United States         Office of Water         EPA 440/5-80-040
               Environmental Protection    Regulations and Standards    October 1980
               Agency           Criteria and Standards Division
                             Washington DC 20460
C.I
&EPA        Ambient
               Water Quality
               Criteria for
               Dichlorobenzidine

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      AMBIENT WATER QUALITY CRITERIA FOR

             DICHLOROBENZIDINE
                 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

             Rcr ',:ccr'.v-*-1 P-otr.otton A^orcT
                       ::,:;! GCXi
                       i

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                              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

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                               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.  alI.   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

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                              ACKNOWLEDGEMENTS
Aquatic Life Toxicology:

    William A. Brungs, ERL-Narragansett
    U.S. Environmental Protection Agency
David J. Hansen, ERL-Gulf Breeze
U.S. Environmental Protection Agency
Mammalian Toxicology and Human Health Effects:
    Havish Sikka (author)
    Syracuse Research Corporation

    Steven D. Lutkenhoff (doc. mgr.)
    ECAO-Cin
    U.S. Environmental Protection Agency

    Jerry F. Stara (doc. mgr.), ECAO-Cin
    U.S. Environmental Protection Agency

    Edward Calabrese
    University of Massachusetts

    Herbert Cornish
    University of Michigan

    Alfred Garvin
    University of Cincinnati
    Norman E. Kowal, HERL
    U.S. Environmental Protection Agency

    Larry K. Lowry
    National Institute for Occupational
      Safety and Health

    Roy E. Albert*
    Carcinogen Assessment Group
    U.S. Environmental Protection Agency
H.T. Appleton
Syracuse Research Corporation

Douglas L. Arnold
Health and Welfare
Canada

Richard A. Carchman
Medical College of Virginia

Patrick Durkin
Syracuse Research Corporation

Ernest Foulkes
University of Cincinnati

Frank Gostomski
Criteria and Standards Division
U.S. Environmental Protection Agency

Roman W. Kuchuda
U.S. Environmental Protection Agency

Frank Stern
National  Institute for Occupational
  Safety  and Health
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,,  T.  Highland,  R. Rubinstein.
*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,  Jeffrey  Rosen-
    blatt,  Dharm V.  Singh, and Todd W. Thorslund.

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                              TABLE OF  CONTENTS
Criteria Summary

Introduction                                                    A-l

Aquatic Life Toxicology                                         B-l
    Introduction                                                B-l
    Effects                                                     B-l
         Residues                                               B-l
    Criteria                                                    B-l
    References                                                  B-3

Mammalian Toxicology and Human Health Effects                   C-l
    Exposure                                                    C-l
         Ingestion from Water                                   C-l
         Ingestion from Food                                    C-l
         Inhalation                                             C-3
         Dermal                                                 C-5
    Pharmacokinetics                                            C-5
         Absorption                                             C-5
         Distribution                                           C-5
         Metabolism                                             C-6
         Excretion                                              C-7
    Effects                                                     C-9
         Acute, Subacute and Chronic Toxicity                   C-9
         Synergistic and/or Antagonistic Compounds              C-10
         Teratogenicity                                         C-10
         Mutagenicity                                           C-ll
         Carcinogenicity                                        C-13
         Summary                                                C-21
    Criterion Formulation                                       C-22
         Existing Guidelines and Standards                      C-22
         Current Levels of Exposure and Special
           Groups at Risk                                       C-22
         Basis and Derivation of Criterion                      C-23
    References                                                  C-26
Appendix                                                        C-31
    Summary and Conclusions Regarding the Carcinogenicity
      of 3,3'-Dichlorobenzidine                                 C-31
    Summary of Pertinent Data                                   C-33

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                              CRITERIA DOCUMENT
                              DICHLOROBENZIDINE
CRITERIA
                                 Aquatic  Life
    The data base  available  for  dichlorobenzidines and freshwater  organisms
is limited to one  test on bioconcentration of  3,3'-dichlorobenzidine,  and  no
statement can be made concerning  acute or chronic toxicity.
    No saltwater organisms  have  been tested with  any  dichlorobenzidine,  and
no statement can be made concerning acute or  chronic toxicity.

                                 Human Health
    For  the  maximum  protection  of   human  health   from  the   potential
carcinogenic effects  due  to exposure of  dichlorobenzidine  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  ,  10  ,   and  10  .    The
corresponding recommended  criteria  are  0.103  yg/1,  0.010  pg/1,  and  0.001
pg/1,  respectively.   If  the above  estimates  are  made  for  consumption  of
aquatic organisms only, excluding consumption  of water, the  levels  are  0.204
vg/1, 0.020 ug/1, and 0.002 yg/l, respectively.

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                                 INTRODUCTION

    Dichlorobenzidine  (^,4'-d>amino-3,3'-dich'lorobipheny1   or  3,3'-dichloro-
benzidine)  (DCB)  is used  in the  production  of dyes  and   pigments  and  as a
curing  agent  for  polyurethanes.  The molecular  formula of dichlorobenzidine
is ci2H10C12N2 and the molecu1ar weight is 253.13 (Stecher, 1968).
    DCB forms brownish needles  with  a melting  point of 132 to 133"C (Pollock
and Stevens,  1965).   It  is readily  soluble  in  alcohol, benzene, and glacial
acetic acid (Stecher, 1968),  slightly soluble  in HC1 (Radding, et al. 1975),
and sparingly soluble in water  (0.7  g/1  at 15"C) (Stecher, 1968).  When com-
bined with  ferric chloride or  bleaching  powder, a green   color  is  produced
(Pollock and Stevens, 1965).
    The  affinity  of DCB for suspended particulates in water  is  not clear;
its basic nature suggests that  it  may be  fairly tightly bound  to humic mate-
rials in  soils  (Radding, et  al.  1975).   Soils may  be  moderate  to  long  term
reservoirs.
    Pyrolysis of  DCB will  most  likely  lead to the  release of HC1.   Because
of the  halogen  substitution,  DCB  compunds probably biodegrade at  a slower
rate  than  benzidine  alone.   The  photochemistry of DCB  is  not  completely
known.  DCB may photodegrade to benzidine (Sikka, et al. 1978).
    Assuming  the  clean  air   concentrations  of  ozone   (2  X 10~*  M)  and  an
average  atmospheric  concentration  of hydroxyl  radicals (3  X  10~*5  M),  the
half-life for oxidation  of  DCB by  either  of these chemical  species  is on the
order of one and one to  10 days,  respectively.   Furthermore, assuming a  rep-
resentative concentration of  10    M for peroxy radicals   in  sunlit oxygen-
ated water,  the  half-life for  oxidation  by  these   species  is approximately
100 days, given the  variability of environmental conditons  (Radding,  et al.
1975).

                                     A-l

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                                  REFERENCES

Pollock,  J.R.A.  and R.  Stevens  (eds.)   1965.  Dictionary  of Organic  Com-
pounds.  Eyre and Spottiswoode, London.

Radding,  S.B., et  al.   1975.   Review  of the environmental  fate  of selected
chemicals.  U.S.  Environ.  Prot. Agency, Washington, D.C.

Sikka, H.C., et  al.   1978.   Fate of 3,3'-dichlorobenzidine  in  aquatic envi-
ronments.  EPA 600/3-8-068.   U.S. Environ. Prot. Agency.

Stecher,  P.G.  (ed.)   1968.   The  Merck  Index.   8th ed.  Merck  and  Co.,  Rah-
way, New Jersey.
                                      A-2

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Aquatic Life Toxicology*
                                 INTRODUCTION
     The  data  base for^dichlorobenzi dines  and freshwater  and  saltwater or-
ganisms is limited to a  bioconcentration  and  depuration study with the blue-
gill and 3,3'-dichlorobenz1dine (Appleton and Sikka, 1980).
                                    EFFECTS
Residues
     The  apparent  equilibrium  bioconcentration  factors  for the bluegill dur-
ing tests of from  96  to  168 hours  were from 114 to 170  for edible flesh and
495 to  507  for whole body  (Table  1).   An initial  rapid rate of elimination
was followed by a  low or negligible rate, with  appreciable residues remain-
ing after 14 days in clean water.
                                   CRITERIA
     The  data  base  available for dichlorobenzidines and freshwater organisms
is limited to  one  test on  bioconcentration of  3,3'-dichlorobenzidine  and no
statement can be made concerning acute or chronic toxicity.
     No saltwater  organisms have been  tested with  any  dichlorobenzidine and
no statement can be made concerning acute or chronic toxicity.
*The reader  is referred  to  the Guidelines  for  Deriving Water Quality  Cri-
teria 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 calculations for deriving various  measures of  tox-
icity as described in  the Guidelines.
                                     B-l

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                                            Table 1.  Residues  for dlchlorobenzldlne (Appleton  A Slkka,  1980}

                                                                                               Bloconcentratlon     Duration
                               Species                       Tissue          CheatcaI        	Factor	      (days}

                                                                     FRESHWATER  SPECIES
                               Bluegill,                    whole  body       3,3'-dlchloro-         495-507             4-7
                               Lepomls macrochlrus                            benzldine

                               Bluegill,                    edible flesh     3.3»-dlchloro-         114-170             4-7
                               Lepomls macrochlrus                            benzldine
CO

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                                  REFERENCES







Appleton, H.T. and H.C.iSikka.  1980.  Accumulation,  elimination,  and metabol-



ism of  dichlorobenzidine  in  the bluegill  sunfish.  Environ. Sci.  Technol.



14: 50.
                                     B-3

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Mammalian Toxicology and Human Health  Effects
                             EXPOSURE
Ingestion from Water
     To date, few systematic measurements of DCS  in water  supplies
have been undertaken.   In one instance/ analysis of purge wells  and
seepage water near  a  waste disposal lagoon receiving DCB-manufac-
ture wastes  showed  levels of DCS ranging from 0.13  to 0.27 mg/1.
High levels of benzidine (up to 2.5  mg/1)  were  also seen, which  may
have arisen  from photodegradation  of  DCS  (Sikka, et  al. 1978) ,
since  benzidine  is no  longer manufactured  in the U.S.   Several
other dichlorobenzidine isomers were also  detected at  levels from  1
to  8  mg/1.    The use of  lagoons to  handle  DCB-containing wastes
might  lead to contamination of ground  water and  pose a threat to
persons relying on nearby wells for drinking water.
     Takemura, et al.  (1965)  analyzed the  water of the Sumida River
in Tokyo during  1964.   This river receives  the waste effluents of
several dye and pigment factories.  The presence  of DCS was demon-
strated by thin  layer chromatography.   Although levels of DCS  it-
self were not quantified, colorimetric  analysis revealed that total
aromatic amine content of the water  (including  benzidine, dichloro-
benzidine, o<-naphthylamine, and  ^-naphthylamine)  reached levels
up to  0.562 mg/1.  The  authors  suggested  that  the presence of  the
free amines might be due  to  chemical  reduction of the azo-dyes by
the high levels of H2S and S02 in the river.
Ingestion from Food
     Few studies  have  attempted to identify DCS as a contaminant of
human food.   Since DCB has never had an application as an agricul-

                               C-l

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tural or food chemical, the most likely source of dietary DCB would
be through consumption of contaminated fish.
     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
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 were 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  bioconcentration  factor of  500  was
obtained for 3,3'-dichlorobenzidine using bluegills  (Appleton and
Sikka, 1980).   Since bluegills  from  another  source  contained an
average of  4.8 percent  lipids  (Johnson, 1980),  these, bluegills
probably contained about  the same  percent  lipids.  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
                               C-2

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 lipids  that is the weighted  average for consumed fish  and  shell-
 fish.  Thus, the weighted average bioconcentration factor for 3,3'-
 dichlorobenzidine  and ttfe  edible portions  of  all freshwater  and
 estuarine aquatic organisms consumed by  Americans is  calculated to
 be 500 x 0.625  - 312.
     No  DCS was detected  in  fish sampled  from  the  vicinity of  a
 DCB-contaminated waste lagoon using  analytical methods with  sensi-
 tivity of 10 to 100 yg/kg  (G. Diachenko, personal communication).
 Inhalation
     The physical properties of  DCB  (low volatility/  large crystal
 structure) probably minimize the  risk of exposure of  general popu-
 lations  to  DCB through inhalation of air contaminated through  in-
 dustrial processes.   However, inhalation might  represent a  major
 source of  occupational exposure  under  sub-optimum working  condi-
 tions.  Akiyama (1970) examined the exposure of workers to DCB in  a
 pigment plant  in Japan and determined  that during the addition of
 DCB to reaction vessels for synthesis of DCB pigments, the concen-
 tration of DCB in air reached  2.5 mg/100  m   in 10  minutes of  charg-
 ing of reaction vessels  and decreased to 0.2 mg/100  m3  within 20
minutes.  The  distance of the sampling  device  from the  operation
was not specified.  Also,  the  amount of  total aromatic amines was
elevated in  exposed  personnel (presumably  due  to the presence of
DCB) . The mean urinary concentrations of  aromatic  amines  in process
workers charging the reaction  vessels with  DCB and plant  laboratory
workers were 20.1 ppm and  21.1 ppm, respectively.   Levels  were only
14.5 ppm in  workers who dried  and cracked the pigments, 12.7  ppm in
office clerks,  and  13.6  ppm in controls (medical students).  Al-
                               C-3

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though  the concentrations detected were highly variable  (i.e.,  the
mean  20.1  ppra from the  charging personnel was  derived  from data
ranging  from 48.5  td  10 ppm),  it  is possible  that the elevated
levels  result from  DCS  exposure,  since  Akiyama claims that few or
no precautions were taken to prevent exposure, particularly on  hot
days.   It is uncertain whether the amines entered the body through
respiration or through dermal absorption.
     Gerarde and Gerarde  (1974)  reported  on an industrial process
in which both DCB and  the DCB  diarylide  pigments were manufactured.
Most steps in the process were performed  in  closed systems, and  the
DCB was  handled  in  a  salt form  in a  slurry (ca.  80 percent water
content).  DCB dust was said not to be a problem.  The possibility
that DCB contamination exposure could, however, occur is indicated
by the statement  that  "...the  floor and accessible surfaces contam-
inated with the  slurry were  usually hosed  down  to prevent accumula-
tion of dried material...."  Also, an outbreak of dermatitis in  the
plant  was  attributed  to  a  process  change  in DCB production.   In
utilizing DCB in  pigment  production, the major sources of potential
exposure are  listed as  the weighing  process and charging  of  the
tanks.   Prior to  May  1973,  operators wore  gloves and goggles but
not dust face masks.  DCB was  manufactured  in this plant from 1938
to 1957.  Thereafter, DCB was purchased  from  an  outside supplier.
On-site inspection of  three  DCB  utilizing  plants  showed that two of
the plants  posed  relatively  low exposure potential which was due to
use of  metal  reactors  and protective  arrangements  at the point of
tank charging.  However, in the third plant, chemicals were dumped
into open  reaction  vessels from  an  elevated platform,  posing  an
                               C-4

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enhanced potential for exposure.  Therefore, a great deal of varia-
bility  concerning  the  exposure of  individuals  to DCS  may exist
among various operations/
Dermal
     Because of  large  particle size and increased usage of closed
systems and protective clothing, dermal absorption of DCB probably
represents  a  relatively minor  route of DCB exposure in humans at
present.  However,  Meigs,  et al.  (1954) presented  some experimental
evidence that under certain environmental  conditions favoring moist
skin conditions, such  as  high  relative humidity and high air tem-
perature, the dermal absorption by humans  of benzidine and possibly
other congeners such as DCB may be enhanced.
                         PHARMACOKINETICS
Absorption
     Virtually no information exists that  quantifies the  degree and
rate of  absorption of  DCB  in  experimental animals  or  in humans,
although Meigs, et al.  (1954)  detected  DCB in the  urine of DCB pro-
cessing and manufacturing workers.
Distribution
     A detailed  distribution study  of DCB in  rats,  monkeys,  and
dogs given  0.2 mg/kg of   C-DCB by  intravenous  injection was re-
ported by  Kellner,  et  al.  (1973).   The results indicate a rather
general distribution within the body  after  a  14-day  observation
period with highest levels found in the livers of all three species.
The  bile  of  monkeys   and  the  lungs of  dogs  showed  significant
levels of radio-activity.
                               C-5

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Metabolism
     DCB metabolites  have  not been detected  in  the urine of dogs
                   jt
administered DCB orally or  by intraperitoneal injection  (Sciarini
and Meigs, 1961; Gerarde and Gerarde, 1974).
     Kellner, et al.  (1973) examined  the  urine of a Rhesus monkey
                 14
given 0.2 mg/kg   C-DCB  intravenously and found  that in the first
                                                               14
four hours following injection, about one-third of the urinary   C
was unchanged DCB,  with  another  third identified as mono-N-acetyl
DCB, based  on chromatographic properties.   The  remainder  of the
        14
urinary   C was not recoverable via ether extraction at pH 11.  At
later intervals, mostly metabolites were excreted, with nonextract-
     14
able   C comprising the majority of this material.
     No ortho-hydroxy metabolites of DCB were detected in the urine
of human subjects after oral dosing (Gerarde and Gerarde, 1974).
     Aksamitnaia (1959) reported that prolonged  ingestion (7.5 to
8.5 months)  of small doses  or  a single large dose  of DCB  in rats led
to the appearance of four transformation products, including benzi-
dine and possibly glucuronide conjugates.   This  conclusion may be
tenuous because analysis was done by paper chromatography  (one sol-
vent system)  without  benefit  of  radiotracer techniques,  and the
products were  not  quantified or  further  characterized.   DCB was
never detected in the urine in any of the experiments; by-products
were seen only after seven months of chronic DCB ingestion.
     In a study of  the bioconcentration of DCB in bluegill sunfish,
over one-half of the DCB  residues  in  the fish were in the form of a
conjugate which, under very'mildly acidic  conditions, hydrolyzed to
reform free DCB  (Sikka, et al. 1978).
                               C-6

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     Hirai and  Yasuhira  (1972)  noted that DCB was not oxidized by
cytochrome c, whereas  benzidine  and  other derivatives  were oxi-
dized.
     The majority of information available at  present suggests that
DCB is resistant to metabolism, with the exception of certain con-
jugative mechanisms and possibly certain bioactivation steps.  Ring
chlorination of benzidine probably blocks ring hydroxylation reac-
tions of  DCB for both electronic  and  steric  reasons (Shriner,  et
al. 1978).
Excretion
     The  excretion  of  DCB  and  metabolites following  a  0.2 mg/kg
                    14
intravenous dose of   C-DCB was  studied by Kellner,  et al.  (1973)
in rats, dogs, and monkeys.  With all species, measurable elimina-
tion  had  ceased within  seven days  of  administration  (Table  1)  .
Fecal excretion  was  the predominant route  of elimination in rats
and dogs, and possibly in monkeys.
     Sciarini and Meigs (1961) also noted a preponderance of fecal
elimination of DCB  in  dogs.   Finally,  Gerarde  and  Gerarde  (1974)
cite  an  unpublished study  utilizing human volunteers  which con-
cluded that DCB  is  excreted largely by the fecal route  in man  as
well as in dogs.
     Insufficient data  is  available to assess  the  ability of the
body  to  accumulate significant  burdens  of  DCB  through  repeated
exposures.
                               C-7

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                                           TABLE 1


                         14                                             14
            Excretion of   C-DCB in Rats, Dogs and Monkeys Administered   C-DCB*
Species

o Rat
CD
Dog
Monkey 1
Monkey 2
Interval
(day)
Urine
*
0-6 18+4
0-7 8+6
0-7 27
0-7 37
Elimination of Total
Feces
*
79 + 12
84 + 11
46
26

fc50
Phase IV
(hr)
45
--
--
--
Dose
Feed
*
1
5
21
20
Administered
Balance
0-7 day
98 + 12
97 + 8
94
83

Residues
%
2
3


*Source:  Kellner, et al.  1973

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                              EFFECTS
Acute, Subacute,  and Chronic  Toxicity
     Gaines  and  Nelso*n (19'77) reported the acute oral  toxicity  of
DCB  to male and  female mice.   The LD^Q (mg/kg/day) for DCB  given
daily for  seven  days was 352  for  female  mice (slope = 27.39) and
386  for  male mice  (slope = 23.15).   The  single dose LD50  (mg/kg)
was  488  for  females and 676 for males.
     Gerarde  and Gerarde  (1974) listed results of  several  toxico-
logical  studies  with DCB.  DCB-dihydrochloride  failed to  produce
skin irritation  in  rabbits at an unspecified  dose.   An  intradermal
dose of 700 mg/kg also gave a  negative reaction.  One hundred  mg  of
DCB-free amine placed  in  the  conjunctival  sac of the eye of a rab-
bit  gave  a negative reaction, while 20 mg of DCB  dihydrochloride
produced erythema,  pus, and opacity of the eye,  giving a score  of
84 of a possible 110 in one hour according  to  the method of  Draize.
The  oral  LD5Q was given as 7.07 g/kg  in  albino  rats for DCB  free
amine, and 3.82 g/kg in male and female Sprague-Dawley rats  for DCB
dihydrochloride.   For topical  application to skin, an LD_Q  of 8
g/kg in male and  female rats was seen.  Pliss (1959)  noted that rats
given 120 mg of DCB subcutaneously exhibited a state of excitation
with short-lived  convulsions.
     No human  fatalities  resulting from exposure to DCB have  been
reported.
     Ten rats  exposed to  a  concentrated  atmospheric dust  of DCB
dihydrochloride for 14 days showed, upon autopsy, slight to moder-
ate  pulmonary congestion  and one  pulmonary  abcess  (Gerarde and
Gerarde,  1974).   An irritant  effect  from  HC1  cannot be discounted
in the study.

                               C-9

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     Freeman, et al.  (1973) noted that DCB was cytotoxic  to embry-
onic rat cells  in culture at concentrations of 5 ppm or greater.
     No mortalities tfere obtained in inhalation- studies where  rats
were exposed to a concentrated  atmosphere of concentrated  DCB dihy-
drochloride  dust  for  14 days,  or  to  355  mg DCB  free  amine for 2
hours daily  for 7 days  (Gerarde and Gerarde,4 1974).
     Gerarde  and  Gerarde  (1974) listed the  principal  reasons for
visits to a  company medical clinic  by  employees  working with  DCB.
These  were   as  follows:   (1) gastro-intestinal  upset,   (2) upper
respiratory   infection,  (3)  sore   throat,    (4)  caustic  burns,
(5) headache, (6) dizziness, and (7) dermatitis.   The only illness
apparently directly related to DCB was dermatitis.  An outbreak of
dermatitis was  attributed  to  a manufacturing process change which
led to small  amounts  of DCB-free base  in  the  isolated  DCB sulfate
salt.  Two cases of  acute cystitis were found in the medical record
review of the workers.  One was of infectious origin and  the other
related to the presence of renal calculi.   Cystoscopic examination
of three other  workers  with urinary system  symptoms  revealed two
had renal calculi, and another had cystitis cystica.
Synergistic and/or Antagonistic Compounds
     No data are available concerning compounds which synergize or
antagonize the toxicity of DCB.
Teratogenicity
     No information  is available defining the teratogenic potential
of DCB.   While  perhaps not directly  relevant  to  the  question of
DCB-induced  teratogenesis,  several  studies summarized  in  the  fol-
lowing discussion show that DCB can cross the placental barrier and
can also affect developmental  systems.

                               C-10

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     DCS has been demonstrated to significantly  increase  the  inci-
dence of leukemia  in the offspring of  pregnant  female mice  given
comparatively low d6ses  (ca. 8-10 mg)  of DCB by subcutaneous injec-
tion in the last week of  gestation (Golub, et al.  1974) .  This  could
have been  due  to postnatal transfer  of DCB  to  the young  through
lactation.   However, transplacental effects of DCB have  also  been
observed.  Shabad, et al. (1972)  and Golub  (1969)  noted  that kidney
tissue taken from embryos of pregnant female mice  treated with DCB
exhibited  altered  behavior in organ  culture,  including  increased
survival and  hyperplastic  changes in epithelium  not  seen  in  con-
trols.
     The degree of  exposure of  pregnant women to DCB  is probably
low.  The work force involved  in  the manufacture  and utilization of
DCB is predominantly or  totally male.  Maclntyre  (1975) lists  five
women, all between the ages of 20 and 34 years, as having been DCB
service  or  production  workers in  a  plant  in  Great  Britain.   The
same area of the plant employed 217 men.
Mutagenicity
     Garner,  et al.  (1975)  compared  the  relative mutagenicity of
benzidine,  DCB, and  other analogs in the bacterial mutagenesis  sys-
tem developed  by Ames,  et al.  (1973) , utilizing  the Salmonella
typhimurium tester strain TA1538, an indicator of  frameshift muta-
genesis.  The relevant data are  summarized in Table 2.   These re-
sults show  that DCB is  considerably  more  potent  as  a frameshift
mutagen  in  this system  than is benzidine.   Also,  a low  degree of
mutation is elicited by DCB.but not by benzidine in the absence of
the S-9 activation enzyme system.
                               C-ll

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                              TABLE 2

               Mutagenicity  of  DCB  in  the  Ames  Assay*
Compound
3,3 '-Dichlorobenzidine
3,3 '-Dichlorobenzidine
Sulfate salt,
technical grade
Benzidine
Dimethyl sulfoxide
(control)
yg Chemical/ „ q#*
Plate s~9
50 +
100 +
50
100
50 +
100 +
50
100
50 +
100 +
50
100
+
Revertants/
Plate
3,360
7,520
114
131
5,490
8,350
127
129
430
640
5
15
16
8
 *Source:  Garner, et al.  1975

**S-9 is the NADPH-fortified rat liver activation enzyme preparation,
  + signifies preparation  present;  -,  preparation absent.
                              C-12

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     Similar  observations  were made  by Lazear  and  Louis  (1977),
utilizing an  enzyme activation  system  obtained  from  the livers of
male mice and Ames  tester  strain  TA98 (an indicator of frameshift
mutation).  As before, DCB  was  much more mutagenic than benzidine
and, unlike benzidine, retained an appreciable mutagenic activity
without the liver enzymes.   DCB  was also  slightly mutagenic  towards
tester strain TA100, indicating base-pair substitution mutation,
Carcinogenicity
     Stula, et al.  (1975) maintained 50  male and 50 female  rats on
a dietary level of DCB of 1,000  mg/kg.   The average 50 percent  sur-
vival was 356 days, with average  days on the test of 349 days for
females and 353 days for males.  The range of days on the test was
118-486 days for males and 143-488 days for  females.  The  rats  were
38 days old at the start  of the  assay and were apparently autopsied
at  time  of  death or after  486-488  days  (not specified) .    The re-
sults of this study are  listed  in  Table  3.
     In  addition  to the  cancers listed  in Table 3, the occurrence
of malignant lymphoma was elevated over controls but not at  statis-
tically significant (p«<0.05) levels.  No bladder cancer was noted.
     In a recent study, Stula, et  al.  (1978)  reported on the induc-
tion of both  papillary transitional cell carcinomas of  the  urinary
bladder and hepatic carcinomas in female beagle  dogs.  An  oral  dose
of  100 mg  DCB was administered to  the experimental animals, three
times per week for six weeks, then five times per week continuously
for periods up  to 7.1 years.  DCB was found to  be carcinogenic  at
statistically significant  -levels   (p<.025).   The  incidences  of
hepatic  carcinomas were 4/5 and  0/6 in DCB-treated  and  control
                               C-13

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                                                TABLE  3



                               Induction of Cancer  in Male and Female Rats


                                       by 1,000 ppm Dietary DCBa
o
i
No. of Cancers
Type of Cancer
Maiqmary adenocarcinoma
Granulocytic leukemia
Zymbal's gland carcinoma
Male0
DCB
7b
9b
8b
Vehicle
control
0
2
0
Female0
DCB
26b
0
1
k-
Vehicle
control
%
3
0
0
         aSource:  Stula, et al. 1975
          Significantly greater than controls at p<0.05
          •

          The number of animals examined histologically was 44 each for male and female.

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groups, respectively.  The incidences of urinary bladder carcinomas
were 5/5 and 0/6, respectively (Table 4).
     For 12 months,-* 6  times  weekly,  Pliss (1959)  added 0.5 to 1.0
ml of a 4.4 percent  suspension of  DCB to the feed of rats of both
sexes of a strain assumed by Pliss to have a low spontaneous tumor
rate.  Each  rat  received a total  dose  of 4.53 g.   Neoplasms were
detected in  22 of  29  (75.8  percent)  surviving  animals.   Tumors,
primarily carcinomas, were observed  in  a broad spectrum of organs
including mammary  gland,  Zymbal's gland  (sebaceous  gland of the
external auditory meatus), bladder,  skin, small  intestine, liver,
thyroid gland, kidney, hematopoietic  (lymphatic)  system, and sali-
vary glands.
     An  assay of  DCB  carcinogenicity  was  also  done with  mice
(Pliss, 1959).  The mice received  0.1 ml  of a  1.1 percent  DCB sus-
pension  in  their food  for 10 months,  receiving a  total  dose of
127.5  to 135  mg  DCB.  Hepatic tumors were found in  4  of  18 mice
surviving after 18.5 months (22.2 percent).  A  sebaceous gland car-
cinoma and a lung adenoma were also seen.
     The  Pliss  studies  show  that  DCB may possess carcinogenic
activity in both rats and mice.   However,  the massive  and apparent-
ly acutely-toxic dose levels employed,  the uncertain  purity of the
commercial product  used, the virtual  lack of  dose-response data,
and  the  lack of adequate  controls limit the studies' utility for
assessing human health hazards.
     Carcinogenicity assays were also performed using rats  and mice
which  received DCB  by  subcutaneous injection  (Pliss, 1959, 1963).
However,  these  studies  are  not  considered  here because of the
                               C-15

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                           Table  4.
Summary  of Grpss^ Pathology and  Microscopic Pathology
I
1
!
i
•
f.
f
r
1
U
SES S
*• H-.* *
ft* *M 4M«J 2
S o ~ at, "
I 2 u *'u I
3 b S ti S *
** C»OSS fATHOLOCV
*•* C 1.* Liven pale fatty appearance
451 t l.t Numerous grey firm nodule*, up to 2.J
cm. In liver, lung, urlnery bladder,
kidney, heart, lymph nodes, temporal
auscles. uterus, and gall bladder.
*•' S ' J.I One pink raised Irregular nodule on
urothellal surface of urinary bladder.
foci, up to 1.5 en, u liver.
*•• S 7.1 Six raised gray nodules, up to 2.S cm,
on urothellel surface of urinary
bladder; numerous palo brown foci, up
to 2.S cm. In liver.
J" S 7.1 Several raised gray nodules, up to 4.0
aa». on urothellal surface of urinary
bladder. Numerous nodules. up to 7.0
eo. In liver with adhesions to gall
bladder and pancreas.
**l S 7.1 Six raised fray nodules, up to 4.0 mm,
on urotliellal surface of urinary
bladder. Numerous gray, hemorrhaglc ,
cystic nodulis. up to 2.S cm. In liver.
*" 1 1.1 Hauaeryt 2 nodules () cm); liver 1 pale
nodule (2 sa»); lung! multiple nodule
(1 cm); spleen! 2 nndules it nm)
°M S (.0 Hannaryi nodule (2 cm); adrenal cortex!
nodule (i mm); liven 2 pale nodulee
(12 mm)
•00 S t.O Hanuryi nodule (t mm)] spleeni
liven pale firm streaks, nodular
'51 f t.O All sun>ary glands enlarged, contained
milk; spleeni nodule (10 m>); vaginal
one ralced nodule (2 ma); livari
	 . multiple pale noJules (l.i cm)
"° S 1.0 Mammary: nodule (S mm); vaginal several
firm nodules (2 mm)
Ml S t.O Ham»aryi 2 nodules (1 mm) firm; kldneyi
several gray nodules in cortex (2 m»)|
lung: diffuse areas of firmness: liven
seversl gray nodules (i mm)
1 • 
          Nul<- 1 Alt du)>s had |H>nrxlnMl jl disease wilh loss ol some leellt
               2 1 IH- organs exan.mod hisloloKically included, brain, spinal < ord. heart, aorla. kinB. Irachca. ovary, ulc-rus. vaBina. esophagus stomach small
                 inluiiute. cecum. large intt-sline, bone marrow, spleen. Ihyrnus. liver, panireas. salivary gland, pituitary, thyioid. parathyroid! adrenal kidiu-y
                 eye. urinary bladder and all gross lesions.

           Source:    Stula,  et  al.  1978.

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irrelevancy of  the  subcutaneous route of  administration to human
exposure.
     Griswold, et al. (1968) examined the potency of cancer induc-
tion by  DCS,  benzidine, and  other compounds,  using  induction of
mammary  cancer  in young female  Sprague-Dawley rats  as  the major
index.    Forty-day-old female  Sprague-Dawley  rats  were given 30 mg
of DCB every three days  for  30 days by gavage and were  then observed
for  nine months.   Under the  conditions of  this assay,  DCB was
ineffective as a mammary carcinogen but benzidine  was  highly effec-
tive at  lower doses.
     Sellakumar, et al.  (1969) maintained male  and female hamsters
for an unspecified length of time on a diet containing 0.1 percent
(1,000 ppm)  of  DCB.  With  30 animals of  each  sex,  no cancer was
observed.  However, at  0.3  percent dietary DCB, four transitional
cell bladder  carcinomas, some  liver tumors,  and diffuse chronic
intrahepatic obstructing cholangitus were seen.  At 0.1 percent in
the diet of benzidine, many liver tumors were obtained but  no blad-
der cancer was found.
     DCB was  also found to produce transformation in cultured rat
embryo cells infected with Rauscher leukemia  virus (Freeman, et al.
1973).   The  index of transformation was the development of macro-
scopic foci of spindle cells,  lacking polar orientation and contact
inhibition.   Cells  from typical foci were tumorigenic when trans-
planted  into  newborn  Fisher rats,  although this  transplantability
was not quantitated.  DCB-induced transformation was seen at a con-
centration of 5  ppm in  the medium, but not at 1 ppm.  Levels of 10
ppm  or higher were  cytotoxic.   This in_ vitro test system  detected
                               C-17

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 transformation-activity  in  6 of  7  aromatic  amines  characterized as
 active  in  vivo  carcinogens, 1 of 2 aromatic amines classed  as weak
 in vivo carcinogens, and K) of 3  aromatic amines classed as non-car-
 cinogenic  in  vivo.   DCB  was classed by the authors as a  weak car-
 cinogen.
     The history  of human industrial experience with DCB has been
 summarized  and  analyzed  by  Gerarde and Gerarde (1974)  and  Rye,  et
 al.  (1970)  in  the  United States;   by  Maclntyre (1975)  and  Gadian
 (1975)  in Great Britain;  and by  Akiyama  (1970)  in  Japan.  The con-
 census of these authors,  achieved  through epidemiological studies,
 is that  there is  no evidence that  DCB  itself has  induced  bladder
 cancer, the characteristic  lesion  induced by  benzidine, naphthyla-
 mine, and  other carcinogenic  aromatic amines used  in  the dye  and
 pigment  industry.   The case for  DCB carcinogenicity has  been made
 largely on  the basis of its structural similarity  to benzidine and
 its tumorigenicity in several species of animals (Maclntyre,  1975).
 One problem associated with epidemiological studies of DCB  effects
 in humans is that  the population  which has been  exposed only to DCB
 is small.   Many workers  have also  handled  benzidine or other  car-
 cinogens.  Also, the characteristic latency  period  for  induction of
 bladder cancer by chemicals is quite long,  exceeding 16  years  for
 benzidine (Haley,  1975),  and may  not have elapsed for many workers.
 Finally, most of  these  studies  have focused solely  upon  bladder
cancer as  the disease of interest.  As  discussed  below,  this  ap-
proach may be misleading  and fallacious  in  view of the pattern  of
DCB carcinogenesis in anima-ls and the nature of cancer observed  in
DCB process workers.
                               C-18

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     Gadian  (1975) examined  the  health records of 59 workers at a
dyestuff plant in Great Britain who were exposed from 1953 through
1973 to DCB only and compared them to  those working with both ben-
zidine and DCB,  and to unexposed  populations.   This time was justi-
fied as the  average  latency period for chemically-induced bladder
cancer in  humans  (ca.  18 years) .  It  was  calculated that the DCB
process worker  was actually  exposed  to DCB  for a  maximum  of 10
hours per  work week.  Men whose total DCB exposure was less than 245
hours  (six months'  full-time work)  were  excluded from the study,
leaving 35 segregated DCB workers.  These 35 workers, representing
a  total  of  68,505  hours  of DCB  exposure,  had  no  urinary  tract
tumors, no other tumors,  and  two  deaths from other causes  (coronary
thrombosis, cerebral hemorrhage).  In contrast, among 14 mixed ben-
zidine and DCB workers with 16,200  hours exposure  (approximately 60
percent worked  with  benzidine,  40  percent worked with DCB),  three
men developed tumors of the bladder,  and one man developed carcino-
ma of  the  bronchus.   One death from coronary  thrombosis occurred.
Since  the  use of  benzidine ceased in  1964,  the  mixed  group  had a
longer  time   to develop   tumors  than  the DCB-segregated  group.
Therefore, the DCB-alone hours worked during the  same period (1953-
1964)  as  the mixed group was 31,945  hours.   These results,  while
admitting that the population studied was small,  were taken as evi-
dence that DCB can be safely  used if  the provisions of the Carcino-
genic Substances Regulations are observed.
     Maclntyre  (1975)  also surveyed  the health  history of a DCB-
utilizing  plant in Great  Britain.   It was  noted  that  the  vast
majority  (209 out of  217)  of production  and  service  workers had
                               C-19

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 received  first exposure to DCB less than 20 years  before  the time
 of  the  report, indicating that the latent period for  tumor  forma-
 tion might not have elapaed.  Only 3 of the 217 exposed workers were
 deceased.   The causes of  death  were  amytrophic lateral  sclerosis
 (age 55 years, 15 years of DCB exposure, 39 years  since  first ex-
 posed) , carcinoma of  the  lung  (age 61 years, one year  of  DCB expo-
 sure, 12  years since first exposed),  and pneumonia  (age 70  years,
 10  years  of DCB  exposure,  43  years  since first  exposed).   Three
 other employees  who  had not been exposed to DCB died  of bronchial
 carcinoma.  All  employees exposed to  DCB since 1965 have  received
 cytological testing twice  yearly,  with all tests proving negative.
 A 1974 meeting of occupational physicians is  also cited, stating
 that in Europe approximately 1,000 persons have been exposed  to DCB
 with a zero incidence of bladder cancer.
     Gerarde and Gerarde (1974) reported the  results of an  epidemi-
 ological study of workers  exposed  to DCB in manufacture and  utili-
 zation in a plant  in the United States.  A survey of the number of
 DCB-exposed workers who  developed neoplasms  and the  type of  neo-
 plasm was presented.   These included lung cancer (2 workers),  leu-
 kemia-bone marrow (1) ,  lipoma (6) , rectum-papilloma   (3) ,  sigmoid
 colon carcinoma (2),  prostate carcinoma  (1), breast muscle myoblas-
 toma (1),  and skin basal cell epithelioma (1).   A total of 17 work-
 ers of the total of 207 workers surveyed had developed neoplasms.
     The etiology of bladder  cancer  was discussed  and  the  data
 treated using  several epidemiological  and  statistical approaches.
Accordingly, if DCB were  as. potent as benzidine as  a bladder  car-
cinogen and the latent period  long enough, a  total  of 22 cases of
                              C-20

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bladder cancer  out of 163 DCS production  workers would have been
observed, whereas none were seen.   The possible  induction by DC8 of
tumors at sites other than the bladder was not considered.
Summary
     Based upon  existing  data,  there is little  doubt that DCB is
carcinogenic in several animal species  including rats, mice, ham-
sters, and  dogs.   According  to  current methodology,  the experi-
mental evidence serves as  an  indication  that a  potential carcino-
genic risk  is  posed to man.   DCB induces tumors  in a variety of
tissues in animals, with mammary, hematopoietic,  and  skin (Zymbal's
gland) tissue  being the most affected.   Many of  the tumors have
been characterized as malignant.
                              C-21

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                       CRITERION FORMULATION
 Existing Guidelines  and  Standards
      The American  Corffereruce  of Governmental  Industrial Hygienists
 (ACGIH,  1977)  has  recommended that  no  exposure  to  DCS  by any route
 should  be permitted,  because  of a  demonstrated high  carcinogenic
 response in animals.   Strict regulations have  recently  been promul-
 gated by the Occupational Safety and Health Administration to mini-
 mize  or  eliminate  occupational exposure to DCB (29 CFR  1910).   To
 date, no standards have been placed on permissable  levels of DCB in
 the environment or in  food.
 Current  Levels of Exposure  and  Special Groups at Risk
      It  is  estimated  that  between  250 and 2,500  workers  receive
 exposure to  DCB  in  the U.S.,  compared  to  62  for benzidine  (Fish-
 bein, 1977).   Given  the  stringent  precautions which must be  taken
 in  the  manufacture and use of DCB, the level  of  exposure may  be
minimal  at present,  although  no data  is available.   However, past
 exposure  of individuals working  without benefit of protective mea-
 sures must present a cause  for concern.   In addition,  the general
population may receive exposure  to DCB through contaminated  drink-
 ing water or  food  (fish),  although there is no significant evidence
for this  at the present.
     Additional groups that may be  at  risk include workers  in  the
printing  or  graphic  arts professions  handling the  DCB-based  azo
pigments.  DCB may be  present as an impurity  in the pigments,  and
there is  very  limited  evidence  to suggest  that  DCB may be metabo-
lically liberated  from  the azp pigment.  More  information is needed
on the levels of  exposure to and metabolism of these pigments.
                              C-22

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Basis and Derivation of Criterion
     The safe dose of DCS in  water was calculated  from the carcino-
genicity assays, using a*linearized  multistage  model described in
the Human Health Methodology  Appendices  to the October 1980 Federal
Register notice which announced the availability of this document.
The calculation assumes a risk of 1  in 100,000 of developing cancer
as a result of daily consumption of 2 liters of water and 6.5 g DCB-
contaminated fish or shellfish having a bioconcentration factor of
312.  Although  several carcinogenicity studies  are  available for
use in calculating a criterion for DCB in drinking water, only the
work of Stula and coworkers  (1975,  1978) was considered, since the
studies by Pliss (1959, 1963) lack appropriate control data.  More
specifically, the data on induction of hepatic carcinomas in female
beagle dogs (Stula, et al. 1978) were chosen as  a  base for the cal-
culation.   Based on  these data,  a DCB  criterion  of  0.103  ug/1 is
judged  to  be  adequate  to  protect  the population  consuming the
water.  This dose is low from an occupational viewpoint and should
justify efforts to eliminate exposure of workers to DCB.
     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."   DCB is sus-
pected of being  a human carcinogen.   Because  there is no recognized
safe concentration for a human carcinogen, the recommended concen-
tration of  DCB  in water  for  maximum  protection  of human health is
zero.
                               C-23

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     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  DCB  corresponding to  several  incremental lifetime
cancer risk levels  have  been  estimated.   A cancer  risk level pro-
vides 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.
     In the Federal Register notice of availability of draft ambi-
ent water quality criteria, the U.S. EPA stated that it is consid-
ering  setting criteria at  an  interim target risk  level  of 10"  ,
10" , or 10~  as shown in the table below.

Exposure Assumptions    Risk Levels and Corresponding Criteria(1)
   (daily intake)_            -            _
                             10~7         10"6         10"5
2 1 of drinking
water and consumption     0.001 ug/1   0.010 ug/1   0.103 ug/1
of 6.5 g of fish
and shellfish (2)
Consumption of fish       0.002 ug/1   0.02 ug/1    0.204 ug/1
and shellfish only.
(1)  Calculated by  applying  a  linearized  multistage model as men-
     tioned above.  Appropriate bioassay data used in the calcula-
     tion are presented  in the Appendix.   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 multiplying or dividing one of the risk levels and
                               C-24

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     corresponding water concentrations shown in the table by fac-
     tors such as 10, 100, 1,000, and so forth.
(2)  Fifty percent o£ DCB exposure results from the consumption of
     aquatic organisms  which exhibit an  average  bioconcentration
     potential of 312-fold.  The remaining 50 percent of DCB expo-
     sure results from drinking water.
     Concentration levels were derived assuming  a lifetime exposure
to various amounts of  DCB, (1) occurring from  the  consumption of
both drinking water and aquatic life grown in water containing the
corresponding DCB  concentrations  and,  (2)  occurring  solely  from
consumption of aquatic life grown in  the waters  containing the cor-
responding DCB concentrations.
     Although total  exposure  information  for DCB  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
ambient water exposure only.   Care must be  taken  to remember that
the proposed  criterion  is  derived from animal experiments using
pure DCB.  In the environment, DCB undergoes degradation to other
possibly toxic compounds such as  benzidine.   The possible addition-
al risk posed by these  breakdown products should  be considered in
the overall assessment of DCB.
                              C-25

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Akiyama, T.  1970. ~*The investigation on  the manufacturing plant of
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Aksamitnaia, I.A.   1959.   Some  data on transformation products of
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American Conference of  Governmental Industrial Hygienists.   1977.
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Ames, B.N., et al.  1973.  Carcinogens are mutagens: A simple test
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Appleton, H.T. and  H.C.  Sikka.   1980.  Accumulation, elimination,
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Pishbein, L.  1977.   Potential industrial carcinogens and mutagens.
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Freeman, A.E.,  et al.   1973.  Transformation of cell cultures as an
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                              C-26

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Gadian, T.  1975.  Carcinogens  in  industry, with special  reference
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Gaines, T.B.  and  C.J.  Nelson.   1977.   In; 5th Anniversary Report,
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Gerarde, H.W. and D.F. Gerarde.   1974.  Industrial experience with
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Golub, N.I.  1969.  Transplacental action of 3,3'-dichlorobenzidine
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Griswold,   D.P.,  et  al.   1968.    The  carcinogenicity  of  multiple
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Hirai, K. and Y.  Yasuhira.   1972.  Mitochondrial oxidation of 3,3'-
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Stula, E.F.,  et al.  1978.  Liver and urinary bladder  tumors  in dogs



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                              C-30

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                             APPENDIX
              Summary and Conclusions Regarding the
       Carcinogenicity  of  3,3'-Dichlorobenzidine (DCS)*
                   -*
     3,3'-Dichlorobenzidine  (DCB) is used as an intermediate  in the
synthesis of dyes and pigments.   It  is structurally related to car-
cinogenic aromatic amines, which have been used in  the  dye and pig-
ment industries.
     Five  epidemiological studies  of  employees  handling  DCB  in
chemical plants in the  United States, Great  Britain, and Japan have
provided no  evidence of  DCB-induced cancers.  However, investiga-
tive problems  associated  with these studies,  such as  too  short a
follow-up time  and  small  sample size,  make them unreliable as the
sole basis  for making conclusions  about human cancer risks from
DCB.
     DCB has  induced carcinomas in  three species  of  experimental
animals receiving oral  doses  of  the  chemical.   Dogs (female) devel-
oped papillary transitional  cell carcinomas of  the urinary bladder
and  hepatocellular  carcinomas.   Hamsters  developed   transitional
cell bladder  carcinomas,  liver  cell,  and cholangiomatous tumors.
Rats developed mammary adenocarcinomas  (male and female), granulo-
cytic leukemia  (males), and  Zymbal's gland  carcinomas  (males).
     Two studies  of the  mutagenicity  of  DCB  showed  that  it was
mutagenic  in two  Salmonella typhimurium  tester  strains  (TA1538,
TA98)  in the  presence  and absence of an  S-9  liver enzyme system.
DCB also transformed cultured rat embryo cells, and the  transformed
cells were tumorigenic when  transplanted  into  newborn  rats.

*This  summary has been prepared and approved  by  the Carcinogens
 Assessment Group, U.S. EPA, on June 15,  1979.
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     The carcinogenic,  mutagenic,  and transforming  activities of
DCB in laboratory organisms and  its  chemical  similarity to benzi-
dine, a  human  bladder carcinogen,  are strong  evidence  that it is
likely to be a human carcinogen.
     The water quality criterion for DCB is based on the induction
of hepatic carcinomas in female beagle dogs, given an oral dose of
100 mg 3,3'-dichlorobenzidine, three times per week for six weeks,
then five times per week continuously  for  up  to 7.1  years  (Stula,
et al.   1978).   The concentration of  DCB  in  water,  calculated to
keep the lifetime cancer risk below 10" ,  is 0.103 ug/1.
                               C-32

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                    Summary of  Pertinent Data



     The water quality criterion  for  DCB is based on the induction

of hepatic carcinomas in  female beagle  dogs,  given an oral dose of

100 mg DCB, three times per week for six weeks, then five times per

week continuously for periods up to 7.1 years  (Stula, et al. 1978).

The criterion was calculated  from the following parameters:


            Dose                           Incidence
         (mg/kg/day)             (No.  responding/No, tested)

            0                              0/6

            7.36                           4/5

      le = 2,593 days                 w = 11.391 kg
      Le = 2,593 days                 R = 312 I/kg
      L  = 3,159 days


With  these parameters  the carcinogenic  potency factor for humans,

q,*, is 1.692 (mg/kg/day)~ .   The resulting water concentration for

DCB,  calculated  to keep the  individual  lifetime cancer risk below

10~5, is 0.103 yg/1.
                               C-3 3    * U. S GOVERNMENT PRINTING OFFICE : 1980 720-016/4362

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