-
taining the corresponding benzidine concentrations.
     Although total exposure information for  benzidine  is discussed
and an estimate  of the contributions  from other  sources of exposure
can be made, this data will not be factored  into the ambient water
quality criteria formulation because  of the tenuous estimates.  The
criteria presented, therefore, assume  an incremental risk from am-
bient water exposure only.
                               C-32

-------
                            REFERENCES
Akiyama, T.  1970.  The investigation on the manufacturing  plant of
organic pigment.  Jikeikai Med. Jour.   17: 1.

Ames, B. et  al.   1973.  Carcinogens  are  mutagens:   A simple  test
system combining liver homogenates for  activation and bacteria for
detection.   Proc. Natl. Acad. Sci.  70: 2281.

Appleton, H.T.  and  B.C.  Sikka.    1980.   Accumulation, elimination
and metabolism  of dichlorbenzidine in  the  bluegill sunfish.  En-
viron. Sci. Technol.  19: 50.

Baker, R.K.   1950.   The carcinogenic  activity  of  dihydroxy  ben-
zidine  (3,3'-dihydroxy 4,4'-diamino  diphenyl).    Acta  Unio  Int.
Contra Cancrum.  7: 46.

Baker, R.K.    1953.    The  carcinogenic activity  of dihydroxyben-
zidine, further investigations.  Cancer Res.  13: 137.

Baker, R.K. and J.G. Deighton.  1953.   The metabolism of benzidine
in the rat.  Cancer Res.  13: 529.

Barsotti, M.  and E.G.  Vigliani.   1952.   Bladder lesions from  aroma-
tic amines.  Arch. Ind. Hyg. Occup. Med.  5: 234.
                               C-33

-------
Billiard-Duchesne, J.L.  1960.   Gas Francais  de  tumeurs profession-
elles de la vessie.  Acta Unio Int. Contra Cancrum.  16: 284.

Bonser, G.M., et  al.   1956.   The induction of tumours of the sub-
cutaneous tissues, liver and  intestine in  the mouse by certain dye-
stuffs and their  intermediates.  Br. Jour. Cancer.  10: 653.

Bowman, M.C., et  al.   1976.   Benzidine and congeners:  Analytical
chemical properties  and trace analysis in  five substrates.  Int.
Jour. Environ. Anal. Chem.  4: 205.

Bradshaw, L.  and  D.B.  Clayson.   1955.  Metabolism of two aromatic
amines in the dog.  Nature.  176: 974.

Bremner, D.A. and J.D.  Tange.  1966.   Renal  and neoplastic  lesions
after injection of N,N'-diacetylbenzidine.  Arch. Pathol.  81: 146.

Gammer, W.  and  C.L. Moore.   1973.   Oxidation of 3,3'-diaminoben-
zidine by rat liver mitochondria.   Biochem.  12: 2502.

Case/ R.A.M., et al.  1954.  Tumours of the urinary bladder  in work-
men engaged  in  the  manufacture  and use of certain dyestuff  inter-
mediates  in  the  British  chemical  industry:   Part I:  The   role  of
aniline,  benzidine,  alpha-naphthylamine   and   beta-naphthylamine.
Br. Jour. Ind. Med.  11:  75.
                               C-34

-------
Christopher,  K.J.   and  B.T.  Jairam.    1970.    Benzidine   (H-NCg-
H4CgH4NH2) poisoning in white rats.  Sci. Cult.  36: 511.

Clayson, D.B.  1969.  Some Problems in  Bladder  Carcinogenesis.  In;
E.D. Bergmann and B. Pullman (eds.), Physico-chemical Mechanisms of
Carcinogenesis.  The Israel Acad. Sci.  Human., Jerusalem.   p. 284.

Clayson, D.B.  1976.  Case Study 2:  Benzidine and 2-naphthylamine
- voluntary substitution or technological alternatives.  Ann. N.Y.
Acad. Sci.  271: 170.

Clayson, D.B., et al.  1959.  The fate of benzidine  in various spec-
ies.  Acta Unio Int. Contra Canerum.   15: 581.

Collier, H.B.  1974.  Are  orthotolidine and  dianisidine  health haz-
ards to laboratory workers?  Clin. Biochem.  7:  3.

Deichmann, W.B. and H.W.  Gerarde.   1969.   Toxicology of Drugs and
Chemicals.  Academic Press, New York.

Deichmann, W.B., et al.   1965.   Synergism among oral carcinogens.
III.  Simultaneously  feeding  four  bladder  carcinogens to dogs.
Ind. Med. Surg.  34: 640.

Dieteren,  H.M.L.    1966.    The  biotransformation  of   o-tolidine.
Arch. Environ. Health.  12: 30.
                               C-35

-------
Dunn, T.B., et al.   1956.   Lipemia and glomerular lesions in rats



fed  diets  containing N,N'-diacetylbenzidine  and 4,4,4',4'-tetra-



methylbenzidine.   Proc. Soc. Exp. Biol. Med.  91: 105.
                                            14
EG & G Bionomics.  1975.  Exposure of fish to   C-benzidine:  Accum-


                                           14
ulation, distribution,  and  elimination of  C residue.  Res. Rep.



to Allied Chemical Corp.
Elson, L.A., et  al.   1958.  The metabolism  of aromatic amines in



relation to carcinogenesis.  Br. Jour. Cancer.  12: 108.







Englebertz, P.  and E.  Babel.    1953.   Nachweis  von  benzidin und



seinen umwand lungs produkten  im harn und in organteilen.   Zentr.



Arbeitsmed. Arbeitsschutz.  3: 161.







Forni, A.,  et al.   1972.  Urinary  cytology  in workers exposed to



carcinogenic  aromatic  amines:   A six-year  study.    Acta Cytol.



16: 142.







Gadian, T.  1975.  Carcinogens in  industry, with  special reference



to dichlorobenzidine.   Chem. Ind.   19: 821.







Garner,  et al.    1975.    Testing of  some  benzidine  anologies for



microsomal activation to bacterial mutagens.  Cancer Lett.  1: 39.







Gehrman, G.H.   1936.   Papilloma and carcinoma of the bladder in dye



workers.  Jour.  Am. Med. Assoc.  107: 1436.
                               C-36

-------
Gerarde, H.W. and D.F. Gerarde.  1974.  Industrial experience with
3,3'-dichlorobenzidine:   An epidemiological  study of  a chemical
manufacturing plant.  Jour. Occup. Med.  16: 322.

GoIdwater, L.J., et  al.   1965.  Bladder tumors  in  a  coal tar dye
plant.  Arch. Environ. Health.  11: 814.

Golub, N.I.  1969.  Transplacental  action of 3,3'-dichlorobenzidine
and orthotoludine on organ cultures of embryonic mouse kidney tis-
sue.  Bull. Exp. Biol. Med.  68: 1280.

Golub, N.I., et al.  1974.  Oncogenic action of some nitrogen com-
pounds on the progeny of experimental mice.  Bull.  Exp.  Biol.  Med.
78: 1402.

Griswold, D.P. Jr., et al.  1968.  The carcinogenicity of multiple
intragastric  doses of  aromatic and  heterocyclic nitro  or amino
derivatives  in young  female  Sprague-Dawley rats.    Cancer Res.
28: 924.

Haley, T.J.   1975.   Benzidine  revisited:   A review of the  litera-
ture and problems associated with the  use of benzidine  and  its con-
geners.  Clin. Toxicol.  8: 13.

Hamblin, D.O.  1963.   Aromatic Nitro and Amino Compounds.   In; D.W.
Fassett and D.D. Irish  (eds.) , Industrial  Hygiene and Toxicology.
Interscience Pub., New York. 2: 2105.
                               C-37

-------
Barman, J.W.   1971.   Chronic glomerulonephritis and the nephrotic



syndrome  induced  in  rats  with  N,N'-diacetylbenzidine.    Jour.



Pathol.  104: 119.







Barman, J.W., et al.   1952.  Chronic  glomerulonephritis  and nephro-



tic syndrome induced in rats by N,N'-diacetylbenzidine.  Am. Jour.



Pathol.  28: 529.








Birai, K.  and K. Yasuhira.   1972.  Mitochondrial oxidation of 3,3'-



diaminobenzidine and related compounds,  and  their possible relation



to carcinogenesis.  Gann.  63: 665.







Holland, V.R.,  et  al.   1974.   A safer substitute for benzidine in



the detection of blood.  Tetrahedron.   30:  3299.







Howard, P.H, and J.  Saxena.   1976.   Persistence and degradability



testing of benzidine and other carcinogenic compounds.  EPA-560/5-



76-005.  U.S. Environ. Prot. Agency, Washington, D.C.







Hueper, W.C.   1954.   Recent developments in environmental cancer.



Arch. Pathol.   58: 475.







International Agency for  Research on Cancer.   1972.   IARC mono-



graphs on the evaluation of carcinogenic risk of chemicals to man.



Vol. I. Lyon, France.
                               C-38

-------
Jenkins,  R.L.  and R.B.  Baird.   1975.   The  determination of  ben-
zidine in wastewaters.   Bull. Environ. Contain. Toxicol.   13:  436.

Johnson, K.  1980.  Memorandum to D.W. Kuehl.   U.S.  EPA.   March 10.

Kellner, H.M., et al.   1973.  Animal studies on the kinetics of  ben-
zidine and 3,3'-dichlorobenzidine.  Arch. Toxicol.   31:  61.

Kleinbauer, V.,  et al.   1969.   Sledovani expozice  zamestnancu pri
vyrobe benzidinu. Cesk.  Hyg.  14:  150.

Kleinfeld, M.,  et al.   1966.    Bladder  tumors in  a coal tar dye
plant.  Ind. Med. Surg.  35: 570.

Kuzelova, M., et  al.   1969.  Sledovani pracovniku zamestnanych pri
vyrobe benzidinu. Prac.  Lek.  21:  310.

Laham, S.   1971.   Metabolism of  a new carcinogen  related to  ben-
zidine.  Toxicol. Appl.  Pharmacol.  19:  368.

Lutin, P.A.,  et  al.   1965.  Oxidation  of selective  carcinogenic
compounds by activated sludge.   Proc.  Ind. Waste  Conf.   20:  131.

Maclntyre,  I.    1975.   Experience of  tumors in  a British  plant
handling 3,31-dichlorobenzidine.   Jour.  Occup. Med.   17:  23.
                               C-3,9

-------
Malaney, G.W.,  et al.   1967.   Resistance of carcinogenic organic
compounds to  oxidation  by activated sludge.   Jour.  Water Pollut.
Control Fed.  39: 2020.

Maneuso, T.F. and A.A. El-Attar.  1966.  Cohort studies of workers
exposed  to   betanaphthylamine  and  benzidine.    Ind.  Med.  Surg.
35: 571.

Mancuso, T.F.  and A.A.  El-Attar.   1967.   Cohort  study of workers
exposed  to  betanaphthylamine  and  benzidine.   Jour.  Occup.  Med.
9: 277.

Marhold, J.,  et al.   1967.   Possible complicity of diphenyline  in
the origin  of tumors in  the  manufacture of  benzidine.   Toxicol.
Appl. Pharraacol.  10: 397.

McCann, J.,  et  al.  1975.   Detection of carcinogens as mutagens  in
the  Salmonella/microsome  test:   Assay of  300 chemicals.   Proc.
Natl. Acad.  Sci.  72: 5135.

Meigs, J.W.,  et al.   1951.   A study  of exposure to benzidine and
substituted  benzidines  in  a  chemical  plant.    Arch.  Ind.  Hyg.
Occup. Med.    4:  533.

Meigs, J.W.  , et al.   1954.  Skin penetration by diamines of the ben-
zidine group.   Arch. Ind. Hyg. Occup. Med.   9:  122.
                               C-40

-------
Nakajima, T.   1955.   On the  influence  of  the  aromatic nitro- and



amino-derivatives  on  the blood  phenolase  activity.   Rodo Kagaku



Kiho  4: 22.







National Academy of Sciences.  1975.  Pest control:  An assessment



of  present  and  alternative   technologies.   Vol.  1:  Contemporary



pest control practices and prospects:  The report of the Executive



Committee.   Washington, D.C.  20148.







Neish, W.J.P.   1967.   Liver  glutathione and polyamines in hepato-



carcinogen-treated rats.  Biochem. Pharmacol.  16:  163.







Painter, R.B. and R. Howard.  1978.  A comparison of the HeLa DNA-



synthesis inhibition test and the Ames test for screening of muta-



genic carcinogens.  Mutat. Res.  54: 113.







Pliss, G.G.   1959.  The blastomogenic action of dichlorobenzidine.



Vopr. Onkol.  5: 524.







Pliss, G.B.   1961.   On  the  cancerogenic action of 3,3'-dioxyben-



zidine (Is  3,3'-dioxybenzidine a basic  cancerogenic metabolite of



benzidine?)   Vopr. Onkol.  7: 33.







Pliss, G.B.   1963.  On some regular relationships between carcino-



genicity of aminodiphenyl derivatives  and  the structure  of sub-



stance.   Acta Unio Int. Contra Cancrum.   19: 499.
                               C-41

-------
Pliss, G.B.   1964.  On  the  cancerogenic  properties of benzidine.
Vopr. Onkol.  10:  50.

Pliss, G.B.   1969.   On  peculiarities of  carcinogenic  effect of
3,3'-benzidine bicarboxylic acid.  Vopr. Onkol.  15: 60.

Pliss, G.B.  and  M.A.  Zabezhinsky.   1970.   Carcinogenic properties
of  orthotolidine  (3,3'-dimethylbenzidine).    Jour. Natl.  Cancer
Inst.  45: 283.

Pliss, G.B.,  et  al.   1973.  On  intestinal  tumors  induced by ben-
zidine in rats.   Vopr. Onkol.  19: 75.

Popler, A., et al.  1964.  Follow-up of exposure in people working
in the production  of benzidine.  Prac. Lek.  16: 147.

Prokofjeva,  O.G.   1971.   Induction  of hepatic  tumors  in mice by
benzidine.  Vopr.  Onkol.   17: 61.

Radding, S.B., et  al.   1975.   Review of the environmental fate of
selected chemicals.  EPA 560/5-75-001.  U.S. Environ. Prot. Agency,
Washington, D.C.

Rao, K.V.N.,  et  al.   1971.   Subacute Toxicity of Benzidine in the
Young Adult Mice.  In; Fed. Proc. Am.  Soc. Exp. Biol.  30: 344.
                               C-42

-------
Riches, E.  1972.  Industrial cancers.  Nurs. Mirror.  134:  21.







Rinde, E. and W. Troll.  1974.  Azo dyes as potential bladder car-



cinogens.  Proc. Am. Assoc. Cancer Res.  15: 65.  (meeting abst.)







Rinde, E. and  W.  Troll.   1975.   Metabolic  reduction of benzidine



azo  dyes  to benzidine in  the rhesus monkey.   Jour.  Natl.   Cancer



Inst.  55: 181.







Rye,  W.A.,  et  al.    1970,    Facts  and myths  concerning aromatic



diamine curing agents.  Jour. Occup. Med.  12: 211.







Saffiotti, U. , et al.  1967.   Induction of Bladder Cancer in Ham-



sters fed Aromatic Amines.  In; W. Deichmann and  K.F. Lampe  (eds.)



Bladder  Cancer;  a  Symposium.   Aesculapis,  Birmingham, Alabama.



p. 129.







Sax,  N.I.   1975.   Dangerous Properties of  Industrial  Materials.



4th ed.  Van Nostrand Reinhold Co., New York.







Schwartz, L. ,  et al.   1947.   Dermatitis in Synthetic Dye Manufac-



ture.  In;  Occupational  Diseases of  the  Skin.    Lea  and Febiger,



Philadelphia, Pennsylvania.  p. 268.







Sciarini, L.J.   1957.   3-Hydroxybenzidine,  a metabolite  of ben-



zidine.  Arch.  Biochem. Biophys.  71: 437.
                               C-43

-------
Sciarini, L.J.  and J.W. Meigs.   1958.   The  biotransformation of



benzidine (4,4'-diaminobiphenyl), an  industrial  carcinogen in the



dog. I.  Am. Med. Assoc. Arch. Ind.  Health.  18:  521.







Sciarini, L.J.  and J.W.  Meigs.   1961a.   The  biotransformation of



benzidine.  II.  Studies  in  mouse and  man.  Arch. Environ. Health.



2: 423.







Sciarini, L.J.  and  J.W.  Meigs.   1961b.   Biotransformation of the



benzidines.  III.  Studies on diorthotoludine, dianisidine  and di-



chlorobenzidine:  3,3'-disubstituted congeners  of benzidine (4,4'-



diaminobiphenyl).  Arch. Environ. Health.  2: 584.







Scott, T.S.   1952. The  incidence of bladder tumours  in a dyestuffs



factory.  Br.  Jour. Ind. Med.  9: 127.







Shabad, L.M.,  et al.   1972.   Transplacental effect of some chemical



compounds on  organ cultures  of  embryonic kidney tissue.   Cancer



Res.  32: 617.







Soloimskaya,  E.A.    1968.   The  distribution  of  benzidine  in rat



organs  and  its  effect  on  the  peripheral blood.   Vopr.   Onkol.



14: 51.







Spitz,  S. ,  et al.   1950.   The  carcinogenic  action  of benzidine.



Cancer.  3:  789.
                               C-44

-------
Stephan, C.E.  1980.  Memorandum to J. Stara.  U.S. EPA.  July 3.







Stula, E.F., et  al.   1971.   Experimental neoplasia in ChR-CD rats



with  the  oral  administration of  3,3'-dichlorobenzidine,  4,4'-



methylenebis  (2-chloroaniline)  and  4,4l-methylenebis   (2-methyl-



aniline).  Toxicol. Appl. Pharmacol.  19: 380.







Stula, E.F.,  et  al.  1975.   Experimental neoplasia  in  rats from



oral  administration of  3,3'-dichlorobenzidine,  4,4'-methylenebis



(2-chloroaniline)   and    4,4'-methylene-bis   (2-methylaniline).



Toxicol. Appl. Pharmacol.  31: 159.








Takemura, N. , et  al.  1965.  A survey of the pollution  of  the Sumida



River, especially on the aromatic amines  in  the water.   Int. Jour.



Air Water Pollut.  9:  665.







Troll, W.  and  N.  Nelson.  1958.  Studies on aromatic amines:  I.



Preliminary observations on  benzidine metabolism.   Am.  Ind. Hyg.



Assoc. Jour.  19: 499.







Troll, W., et al.  1963.   N-hydroxy  acetyl amino compounds, urinary



metabolites of aromatic  amines in  man.   Proc. Am.  Assoc.  Cancer



Res.  4: 68.







Tsuchiya, K. ,  et al.   1975.    An epidemiological  study of occupa-



tional bladder tumours  in the dye  industry  of Japan.   Br.  Jour.



Ind. Med.  32: 203.
                               C-45

-------
U.S. EPA.  1978.  In-depth studies on health and environmental im-
pacts of selected water pollutants.  Contract No. 68-01-4646.  U.S.
Environ. Prot. Agency.  Washington, D.C.

U.S. EPA.  1980.  Seafood consumption data analysis.  Stanford Re-
search  Institute International.   Menlo Park,  California.   Final
Report, Task 11.  Contract No. 68-01-3887.

Veys, C.A.  1972. Aromatic amines:  The present status of  the prob-
lem.  Ann. Occup. Hyg.  15: 11.

Vigliani, E.C. and M. Barsotti.  1962.   Environmental  tumors of the
bladder in some  Italian dyestuff factories.  Acta Unio Int. Contra
Canerum.  18: 669.

Weisburger, J.H., et al.   1967.   New carcinogenic naphthalene and
biphenyl derivatives.  Nature.  213: 930.

Wendel,  R.G.,  et al.   1974.   Benzidine:  A  bladder carcinogen.
Jour. Urol.  Ill: 607.

Wood,  J.M.  and  R.  Spencer.    1972.   Carcinogenic  Hazards in the
Microbiological Laboratory.   In; D.A. Shapton and R.G.  Board (eds.),
Safety  in Microbiology.  Academic Press,  London,  p.  185.
                               C-46

-------
Yoshida, 0.  and M. Miyakawa.   1973.   Etiology  of Bladder Cancer



"Metabolic" Aspects.   In; W.  Nakahara, et al.  (eds.),   Analytical



and Experimental  Epidemiology of Cancer.   University  Park Press,



Baltimore.   p. 31.







Zavon, M.R., et al. 1973.  Benzidine exposure as a cause of bladder



tumors.  Arch. Environ. Health.  27: 1.
                               C-47

-------
                            APPENDIX  I

                Summary and Conclusions Regarding
                the Carcinogenicity of Benzidine*
     Benzidine ((1,1'-biphenyl)-4,4'-diamine) is used in the manu-

facture of dyes,  as a  reagent for detection  of H-O- in milk, and as

a reagent for hemoglobin.

     It appears that the greatest  hazard to  exposure  from benzidine

occurs during its manufacture.  Absorption  through the skin is the

primary  route  of  entry  into  the  body,  although other  routes of

exposure such as inhalation and ingestion also exist.  Exposure to

benzidine,  its  derivatives,  and  other chemicals involved  in the

manufacture of dyes has  long been known to be  associated  with an

elevated  incidence  of  bladder  cancer  in workers in  Germany,

England, Italy, France,  Switzerland, Japan,  and  the  United States

(see Haley, et al. 1975, Zavon, et al.  1973, Clayson, 1976).

     Epidemiological data clearly  demonstrate  that  benzidine  is a

bladder carcinogen  in  humans, and  experimental evidence indicates

that it can induce cancer in a variety  of organs  in several species

of animals.  Several animal studies have reported carcinogenic ef-

fects of  benzidine  in  hamsters (liver), rats  (liver and Zymbal's

gland), and mice (liver).  Dogs have  been reported to develop  urin-

ary  bladder  tumors following  chronic  exposure  to large  doses of

benzidine (Spitz,  et al. 1950; Bonser,  et al. 1956).   However, the
*This  summary  has been  prepared  and approved  by  the Carcinogens
 Assessment Group, EPA, on July 15,  1979.
                               C-48

-------
small  numbers  of animals  involved make  the significance of  these
findings questionable.
     The difference  in organotropic  properties of benzidine  among
the different  species  is  probably  due  to both its route of excre-
tion and metabolism.  For example,  in humans and dogs,  benzidine or
its metabolites  are largely excreted through the urine, whereas in
mice and rats, excretion is largely through  the bile.  In man,  70 to
90 percent of benzidine is excreted  in the  urine in the form  of 3-
hydroxybenzidine.  In rats, it is questionable  whether  this metabo-
lite is even formed, but  it is formed in the dog and rabbit.
     Three  studies  have  reported  mutagenic activity  of benzidine
towards Salmonella  typhimurium  (TA 1537  and TA 1538)  in the  pres-
ence of  a rat  liver  mixed function oxidase  system  (Ames,  et al.
1973; McCann, et al. 1975).
     The  carcinogenic  and  mutagenic activities  of  benzidine in
animal systems  clearly substantiate the epidemiological findings
that show  benzidine  to be carcinogenic  in humans.    In  a recent
report, The National Academy of  Sciences (NAS, 1975) calculated an
estimate of the  total benzidine  exposure of occupationally exposed
humans on the basis of the urinary  levels.   The NAS report present-
ed a table comparing tumor incidence and total accumulated dose in
humans and two species of laboratory animals.
     Table 1  contains  data from the NAS  (1975)  report as well as
additional animal data.  On the basis of  the data presented  in this
table,  it  is  apparent  that in  animal  studies  where benzidine was
injected and where liver  tumors  were induced, much higher doses of
benzidine were  required  than  in the sensitive mammary tumor rat
                              C-49

-------
had a fibroadenoma.  Based on these data/  the  concentration  of ben-
zidine in water, calculated  to keep the lifetime cancer risk below
10~5, is 8.5 x 10"4 jug/1.
     Although the criterion  value  derived from human exposure data
is higher than that calculated from the most  sensitive animal sys-
tem,  it  seems  reasonable that human epidemiological data are most
appropriate for estimating human risks.   The study  of Zavon, et  al.
(1973) was selected as the data base for  deriving  the water  quality
criterion.  Based on  these data, the concentration of benzidine  in
water calculated to keep the lifetime cancer risk  below  10~   is  1.2
x 10"3 iig/1.
                               C-52

-------
                  Summary of Pertinent Data

     The data  from  the human epidemiology  study  of  Zavon,  et al.
(1973) was used to estimate  the concentration of benzidine in water
calculated  to  keep  the lifetime cancer risk below 10"  .   In this
study 25 workers in a  benzidine  manufacturing  plant  were observed
for the  appearance  of  bladder  tumors after a mean exposure period
of 13.61  years,  their  average age  at the end of  exposure  was 44
years and at the end of a  13 year observation was 57 years.  The men
not showing evidence of cancer had  a mean exposure period of 8.91
years, their average age at the  end  of exposure was 43 years and at
the end of  observation  56 years.  The estimated  total accumulated
dose of 130 mg/kg was estimated  from average urinary  levels of ben-
zidine in these workers at the end of a workshift (see Table 1 and
Zavon, et al.  1973). The  criterion  was calculated  from the follow-
ing parameters:
     Average weight of man = 70 kg
     Observed  incidence of bladder cancer = 13/25 (52 percent)
     Bioconcentration factor of benzidine = 87.5
     X = average daily exposure producing lifetime risk of 10
     B* = potency factor,  which  is an estimate of  the linear depen-
          dency of cancer rates on lifetime average dose
     C = concentration of  benzidine  in water, calculated to produce
         a lifetime risk of 10~ , assuming ,
         ters of water and 0.0065 kg fish.
a lifetime  risk of 10~ ,  assuming a daily ingestion of 2 li-
                               C-53

-------
 The  average  duration of  benzidine exposure  for  this cohort  was
11.46 years.  The average  urine  level of benzidine  at  the  end  of  a
workshift was approximately 0.04 mg/1 of urine*  Assuming the aver-
age urine output per day for a man  is 1.2  I/day  the expected urine
concentration would be
                    0.04 nig/1 x  1.2  I/day
                  = 0.0480 mg/day worked
Assuming  a  recovery  factor  of  1.45%  (i.e.,  1.45% of the  actual
exposure concentration was found in the urine according to  Rhinde
and Troll,  1974 )  and assuming an  average  human body weight of 70
kg, the estimated exposure  is
            -r  70 = 0.0473 mg/kg/day worked
Assuming that an average of 240 days  are worked  in  a year,  the  re-
sulting average lifetime exposure would be
     0.0473 x     x —=— « 0.0063 mg/kg/day,
              JV-I   -»U . J
where 11.46  is  the  average  duration of exposure and  56.5  years  is
the average age of the cohort at  the end of  study.
The carcinogneic potency of  benzidine  is estimated,  using the model
     P = 1 - exp  £-Bdt~ j, as
     B »[- In  (1 - 13/25JJ -j- [0.0063  x  (56. 5/71. 3 ) 3 J
       = 234.13 (mg/kg/day)""1,
where 71.3 years  represents the average life span  in  the  U.S.  and
56.5 years is the  average age of the cohort at the end  of the study.
                               C-54

-------
Therefore, the water concentration is calculated as:
            70 x 10"5
    234.13 (2 + 0.0065 x 87.5)
    1.16 x 10~6 mg/1
    1.16 ng/1.
                          C-55

-------