HEALTH EFFECTS AND DOSE-RESPONSE ASSESSMENT
FOR HYDROGEN CHLORIDE FOLLOWING SHORT-TERM EXPOSURE
                          ASSIGNMENT NO. 2
                            FINAL REPORT
                              prepared for

                    Air Risk Information Support Center
                 Office of Air Quality Planning and Standards
                 and Office of Health Evaluation Assessment
                    U.S. Environmental Protection Agency
                 Research Triangle Park, North Carolina 27711
          EPA Work Assignment Managers: Daniel Guth and Holly Reid
                              prepared by

                     Clement International Corporation
                           K S Crump Division
                           1201 Gaines Street
                         Ruston, Louisiana 71270
                                             US. Erwironrn
                                             jvr'icn 5, il ,r
                                 loci         /JWest J'C:::
                                 1991

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                                 FOREWORD
      This report has been prepared by Clement International Corporation for the U.S.
Environmental Protection Agency's Office of Air Quality, Planning and Standards,
Pollution Assessment Branch (OAQPS/PAB) in response to a request to investigate
approaches to development of air quality standards for short-term exposures to air toxics.
The project was directed by Mr. David Patrick and the principal investigators were Dr.
Annette Shipp, Dr. Richard Howe,  Dr. Carl Watson, and Ms. Mary Lee Hogg.
Dr. Daniel Guth of ECAO and Ms. Holly Reid of OAQPS/PAB served as the Work
Assignment Managers.  The authors wish to thank Dr. John Vandenberg and Beth
Hassett-Sipple with OAQPS/PAB, and Drs. Richard Hertzberg and Linda Knauf with
ECAO for their expert peer review.

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                                 DISCLAIMER
      This report has been reviewed by the Office of Air Quality, Planning and
Standards, Pollution Assessment Branch, U.S. Environmental Protection Agency, and has
been approved for distribution as received from Clement International Corporation.
Approval does not signify that the contents reflect the views and policies of the U.S.
Environmental Protection Agency, nor does mention of trade names or commercial
products constitute endorsement or recommendation for use.
                                       n

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                            TABLE OF CONTENTS


                                                                          Page

1.     Introduction	1

2.     Approaches Used for Short-Term Exposure to Hydrogen Chloride	  3

3.     New Method for Quantitative Estimates of Risk of Noncancer Effects
      from Short-Term Exposure   	 10
      3.1    Background	 10
      3.2    Application of a New Method for Assessing Risk from
            Short-Term Exposure to Hydrogen Chloride  	 15
            3.2.1 Categorizing by Severity Index  	 16
            3.2.2 Human Equivalent Concentration Estimation  	25
            3.2.3 Description of the Dose-Duration-Response Model	27
            3.2.4 Results	30
      3.3    Conclusions and Relevance to Human Health 	52

4.     References 	57

Appendix A: Discussion of Acute Animal Toxicity Data	A-1

Appendix B: Animal Bioassay Data for Input into the
            Dose-Duration-Response Model 	  B-l

Appendix C: Derivation of Maximum Likelihood Estimate Bounds
            and Lower Confidence Limits 	  C-l

Appendix D: Computer Output for Dose-Duration-Response Model	D-l
                                      111

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                               LIST OF TABLES
                                                                          Page
Table 1.     Physiological Response to Various Concentrations
            of Hydrochloric Acid Gas  	   5

Table 2.     Various Effect Levels and Their Definition  	  11

Table 3.     Preliminary Ranking System for Evaluation of the Acute
            Inhalation Toxicity in Animals Exposed to Hydrogen Chloride 	18

Table 4.     Response Levels (Ranked in Order of Increasing Severity
            of Toxic Effect) Considered in Deriving Inhalation Reference
            Concentrations (RfCs) for Systemic Toxicants  	  19

Table 5.     Reading Data Notation	20

Table 6.     Maximum Likelihood Estimates and 95% Lower Bounds for
            P(s>l | d,T) = 0.05 with Exposure to Hydrogen Chloride
            with for Various Durations of Exposure	44

Table 7.     Maximum Likelihood Estimates and 95% Lower Bounds for
            P(s>l | d,T) = 0.01 with Exposure to Hydrogen Chloride
            with for Various Durations of Exposure	46

Table 8.     Relative Comparison of Several Regulatory Criteria and
            Human Data with Maximum Likelihood and 95% Lower Bounds
            on P(s>i | d,T)=0.01  	47

Table 9.     Relative Comparison of Several Regulatory Criteria and
            Human Data with Maximum Likelihood and 95% Lower Bounds
            on P(s>i | d,T)=0.05  	48
                                      IV

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                              LIST OF FIGURES

                                                                        Page

Figure 1.    Effect-Dose-Duration Plot of All Relevant Human
            and Animal Toxicity Data for an Example Chemical	  13

Figure 2.    Animal to Human Extrapolation Based on Total Lung Surface Area
            Maximum Likelihood Estimate of P(s>i|d,T)=0.05	31

Figure 3.    Animal to Human Extrapolation Based on Total Lung Surface Area
            95% Lower Bound of Maximum Likelihood of P(s>i | d,T)=0.05  	32

Figure 4.    Animal to Human Extrapolation Based on Total Lung Surface Area
            Maximum Likelihood Estimate of P(s>i | d,T)=0.01	33

Figure 5.    Animal to Human Extrapolation Based on Total Lung Surface Area
            95% Lower Bound of Maximum Likelihood of P(s>i | d,T)=0.01  	34

Figure 6.    Animal to Human Extrapolation Based on Total Lung and
            Extrathoracic Surface Area.  Maximum Likelihood Estimate of
            P(s>i | d,T)=0.05	35

Figure 7.    Animal to Human Extrapolation Based on Total Lung and
            Extrathoracic Surface Area.  95% Lower Bound of Maximum
            Likelihood of P(s>i | d,T)=0.05  	36

Figure 8.    Animal to Human Extrapolation Based on Total Lung and
            Extrathoracic Surface Area.  Maximum Likelihood Estimate of
            P(s>i | d,T)=0.01	37

Figure 9.    Animal to Human Extrapolation Based on Total Lung and
            Extrathoracic Surface Area.  95% Lower Bound of Maximum
            Likelihood of P(s>i | d,T)=0.01  	38

Figure 10.    Animal to Human Extrapolation Based on Administered Animal Doses
            Maximum Likelihood Estimate  of P(s>i | d,T)=0.05	39

Figure 11.    Animal to Human Extrapolation Based on Administered Animal Doses
            95% Lower Bound  of Maximum Likelihood of P(s>i | d,T)=0.05  	40

Figure 12.    Animal to Human Extrapolation Based on Administered Animal Doses
            Maximum Likelihood Estimate  of P(s>i | d,T)=0.01	  41

Figure 13.    Animal to Human Extrapolation Based on Administered Animal Doses
            95% Lower Bound  of Maximum Likelihood of P(s>i | d,T)=0.01  	42

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 1.     Introduction









       The Environmental Protection Agency's (EPA) Office of Air Quality, Planning




 and Standards (OAQPS) and Office of Health and Environmental Assessment (OHEA)




 are responsible for providing technical support on health-related issues pertaining to air




 toxics. This support is provided to EPA Regional Offices and to State and local air




 pollution control agencies through the Air Risk Information Support Center (Air RISC),




 a joint project of OAQPS and OHEA.  Several requests to Air RISC for information on




 the potential adverse health effects resulting from short-term exposure to hydrogen




 chloride have been received.




       Information concerning the toxicity of hydrogen chloride is available, and the




 potential adverse effects that may occur with short-term human exposure to this chemical




 are known.  Criteria  have been established in many states for ambient air concentrations




 for environmental exposure to toxic air pollutants. Several states have established




 ambient air concentrations for short-term exposure to hydrogen chloride (McCune 1990,




 North Dakota State Department of Health 1990, Rhode Island Department of




 Environmental Management 1990). In addition, the Occupational Safety and Health



Administration (OSHA) has established a ceiling for occupational exposure to hydrogen




chloride.  However, the range of exposure concentrations of hydrogen chloride over a




range of exposure durations that is  likely to be without adverse effects in exposed




populations is not well characterized.  In evaluating acute exposure situations, the risk




assessor/risk manager may have to make decisions regarding the impact of ambient levels




on the exposed population.  Ideally, sufficient dose-duration-response information for

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short-term exposure to hydrogen chloride may provide the risk assessor/risk manager with




the necessary information for characterizing potential public health risks and making




informed decisions on appropriate mitigation procedures.




      The purpose of this project was to investigate the development of dose-duration-




response information for short-term exposure to hydrogen chloride.  This approach is one




alternative for providing the risk assessor/risk manager a readily available guide for




decision making with respect to short-term exposure to hydrogen chloride. The




objectives of this project then were to provide a detailed analysis of the health effects




associated with short-term exposure to hydrogen chloride and to propose an approach for




evaluating the hazard to humans exposed to hydrogen chloride for short periods of time.




      The technical approach .used to accomplish these objectives consisted of several




elements:  the first was to conduct a critical review of the literature to assess the relevant




experimental data and to identify the types of adverse health effects and the dose-




duration at which these effects were observed (discussed in Appendix A); secondly, the




approaches currently used by EPA and state and local air pollution programs for




assessment of human health effects from short-term exposure to hydrogen chloride were




reviewed (Chapter 2); third, a dose-duration-response method was proposed and




demonstrated (Chapter 3).

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2.     Approaches Used for Short-Term Exposure to Hydrogen Chloride




       OSHA and various state and local agencies responsible for air pollution programs

have established air concentration criteria for hydrogen chloride, some  of which are

intended for a specified duration of exposure.  Those approaches for which information

were available for hydrogen chloride are reviewed here.  The intent of this review was to

consider the scientific basis, the assumptions maintained, and the uncertainties associated

with each approach along with the utility of the particular approach for evaluating short-

term exposures to hydrogen chloride.  Current regulations or recommended standards on

hydrogen chloride exposure are discussed in  the following paragraphs,  including

standards for exposure in the workplace, as well as exposure to the general public.  In

addition, other toxicity criteria, some of which were developed for evaluating acute

exposures under emergency response conditions, were reviewed; however, only those with

a specific value for hydrogen chloride are included in this discussion.

       The American Conference of Governmental Industrial Hygienists (ACGIH) has

set a threshold limit ceiling for exposure to hydrogen chloride in air of 5 ppm

(~7 mg/m3).  The threshold limit ceiling is the concentration of a chemical that should
           •
not be exceeded during any part of the working exposure (ACGIH 1987).  The rationale

for choosing this threshold limit value (TLV) is given in the ACGIH  Documentation of

Threshold Limit Values (1980) and refers to reviews of hydrogen chloride toxicity by

Elkins  (1959) and Patty (1963). Elkins  (1959) reported that hydrogen chloride is

"...immediately irritating when inhaled in concentrations of 5 ppm or  more...," and

proposed a maximum allowable concentration of 5 ppm (~7 mg/m3). However, the

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 scientific basis of this conclusion was not provided.  Patty (1963), citing Henderson and




 Haggard (1943), reports that, in human volunteers,  increasingly severe irritation of the




 nose and throat occurred from exposure to 10 to 100 ppm (15 to 150 mg/m3) hydrogen




 chloride for various periods of time (Table 1).  Other studies cited  in the ACGIH




 documentation referred to individuals exposed to higher doses at which adverse effects



 resulted.




       OSHA has also set a Permissible Exposure Level (PEL) for  hydrogen chloride in




 air of 5 ppm (~7 mg/m3), apparently in accordance with ACGIH (HSDB 1991).  In




 addition, OSHA has established an Immediately Dangerous to Life and Health (IDLH)




 value of 100 ppm (150 mg/m3) (HSDB 1991). The  IDLH is established for workers in




 the event of respirator failure, thereby allowing for a 30 minute escape time.




       Based on the National Air Toxics Information Clearinghouse (NATICH) data




 base (1988), nine  states have established acceptable ambient concentration guidelines or




 standards for hydrogen chloride.  Agencies responsible for setting these guidelines in six




 states were contacted for information on i:he basis of their standard, and four states



 supplied the requested information.




       State agencies of Massachusetts, North Carolina, and North Dakota based their




•guidelines on the ACGIH occupational ceiling limit of 5 ppm (~7 mg/m3), with each




 state using a different uncertainty factor or other modifying factors.  North Carolina




 divided the ACGIH value by an uncertainty factor of 10, while North Dakota divided this




 value by a factor of 100, resulting in guidance levels  of 0.47 ppm (0.7 mg/m3) (15 minutes




 averaging time) and 0.047 ppm (0.07 mg/m3) (1 hour averaging time), respectively




 (McCune 1990, North Dakota State Department of Health 1990). The rationale for




 using these uncertainty factors was not provided.  The Commonwealth of Massachusetts

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                                    Table 1

                         Physiological Response to Various
                     Concentrations of Hydrochloric Acid Gas
                                           Hydrogen chloride in ppm (mg/m3)
Maximum concentration allowable
      for prolonged exposure

Maximum concentration tolerable
      for a few hours

Maximum concentration tolerable
      for 1 hour

Dangerous for even short
      exposures
10
10 to 50
50 to 100
(15)
(15 to 75)
(75 to 150)
1,000 to 2,000      (1,500 to 3,000)
SOURCE:  Henderson and Haggard (1943).

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 used a more complex approach and divided the ACGIH standard by the following

 factors:
       4.2 (ratio of continuous exposure/occupational exposure; 168 hrs/40 hrs)
       1.75 (ratio of breathing rate and weight of child to adult)
       10 (uncertainty factor for high risk groups)
       10 (uncertainty factor for quality of data)
These adjustments result in what Massachusetts terms an AAL (Allowable Ambient

Level) of 0.007 ppm (0.01 mg/m3) (for 24 hours) (Commonwealth of Massachusetts

1990).

      The State of Rhode Island derived its standard based on the experimental data of

Machle et al (1942) after applying dose conversion and uncertainty factors. Machle et al.

exposed three rabbits. :I;ree guinea pigs, and a monkey to 34 or 67 ppm (50 or

100 mg/m3) hydrogen chloride for 6 hours/day, 5 days/week for 4 weeks.  Various effects

were reported at the higher dose; therefore, a no-observed-effect-level (NOEL)  of

34 ppm (50 mg/m3) was determined.  From these data the State derived a one-hour

standard  under the assumption that, "...effects of hydrogen chloride exposure appear to

be more  closely related to concentration rather than concentration  times time" (Rhode

Island Department of Environmental Management 1990).  Animal doses were first
                                 •
converted to units of mg/kg/hr based on species-specific breathing rates and body weights.

These doses were then converted to equivalent human hourly doses (in mg/m3) by

multiplying by human body weight/hourly breathing rate (70 kg/1  m3/hr).  The equivalent

human hourly doses were then converted to a surface area equivalent dose [inverse of

(human weight/animal weight)1^3] and divided by an uncertainty factor of 10 for

intraspecies variation.  The adjusted doses for the three different species ranged from

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 1.3 to 1.5 ppm (1.9 to 2.2 mg/m3). The State of Rhode Island chose to use 1.3 ppm

 (2 mg/m3) as the one-hour TLV (Rhode Island Department of Environmental

 Management 1990).

      Other short-term limits have been proposed.  Short-Term Public Limits (STPL)

 and Public Emergency Limits (PEL) were recommended by the Subcommittee on

 hydrogen chloride of the National Research Council in a 1971 report (as cited in

 GEOMET 1981). The committee believed that the proposed limits, listed below, would

 not present any health hazard but might be detectable by odor and could cause minimal

 irritation.  The scientific basis of these values was not presented.
                  Exposure time (min)

                                   STPL
                           10
                           30
                           60
                           5 h/d, 3-4 d/mo
                                   PEL
                           10
                           30
                           60
Hydrogen chloride
 concentration
 ij'i puiii frng/m t
      4(6)
      2(3)
      2(3)
      0.7 (1)
      7(10)
      3.4 (5)
      3.4 (5)
      The RD50 (concentration necessary to reduce respiratory rate by 50%) has been

proposed by Alarie and colleagues as a quantitative tool for the prediction of acute

human sensory irritation, i.e., a burning sensation in the eyes, nose, and throat of an

exposed individual, that can be used to establish standards under emergency (/>.,

Emergency Exposure Limits) or short-term conditions (Le., TLVs, STELs). The RD50 is

an experimentally derived value and is the concentration at which inhalation exposure

                                        7

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 (usually from 10 to 15 minutes) to a chemical produces a 50% reduction in the




 respiratory rate of mice.  Measurement of the percent decrease in respiratory rate is




 utilized to evaluate the degree of sensory irritation.  While the RI>5oS are based on




 decreases in  respiratory rate in mice, they have been reasonable predictors of whether




 sensory irritation would occur in humans in 50 of 51 chemicals evaluated (Barrow et al.




 1977).  Using values of 1/10 RD50 and 1/100 RD50, an estimate of a TLV for hydrogen




 chloride has been proposed by Barrow et al (1977) to range from 3 to 31 ppm  (4.5 to




 46.5 mg/m3).  Based on these results, the authors suggested that at the lower limit of




 3 ppm (4.5 mg/m3,  1/100  RD50), little  if any sensory irritation is expected to occur in




 humans, while at the upper limit of 31 ppm (46.5 mg/m3,  1/10 RD50) only slight irritation



 (/.«., slight stinging/burning of the eyes, nose, and throat) is expected.  Exposure to




 hydrogen  chloride at the RD50 (309 ppm, 465 mg/m3) was predicted to be incapacitating




 to humans due to sensory irritation (Barrow et al. 1977).




      As a comparison to the other hydrogen chloride criteria developed, EPA's chronic




 reference  concentration (RfC) is included in this discussion. In general, the RfC is an




 estimate of a daily exposure to the human population (including sensitive subgroups)  that




 is likely to be without an appreciable risk of deleterious effects during a lifetime.  An




 inhalation RfC for hydrogen chloride was calculated based on the study by Sellakumar




et al. (1985) (EPA 1991).  In this lifetime study, rats were exposed to hydrogen  chloride




 for 6 hours/day for 4.7 days/week for life and a lowest-observed-adverse-effect level




 (LOAEL) of 15 mg/m3 (10 ppm) (the only dose tested) was reported based on  the




occurrence of hyperplasia of the nasal  mucosa, larynx, and trachea at that dose.  The




adjusted LOAEL (adjusted by 6/24 and 4.7/7) was approximately 2.5 mg/m3 (1.7 ppm).
                                        8

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The LOAEL (adj) of 2.5 mg/m3 (1.7 ppm) was further converted to a human equivalent

concentration (LOAELHEC) by use of the following conversion:
2.5 mg/m3 x
(BRA/SAA)
(BRH/SAH)
= 6.5 mg/m3
where,

      BRA =  animal breathing rate of 0.5 m3/day
      SAA =  regional surface area (cm2) of respiratory region (extrathoracic and
               tracheobronchial) affected in animals (49.2)
      BRH =  human breathing rate of 20 m3/day,
      SAH =  regional surface area (cm2) of respiratory region (extrathoracic and
               tracheobronchial) affected in humans (5213)

The LOAEL  (HEC) was then divided by 1000 (factors of 10 for intraspecies variability,

interspecies extrapolation, and use of a LOAEL instead  of a NOAEL), and rounded to

one significant figure.  The resulting inhalation RfC is 7xlO"3 mg/m3 (5.0xlO'3 ppm).

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3.    New Method for Quantitative Estimates of Risk of Noncancer Effects
      from Short-Term  Exposure


3.1   Background
      The evaluation of toxicity data for noncarcinogens is complicated by the

multiplicity of possible endpoints, and the variation both in the severity of effect and in

the response rate.  As stated by Hertzberg and Knauf (1989) standard dose-response

models most often assume a fixed severity (e.g., lethality) and endpoint (e.g., cancer), and

would then need to be generalized into a multivariate form to be applicable to

noncarcinogenic effects.  Since response rates for noncancer endpoints are often poorly

reported, multivariate dose-response models are seldom developed, and "dose-response"

analysis usually relates dose only to the severity of the observed effects, often in a

qualitative way (Hertzberg and Knauf 1989, Guth et al. 1991).

      Dourson et al. (1985) presented an approach, described in the following

paragraphs, which assigns a severity description to ordered categories and graphs the

"dose-category" relationship. In this approach, each experimental group in a bioassay is

summarized by five variables: human equivalent exposure concentration (mg/m3), human

equivalent exposure durations (years), effect levels (NOEL, NOAEL, NOFEL,  etc., see

Table 2), target organ, and study usefulness.  Usefulness is based on quantitative

accuracy (e.g., sample size, measurement error, whether certain values are reported or

must be assumed) and qualitative characteristics of the experiment (e.g., extent of

pathological workup, existence of widespread adverse health effects in control group,

unnatural route of exposure). These five parameters are graphed in the following way.
                                        10

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                                     Table 2
                     Various Effect Levels and Their Definition
   Effect
   Levela
Symbol
Definition5
 PEL          *      Frank-effect level.  That exposure level which produces
                      unmistakable adverse effects, such as irreversible functional
                      impairment or mortality, at a statistically or biologically
                      significant increase in frequency of severity between an exposed
                      population and its appropriate control.

 AEL          •      Adverse-effect level.  That exposure level at which there are
                      statistically or biologically significant increases in frequency or
                      severity of effects between the exposed population and its
                      appropriate control.

 NOFEL       A      No-observed-frank-effect level. That exposure level at which
                      there are no statistically or biologically significant increases in
                      frequency or severity of frank effects between an exposed
                      population and its appropriate control.  Experimenters may or
                      may not have looked for other adverse  effects.

 NOAEL      O      No-observed-adverse-effect  level. That exposure level at which
                      there are no statistically or biologically significant increases in
                      frequency or severity of adverse effects  between the exposed
                      population and its appropriate control.  Effects are produced
                      at this level, but they are not considered to be adverse.

 NOEL        o      No-observed-effect level.  That exposure level at which there
                      are no statistically or biologically significant increases in
                      frequency or severity of effects between the exposed
                      population and its appropriate control.

a  Listed in order of decreasing severity.
b  Adverse effects are considered to be functional impairment or pathological lesions that
   may affect the performance of the whole organism, or that reduce an organism's
   ability to respond to an additional challenge (EPA 1980).

SOURCE: Dourson et aL 1985.
                                        11

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The first two parameters (exposure concentration and duration) are continuous variables




which are usually defined by the experimental protocol; thus, these are used as




independent axis variables. The remaining three are categorical variables, which are




denoted by symbols and placed on the graph at the corresponding "dose-duration"




location.



      The categorical variables (effect severity, study usefulness, and target organ) are




represented by the shape, size or labeling of graphics symbols (see Figure 1).  Each




symbol's shape denotes one of the "effect level" designations used for toxicants as defined




in Table 2. These designations represent a simple ranking scheme for the severity of the




effect.  The size of the symbol denotes the relative usefulness  of the study for




quantitative health risk estimation, with the larger symbol denoting the more appropriate




study.




      By partitioning the dose rate axis  into areas expected to cause:  (a) gross toxicity




and death, (b) adverse effects to various organ systems, (c) no adverse effects, and (d)




levels which are now considered "safe", /.&, the RfD  (see Figure 1 and Table 2), an




overview of the expected toxicity in a group of individuals with a known or estimated




exposure pattern (both time and dose) may be accomplished.  Lines are drawn to



approximate the boundary between effect levels.




      This approach could similarly be related to the RfC concept and could be




extended to exposures shorter than the subchronic or chronic studies used for RfC




derivation. Operationally, RfCs are calculated by dividing the  human  equivalent




concentration of a NOEL. NOAEL, or the lowest observed AEL (LOAEL) derived from




human or animal toxicity studies by required uncertainty factors.  One possible approach




is to interpolate along the NOAEL curve, defined as the line beneath which no AEL is




                                        12

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                                                                Figure 1
                   100.000 -
                     10.000
                                                                                                                      PEL
                      1.000 -
      EQUIVALENT
      HUMAN
      DOSE
      Img/d)
                           0.07
  0.7                       7.0

EQUIVALENT HUMAN DURATION (yoiiu)
                                                                              Oo,e
                                                                                                «v.l.  irrflc.ted by .yrt.1.  .re
             -         K         ,                     eonw'rled •* • ^^ •«•«•«• •«• «««"  «<> •PPTMIMU the equlv.lent liu** do.e.
        .r, di« ted by ih..pproprl.te •pecUt Illetpan to yl.ld . (r.ctlon. which.  Nhen ^ItlplUd by 70 yt.n (th. ...uMd -vcr.fl. h«Mn
ll.ip*n)  glv.. th* corrttpoodlog position on th. ..«,!..  study uselulnti.  I. dtMted by .y^>ol  .Ife/ f.rl.t «r««na .r. iv (liver)  »
r»pro«k«  v. .r|M>.  GR (.^th reduction), .nd IP (.pl.en).  The do.. ..I,  |. divided |j,,.\r... t.pect«l to c.^ro.! u.|e H 2nd de.th (A)
      cflectt !•), nor,-»dv*rM effect* (C). or no effect! (0).   (Sourc*: oourton 19Bo)                               tomciiy ana aeith (A).

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observed, to the desired duration, and then divide the corresponding dose rate by an

uncertainty factor(s) to obtain the estimate analogous to the RfC for that duration.

       Since these lines are "sight" fitted and somewhat arbitrary in nature, it is easy to

see that two experimenters could get lines which differed by a large amount. To remove

the objection of arbitrarily drawn lines, categorical regression has been suggested.

Hertzberg (1989) suggests that the form of categorical regression for risk estimation

should be the logistic model.  The numerical score assigned to each category (defined

below) only serves as an index of the ordering of categories, e.g., category 2 is not

interpreted as twice as severe as category 1, only more severe.

       The following model is  assumed:

       P(s>i|X) = l/(l+exp[-0i - X*/J])

where:
       s   =  severity
       i   =  severity category 1, 2,...,L-1
       L  =  number of severity levels
       X  =  an independent variable such as log-dose (can be a vector representing
             more than one independent variable)
       0   =  parameter estimate associated with an independent variable (can be a
             vector representing more than one parameter estimate)
       oij  =  parameter estimate associated with response category i.

       The logistic dose-risk model is then L equations that are coupled by the common

slope parameter (vector of parameters), p.  Note that all other probabilities are linearly

related to the above  L-l probabilities. That is,

          P(s=l) =
          P(s=i) =
          P(s=L) =

       Some difficulties arise because of the data that are available for analysis. Almost

all of these data are from animal bioassays, so  the risk estimates that are produced by

the regression analyses are animal risk estimates that must be extrapolated to produce

                                         14

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human risk estimates. Also, many times the data available represent information from an

entire dose group, not from an individual animal. The interpretation of the risk

estimates depends, then, upon the unit of input: animal versus human data and

individual versus dose group information.

      Guth et al. (1991) applied this approach to data for acute inhalation exposure for

methyl isocyanate, tetrachloroethylene, dichloromethane, and propylene oxide.  Data sets

were developed and analyzed using categorical regression using information at the

experimental group level.  In addition to analysis of the complete: data sets for acute

exposure (all available studies), experimental data for specific endpoints, exposure

duration ranges, and species (human or experimental animal) were analyzed and the

results were compared with the results obtained using concentration response modeling

(benchmark approach) or a LOAEL/NOAEL approach.

      The methodology presented below continues development of the model proposed

by Hertzberg (1989) and Hertzberg and Knauf (1989) as previously discussed. The

model is expanded to allow for more  extensive use of the experimental data (see section

3.2.3).  Individual animal data for all of the dose groups can  be considered in the analysis

to develop maximum likelihood estimates, (MLEs) and statistical lower bounds for the

prediction of various levels of severity for a range of time and dose values.
3.2   Application of a New Method for Assessing Risk from Short-Term Exposure
      to Hydrogen Chloride
      This approach to developing quantitative estimates of risk incorporated several

elements.  The first was to conduct a thorough literature search for all the available

acute inhalation toxicity data on hydrogen chloride.  Then, a critical review of the studies

                                        15

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was made to select relevant experimental data and to identify the types of adverse health




effects and the exposures (concentration-duration) at which these effects were observed




(discussed in Appendix A).  Next, the adverse effects were assigned a severity index




ranking using a rank order scale (section 3.2.1).  Finally, animal exposure concentrations,




described in section 3.2.2 and Appendix A, were converted to human equivalent




concentrations based on  the methodology developed for determining inhalation RfCs




(EPA 1990).  Once input data (including size of dose group, dose, duration, and severity




of effect and number of  animals with that effect in each dose group) were developed




from the relevant studies, these data were analyzed by the proposed model (section




3.2.3).  The results  of this analysis are discussed in section 3.2.3 and model output values




given in Appendix D.  Conclusions and recommendations are given  in section 3.3.








3.2.1  Categorizing by Severity Index




      The experimental data indicated that the response to hydrogen chloride exposure




is dependent on both the concentration and the duration of exposure. As either the time




or the concentration increased, either the number of animals exhibiting a specified effect




or the severity of that effect increased, or both.  In studies in which  alterations in




respiratory function or respiratory histopathology were evaluated, the results were usually




reported as a continuum of effects of increasing severity rather than as an increasing




number of  animals  with any one discrete effect.  Usually in lethality studies only the




mortality incidence  was reported without discussion of the presence  of nonlethal effects.




      Given the variety  of the level of detail and the quality of the  data reported,




ranking by  use of a complex severity index, such as that proposed by Hartung (1986), was




not feasible.  For the purpose of this assessment, a simplified severity scale  (given in




                                         16

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Table 3) was utilized similar to those developed by Dourson et al. (1985) and Hertzberg




and Miller (1985) (see Table 4). Table 3 lists a rank order scale in that the difference




between severity categories is not an arithmetic assignment, i.e., an index of 2 is not twice




as severe as an index of 1.




      The four response levels listed in Table 3 are ranked in order of increasing




severity of the toxic effect.  An index of 1 is equivalent to a NOAEL at which there are




no statistically or biologically significant effects observed. Exposure levels which




produced minor toxic effects (biologically significant adverse effects) are assigned  an




index of 2. An index of 3 is assigned to exposure levels which produce moderate  (more




severe than index of 2) adverse effects which may be considered biologically significant.




When severe adverse effects, such as mortality or irreversible tissue damage, were




observed, the exposure level was given an index of 4.  For example, in a bioassay  of




rodents  exposed to hydrogen chloride, no effect or a non-adverse effect (such as




reversible decrease in respiratory rate) would be assigned a severity index of 1, while an




effect such as slight damage (e.g., ulcerations) to the mucosa of the upper respiratory




tract with no other tissues affected would receive a severity index of 2.  More extensive




damage to the mucosa (damage to the squamous epithelium) including damage to the




submucosa would receive a severity index of 3; more serious effects, such as further




damage to underlying support structures and/or death, would receive a  severity index




of 4.




      Each animal within a dose group was assigned a severity index based, when




possible, on the degree of injury reported by the investigator, as illustrated in Table 5.




For each dose group within a study, the close, duration of exposure, the highest severity
                                         17

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                               Table 3

               Preliminary Ranking System for Evaluation
of the Acute Inhalation Toxicity in Animals Exposed to Hydrogen Chloride
   Severity
   categories
Toxic
effects
Analogous EPA effect levels
      1

      2

      3

      4
None        No observed adverse effect

Minor       Mild adverse effect

Moderate    Moderate (to severe) adverse effect

Severe       Frank effect
                                 18

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                                       Table 4
                        Response Levels (Ranked in Order of
               Increasing Severity of Toxic Effect) Considered in Deriving
           Inhalation Reference Concentrations (RfCs) for Systemic Toxicants
 NOEL:    No-Observed-Effect Level. That exposure level at which there are no
           statistically or biologically significant increases in frequency or severity of
           effects between the exposed population and its appropriate control.

 NOAEL:   No-Observed-Adverse-Effect Level. That exposure level at which there are
           no statistically or biologically significant increases in frequency or severity of
           adverse effects3 between the exposed population and its appropriate control.
           Effects are produced at this level, but they are not considered to be adverse.

 LOAEL:   Lowest-Observed-Adverse-Effect Level. The lowest exposure level in a study
           or group of studies that produces biologically significant increases in
           frequency or severity of minor adverse  effects between the exposed
           population and its appropriate control.

 AEL:      Adverse-Effect Level. The exposure level in a study or group  of studies that
           produces biologically significant increases in frequency or severity of moderate
           adverse effects between the exposed population and its appropriate control.

 FEL:      Frank-Effect Level5.  That exposure level which produces frankly apparent
           and unmistakable adverse effects, such  as irreversible functional impairment
           or mortality, at a statistically or biologically significant increase in frequency
           or severity between an exposed population and its appropriate control.
a  Adverse effects are defined as any effects resulting in functional impairment and/or
   pathological lesions that may affect the performance of the whole organism, or that
   reduce an organism's ability to respond to an additional challenge.

b  Frank effects are defined as overt or gross adverse effects (severe convulsions,
   lethality, etc.).

SOURCE: EPA (1989).
                                        19

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                                  Table 5
                           Reading Data Notation
                                    Number of Animals
 Dose Group     Severity Index     in Each Dose Group       Indicator3
1 b,c
2b,d
3e
4b,f
4
4
4
4
10
10
10
10
0
6
10
-1
a Indicator is defined as the number of animals in that dose group with an effect at that
  severity level, with the exception of an indicator of -1 (see footnote e).
b In each case when some of the animals are assumed to be of a severity of less than
  severity i, which in this case is 4, the model estimates the probability that these animals
  are at a severity of less than i, in this case the probability of a severity of 3 or less.
c Indicator is zero.  Zero animals had an index of 4 and all ten animals were assumed to
  have an index of less than 4.
d Indicator is positive but less than number of animals in the dose group. Six animals
  had an index of 4 and the other four animals were assumed to have an index less
  than 4.
e Number of animals in the dose group and indicator number are equal. All ten animals
  have an index of 4.
f Indicator is -1. The study indicates that at least one animal had an index of 4 but
  provides no information on other animals. The other animals were assumed to have a
  severity of less than 4.
                                       20

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index assigned to that dose group, and the number of animals with an effect of that




severity are entered into the model.




      For studies in which dose-response information was adequately reported,




assignment of a severity index was straightforward. In other cases, assignment of a




severity index was complicated by the limitations of reported data. For example (see




Table 5), in studies for which the incidence of lethality was the only result reported




(Darmer et al. 1975, Hartzell et al. 1985, Kaplan et al. 1984, Machle et al. 1942,




Wohlslagel et al. 1976), all dose groups with one or more deaths were assigned a  severity




index of 4 with the indicator reporting the actual number of animals that died (see Table




5).  However, in a lethality study, when no deaths were reported for one  of the dose




groups and no other effects were reported, a severity index of 4 was assigned, but the




number of animals at that severity was designated as 0. Operationally, the model actually




estimates the probability that animals within the dose group were at a severity of less




than 4 (severity index 3 or less).




      Only two lethality studies (Burleigh-Flayer et al. 1985, Kaplan 1987) included




control groups.  However, no effects were observed in these groups and they were not




included in the analysis. In all of the other studies, due to the nature of the effects




reported, it was assumed that any adverse effects reported were due to hydrogen  chloride




exposure.  It should be noted that the model used in this analysis can account for a




background  rate of an effect when one can be identified.




      Toxicity studies were conducted in mice, rats, guinea pigs, and baboons  (discussed




further in  Appendix A). The effects of hydrogen chloride on non-human primates were




examined  in a series of recent studies by Kaplan and his colleagues (Anzueto et al. 1987;
                                        21

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 Kaplan 1987; Kaplan et al  1984, 1988).  In one experiment, seven baboons were exposed




 to hydrogen chloride gas for a single 5 minute period to concentrations ranging from 190




 to 17,290 ppm (285 to 25,935 mg/m3) (one baboon/exposure concentration); no




 concurrent control was included. "Severe irritant effects" were observed at all




 concentrations except at the lowest concentration, 190 ppm (285 mg/m3), and all of the




 animals survived exposure concentrations up to 11,400 ppm (17,100 mg/m3).  Animals




 exposed to concentrations of 16,570 and 17,290 ppm (24,855 and 25,935 mg/m3) died




 from bacterial pneumonia 18 and 76 days post-exposure, respectively. From this




 information, severity categories were assigned as follows: based on the fact that at




 190 ppm (285 mg/m3) no irritant effects were observed during exposure or during the




 post-exposure period, an index of 1 was ascribed; exposure to 810 to 2780 ppm (1215 to




 4170 mg/m3) reportedly caused irritation (coughing and salivation), but no post-exposure




 symptoms were observed; therefore, a severity index of 2 was assigned; exposure to




 11,400 ppm (17,100 mg/m3) caused immediate agitation and  salivation with coughing,




 blinking of the eyes, and "raspy breathing" post-exposure when the animal was excited




 (assigned a severity index of 3); and effects from the two highest exposures were



 classified as indices of 4 because  of lethality.




      In a  separate experiment with anesthetized baboons (Kaplan 1987, Kaplan et al




 1988), exposure to hydrogen chloride at nominal concentrations of 500, 5000, and 10,000




 ppm (750, 7500 and 15,000 mg/m3) for 15 minutes was evaluated for  effect on respiratory




 response and pulmonary function. Nine  baboons  (three  per dose) were exposed to




 hydrogen chloride, while three controls were exposed to air only. There was a




concentration-related increase in  respiratory rate and minute volume  at the two higher




concentrations during exposure. Observation of these animals for up to one year post-




                                        22

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exposure (Anzueto et al. 1987) revealed no long-term effects in animals exposed to 500




and 5000 ppm (750 and 7500 mg/m3); however, chronic nasal obstruction and mouth




breathing, persistent hypoxemia, increased lung functional capacity, and focal lung fibrosis




in animals exposed to the high concentration were observed.  At 500 ppm (750 mg/m3),




no statistically significant alterations in respiratory response or pulmonary function were




observed in the animals, although respiratory rate and minute volume increased slightly




and it was thought that these respiratory effects were biologically significant. For this




effect an index of 2 was assigned.  Significant acute responses, including increased




respiratory rate and minute volume, were reported following expiosure to 5000 ppm




(7,500 mg/m3) and were assigned a severity index of 2 because all parameters had




returned to  normal by 3 days after exposure. An index of 3 was assigned to the




10,000 ppm (15,000 mg/m3) exposed group for the moderately severe effects observed




(including focal lung fibrosis) in one of the three animals  one year after exposure




(Anzueto et al 1987).




      The effect of hydrogen chloride inhalation exposure in mice has been reported in




three studies performed by the same research group using similar concentration ranges




and the same exposure intervals, protocols, and laboratory animal species.   In the study




by Lucia et al.  (1977), mice were exposed to levels of hydrogen chloride ranging from 17




to 7,279 ppm (25 to 10,918 mg/m ) for 10 minutes (nine dose groups of four animals




each). Twenty-four hours after exposure the mice were sacrificed and the  heads were




prepared for histopathological examination by sectioning each head into four transverse




sections. A semi-quantitative scale (0  to 4+) of upper respiratory tract damage in mice




was devised by the authors to evaluate the extent of histological insult to the respiratory




tract mucosa.  Exposure to hydrogen chloride at  17 ppm (25 mgfai3) for 10 minutes




                                        23

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resulted in superficial ulceration of upper respiratory tract mucosa (observed in only one

of four sections microscopically examined) (Lucia et al. 1977), which was considered in

this analysis to be non-adverse (severity index 1).  The degree of mucosa and underlying

submucosa/structural damage  increased directly with increasing dose.  This is one of the

few studies in which all four levels of severity were observed (see Table B-l).  The

effects and accompanying severity indices were:


           No damage seen at 24 hours - severity index 1

           1 to 75% of the mucosa destroyed and some submucosal damage from 131 to
           723 ppm (197 to 1,085 mg/m3) - severity index 2
           25 to 75% of the mucosa destroyed and some submucosal damage and
           damage to unde
           severity index 3
damage to underlying support structures at 1,088 ppm (1,632 mg/m3) -
           50 to 100% of the mucosa destroyed and extensive destruction of all
           underlying tissues at 1,473 to 7,279 ppm (2,960 to 10,919 mg/m3) - severity
           index 4. [Note:  High-dose animals 7,279 ppm (10,919 mg/m3) also  suffered
           total destruction of the eyes]
      In one study by Barrow et al. (1979), mice exposed to 127 ppm hydrogen chloride

(190 mg/m3) for 10 minutes sustained ulceration of nasal epithelium located in the

inferior of the nasal mucosa. Since the extent of ulceration was not clearly reported, it

was assumed that the animals experienced similar insult as reported by Lucia et al. in

mice exposed to a concentration of 131 ppm (197 mg/m3) for 10 minutes (damage of

upper respiratory tract mucosa in three of four sections examined). Therefore, this dose

group was assigned an index of 2.  The next two dose groups [478 and 710 ppm (730 and

1,060 mg/m )] had increasing damage to the nasal epithelium and underlying structures

and were assigned a severity index of 3.  All other dose groups in Barrow et al.  (1979)

exposed to 1,072 to  19,333 ppm (1,600 to 20,000 mg/m3) had extensive damage to the

                                        24

-------
                           f



mucosa/submucosa and underlying structures or extensive cornea! damage or death and




were given severity indices of 4.




      Barrow et aL  (1977) reported a 12% decrease in respiratory rate in mice exposed




to 40 ppm (364 mg/m3) hydrogen chloride for  10 minutes; however, the animals showed




complete recovery in 6 minutes following exposure, indicating a severity level of 1.




Exposure  to 100 to 440 ppm (149 to 660 mg/m3) hydrogen chloride resulted in up to a




52% decrease in respiratory rate and was assigned an index of 2. The highest dose group




with reported mortality was given an index of 4.




      In the study by Burleigh-Flayer et aL  (1985) guinea pigs were exposed to  hydrogen




chloride for 30 minutes.  Pulmonary irritation and significant acute respiratory parameter




changes were noted, most of which  were reversible within 15 days post-exposure.  The




lower concentration of 320 ppm (480 mg/m3) was assigned an index of 2 based on the




significant reduction in respiratory frequency achieved during a CO2 challenge 30  minutes




following exposure.  One of four animals exposed to 680 ppm (1,020 mg/m3) exhibited




corneal damage; this effect was assigned a severity index of 3.  Mortality was reported




among animals exposed to 1,040 and 1,380 ppm (1,560 and 2,070 mg/m3) hydrogen




chloride. As a result, an index of 4 was given to both of these dose groups.




      Data extracted from animal bioassays  along with severity index  assignments and




human equivalent exposure levels may be found in Appendix B.








3.2.2  Human Equivalent Concentration Estimation




      Animal exposure concentrations reported in the studies described in the previous




section were converted to a human  equivalent dose according to the methods used to




develop inhalation RfCs (EPA 1989).  In this study, human breathing  rates (BRH) and




                                       25

-------
surface area of the respiratory region affected (SA) were used to convert experimental

concentrations to an equivalent human exposure in air.  The human equivalent

concentration (mg/m3)H was calculated by:


    (mg/m3)A x [BRArm3/davHSAArcm2>l] = (mg/m3)H
               [BRH(m3/day)-HSAH(cm2)]

If:

      BRA   =     animal breathing rate
      SAA   =     animal surface area of the respiratory region affected
      BRH   =     human breathing rate of 20 m /day,
      SAH   =     human surface area of the respiratory region affected


For example, a concentration of 4,800 mg/m3 in a mouse (Darmer et al. 1974) would be

equivalent to a human concentration (based on total lung surface area) of 33,060 mg/m3:


    4,800 mg/m3 x 0.064 m3/dav H- 297.7 cm2 = 33,060 mg/m3
                  20 m3/day + 640758 cm2


Study-specific parameters for breathing rates and surface areas were used whenever

possible.  Otherwise, standard values from RfC methodology were used. For the

purposes of this analysis, the human equivalent concentration (HEC) was estimated

based on the assumption that the total lung was the target (HEC-Total).  For comparison

purposes, the model was also fit to the data using the unadjusted animal concentration

and a human equivalent concentration based on the assumption that the extrathoracic

region (for two of the animal data sets) as well as the total lung (for all the remaining

data sets) were targets.  The experimental data upon which the dose conversions were

based are discussed in section 3.2.1 and in Appendix A.
                                       26

-------
                                      an
      Since the longest duration to be considered was one day, no adjustment of time

was made to account for the difference in lifespan between animals and humans.  That

is, for short exposures, it was assumed there is no interspecies time difference. Also, in

this investigation, no adjustment for duration of exposure was incorporated into the

human equivalent concentration at this time since the model takes time into

consideration.



3.2-3  Description of the Dose-Duration-Response Model

      Two dose-duration-response models were considered for this investigation.  Both

models estimate  the probability function F(s>i|d,T), which is the probability (P) of

effect of severity (s) greater than the index i at a fixed dose (d) and duration (T).

      The two models considered were the Weibull,

      P(s > i) = 1 - exp[-qi(d-d0)wTk],

where,

      s    =       severity
      q{   =       parameter estimate associated with response category i
      i     =       severity index (i=l,2,3...,L-l, with L the number of severity
                   categories)
      d    =       dose
      d0   =       threshold  dose
      T    =       time
      w and k constrained  to be > zero,

and the log-logistic,

      P(s > i) = 1 /[I + exp[- q{ - W loglo(d-d0)-K log10T]],
27

-------
where,
                    severity
       q{   =       parameter estimate associated with response category i
       i    =       severity index (i=l,2,3...,L-l, with L the number of severity
                    categories)
       d   =       dose
       d0   =       threshold dose
       T   =       time
       W and K are unconstrained
      The threshold dose (d0) below which no effect can be attributed to exposure to

the chemical is assumed to be a known constant.  For this analysis, threshold dose (d0)

below which no effect can be attributed to hydrogen chloride was assumed to be zero.

This assumption should certainly be conservative for exposures up to one day.

      While data should be found and analyzed that provide information on individual

animal effects instead of dose group effects, the data presently available could be used

on an individual animal basis if the proper terms were added to the likelihood as

discussed in Appendk C.  For example, at a certain dose, if four out of ten animals died,

then the dose group method would put all ten animals at the highest severity. The

individual animal method discussed would put four at the highest severity and six with

severity less than the highest severity.

      Since many of the bioassays available did not report the  results for each individual

animal, likelihoods, which convert the information available to a per animal per dose

group basis, have to be considered in this model as follows. For N  animals at dose d and

time T with index i, the contribution to the log-likelihood is N In [P^d/T)], where
                                        28

-------
      P^d/T) =  l-P(s > 1  |d,T)
      Pj(d,T) = P(s > i-1  | d,T) - P(s > i | d,T)        i = 2,3
      P4(d,T) =  P(s > 3  | d,T).
      Suppose for N animals with fixed d and T, X (number) had an effect of severity

index i, and all that is known about the other animals is that their index is less than i.

For example, at fixed dose and time, three (X=3) out of ten animals (N= 10)  died. The

contribution to the log-likelihood is then,


      X In [Pj(d,T)] + (N-X) In [l-P(s > i-11 d,T)].


That is, three animals would be assigned a severity index of 4, and six animals would be

assigned, by the likelihood method, severity indices of 3 or less.  A special case of this is

when X is zero. For example, the only information is that no animals died.  In this case

all animals would be assigned severity indices of 3 or less.  This may not be  a

conservative assumption in that some animals may  have had effects of severity 4;

however, when these data were not available the stated assumption was made. Further

examples of input data and their meaning are found in Table 5.

      If for fixed d and T only the maximal effect (index) is given, then at least one

animal has index i and  the remainder have index i or less.  The contribution to the log-

likelihood is then


      In {[1 -  P(s > i|d,T)]N - [1  - P(s >(i-l)|d,T)]N}.


There are other possible situations, but these are the only ones necessary to utilize all of

the hydrogen chloride bioassay data on an individual animal basis.
                                        29

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       Bands may be established where a particular effect would be expected for a given




 time and dose. Let a (say 0.01) be given once the model is fitted to the data; curves




 generated from the Weibull and log-logistic model would yield lines for which the




 probability of a severity index greater than i would be a,  Le., [P(s>i | d,T)=a].




       For fixed time T and a (e.g., a=0.01), a lower bound on the dose, such that




 P(s>i, | d,T)=a, may be found using the likelihood ratio method reported in Crump and




 Howe (1985). For fixed time, this is the benchmark approach suggested by Crump



 (1984). If the benchmark lower bound is found for various times and connected to form




 a line, a benchmark lower bound band can be drawn. (See Appendix C for the




 mathematical description of the approach described above.)








 3.2.4   Results




       While  both models have about the same predicted  values, the log-logistic model




 values are reported in this investigation since this model offers faster convergence of the




 optimization  routine.




       Using  the data described  above and the log-logistic dose-duration model, the MLE




 and the 95%  lower bound (confidence  limit) on the concentration of hydrogen chloride




 are predicted for probability less than 0.05 or 0.01 of observing an effect of a severity




 greater than that represented by index  i, for various exposure  times, T.  Expressed




 mathematically, estimates of the MLE and 95% lower bound on the MLE for P(s>i | d,T)




 = 0.05 or 0.01 were determined. Graphs (Figures 2 to 13) were generated indicating the




MLE  and the 95% lower bound (confidence limit) on the MLE.  Figures 2 to 5  were




derived using human equivalent  concentrations of hydrogen chloride assuming that the




total lung surface area was the target, while Figures 6 to 9 represent the same  data




                                       30

-------
100000 -J
 10000 - =
 1000 i
  100
   10
                                           Figure 2

                            Animal to Human Extrapolation Based on
                                    Total Lung Surface Area
  01
  001
                           i     ii   i ~ ~r r ~r  r~i
                 0 1
    1
Time (hours)
                                                         i      i - -  i   i —r i  i
I
10
                           Maximum Likelihood Estimate of P(S>i | d,T)=0.05
                                              24

-------
                                                       Figure 3

                                        Animal to Human Extrapolation Based on
                                                Total Lung Surface Area
             100000 _
N>
             10000 :
           n  1000 .
           £   100
               10
               01 ,
              001
                             o i
                                            i    IT —r~
                                              (=1
                                                            1
                                                         Time (hours)
                                                           1=2
                                                                     i      i
1=3
                                                                                 r  T  i i  r
                  10
                                                                                                      24
                             95.0% Lower Bound on Maximum Likelihood Estimate of P(S>i | d,T)=0.05

-------
                                             Figure 4

                              Animal to Human Extrapolation Based on
                                      Total Lung Surface Area
  100000
   10000
    1000
I   100 -=
     10
      i -
    01
    001
                   01
                                  1    1   1  1  1
                                    i-1
-l-T-j

    1
Tim« (hours)

   i-2
                                                           i      i	i
1-3
                  10
                             Maximum Likelihood Estimate of P(S>i | d,T)=0 01
                                                                                             24

-------
  100000 .
   10000 :
Jo  1000 •_
0,
    100 -
     10
                                             Figure 5

                              Animal to Human Extrapolation Based on
                                      Total Lung Surface Area
    0 1
    001
                  0 1
                            r      i    i
                                    1=1
                                                           i     r   i  —r—T~ t
   1
Tim.i jh>.i | d,T)=0.01
                                                                                            24

-------
                                         Figure b
10000
 100
 oot
                           Animal to Human Extrapolation Based on
                         Tolal Lung and Extrathoracic Surface Area
0    i  I  I  i I  I

             0 1
                               1   1   \-\~T ~T T~
                                              1
                                           Time (hours)
                                                                            10
                                                                                        24
                                              i-2
                          Maximum Likelihood Estimate of P(S>i | d,T)=0.05

-------
                                            Figure 7
                             Animal to Human Extrapolation Based on
                            Total Lung and Extrathoracic Surface Area
  10000
   too
i    ,
   001
                           i      i    i "~i  r~~r~!~~r
                  0 I
   1
   i
Time (hours)
                                                (•=2
                                                          i     i
-r-i ,  i |

       10
                                                                                          24
                  95.0% Lower Bound on Maximum Likelihood Estimate of P(S>i | d,T)=0.05

-------
  10000
   100
I    ,
   001
                                           Figure 8

                             Animal to Human Extrapolation Based on
                           Total Lung and Extrathoracic Surface Area
                  01
                                          1—I—i—r
                                   l-t
   1
Time (hours)
   1-2
                                                                              10
1=3
                            Maximum Likelihood Estimate of P(S>i | d,T)=0.01
                                                                                     "	~\
                                             24

-------
                                                     Figure 3
u>
00
           10000
             100
         co

         I
         i
            001
                                      Animal to Human Extrapolation Based on

                                     Total Lung and Extrathoracic Surface Area
                                    i      iii —r -~r ~i~\
                           0 1
T

 i
                                                      Time (hours)
                                                         i-2
             1-3
10
                                                                                                   24
                           95.0% Lower Bound on Maximum Likelihood Estimate of P(S>i | d,T)=0.01

-------
                                           Figure 10
  10000
   1000 -
P)

E  100
O)
    10
i

5    «
    0 1
   001
                             Animal to Human Extrapolation Based on

                                   Administered Animal Doses
                  01
                                              _., T
                                             Time (hcuis)
                                                1=2
                                                          I     I  "  I   T— 1	1  I
1=3
                  I

                  10
24
                            Maximum Likelihood Estimate of P(S>i | d,T)=0.05

-------
                                           Figure 11
  10000 -_
   1000
f  100
Q>
    10
                            Animal to Human Extrapolation Based on
                                   Administered Animal Doses
   001    i  i  i  i  i
                           I     I    III —I—I
                 0 1
                                                1
                                             Time (hours)
                                  1=1
                                               1=2
                                                         i     i
                                                            1-3
                                                                              10
                                                                                         24
                  95.0% Lower Bound on Maximum Likelihood Estimate of P(S>i | d,T)=0.05

-------
                                          Figure 12
  10000
   1000
P)
E
   100
    to
   0 1 ,
   001
                            Animal to Human Extrapolation Based on
                                   Administered Animal Doses
         I  T  I -| I
                 01
                                                1
                                            Time (hours)
                                                               	r  T	r
10
           24
                            Maximum Likelihood Estimate of P(S>i | d,T)=0.01

-------
                                           Figure 13
i
  10000
   1000
   too
    10
                            Animal to Human Extrapolation Based on
                                   Administered Animal Doses
    0 1
   001    i  i  I  i  i ]

                 0 1
i     i    11 —i—r"~r~r
                                                1
                                             Time (hours)
                                               1=2
                              i     i    i
                                 1=3
                                                              24
                  95.0% Lower Bound on Maximum Likelihood Estimate of P(S>i | d,T)=0.01

-------
assuming that the human equivalent concentration was based on the total lung surface




area except for the studies by Lucia et al (1977) and Barrow et al (1979) for which the




target was assumed to be extrathoracic.  Human equivalent concentrations were derived




based on the methodology used in the development of inhalation RfCs (EPA 1989).  For




comparison, additional modeling was done using as input the actual concentrations used




in the animal experiments (Figures 10 to 13).  In addition, the MLE and 95%  lower




bound hydrogen chloride concentrations for P(s>i|d,T) = 0.05 or 0.01, that is, the




probability of an  effect of severity corresponding to an index of 1 for selected time




periods, are given in Tables 6 and 7. The input data upon which the modeling was based




are given in Appendix B and the model output is given in Appendix D.




      The results discussed in this section were derived by using data directly, or




interpolating, from tables in Appendix D, and by comparison to the appropriate figures.




Model estimates derived from human equivalent concentrations based on the total lung




as the target tissue (Table D-l in Appendix D) are given in Figures 2 to 5. Based on the




model output, estimation or prediction of the probability (at the 0.05 or the 0.01 level)  of




an adverse human health effect of various severity levels for any combination of time and




dose can be made.  For example, Figures 2 and 3 indicate the MLE and lower bounds




for P(s>i | d,T)=0.05. Using these figures, the MLE and 95% lower bound for the




probability of an  effect of severity represented by index 1 was estimated to be




approximately 1 ppm (2 mg/m3) and 0.5 ppm (0.9  mg/m3), respectively, following an




8-hour exposure [P(s>i|d,8h)=0.05] (Table 6). For a 10-minute exposure




[P(s>i|d,10min)=0.05] the MLE was 55 ppm (85 mg/m3), while the lower bound was




21 ppm  (31 mg/m3) (Table 6). Figures 4 and 5 indicate that for [P(s>i| d,T)=0.01], the




MLE was 0.6 ppm (0.9 mg/m3) for an 8-hour exposure and 20 ppm (30 mg/m3) for a




                                       43

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                                     Table 6
               Maximum Likelihood Estimates and 95% Lower Bounds
                 for P(s>l | d,T) = 0.05 with Exposure to Hydrogen
                     Chloride for Various Durations of Exposure
Human Equivalent Concentrations ppm (mg/m3)
Total Lung3
Time
10 mind
4hrs
8hrs
24hrs
MLEe
55
3
1
0.6
(82)
(5)
(2)
(0.9)
LBe
21
1
0.5
0.2
(3D
(2)
(0.9)
(0-3)
Extrathoracicb
MLE
0.3
0.01
(2)
(0.1)
0.007 (6)
3
(2)
LB
13 (0.4)
0.6 (0.02)
0.5 (0.01)
0.2 (4)
Animal0 pp
(mg/m3)
MLE
13
(19)
0.6 (1)
0.5
0.2
(0.8)
(0.3)
m
LB
6
0.4
0.2
0.07
(9)
(0.6)
(0.3)
(0.1)
a Estimates of human equivalent concentrations were based on the assumption that the total
  lung was the target.
b Estimates of human equivalent concentrations were based on the assumption thai the total
  lung was the target in all studies except that for Lucia et al. (1977) and Barrows
  et al. (1979) the extrathoracic area was assumed to be the target.
c No conversion made; concentrations are those used in animal experiments.
d Times are approximate, interpolated from values in Tables D-l to D-3.
e Maximum Likelihood Estimate (MLE) and 95% Lower Bound (LB).
                                          44

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 10-minute exposure (Table 7).  The lower bound on the MLE was 0.1 ppm (0.2 mg/m3)




 for an 8-hour exposure and 6 ppm (9 mg/m3) for a 10-minute exposure  (Table 7).




      Exposure estimates developed from the proposed model were  compared to




 criteria values and reported data. These estimates are presented in Tables 8 and 9.




 While data in the tables are given for both a probability of effect of 0.01 (Table 8) and




 0.05 (Table 9), the  remainder of this discussion will focus on a probability of 0.01, i.e.,




 [P(s>i | d,T)=0.01].  Concentration estimates obtained in this analysis  approximate




 severity effects within the  range of acute criteria values and bracket human data




 reported.  As an example  of reported data, according to Henderson and Haggard (1943),




 10 to  50 ppm (15 to 75 mg/m3) was estimated to be the maximum concentration




 tolerable for a few  hours.  An analogous comparison would be to compare model




 predictions at 3 hours for  a severity index 2.  As listed in Table 8 under Total Lung




 (derived by using Figures  4 and 5 and interpolating between times as  given in Table




 D-l),  for P(s>2|d,3h)=0.01, the MLE was approximately 56 pprn (84 mg/m3), while the




 95% lower bound on the MLE was 16 ppm (24 mg/m3) for 3 hours exposure.  The




 maximum concentration tolerable for a  1-hour exposure to hydrogen chloride was




 reported  to range from 50 to 100 ppm (75 to 150 mg/m3) (Henderson and Haggard




 1943). The estimated MLE and 95% lov/er bound on P(s>2| d,lh)=0.01 (Figures 4 and




 5) were 153 and 43 ppm (229 and 64 mg/m3), respectively.    Criteria for acute non-




 lethal effects have been established for  hydrogen chloride. These values are set for




various exposure time periods and are intended for differing regulatory criteria.




 Exposure estimates developed from the proposed model based on total  lung were




 determined and compared to the criteria values reported.  This comparison considered




 both the intended time frame and the intended degree of protection for a specified




                                       45

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                                         Table 7
                  Maximum Likelihood Estimates and 95% Lower Bounds
                     for P(s>l | d,T) = 0.01 with Exposure to Hydrogen
                        Chloride for Various Durations of Exposure
 Time
             Human Equivalent Concentrations ppm (mg/m )
               Total Lung3
                            Extrathoracic5
MLEe
LBe
MLE
LB
                                            Animalc ppm (mg/m3)
MLE
LB
 10 mind   20 (30)      6 (9)

 4 hrs       1 (2)     0.3 (0.5)

 8 hrs      0.6 (0.9)   0.1 (0.2)

 24 hrs     0.2 (0.3)   0.05 (0.8)
                       0.1 (0.2)       0.05 (0.07)

                     0.007 (0.01)    0.001 (0.002)

                     0.004 (0.006)   0.0005 (0.0008)

                     0.001 (0.002)   0.0002 (0.0003)
                                             5 (7)       2 (3)

                                            0.3 (0.5)     0.1 (0.2)

                                            0.2 (0.3)    0.07 (0.1)

                                           0.07 (0.1)  0.03 (0.04)
a Estimates of human equivalent concentrations were based on the assumption that the
  total lung was the target.
b Estimates of human equivalent concentrations were based on the assumption that the
  total lung was the target in all studies, except that for Lucia et al. (1977) and Barrows
  et al. (1979) the extrathoracic area was assumed to be the target.
c No conversion made; concentrations are those used in animal experiments.
d Times are approximate, interpolated from values in Tables D-l to D-3.
e Maximum Likelihood Estimate (MLE) and 95% Lower Bound (LB).
                                       46

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                                                                            Tables
                                                            Relative Comparison of Several Regulatory
                                                       Criteria and Human Data with Maximum Likelihood
                                                           and 95% Lower Bounds on P(s>i |d,T)=O.Or
Human Equivalent Concentrations ppm


IDLH
PEL
RfC
Human 1"
Human-2r
Human-3s
Criteria
Value ppm (mg/m3)
100(150)
5(7)
0.005 (0.007)
!Q 50 (15-75)
50-100 (75-150)
1000-2000 (1500-3000)
Reference
Time
(Hours)
0.5
0.25
24
3
1
0.17
Reference
Severity
Index
2
1
1
2
2
3
Total
MLE
281 (421)
13 (20)
0.2 (0.3)
56(84)
153 (229)
2893 (4339)
Luncb
LB
77(115)
2(3)
0.05 (0.08)
16 (24)
43(64)
1104(1656)
(mg/m3)
Extrathoracic'
MLE LB
5(8)
0.07 (0.1)
0.001 (0.002)
1.3 (2)
3(5)
107 (161)
1.3 (2)
0.01 (0.02)
0.0002 (0.0003)
0.3 (0.4)
0.7 (1)
35 (52)


Animal*1 ppm fmu/m3)
MLE LU
63 (94)
3(5)
0.07 (0.1)
15 (22)
36 (54)
437 (655)
35 (53)
1(2)
0.03 (0.04)
8(12)
20 (30)
279 (418)
* All values are based on the probability of a severity greater than 1 at the 0.01 level and are extrapolated from data given in Tables D-1, D-2, and D-3.
b Estimates of human equivalent concentrations were based on the assumption that the total lung was the target.
c Estimates of human equivalent concentrations were based on the assumption that the total lung was the target in all studies, except that for Lucia et al. (1977) and Barrows
  et aj. (1979) the extrathoracic area was assumed to be the target.
d No conversion made; concentrations are those used in animal experiments.
c Maximum concentration tolerable for a few (3)  hours (Henderson and Haggard 1943).
' Maximum concentration tolerable for one hour  (Henderson and Haggard 1943).
* Dangerous for even short exposures.

-------
                                                                            Table 9
                                                            Relative Comparison of Several Regulatory
                                                       Criteria and Human Data with Maximum Likelihood
                                                          and 95% Lower Bounds on P(s>i |d,T)=0.05*
                                                                             Human Equivalent Concentrations ppm (mg/m3)
                Criteria
Total Lung"
Extrathoracicc
Animal** ppm (mg/m3)

IDLII
PEL
RfC
Human-lc
Human-2f
IIuman-31
Value ppm (mg/m3)
100(150)
5(7)
0.005 (0.007)
10-50(15-75)
50-100 (75-150)
1000-2000 (1500-3000)
Reference
Time
(Hours)
0.5
0.25
24
3
1
0.17
Reference
Severity
Index
2
1
1
2
2
3
MLE
785 (1177)
37 (55)
0.6 (0.9)
157 (236)
427 (640)
8076(12114)
LB
287 (431)
14(21)
0.2 (0.3)
66(99)
166 (249)
4277 (6416)
MLE
48 (72)
0.7(1)
0.01 (0.02)
10(15)
26 (39)
943 (1414)
LB
18 (27)
0.2 (0.3)
0.003 (0.004)
3(5)
10 (15)
452 (678)
MLE
185 (278)
9(13)
0.2 (0.3)
43(64)
106 (159)
1285 (1927)
LB
117(176)
4(6)
0.07 (0.1)
25 (38)
66(99)
954(1431)
* All values are based on the probability of a severity greater than 1 at the 0.05 level and are extrapolated from data given in Tables D-l, D-2, and D-3.
b Estimates of human equivalent concentrations were based on the assumption that the total lung was the target.
c Estimates of human equivalent concentrations were based on the assumption that the total lung was the target in all studies, except that for Lucia et al. (1977) and Barrows
  et al. (1979)  the extrathoracic area was assumed to be the target.
d No conversion made; concentrations are those used in animal experimenis.
" Maximum concentration tolerable for a few (3) hours (Henderson and Haggard 1943).
' Maximum concentration tolerable for one hour (Henderson and Haggard 1943).
8 Dangerous for even short exposures.

-------
criteria value and compared those to analogous time and severity levels estimated from




the proposed model.  For example, the IDLH is an exposure concentration regarded as




immediately dangerous to life and health but is the concentration; that in the event of




respirator failure could be tolerated for 30 minutes. The IDLH for hydrogen chloride




has been established at 100 ppm (150 mg/m3) (HSDB 1991). A similar comparison, for




example, would be to compare the model prediction at 30 minutes for a severity index




of 2. Again referring to Table 8, the MLE and 95% lower bound on P(s>2| d,0.5hr) =




0.01 are 281 and 77 ppm (421 and 115 mg/m3), respectively.  In reality, the IDLH may




be analogous to some severity represented by an index between level 2 and 3, indicating




that estimates at level 2 may be lower than would be expected if the data could have




been divided into more severity categories. Therefore, it should be noted that the




severity indices used in this analysis did not equate exactly with effects associated with




IDLH.




      The OSHA PEL of 5 ppm (~7  mg/m3) is the concentration that should  not be




exceeded at any time during the work day. Concentrations below this value may be




considered to be analogous to a severity category 1; therefore, the  PEL was compared to




concentration estimates at a severity index of 1 for 15 minutes (Table 8).  Again focusing




on Total Lung, the MLE and 95% lower  bound at P(s>l | d,0.25hr)=0.01 were 13 ppm




(20 mg/m3) and 2 ppm (3 mg/m3), respectively, which bracket the 5 ppm (—7 mg/m3)




standard.  Conversely, if the dose is held  constant and  time is estimated from the model




for P(s>l 17 mg/m3,T)=0.01, and if the MLE estimate of concentration is 5 ppm




(~7 mg/m3), then the time corresponding to that dose was approximately 45 minutes




(Figure 4). If the 95% lower bound on that  concentration was assumed to be 5 ppm




(~7 mg/m3), the corresponding time was  approximately 13 minutes (Figure 5).  That is,




                                      49

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exposure durations of 13 minutes at 5 ppm (~7 mg/m3) would not be expected to result




in an adverse effect. Stated another way, the probability of exceeding a severity level




corresponding to an index of 1 is less than 0.01 when concentration is 5 ppm (~7 mg/m3)




and time is 13 minutes  [P(s>l | 7mg/m3, 13min)=0.01].




      The concentration values, as depicted in Figures 4 and 5, agreed with values




estimated using the RD50 method (Barrow et al 1977).  The 1/100 RD50 and 1/10 RD50




concentrations reported by Barrow et al (1977) were 3.1 and 31 ppm (4.6 and 46




mg/m3), respectively. If it is assumed that at the lower concentration of 3.1 ppm




(4.6 mg/m3), no adverse effects would be expected to occur (Le., corresponding to a




severity index of 1), then according to this model for P(s>l 14.6 mg/m3,T)=0.01, the




MLE concentration of 3.1 ppm (4.6 mg/m3) corresponds to an exposure time of




approximately 1 and one-half hours.  Similarly, the 95% lower bound concentration of 3.1




ppm (4.6 mg/m3) corresponds to approximately 20 minutes. If it is assumed that a




concentration of 31 ppm (46 mg/m3) may be accompanied by some sensory irritation,




then this concentration corresponds to an index of 2, Le., [P(s>2| 46 mg/m3,T)].




      As another comparison, the RfC represents the concentration that is not expected




to result in adverse effects should chronic exposure occur at that concentration. The RfC



for hydrogen chloride, 7xlO"3 mg/m3 (5xlO~3 ppm), was based on the adjusted LOAEL in




a lifetime animal study (Sellakumar et al 1985), which was 2.5 mg/m3 (1.7 ppm).  When




converted to a human equivalent concentration (6.5 mg/m3 or 5 ppm) and adjusted by




uncertainty factors totaling 1000, the RfC of 7xlO"3 mg/m3  (5xlO~3 ppm) was obtained.




An analogous time and severity index for comparative purposes would be 24 hours at an




index of 1.  The MLE and 95% lower bound for P(s>l | d,24hr)=0.01 were 0.2 and 0.05
                                       50

-------
 ppm (0.31 and 0.08 mg/m3), respectively.  These values are less than the human




 equivalent concentration of 5 ppm (—7 mg/m3), but greater than the RfC.  In fact, the




 model estimates are only 19 to 76 times Jess than the human equivalent concentration




 derived from the Sellakumar et al. data.  When model estimates were derived from




 human equivalent concentrations extrapolated based on total lung and extrathoracic




 surface area (from Figures 8 and 9 and Table D-2), the MLE and 95% lower bound on




 P(s>l |d,24h)=0.01 were l.lxlO'3 to IQxKT4 ppm (2xlO'3 to  3x10^ mg/m3) (Table 8).




 When comparing model estimates based on Total Lung to those based on Total Lung




 and Extrathoracic, the latter more closely approximate the RfC (the model estimates  for




 the MLE closely approximate the RfC, the 95% lower bound is an order of magnitude




 smaller than the RfC).  However, when comparing across all other criteria values, the




 model estimates based on Total Lung provide a closer match, especially the 95% lower




 bound values.




       Although there are three curves (since these are log-log plots, the curves are seen




 as straight lines) on each graph, the curve indicating no adverse effect is the lowest curve,




 i = 1.  A severity curve for severity index 4, i = 4, is not depicted, since the model solves




 for maximum likelihood or lower bound on dose to exceed severity of i, and severity




 exceeding index 4 (life-threatening effects or death) is undefined.  What can be said is




 that, should the hydrogen chloride air concentration exceed approximately 2.935 to




 1,121 ppm (4,403 to 1,682 mg/m3) for as little as 10 minutes or 31 or 11 ppm (46 or




 16 mg/m3) for 24 hours, irreversible, severe damage is likely to occur [for the MLE and




95% lower bound on  P(s>31 d,T)=0.01] (Figures 4 and 5).  This agreed with those data




reported by Henderson and Haggard (1943) who estimated that exposure to hydrogen
                                       51

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chloride at concentrations of 1,000 to 2,000 ppm (1,500 to 3,000 mg/m3) for even short




periods of time was dangerous to human health.








33    Conclusions and Relevance to Human Health








       There is limited information in the literature on the inhalation toricity of hydrogen




chloride in humans, and that which is available presents some conflicting information.




According to the EPA (1988), reported odor threshold levels range from 0.07 ppm




(0.1 mg/m3) to as high as 204 ppm (306 mg/m3).  Hydrogen chloride is expected to be a




strong irritant, especially to mucous membranes lining the nasal passages and respiratory




tract.  However, the ambient air concentration at which irritation may be first




experienced and the severity of that  irritation over various concentrations and durations




is not well characterized.




       There is an important difference between this method and methods used to derive




short-term standards.  In existing methods a NOEL or a NOAEL from either animal or




human studies is divided by uncertainty factors that reflect the type of data and the




confidence in the data. Although numerous studies may have been reviewed, in the




NOAEL/uncertainty factor approach only one data point (one dose, from one study) is




actually used.  In this proposed  method, all data from all studies are subjected to




analysis, and the MLE of the dose for fixed time and probability, which may or may not




be any one of the actual experimental doses associated with an effect of specific severity,




is derived.  Experimental doses are first converted to human equivalent doses.  Then the




MLE, as estimated by the model, is the most likely dose, given all the evidence, that at a




specified time is not expected to be above a specified level of severity at a given level of




                                        52

-------
statistical probability. The lower bound or confidence limit on the MLE is also estimated




by the model. (Lower bounds that may be considered include 90%, 95%, 97.5% and




99%.)




       Applying the model to the hydrogen chloride data illustrates that the model is




robust enough to use a minimal data base; minimal in terms of number of studies




available and the lack of extensive data reported in some of the studies.. These




limitations in the data base, as well as any inconsistencies in results among studies, are




reflected in both the fit of the model to  the data and the estimation of the lower




confidence limits on these data. The distance between the MLE and the 95%  lower




confidence limit is reflective of the data  limitations. For example, as illustrated in figures




for the 95% lower confidence limit, the curve representing a severity equal to or greater




than one is considerably lower than the curve for the corresponding MLE in each case.




This reflects both the few data points with a  severity index of 1 and some of the overall




variability in the data.




       Guth et al. (1991) showed that visually improved model fit was attained  by




application of categorical regression  to a specific toxicological endpoint for methyl




isocyanate and tetrachloroethylene.  Modeling of data for specific endpoints or  data only




from studies in humans for propylene oxide and dichloromethane resulted in poor model




fit due to data limitations imposed by selecting specific subsets of the data.  Although




analysis of data disaggregated to the level of  endpoint or species may clarify




interpretation of the results by increasing the similarity of the various data points used,




data requirements limit the extent of data  reduction that is possible. Criteria for model




fit and minimum data base have not been  established for this method.
                                        53

-------
      Since hydrogen chloride did not have data for all time periods and all severity




indices,  i.e., data gaps, the model fills in these data gaps by the likelihood method.  While




this is a useful procedure, it introduces a degree of uncertainty in the estimation of the




dose for fixed severity, probability, and time when there are data gaps.  Other




uncertainties  in this method are those inherent in the use of any  model for dose-




response, such as the use of the appropriate model, the use of the correct explanatory




variables (i.e., sex, age, or species, etc. in addition to time and dose).




      The use  of other models that may be superior in their predictive abilities to the




log-logistic and  Weibull  models should be explored.  Methods should also be developed




that will validate the assumptions implicit in the model  whenever the regression is




performed. Some goodness-of-fit criteria should be  developed which measure the




usefulness of the regression procedure relative to a particular data set.  Due to the




partial likelihoods used, even  graphs of the data and concordance statistics as presently




developed could not be  used  to get some idea of the fit. Since one would expect the




biological mechanism to change as the severity of the effect increased, a more general




model that allows the time and dose parameters to change over severity levels should be




considered.



      Another limitation in the wide-spread application of this model is that it requires




critical evaluation of all  the data and construction of a severity scale that is reflective of




the entire data  base. While this process can be somewhat codified, since severity




schemes have been proposed  and used in other applications, it still requires some




subjective judgement and, therefore, should be approached in a way that gains some




consensus among reviewers.
                                        54

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       Another uncertainty is in the interspecies extrapolations.  For other methods,




extrapolation is accomplished by either expressing dose in units i:hat are assumed to be




equivalent across species, such as the surface area equivalence assumed in cancer




extrapolation, or by the application of uncertainty factors. The RfC method incorporates




both by expressing units as a human equivalent concentration and by the application of




uncertainty factors.  With this dose-duration-response method, doses are expressed as




human equivalent concentrations; however, further species extrapolation is not explicitly




done.  What is done is to estimate the 95% lower confidence limit at the specified  level




of probability, in this case at the 0.05 and 0.01 levels, for  each dose/duration combination




that is not expected to cause adverse effects in exposed populations (i.e., the probability




of exceeding a severity index greater than 1). Other confidence limits, e.g., the 99%




confidence limit, or other probability levels could have been selected.  For hydrogen




chloride, the 95% lower limit at the 0.01 level adequately characterized the human data




(Table 8).




       It appears that much of the data reported on air concentrations for human




exposure to hydrogen chloride are derived from the same source (Elkins 1959.




Henderson and Haggard 1943), the interpretation of which may be open to question.




Use of all data on adverse effects following short-term hydrogen chloride exposure, as in




this proposed method, may provide a more scientifically defensible rationale for setting




guidelines for protection of human health and for guidelines on response to emergency




situations.




      The proposed dose-duration response model estimated values for hydrogen




chloride that closely agreed with reports of human exposure and established regulatory




criteria.  The proposed dose-duration-response model, when verified, may provide a




                                        55

-------
useful tool for the risk assessor/risk manager.  At a glance, the risk assessor may be able




to evaluate if an adverse effect is likely to occur from exposure to a chemical at a




specified dose and time by referring to a graph or table that incorporates the output of a




dose-duration-response model.
                                         56

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 4.     References
 Alarie Y. 1973. Sensory irritation by airborne chemicals.  CRC Crit Rev Toxicol
    2:299-363.

 American Conference of Governmental Industrial Hygienists. 1980. Documentation of
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 American Conference of Governmental Industrial Hygienists. 1987. Threshold Limit
    Values and Biological Exposure Indices for 1987-1988.  ACGIH.  Cincinnati, Ohio.
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 Anzueto A,  Switzer W, Kaplan H, et al.  1987. Long-term effects of hydrogen chloride
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 Archuleta D, Stavert D, Behr M, et al.  1990.  Pathologic responses to HF, HBr, and HC1
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 Barrow C, Lucia H, Alarie Y. 1979.  A comparison of the acute  inhalation toxicity of
    hydrogen chloride veiius the thermal decomposition products  of polyvinylchloride.
   / Combust Toxicol 6:3-12.

 Barrow C, Alarie Y, Warrick J, et al.  1977. Comparison of the sensory irritation
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 Burleigh-Flayer H, Wong K, Alarie Y. 1985. Evaluation of the pulmonary effects of
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 Commonwealth of Massachusetts.  1990.  Summary of Massachusetts' Methodology for
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 Crump K. 1984. A new method for determining allowable daily intakes.  Fund Appl
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 Crump K, Howe R. 1985.  A review of methods for calculating confidence limits in low
   dose extrapolation. In:  Toxicological Risk Assessment. Krewski D, ed. CRC Press,
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 Darmer K Jr, Kinkead E, DiPasquale L.  1974. Acute toxicity in rats and mice exposed
   to hydrogen chloride gas and  aerosols. Am  Ind HygAssocJ 35:623-631.

Dourson M.  1986.  New approaches in the derivation of acceptable daily intake (ADI).
   Comments Toxicol 1:35-48.
                                       57

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 Dourson ML, Hertzberg RC, Hartung R, Blackburn K. 1985. Novel methods for the
    estimation of acceptable daily intake.  Toxicol Ind Health 1:23-41.

 Elkins H.  1959.  Tlie Chemistry of Industrial Toxicology. 2nd Edition. John Wiley and
    Sons, New York. pp. 79-80.

 Environmental Protection Agency (EPA).  1980.  Guidelines and methodology used in
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 Environmental Protection Agency (EPA).  1988.  Health Assessment Document for
    Chlorine and Hydrogen Chloride.  Office of Health and Environmental Assessment.
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 Environmental Protection Agency (EPA).  1990.  Interim Methods for Development of
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    1990.

^Environmental Protection Agency (EPA).  1991.  Integrated Risk Information System
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 GEOMET Technologies, Inc. 1981.  Hydrogen Chloride:  Report 4, Occupational
    Hazard Assessment.  U.S. Department of Health and Human Services. NIOSH,
    Cincinnati, OH.  p. 56.

 Guth DJ, Jarabek AM, Wymer L, Hertzberg RC.  1991. Evaluation of Risk Assessment
    Methods for Short-Term Inhalation Exposure.  Presented at 84th Annual Meeting Air
    & Waste Management Association, Vancouver, British Columbia, June 16-21, 1991.

 Hartung R. 1986. Ranking the severity of toxic effects. In:  Hemphill D, ed. Trace
    Substances in Environmental Health. XX. University of Missouri-Columbia,
    Columbia, Missouri,  pp. 204-211.

 Hartzell G, Packham S, Grand A, et al.  1.985.  Modeling of lexicological effects  of fire
    gases:  III.  Quantification of post-exposure  lethality of rats from exposure to HC1
    atmospheres. J Fire Sci 3:195-207.

 Hazardous Substances Data Base (HSDB).  1991.

 Henderson Y, Haggard H. 1943. Noxious Gases.  Reinhold Publishing Corporation, New
    York. pp. 124-141.
                                       58

-------
Hertzberg R.  1989.  Fitting a model to categorical response data with application to
   species extrapolation of toxicity. Proceedings of 26th Hanford Life Sciences
   Symposium. Modeling for Scaling to Man:  Biology, Dosimetry and Response. Health
   Phys (Suppl 1):405-409.

Hertzberg R, Knauf L.  1989. Statistical Methods for Estimating Risk for Exposure
   Above the Reference Dose.  Environmental Criteria and Assessment Office, Office of
   Health and Environmental Assessment, Office of Research and Development, U.S.
   Environmental Protection Agency, Cincinnati,  OH.

Hertzberg R, Miller M.  1985.  A statistical model for species extrapolation using
   categorical response data.  Toxicol Ind Health  1:43-57.

Kaplan H.  1987.  Effects of irritant gases on avoidance/escape performance and
   respiratory response of the baboon.  Toxicology 47:165-179.

Kaplan H, Anzueto A, Switzer W, et al  1988.  Effects of hydrogen chloride on
   respiratory response and pulmonary function of the baboon.  / Toxicol Environ Health
   23:473-493.
Kaplan H, Anzueto A, Switzer W, et al.  1986.  Respiratory effects of hydrogen chloride
   in the baboon.  Toxicologist 6:52 (As cited in EPA 1988).

Kaplan H, Grand A, Rogers W, et al  1984.  A Research Study of the Assessment of
   Escape Impairment by Irritant Combustion Gases in Postcrash Aircraft Fires.
   AD-A146-484.  Prepared by South West Research Institute, San Antonio. Texas.
   Prepared for Federal Aviation Administration, Atlantic City Airport, NJ.

Kusewitt D, Stavert D, Ripple G, et al.  1989. Relative acute toxicity in the respiratory
   tract of inhaled hydrogen fluoride, hydrogen bromide and hydrogen chloride.
   Toxicologist 9

Lucia H, Barrow C, Stock M, et al.  1977.  A semiquantitative method for assessing
   anatomic damage sustained by the upper respiratory tract  of the laboratory mouse,
   Mus musculis.  J Combust Toxicol 4:472-486.

Machle W,  Kitzmill K, Scott E, Treon J. 1942. The effect of inhalation of hydrogen
   chloride. J Ind Hyg Toxicol 24:222-225.

McCune  E.  1990. Personal communication.  North Carolina  Division of Environmental
   Management, Air Quality Section. February 2, 1990.

National  Air Toxics Information Clearinghouse (NATICH). 1988.  NATICH Data Base
   Report on State. Local and EPA Air Toxics Activities.  USEPA, Office of Air Quality
   Planning and Standards.  Research Triangle Park, NC.  July 1988.
                                        59

-------
North Dakota State Department of Health.  1990.  Policy for the Control of Hazardous
   Air Pollutant Emissions in North Dakota.  Air Quality Management Branch.

Patty F.  1963.  Industrial Hygiene and Toxicology.  Vols. 1 and 2.  New York:
   Interscience  Publishers.

Pavlova T.  1976.  Disturbance of development of the progeny of rats exposed to
   hydrogen chloride.  Bull Exp Biol Med 82:1078-1081.

Rhode Island Department of Environmental Management. 1990,, Rhode Island Air
   Toxics Guidelines.

Sellakumar A, Snyder C, Solomon J, Albert R.  1985.  Carcinogenicity of formaldehyde
   and hydrogen chloride in rats.  Toxicol Appl Pharmacol 42:417-423.

Wohlslagel J, Dipasquale L, Vernot E. 1976. Toxicity of solid rocket motor exhaust:
   effects of HC1, HF, and alumina on rodents.  / Combustion Toxicol 3:59-70.
                                       60

-------
              APPENDIX A




DISCUSSION OF ACUTE ANIMAL TOXICITY DATA

-------
       Hydrogen chloride (HC1) forms a corrosive acid in air and, as such, is acutely




toxic.  The primary target for acute inhalation exposure is the respiratory tract. Adverse




effects following acute exposure to hydrogen chloride include irritation, pulmonary




edema, nasal and respiratory tissue injury, and death.  These adverse respiratory effects




have been assessed in laboratory animals and have been evaluated by focusing primarily




on three endpoints: lethality, alterations in respiratory function, and histopathological




changes to the nasal or pulmonary tissues.




       Review of the available literature indicated that there are  some data gaps in our




knowledge concerning the adverse health effects from acute  exposure to sublethal




concentrations of hydrogen chloride that impact development of dose-duration-response




relationships. One of these data limitations is that few studies have reported the results




of all three of the endpoints mentioned above by dose group when evaluating the toxicity




of hydrogen chloride.  For example, a study may report on alterations in respiratory




function without corresponding histopathological injury to the respiratory tissue or a




study may present mortality data without describing any of the nonlethal effects also




observed.  Even though some of these effects have been reported separately in animal




bioassays, they are not independent responses. Rather, these effects represent a




continuum of toxicity, the severity of which is  dependent on the concentration of




hydrogen  chloride to which the subject was exposed, the duration of that exposure, and




the individual sensitivity.  As either the concentration or the time increased, toxic effects




would be  expected to increase from slight irritation to severe irritation which overlaps




with slight, reversible  tissue injury and progresses to severe tissue destruction, pulmonary




distress and finally death. As such, it is important to develop an overall perspective for a




dose-response assessment of the adverse health effects of hydrogen chloride by analyzing




                                        A-l

-------
 data on multiple endpoints across studies.  For example, Barrow et al (1977) observed




 decreases in the respiratory rate of mice over time which were concentration related.




 The significance of these responses relative to the animals' health may be qualitatively




 assessed, but when combined with the histopathological effects reported in the same




 species of mice exposed by the same protocol to similar concentrations and exposure




 duration (Lucia et al 1977), a more quantitative assessment can be made, Le., the




 relative degree of  respiratory damage experienced by the animals that corresponds to the




 changes observed in respiratory rates. By comparing across studies it may be possible to




 generalize these results and equate alterations in respiratory function with




 histopathological injury and thereby assess the extent and permanence of the respiratory




 damage.




       Another limitation of the data is that only a limited number of exposure  durations




 have been tested.  Most exposure protocols required examination for effects of  high




 concentrations for  durations of less than 30 minutes. Only two studies reported effects




 from single-exposure durations of greater than 30 minutes.  In one study, Machle et al.




 (1942) exposed guinea pigs and rabbits (three animals per group) to concentrations




 ranging from 33  to 13,667 ppm (50 to 20.500 mg/m3) for single-exposure periods up to 6




 hours.  The  other investigation, Hartzell et al. (1985), was a series of acute toxicity




 studies in rats and  the longest  exposure duration was 60 minutes.  To overcome this




 limitation, evaluation of studies should be conducted across studies rather than evaluation




of each study independently.




       It is  important to note  that the mathematical model described in Chapter 3 of




this report allows an analysis of these data across endpoint, time, and specific study.  The




data from the available literature used in the dose-duration-response  analyses (presented




                                        A-2

-------
briefly in Chapter 3) are discussed in the following paragraphs. The studies considered




are grouped according to the main endpoints reported in these studies.  Some cross-study




or cross-endpoint comparisons have been made; however, comparisons across studies,




especially as they relate to the severity index assigned for analysis, are described in




section 3.2.1 and are not repeated in this section.








Acute lethality studies




       The LC50 values derived in acute toxicity studies in rats, mice, rabbits, and guinea




pigs indicate that the hydrogen chloride concentrations that result in mortality lie within




fairly similar ranges for all species tested.  However, rats may be somewhat less sensitive
to the acute lethal effects of hydrogen chloride than mice and guinea pigs. The results of




these lethality studies demonstrated that the toxicity of hydrogen chloride is related to the




"exposure dose," which is dependent upon the concentration of hydrogen chloride to




which the animals were exposed and the duration of exposure.  In a series of studies by




Darmer et al. (1974) rats and mice were exposed to high concentrations of hydrogen




chloride for either 5  or 30 minutes.  Groups of ten male Sprague-Dawley rats were




exposed to concentrations ranging from 30,000 to 57,290 ppm (45,000 to 85,935 mg/m3)




for 5  minutes, or 2,078 to 6,681 ppm (3,117 to  10,022 mg/m3) for 30 minutes. Calculated




LC50  values were 40,989  ppm (61,483 mg/m3) for the 5-minute exposure but were




4,701  ppm (7,051 mg/m3) for the 30-minute exposure.  During the 7-day post-exposure




observation period, no deaths occurred in rats exposed to the lowest concentration for




either exposure time. In  the study with CF-1 male mice, concentrations ranged from




3,200  to 30,000 ppm  (4,800 to 45,000 mg/m3) for 5  minutes, or 410 to 5,363 ppm (615 to




8,045  mg/m3) for 30 minutes. LC50 values of 13,745 and 2,644 ppm (20,617 and




                                        A-3

-------
3,966 mg/m3) were determined for the 5 and 30 minute exposures, respectively.  A low




incidence of mortality (a total of four out of 30 mice) occurred in the 5-minute exposure




groups at concentrations up to 6,410 pprn (9,615  mg/m3) hydrogen chloride, the fourth




highest exposure concentration.  No deaths were  reported in the  mice exposed to




410 ppm (615 mg/m3) hydrogen chloride for 30 minutes, but mortality increased rapidly




with increasing hydrogen chloride concentration.




      In studies by Hartzell et al. (1985), male Sprague-Dawley rats (6  or 8 rats/group)




were exposed to multiple concentrations of hydrogen chloride over a range of 5  to 60




minutes.  The values for the 14-day LC50s appeared to be a function of both time  and




concentration, e.g., no deaths occurred ai: a  5-minute exposure to 9,200 ppm (13,800




mg/m3), whereas exposure for 10 minutes to 9,170 ppm (13,755 mg/m3) caused~100%	




mortality. At the longest exposure duration, 60 minutes, no mortality occurred at a




concentration of 1,793 ppm (2,690 mg/m3).  The LC50s values from the  5-,  10-, 15-, 30-,




and 60-minute exposures were 15,900, 8,370, 6,920, 3,715, and 2,810 ppm (23,850, 12,555,




10,380, 5,572, 4,215 mg/m3), respectively.




      In guinea pigs and rabbits of unspecified strains, an exposure concentration  of




3,667 ppm (5,500 mg/m3) for 5 minutes, caused no mortality, but at 4,333 ppm



(6,500 mg/m3) for 30 minutes or 667  pprn (1,000 mg/m3) for 2 to 6 hours, 100% mortality




occurred in both species (Machle et al. 1942).   Mortality was observed in English smooth-




haired guinea pigs at a lower exposure concentration of 1,040 ppm (1,560 mg/m3) for 30




minutes, when the animals were subjected to hydrogen chloride by head-only exposures




(Burleigh-Flayer et al 1985).  In baboons, hydrogen chloride concentrations up to 11,400




ppm (17,100 mg/m3)  for 5 minutes were tolerated without mortality (Kaplan et al.  1984).
                                       A-4

-------
       The apparent discrepancy in the magnitude of LC50 values in rats from the




 5-minute exposure groups may be attributed to several factors.  Whole body exposures




 were used in the studies by Darmer et al. (1974), while Hartzell et al (1985) subjected




 animals  to head-only exposures. This difference in protocol may have altered the actual




 dose of hydrogen chloride received enough to result in a difference in the observed




 toxicity in the shorter-term exposures (e.g., 5 minutes).  Another distinction is that post-




 exposure observation times varied from 7 days in the Darmer et al. study to 14 days in




 the Hartzell et al.  study. It is reasonable to assume that extending the observation time




 two-fold would provide data points of moribund animals which might have succumbed




 within the additional time period and therefore, lower the median lethal  dose value.  The




 differential values reported for toxicity in guinea pigs may also be attributed to exposure




 protocols of head-only versus whole body; however, the study  by Machle  et al. (1942)  is




 confounded by exposure in a copper chamber, by hydrogen chloride gas generated from




 sulfuric acid, and by a non-homogeneous test population.








 Histopathological changes in nasal and respiratory tract tissues




       When male Swiss-Webster mice (four mice/group) were exposed to a range of



 hydrogen chloride concentrations for 10  minutes, superficial ulceration of the epithelium




 of the external nares was evident at  17 ppm (26 mg/m3), and as  hydrogen chloride




 concentrations increased, progressive damage occurred (Lucia et al. 1977).  Total




 destruction of the upper respiratory tract was observed at 7.279  ppm (10,919 mg/m3).




 However, the extent of injury to  the  lower respiratory tract was not evaluated.  In a




similar study, groups of eight male Fischer-344 rats  were exposed for 30 minutes to
                                       A-5

-------
concentrations of 100 to 1,000 ppm (150 to 1,500 mg/m3) (Kusewitt et al 1989).  The




observed injury scaled with concentration and was confined only to the nasal cavity.  In




male English smooth-haired guinea pigs (four guinea pigs/group) following exposure to




1,040 ppm (1,560 mg/m3) hydrogen chloride for 30 minutes, tissue damage in both the




large airways and alveolar regions was noted. Squamous metaplasia and bronchitis in the




large conducting airways along with acute inflammation of the alveoli were observed




(Burleigh-Flayer et al. 1985).




      The extent and location of damage to the respiratory tract may be species-specific




and may also be related to breathing patterns. A recent study with Fischer-344 rats (five




to eight rats/group) demonstrated that lesion sites in the respiratory tract are primarily




dependent upon inhalation pathway, Le., mouth versus nose breathing of hydrogen




chloride gas (Archuleta et al. 1990). Pseudo-mouth breathing (PM), which consisted of




animals being fitted with mouthpieces with attached silastic tracheal tubes, and normal




nose-breathing (NB) rats, were exposed to 1,000 ppm (1,500 mg/m3) hydrogen chloride




for 30 minutes. Histopathological analysis of the upper and lower respiratory tract




revealed that tissue injury was confined to the nasal region only for NB exposure,




whereas the PM exposure produced major tissue disruption in the trachea and peripheral




lung damage.  However, this difference may be less apparent as the hydrogen chloride




concentration increases because the filtering action of the nasal mucosa may be less




efficient as concentration increases.
                                        A-6

-------
Irritation



       Hydrogen chloride is both a sensory and pulmonary irritant (Burleigh-Flayer et al




1985). Sensory irritation was manifested by a decrease in the respiration rate at lower




hydrogen chloride concentrations, but pulmonary irritation characterized by an increase




in respiratory rate followed by a decreased rate occurred at higher doses (Burleigh-Flayer




et al,  1985).




       The onset of sensory irritation in mice or guinea pigs was concentration and time




dependent (Barrow et al 1977, Burleigh-Flayer et al  1985). Within 5 to 6  minutes at




exposure to 40 ppm (60 mg/m3), irritation was evident in male Swiss-Webster mice (four




mice/group). As the concentrations increased, sensory irritation occurred within 1 minute




of exposure, and the RD50 (concentration producing  50% decrease in respiratory rate) in




mice was 309 ppm (460 mg/m3) (Barrow et al  1977).




       In guinea pigs, pulmonary irritation occurred after 20 minutes exposure to




320 ppm (480 mg/m3) and in less than 4 minutes to 1,380 ppm (2,070 mg/m3) (Burleigh-




Flayer et al. 1985).  Persistent impairment of respiratory function was observed in guinea




pigs after 30 minute exposure to 1,040 or 1,380 ppm (1,560 or 2,070 mg/m3) which was




supported by evidence (in the 1,040 ppm exposed animals) of histological damage in both




the airways and alveolar regions.




       The no-effect level for irritation in the baboon was 190 ppm (285 mg/m )




hydrogen chloride for 5 minutes (Kaplan et al.  1984). Irritation occurred at a level of




810 ppm (1,215 mg/m ) but animals were asymptomatic post-exposure, whereas exposure




to 2,780 ppm (4,170 mg/m3) caused a reversible post-exposure cough. Baboons tolerated




an exposure of 5,000 ppm (7,500 mg/m3) for 15 minutes without evidence of long-term
                                       A-7

-------
effects.  An exposure to 10,000 ppm (15,000 mg/m  ) for 15 minutes caused long-term




pulmonary effects, such as chronic nasal obstruction, persistent hyporia, and focal lung




fibrosis (Kaplan et ai  1988, Anzueto et ai  1987). Death from bacterial pneumonia




resulted at levels of 16,570 and 17,290 ppm (24,855 and 25,935 mig/m3) for 5  minutes




(Kaplan 1987).








Extra-pulmonary effects




      Extra-pulmonary effects of inhaled hydrogen chloride have been reported in some




experimental studies.  Degenerative and necrotic lesions in the heart, liver, and kidneys




have been reported in some studies in which guinea pigs and rabbits were exposed to




hydrogen chloride concentrations ranging from 150  to 3,075 ppm (225 to 4,613 mg/m3)




for periods of 5 minutes to  12 hours (Machle et al.  1942).  Exposure of male Swiss-




Webster mice (four mice/group) to concentrations of 130 to 20,000 ppm (190 to 30,000




mg/m3) hydrogen chloride for 10 minutes, produced passive congestion in the intestine,




liver, and kidney (Barrow et al. 1979).  However, in both studies it was difficult to




determine the direct contribution of hydrogen chloride since insufficient respiratory




function can cause extra-pulmonary deleterious effects.




      Pregnant Wistar rats (8 to 15 rats/group) exposed for 1 hour to 300 ppm




(450 mg/m3), the LC50, exhibited severe lung lesions and disturbed kidney function.




These maternotoxic effects were directly related to  disturbances of embryogenesis and




postnatal organ dysfunction in the progeny of the exposed females (Pavlova 1976).
                                        A-8

-------
              APPENDIX B

ANIMAL BIOASSAY DATA FOR INPUT INTO THE
    DOSE-DURATION-RESPONSE MODEL

-------
                   Table B-l
Acule Toxicity Data Derived from Animal Bioassays
Hydrogen
exposure
•ng/m3Anima,

45,000
48,383
59,775
67,800
85,935
3,117
4,017
4,607
7,770
9,102
10,022

4,800
7,590
9,218
9,615
11,288
12,098
13,914
20,483
39,728
45,000
chloride
level
mg/m3Human

220,000
236,539
292,233
331,467
420,127
15,239
19,639
22,523
37,987
44,499
48,9%

33,060
52,277
63,489
66,224
77,747
83,326
95,833
141,078
273,629
309,940
Time in
minutes

5
5
5
5
5
30
30
30
30
30
30

5
5
5
5
5
5
5
5
5
5
Severity
index

4
4
4
4
4
4
4
4
4
4
4

4
4
4
4
4
4
4
4
4
4
Number of
laboratory
animals
Darmer el aL
10
10
10
10
10
10
10
10
10
10
10
Darmer et aL
10
10
10
10
10
10
10
10
15
15
Indicator
1974 - Rats
0
1
6
7
9
0
1
0
5
8
10
1974 - Mice
1
1
2
0
6
2
5
6
13
13
Comments

Determined post-exposure lethality; other
loxicity symptoms reported were not attributed
to specific exposure concentrations.









Determined post-exposure lethality; other
loxicity symptoms reported were not attributed
to specific exposure concentrations.








-------
              Table B-l (continued)
Acute Toxicity Data Derived from Animal Bioassays
Hydrogen
exposure
«.g/m3Animal

615
1,701
4,017
4,082
4,413
4,607
6,068
6,114
8,045
DO
tv>
13,800
16,178
18,876
21,460
23,189
30,450
8,166
11,444
12,171
12,638
13,755
6,540
9,257
11,970
13,440
14,985
chloride
level

-------
                                                                  Table B-l (continued)
                                                    Acute Toxicity Data Derived from Animal Bioassays
CO
Hydrogen chloride
exposure level
roe/"1 Animal mg/m3||Uman
Time in
minutes
Severity
index
Number of
laboratory
animals Indicator
Comments
17,700
21,615
22,875
27,645
33,390
37,950
38,775
41,535
68,250
80,850
115,095
131,490
86,533
105,673
111,833
135,153
163,240
185,533
189,567
203,060
333,667
395,267
562,687
642,840
5
5
5
5
5
5
5
5
5
5
5
5
3
3
4
4
4
4
4
4
4
4
4
4
285
1,215
1,335
1,410
4,170
17,100
24,855
25,935
657
2,803
3,080
3,253
9,619
39,447
57,336
59,828
                                                                Kaplan el al 1984 •• Rats
                                                                                    1
                                                                                    1
                                                                                    1
                                                                                    1
Monitored clinical symptoms during and post-
exposure and body weight and survival post-
exposure.
5
5
5
5
5
5
5
5
1 1
2
2
2
2
2
4
4
                                                               Kaplan et al 1984 -- Baboons
                                                                                    1
Monitored clinical symptoms during and post-
exposure, and survival post-exposure.

26
197
420
740
1,085
1,632
2,960
4,665
10,919

179 (5)a
1,357 (38)
2,893 (82)
5,097 (145)
7,473 (212)
11,240(319)
20,387 (578)
32,130(911)
75,205 (2132)

10
10
10
10
10
10
10
10
10

1
2
2
2
2
3
4
4
4
Lucia et al. 1977 -- Mice
4 ' 4
4
4
4
4
4
4
4







4 4
                                                                                                   Historically evaluated anatomical injury to the
                                                                                                   upper respiratory tract.  Authors ranked effects
                                                                                                   using a semi-quantitative scale.

-------
                                                               Table B-l (continued)
                                                  Acute Toxicity Data Derived from Animal Bioassays


-------
              Table B-l (continued)
Aculc Toxicity Data Derived from Animal Bioassays
Hydrogen
exposure
•"^Animal

2,720
3,872
4,911
5,912
6,683

834
1,478
2,081
2,853
3,714
chloride
level
m&/m3Human

13,298
18,959
24,(X)9
28,903
32,672

5,744
10,180
14,333
19,650
25,580
Time in
minutes

60
60
60
60
60

60
60
60
60
60
Severity
index

4
4
4
4
4

4
4
4
4
4
Number of
laboratory
animals
Wohlslagel el aL
10
10
10
10
10
Wohlslagel el aL
10
10
10
10
10
Indicator
1976 - Rats
0
2
6
8
10
1976 - Mice
2
3
6
8
10
Comments

Determined post-exposure lethality. Observed
toxicity symptoms and gross histopathology were
not discussed per specific exposure
concentration.


Determined post-exposure lethality. Observed
toxicity symptoms and gross histopathology were
not discussed per specific exposure
concentration.

Burleigh-Flayer el aL 1985 - Guinea pigs
480
1,020
1,560
2,070

1(K)
1,000
5,5(X)
6,500
1,163
2,471
3,780
5,016

154
1,540
8,471
10,011
30
30
30
30

1,800
360
5
30
2
3
4
4

3
4
3
4
4
4
8
8
Machle et aL 1942
3
3
3
3
-1
-1
2
3
-- Guinea pigs
0
3
3
3
Measured effects of hydrogen chloride on pulmo
nary function. Examined pulmonary histo-
pathology for only one exposure concentration.
Corneal damage and mortality also reported.

Data on lethality were the only useable
information for dose-response effects.


Machle el aL 1942 - Rabbits
100
1,000
5,500
6,500
128
1,278
7,026
8,304
1,800
360
5
30
3
4
3
4
3
3
3
3
0
3
3
3
Data on lethality were the only useable
information for dose-response effect:;.



-------
03
                                                                  Table B-l (continued)
                                                    Acute Toxicity Data Derived from Animal Bioassays
Hydrogen chloride
exposure level Time in
nig/in Animal nig/iTi i-iijiTian iiiinuies

190
730
1,060
1,600
4,570
10,700
12,000
20,000
29,000

60
149
368
660
1,415

1,309 (37)a
5,028 (143)
7,301 (207)
11,020(312)
31,476 (893)
73,697 (2090)
82,651 (2344)
137,751 (3905)
199,739 (5664)

413
1,026
2,535
4,546
9,746

10
10
10
10
10
10
10
10
10

10
10
10
10
10
Severity
index

2
3
3
4
4
4
4
4
4

1
2
2
2
4
Number of
laboratory
animals
Barrow et aL
4
4
4
4
4
4
4
4
4
Barrow el aL
4
4
4
4
4
Indicator
1979 -- Mice
4
-1
-1
-I
-1
-1
2
2
4
1977 -- Mice
4
-1
-1
-1
-1
Comments

Examined histopathological lesions in the upper
respiratory tract and mortality.








Evaluated sensory irritation as measured by
decreases in respiratory rate. Reported one
incidence of mortality.


          All dose conversions based on total lung surface area except for values in parentheses which are based on extrathoracic surface area.

-------
                   APPENDIX C

DERIVATION OF MAXIMUM LIKELIHOOD ESTIMATE BOUNDS
          AND LOWER CONFIDENCE LIMITS

-------
   Log linear bands in d and T for



                                 P(s>i|d,T) = a



may be found by taking the natural logarithm of the above expression and solving for a

linear equation in logarithm to the base ten for dose and time. For the Weibull model

the linear equation is
                   Io8l0
                         -ln(l-a)
      = Wlog10(d-d0)  + Klog10T
and for the log-logistic model the linear equation is
                    In
                       l-o
- qj  . W Iog10(d-d0) + K log10T.
   For fixed a and using the MLE for qj, W and K bands or lines in log time and dose

may be graphed.

   A benchmark band or a lower bound on the P(s>i | d,T) =  a line is not as easy to

find.   However, a good approximation is to find individual points on the line and connect

them with straight line segments.  Since the time considered was 24 hours, twelve equally

spaced intervals in  Iog10 (time) were used.  For each fixed time (T:) where:


   j    =    1 to 12, and
   T;  =    equal divisions of time in terms of Iog10 time


the following problem was solved:
                                       C-l

-------
    Minimize d,




    subject to:      P (s > i j d,T:) = o




      and         LL(0) - LL(0) =  1/2 X2lj2p






Here 9 represents the vector of MLEs and 6 represents the vector of estimates which




satisfy the constraints with LL(*) representing the loglikelihood.  For this paper, p = 0.05




or 95% confidence intervals are presented.
                                        C-2

-------
r  *
                           APPENDIX D
        COMPUTER OUTPUT FOR DOSE-DURATION-RESPONSE MODEL

-------
                        Table D-l
     Maximum Likelihood Estimates and 95% Lower Bounds
on Hydrogen Chloride Concentrations for Various Exposure Times
     and Severity Levels. Human Equivalent Concentrations
        Based on Total Lung Surface Area as the Target.
Human Equivalent Concentration fms/m ^
Index Time CHours^
P(s>i)=0.01 1 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
P(s>i)=0.01 2 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
P(s>i)=0.01 3 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
MLE
95.439
56.691
33.675
20.003
11.883
7.0582
4.1927
2.4905
1.4794
.88883
.52111
.31008
3718.1
2208.5
1311.9
779.29
462.92
274.97
163.34
97.024
57.635
34.627
20.301
12.080
14225.
8449.3
5019.0
2981.4
1771.0
1052.0
624.89
371.19
220.50
132.47
77.667
46.215
95% LB
27.789
16.630
9.9205
5.8999
3.4983
2.0681
1.2192
.71688
.42048
.24895
.14344
8.37019E-02
966.32
577.60
346.33
208.36
125.78
76.139
46.166
27.988
16.918
10.297
6.0848
3.6268
5306.1
3194.2
1914.7
1143.0
679.62
402.57
237.65
139.85
82.061
48.574
27.963
16.305
                           D-l

-------
Table D-1 (continued)
Human Equivalent Concentration fme/m3>)
Index Time (Hours)
P(s>i)=0.05 1 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
P(s>i)=0.05 2 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
P(s>i)=0.05 3 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
MLE
266.45
158.27
94.016
55.847
33.174
19.706.
11.705
6.9531
4.1304
2.4815
1.4549
.86570
10380.
6165.9
3662.6
2175.6
1292.4
767.68
456.01
270.88
160.91
96.673
56.678
33.725
39713.
23589.
14012.
8323.5
4944.4
2937.0
1744.6
1036.3
615.60
369.85
216.84
129.03
95% LB
98.822
59.223
35.367
21.042
12.482
7.3775
4.3463
2.5529
1.4954
.88388
.50828
.29603
3674.6
2139.2
1262.3
761.34
469.34
293.61
183.62
113.27
68.698
41.543
24.250
14.253
20319.
12307.
7409.5
4432.5
2635.5
1558.2
916.75
536.96
313.23
184.20
105.24
60.894
        D-2

-------
                         Table D-2
    Maximum Likelihood Estimates and 95% Lower Bounds
on Hydrogen Chloride Concentrations for Various Exposure Times
and Severity Levels.  Human Equivalent Concentrations Based on
       Total Lung and Extrathoracic Areas as the Target.
Human Equivalent Concentration
Index Time (Hours')
P(s>i)=0.01 1 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
P(s>i)=0.01 2 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
P(s>i) = 0.01 3 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
MLE
.69755
.41507
.24698
.14697
8.74551E-02
5.20386E-02
3.09654E-02
1.84259E-02
1.09646E-02
6.59866E-03
3.87560E-03
2.31013E-03
72.281
43.010
25.593
15.229
9.0622
5.3923
3.2087
1.9093
1.1362
.68376
.40159
.23938
526.38
313.21
186.38
110.90
65.994
39.269
23.367
13.904
8.2739
4.9794
2.9245
1.7432
Cmg/m3>)
95% LB
.12260
7.29395E-02
4.31714E-02
2.54210E-02
1.48935E-02
8.68202E-03
5.03716E-03
2.90902E-03
1.67275E-03
9.69608E-04
5.45357E-04
3.10538E-04
19.544
11.745
7.0064
4.1492
2.4394
1.4240
.82564
.47572
.27249
.15718
8.78675E-02
4.96971E-02
168.10
101.11
60.314
35.680
20.936
12.183
7.0377
4.0373
2.3018
1.3213
.73477
.41358
                           D-3

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Table D-2 (continued)
Human Equivalent Concentration (me/m3)
Index Time (Hours)
P(s>i)=0.05 1 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
P(s>i)=0.05 2 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
P(s>i)=0.05 3 4.26775E-02
7.58947E-02
.13496
.24000
.42677
.75895
1.3496
2.4000
4.2677
7.4947
13.522
24.000
MLE
6.1183
3.6406
2.1663
1.2891
.76707
.45643
.27160
.16161
9.61709E-02
5.78771E-02
3.39993E-02
2.02623E-02
633.98
377.24
224.47
133.57
79.485
47.296
28,143
16.747
9.9653
5.9973
3.5224
2.0096
4616.9
2747.2
1634.7
972.73
578.84
344.43
204.95
121.96
72.571
43.674
25.651
15.290
95% LB
1.4091
.84117
.49920
.29446
.17268
.10069
5.83847E-02
3.36785E-02
1.933 16E-02
1.11804E-02
6.27099E-03
3.56038E-03
236.80
143.54
86.198
51.258
30.183
17.604
10.177
5.8356
3.3228
1.9035
1.0558
.59257
2138.5
1303.6
783.65
465.62
273.16
158.33
90.791
51.585
29.085
16.510
9.0660
5.0427
        D-4

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                        Table D-3
    Maximum Likelihood Estimates and 95% Lower Bounds
on Hydrogen Chloride Concentrations for Various Exposure Times
         and Severity Levels.  Based on Concentrations
                Used in Animal Experiments
Index Time (Hours)
P(s>i)=0.01 1 .426775E-01
.758947E-01
.134962
.240000
.426775
.758947
1.34962
2.40000
4.26775
7.49466
13.5219
24.0000
P(s>i)=0.01 2 .426775E-01
.758947E-01
.134962
.240000
.426775
.758947
1.34962
2.40000
4.26775
7.49466
13.5219
24.0000
P(s>i)=0.01 3 .426775E-01
.758947E-01
.134962
.240000
.426775
.758947
1.34962
2.40000
4.26775
7.49466
13.5219
24.0000

MLE
19.448
12.066
7.4862
4.6447
2.8819
1.7880
1.1093
.68827
.42704
.26772
.16412
.10199
695.43
431.46
267.69
166.09
103.05
63.935
39.668
24.611
15.270
9.5733
5.8688
3.6470
1949.7
1209.7
750.52
465.65
288.91
179.25
111.21
69.001
42.812
26.840
16.454
10.225
mg/m
95% LB
8.6214
5.3566
3.3182
2.0493
1.2618
.77466
.47425
.28955
.17634
.10830
6.4825 1E-02
3.92769E-02
388.18
242.98
151.41
93.911
57.979
35.630
21.801
13.286
8.0678
4.9367
2.9417
1.7738
1226.4
768.65
479.15
296.99
183,04
112.18
68.403
41.521
25.104
15.295
9.0727
5.4472
                          D-5

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Table D-3 (continued)
Index Time (Hours')
P(s>i)=0.05 1 .426775E-01
.758947E-01
.134962
.240000
.426775
.758947
1.34962
2.40000
4.26775
7.49466
13.5219
24.0000
P(s>i)=0.05 2 .426775E-01
.758947E-01
.134962
.240000
.426775
.758947
1.34962
2.40000
4.26775
7.49466
13.5219
24.0000
P(s>i)=0.05 3 .426775E-01
.758947E-01
.134962
.240000
.426775
.758947
1.34962
2.40000
4.26775
7.49466
13.5219
24.0000

MLE
57.171
35.470
22.007
13.654
8.4718
5.2561
3.2611
2.0233
1.2554
.78702
.48247
.29982
2044.3
1268.4
786.94
488.25
302.94
187.95
116.61
72.350
44.890
28.143
17.252
10.721
5731.6
3556.0
2206.3
1368.9
849.32
526.94
326.93
202.84
125.85
78.901
48.369
30.058
mg/m
95% LB
27.370
17.028
10.560
6.5276
4.0218
2.4699
1.5122
.92315
.56200
.34499
.20636
.12494
1271.5
799.19
499.64
310.59
191.96
117.95
72.092
43.850
26.559
16.205
9.6259
5.7859
4137.5
2612.7
1637.8
1018.2
627.57
383.63
232.87
140.54
84.443
51.129
30.140
17.993
        D-6

-------