&EPA
              United States
              Environmental Protection
              Agency
              Office of Research and
              Development
              Washington DC 20460
Draft
Revisions to the
Guidelines for
Carcinogen Risk
Assessment
 EPA/600/BP-92/003
 August 1994
 External Review Draft
Review
Draft
(Do Not
Cite or
Quote)
                              Notice
               This document is a preliminary draft. It has not been formally
              released by EPA and should not at this stage be construed to
              represent Agency policy. It is being circulated for comment on its
              technical accuracy and policy implications.

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  EPA/600/BP-92/003
       August 1994
External Review Draft
                 DRAFT REVISIONS TO THE
 GUIDELINES FOR C ARCINOGEN RISK ASSESSMENT
                                NOTICE

THIS DOCUMENT IS A PRELIMINARY DRAFT. It has not been formally released by
the U.S. Environmental Protection Agency and should not at this stage be construed to
represent Agency policy. It is being circulated for comment on its technical accuracy and
policy implications.
                  Office of Health and Environmental Assessment
                      Office of Research and Development
                     U.S. Environmental Protection Agency
                             Washington, D.C.
                                                      Printed on Recycled Paper

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                                  DISCLAIMER

      This document is an external draft for review purposes only and does not constitute
Agency policy. Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
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       Workshop on Revising the Guidelines for Carcinogen
                         Risk Assessment  • •
AGENCY:  U.S. Environmental Protection Agency.
ACTION:  Notice of Meeting.
SUMMARY: 'This notice announces a workshop sponsored by the U.S.
Environmental Protection Agency's  (EPA's) Office of Health and
Environmental Assessment  (OHEA) and Risk Assessment Forum.  OHEA
and the Risk Assessment Forum will convene a panel of experts to
review a draft document entitled, Draft Revisions to the
Guidelines for Carcinogen Risk Assessment (External Review Draft,
August 1994).  Discussion will focus on the proposed revisions to,
the Agency's cancer risk assessment guidelines.
DATES:  The workshop will be held Monday, September 12, 1994,
through Wednesday, September 14, 1994.  The meeting will begin at
S-:30_a,,m._ ^and end at ,5:00 ,p,m. on Monday,, and Tuesday, and wi3-3-
begin at 9:00 a.m. and end at noon on Wednesday.  Members of the
public may attend as observers.
ADDRESSES:  The meeting will be held at the Hyatt Regency Hotel,
1800 Presidential Street, Reston, Virginia 22090, Tel: 703/709-
1234.
     Eastern Research Group, Inc., an EPA contractor, is
providing logistical support for the workshop.  To attend the
workshop as an observer, contact Eastern Research Group, Inc.,
110 Hartwell Avenue, Lexington, Massachusetts 02173, Tel:
617/674-7374 by August 31, 1994.  Space is limited,  so please
register early.
FOR FURTHER INFORMATION CONTACT:  For technical inquiries,
contact Dr. Harry.Teitelbaum, U.S. Environmental Protection

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                     Cancer Guidelines  Workshop  —  Page  2  of  3
 Agency (8101),  401 M Street,  S.W.,   Washington, DC 20460,  Tel:
 202/260-6743.
 SUPPLEMENTARY INFORMATIONS  In 1986, EPA published Guidelines  for
 Carcinogen Risk Assessment (51 FR 33992; September 24,  1986).
 Scientific advances in both risk  assessment and carcinogenesis
 have led EPA and the broader scientific community  to new
 perspectives on cancer risk assessment and related new
 perspectives on EPA's Cancer Risk Assessment Guidelines.
      As  part of its efforts to update and revise the 1986
 Guidelines,  the Agency will hold  a workshop in  Reston, Virginia,
 on September 12-14,  1994,  to  discuss the major  changes
 contemplated for these guidelines.  At this meeting,  experts on
 cancer risk assessment and its associated sciences will comment
 on and discuss  a working draft for revising the 1986 cancer risk
 assessment  guidelines.  The workshop aims to produce
 recommendations to  the Agency on  the use of default assumptions
 and wider application of mechanistic data in cancer risk
 assessment,  among other things.
      To obtain  a single copy  of the draft document (paper or Word
 Perfect 5.1  disk),  interested parties should contact the ORD
publications office by telephone  or FAX,  CERI,  U.S. Environmental
 Protection Agency, 26  West Martin Luther King Drive,  Cincinnati,
OH 45268, Tel:  (513)  569-7562, FAX (513). 569-7566.   Please
provide your name and mailing  address,  the document title:  Draft
Revisions to the Guidelines for Carcinogen Risk Assessment

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                    Cancer Guidelines Workshop — Page 3 of 3

(External Review Draft, August 1994), and EPA document number

EPA/600/BP-92/003  (for paper) or EPA/600/BP-92/003a (for disk)
Date
   T
Acting Assistant Administrator
  for Research and Development

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                                 CONTENTS
Authors, Contributors, and Reviewers	vii

1. INTRODUCTION	  1

   1.1.  PURPOSE AND SCOPE OF THE GUIDELINES  	  1
   1.2.  ORGANIZATION AND .APPLICATION OF THE GUIDELINES  ........  1
        1.2.1.  Organization	  i
        1.2.2.  Application	  2
   1.3.  OVERVIEW OF CANCER PROCESSES	  3
   1.4.  USE OF DEFAULT ASSUMPTIONS	  8

2. HAZARD ASSESSMENT  	  9

   2.1.  OVERVIEW OF HAZARD ASSESSMENT AND CHARACTERIZATION      9
   2.2.  ANALYSIS OF TUMOR DATA	   11
        2.2.1.  Human Data	   11
              2.2.1.1. Types of Studies	   11
              2.2.1.2. Study Design and Conduct	   12
              2.2.1.3. Analysis of Causality	   15
              2.2.1.4. Conclusions  	   16
        2.2.2.  Animal Data	   17
              2.2.2.1. Long-Term Studies	   17
              2.2.2.2. Special Studies	   21
              2.2.2.3. Significance for Human Hazard	   21
   2.3. .ANALYSIS OF OTHER KEY EVIDENCE  	,	   23
        2.3.1.  Physicochemical Properties	   23
        2.3.2.  Structure-Activity Relationships (SAR)	   24
        2.3.3.  Metabolism and Pharmacokinetics	   25
        2.3.4.  Short-Term Studies	,	   26
              2.3.4.1. Genotoxicity Information 	   27
              2.3.4.2. Other Short-Term Test Information	   28
              2.3.4.3. Biomarker Information	   30
              2.3.4.4. Confidence in Conclusions  	        30
   2.4. MODE OF ACTION-IMPLICATIONS FOR HAZARD
       CHARACTERIZATION AND DOSE-RESPONSE	      31
   2.5. HAZARD CHARACTERIZATION  	   33
       2.5.1.  Carcinogenic Potential for Humans	   33
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                                       CONTENTS (continued)


                   2.5.2. Conditions of Expression	   34
                   2.5.3. Descriptions of Weight of Evidence	   35
                   2.5.4. Hazard Narrative	   37

            3.  DOSE-RESPONSE ASSESSMENT	   38

               3.1. RESPONSE DATA	   39
               3.2. DOSE DATA	   41
                   3.2.1. Basic Analyses	   42
                   3.2.2. Pharmacokinetic Analyses	   43
                   3.2.3. Additional Considerations for Dose in Human Studies  	   44
               3.3. SELECTION OF QUANTITATIVE APPROACH  	   45
                   3.3.1. Analysis in the Range of Observation	   45
                   3.3.2. Extrapolation  	   46
                   3.3.3. Issues for Analysis of Human Studies  	   48
                   3.3.4. Use of Toxicity Equivalence Factors and Relative Potency Estimates  .   49
               3.4. DOSE-RESPONSE CHARACTERIZATION	   50

            4.  EXPOSURE ASSESSMENT AND CHARACTERIZATION  	   52

            5.  RISK CHARACTERIZATION	   53

               5.1. PURPOSE	   53
               5.2. APPLICATION	   54
               5.3. CONTENT  	   54
                   5.3.1. Presentation	   54
                   5.3.2. Strengths and Weaknesses	   55

            REFERENCES  	   56

            APPENDIX A	•	68
                                                 IV
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                AUTHORS, CONTRIBUTORS, AND REVIEWERS


      This external review draft was prepared by a Technical Panel of the Risk Assessment

Forum, Office of Research and Development (ORD).
AUTHORS

Jeanette Wiltse
Richard Hill
Vanessa Vu
Arnold Kuzmack
ORD/Office of Health and Environmental Assessment
Office of Prevention, Pesticides, and Toxic Substances
Office of Prevention, Pesticides, and Toxic Substances
Office of Water
CONTRIBUTORS AND REVIEWERS

To be provided in the next draft.
                                                                       07/25/94

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                                 1.  INTRODUCTION

1.1. PURPOSE AND SCOPE OF THE GUIDELINES
       These guidelines revise and replace United States Environmental Protection Agency
(EPA) Guidelines for Carcinogen Risk Assessment published in 51 FR 33992, September 24,
1986.  The guidelines provide EPA staff and decision makers with guidance and perspectives
necessary to develop and use risk assessments.  They also provide basic information to the
public about the Agency's risk assessment methods.
       The guidelines encourage both consistency of procedures to support consistency in
scientific components of Agency decision making and innovation to remain up-to-date in
scientific thinking.  In balancing these goals, the Agency relies on input from the general
scientific community through established scientific peer review processes.  The guidelines
incorporate basic principles and science policies based on evaluation of the currently
available information.  As more is discovered about carcinogenesis, the need will arise to
make appropriate changes hi risk assessment guidance.  The Agency will revise these
guidelines when extensive changes are due.  In the interim, the Agency will issue special
reports, after appropriate peer review, to supplement and update guidance on single topics,
(e.g., U.S. EPA, 1991b)

1.2. ORGANIZATION AND APPLICATION OF THE GUIDELINES
1.2.1.  Organization
       Publications  of the Office of Science and Technology Policy (OSTP, 1985) and the
National Research Council (NRC, 1983 and 1994) provide information and general principles
about risk assessment.  Risk assessment utilizes available scientific information bearing on
the properties of an agent and its effects hi biological systems to provide an evaluation of the
potential for harm as a consequence of environmental exposure to the agent.  Risk
assessment is one of the scientific analyses available for consideration, with other analyses,
in decision making on environmental protection.  The 1983 and 1994 NRC documents
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 organize risk assessment information into four areas:  hazard identification, dose-response
 assessment, exposure assessment, and risk characterization.  This structure appears in these
 guidelines which additionally emphasize characterization of evidence and conclusions in each
 part of the assessment.  The risk assessment questions addressed in these guidelines are:
 •     For hazard-Can the agent1 present a carcinogenic hazard to humans, and, if so,
       under what circumstances?
 •     For dose-response—At what levels of exposure might effects occur?
 •     For exposure-What are the conditions of human exposure?
 •     For risk—What is the character of the risk?  How well do data support conclusions
       about the nature and extent of the risk?

 1.2.2. Application
       The guidelines apply within the framework of policies provided by applicable EPA
 statutes and do not alter such policies. The guidelines cover assessment of available data.
 They do not imply that one land of data  or another is prerequisite for regulatory action
 concerning any agent. Risk management applies directives of regulatory legislation,  which
 may require consideration of potential risk, or solely hazard or exposure potential, along  with
 social, economic, technical, and other factors in decision making.  Risk assessments support
 decisions, but, to maintain their integrity as decision-making tools, are not influenced by
 consideration of the social or economic consequences  of regulatory action.
       Not every EPA assessment has the same scope or depth.  Agency staff often conduct
 screening-level assessments  for priority setting or separate assessments of hazard or exposure
 for ranking purposes or to decide whether to invest resources in collecting data for a full
 assessment.  Moreover, a given assessment of hazard  and dose-response may be used with
more than one exposure assessment that may be conducted separately and at different times
as the need arises hi studying environmental problems hi various media. The guidelines
    1The term "agent" refers generally to any chemical substance, mixture, or physical or
biological entity being assessed, unless otherwise noted.
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 apply to these various situations, in appropriate detail given the scope and depth of the
 particular assessment.
       When adopted by the Agency, the guidelines will apply prospectively to new
 assessments and to revisions of previous assessments prompted by new data that may alter
 previous conclusions.

 1.3. OVERVIEW OF CANCER PROCESSES
       The following discussion provides background for considering different ways in which
 agents may be factors in carcinogenicity. The picture will change as research reveals more
 about carcinogenic processes.   Nevertheless, it is apparent  that several general modes of
 action are being elucidated from direct reaction with DNA  to hormonal or other growth
 signaling processes.  While the exact mechanism of action  of an agent at the molecular level
 may not be clear from existing data, the available data will often provide support for
 deducing the general mode of action. Under these guidelines, using all of the data to arrive
 at a view of the mode of action supports both characterization of human hazard  potential and
 assessment of dose-response relationships.
       Cancers are diseases of somatic mutation affecting growth and differentiation of cells.
 The genes that control cell growth, programmed cell death  and cell differentiation are critical
 to normal development  of tissues from embryo to adult metazoan organisms. These genes
 continue to be critical to maintenance of form and function of tissues in the adult (e.g.,
 Meyn,  1993), and changes in them are essential elements of carcinogenesis (Hsu et al., 1991;
 Kakizuka et al.,  1991; Bottaro et al., 1991; Kaplan et al., 1991; Sidransky et al.,  1991;
Salomon et al.,  1990; Srivastava et al.,  1990).  The genes involved are among the most
highly conserved in evolution as evidenced by the great homology of many of them in DNA
sequence and function in organisms as phylogenetically distant as worms, insects, and
mammals  (Auger et al., 1989a, b; Kaplan,  et al. 1991;  Hollstein et al., 1991; Herschman,
 1991; Strausfeld et al.,  1991; Forsburg and  Nurse,  1991).
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 1               Adult tissues, even those composed of rapidly replicating cells, maintain a constant
 2         size and cell number (Nunez et al., 1991) by balancing three cell fates:  (1) continued
 3         replication; (2) differentiation to take on specialized functions; or (3) programmed cell death
 4         (apoptosis) (Raff, 1992; Mailer, 1991; Naeve et al., 1991; Schneider et al., 1991; Harris,
 5         1990).  Neoplastic growth through clonal expansion can result from somatic mutations that
 6         inactivate control over cell fate (Kakizuka et al.,  1991; deThe et al., 1991; Sidransky et al.,
 7         1992; Nowell,  1976).                                                   ^
 8               Cancers may also be thought of as  diseases of the cell cycle. For example, genetic
 9         diseases that cause failure of cells to  repair DNA damage prior to cell replication predispose
 10        people to cancer. These changes are also frequently found in tumor cells in sporadic
 11        cancers.  These changes appear to be particularly involved at points in cell replication called
 12        "checkpoints" where DNA synthesis or mitosis is normally stopped until  DNA damage is
 13       repaired or cell death induced  (Tobey, 1975).  A cell that bypasses a checkpoint may acquire
 14       a heritable growth advantage.  Similar effects on the cell cycle occur when mitogens such as
 15       hormones or growth factors stimulate cell growth. Rapid replication in response to tissue
 16       injury may also lead to unrepaired DNA damage  that is a risk factor for carcinogenesis.
 17             Normally a cell's fate is determined by a timed sequence of biochemical signals.
 18       Signal transduction in the cell involves chemical signals that bind to receptors, generating
 19       further signals in a pathway whose target in many cases is control of transcription of a
20       specific set of genes (Hunter, 1991; Cantley et  al., 1991; Collum and Alt, 1990).  Cells are
21        subject to growth signals from the same and distant tissues, e.g.,  endocrine tissues (Schuller,
22       1991) .  In addition  to hormones produced by endocrine tissues, numerous soluble
23       polypeptide growth factors have been identified that control normal  growth and
24       differentiation (Cross and Dexter, 1991; Wellstein et al., 1990).  The cells responsive  to a
25       particular growth factor are those that express transmembrane receptors that specifically bind
26       the growth factor.
27             Solid tumors  develop in stages operationally defined as initiation, promotion, and
28        progression (see, for example,  Pilot and Dragan, 1991).  These terms, which were coined in
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1         the context of specific experimental designs, are used for convenience in discussing concepts,
2         but they refer to complex events that are not completely understood.  During initiation, the
3         cell acquires a genetic change that confers a potential growth advantage. During promotion,
4         clpnal expansion of this altered cell occurs. Later, during progression, a series of genetic
5         and other biological events both enhance the growth advantage of the cells and enlist normal
6         host processes to support tumor development, and cells develop the ability to invade locally
7         and metastasize distally, taking on the characteristics of malignancy.  Many endogenous and
8         exogenous factors  are known to participate in the process as a whole.  These include specific
9         genetic predispositions or variations in ability to detoxify agents, medical history (Harris,
10        1989;  Nebreda et al., 1991), infections,  chemicals, ionizing radiation, hormones and growth
11        factors, and immune suppression.  Several such risk factors likely work together to cause
12        individual human cancers.
13              A cell that  has been transformed, acquiring the potential to establish a line of cells
14        that grow to a tumor, will probably realize that potential only rarely.  The process of
15        tumorigenesis in animals and humans is a multistep one (Bouk,  1990; Fearon and Vogelstein,
16        1990;  Hunter, 1991; Kumar et al., 1990; Sukumar, 1989; Sukumar, 1990), and normal
17        physiological processes appear to be arrayed against uncontrolled growth of a transformed
18        cell (Weinberg, 1989).  Powerful inhibition by signals from  contact with neighboring normal
19        cells is one known barrier (Zhang et al., 1992).  Another is  the immune system  (at least for
20        viral infection).  How a cell with tumorigenic potential acquires additional  properties that are
21        necessary to enable it to overcome these and other inhibitory processes is a subject of
22        ongoing research.  For known human carcinogens studied thus far, there is an often decades-
23        long latency between exposure to carcinogenic agents and development of tumors (Fidler and
24        Radinsky, 1990; Tanaka et al., 1991; Thompson et al., 1989).   This latency is also typical of
25        development of tumors in individuals with genetic diseases that make them cancer prone
26        (Meyn, 1993; Srivastava et al., 1990).
27              The importance of genetic mutation in  the carcinogenic process calls for special
28        attention to assessing agents that cause such mutations.  Much of the screening and testing of
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1        agents for carcinogenic potential has been driven by the idea of identifying this mode of
2        action.  Cognizance of and emphasis on  other modes of action such as ones that act at the
3        level of growth signalling within or between cells, through cell receptors, or that indirectly
4        cause genetic change, comes from more  recent research.  There are not yet standardized tests
5        for many modes of action, but pertinent  information may be available in individual cases.
6               Agents of differing characteristics influence cancer development:  inorganic and
7        organic, naturally occurring and synthetic,  of inanimate or animate origin, endogenous or
8        exogenous, dietary and non-dietary. The means by which these agents act to influence
9        carcinogenesis are variable, and reasoned hazard assessment requires consideration of the
10       multiple ways chemicals influence cells in experimental systems and in humans.  Agents
11       exert genotoxic effects either by interacting directly with DNA or by indirect means through
12       intermediary substances (e.g., reactive oxygen species) or processes.  Most DNA interactive
13       chemicals are electrophilic or can become electrophilic when metabolically activated.
14       Electrophilic molecules may bind covalentiy to DNA to form adducts and this may lead to
15       depurination, depyrimidation or produce  DNA strand breaks;  such lesions can be converted
16       to mutations with a round of DNA synthesis and cell division. Other DNA-interactive
17       chemicals may cause the same result by intercalation into the DNA helix.  Still other
18       chemicals may methylate DNA, changing gene expression. Non-DNA-reactive chemicals
19       produce genotoxic effects by many different processes.  They may affect spindle formation
20       or chromosome proteins,  interfere with normal growth control mechanisms, or affect
21       enzymes involved with ensuring the fidelity of DNA synthesis (e.g., topoisomerase),
22       recombination, or repair.
23              The "classical" chemical carcinogens in laboratory rodent studies are agents that
24       consistently produce gene mutations and  structural chromosome aberrations in short-term
25       tests. A large data base reveals that these mutagenic substances commonly produce tumors
26       at multiple sites and in multiple species (Ashby and Tennant,  1991).  Most of the carcinogens
27       identified in human studies, aside from hormones, are also gene or structural chromosome
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 1         mutagens (Tennant and Ashby,  1991).  Most of these compounds or their metabolites contain
 2         electrophilic moieties that react  with DMA.
 3               Numerical chromosome aberrations, gene amplification and the loss of gene
 4         heterozygosity are also found in animal and human tumor cells that may arise from initiating
 5         events or during progression. There is reason to believe that accumulation of additional
 6         genetic changes is  favored by selection in the evolution of tumor cells because they confer
 7         additional growth advantages. Exogenous agents may function at any stage of carcinogenesis
 8         (Barrett, 1993).  Some aberrations may arise as a consequence of genomic instability arising
 9         from tumor suppressor gene mutation, e.g., p53 (Harris and Hollstein, 1993). The frequent
 10       observation in tumor cells that both of a pair of homologous chromosomes have identical
 11       mutation spectra in tumor suppressor genes suggests an ongoing, endogenous process of gene
 12       conversion. Currently, there is  a paucity of routine test methods to screen for events such as
 13       gene conversion  or gene amplification, and knowledge regarding the ability of particular
 14       agents of environmental interest to induce them is, for the most part, wanting. Work is
 15       underway to characterize, measure, and evaluate their significance (Bianchi et al., 1991;
 16       Cowell et al.,  1991; see Schwab, 1992; Travis et al., 1991).
 17             Several kinds of mechanistic studies aid in risk assessment. Comparison of DNA
 18       lesions in tumor  cells taken from humans to the lesions  that a  tumorigenic agent causes in
 19       experimental systems, can permit inferences about the association of exposure to the agent
20       and  an observed human effect (Vahakangas et al., 1992; Hollstein et al.,  1991; Hayward et
21        al., 1991). An agent that is observed to cause mutations experimentally may be inferred to
22       have potential for carcinogenic activity (U.S. EPA, 1991a).  If such an agent is shown to be
23        carcinogenic in animals, the inference that its  mode of action is through mutagenicity is
24       strong.  A carcinogenic agent that is not mutagenic in experimental systems, but is mitogenic
25        or affects hormonal levels or causes toxic injury followed by compensatory growth may be
26        inferred to have effects  on growth signal transduction or to have secondary carcinogenic
27       effects.  The strength of these inferences depends in each case  on the nature and extent of all
28       the available data.
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 1               Differing modes of action at the molecular level have different dose-response
2        implications for the activity of agents.  The carcinogenic activity of a direct-acting mutagen
3        should be a function of the probability of its reaching and reacting with DNA. The activity
4        of an agent that interferes at the level of signal pathways with many potential receptor targets
5        should be a function of multiple reactions.  The activity of an agent that acts by causing
6        toxicity followed by compensatory growth should be a function of the toxicity.
7
8        1.4.  USE OF DEFAULT ASSUMPTIONS
9               The National Research Council (NRC), in its 1983 report on the science of risk
10       assessment (NRC,  1983), recognized that default assumptions are necessarily made in risk
11       assessments when gaps in general knowledge or in data available for a particular agent are
12       encountered.  These default assumptions are inferences based on general scientific knowledge
13       of the phenomena in question and are also matters of policy. In its 1994 report on risk
14       assessment, the NRC supported continued use of default assumptions (NRC, 1994).  The
15       1994 report recommended that the EPA explain the  science and policy underlying  the
16       defaults and provide general criteria for departing from them.  (Descriptions of major
17       defaults and their rationales appear in the responses  to comments accompanying this
18       document.  NOTE:  the responses will appear with the Federal Register proposal of revisions
19       and do not accompany this review draft.)
20              Under these guidelines, it is the policy of the EPA to continue to use default
21       assumptions.  Instead of considering them to be positions from which departure is  justified, it
22       is the policy of these guidelines that default assumptions are indeed default positions, and that
23       they are not used unless supported by the circumstances of a particular case. In each case in
24       which the risk assessor decides that it is appropriate  to use a default, the use is explained and
25       the lack or inadequacy of data justifying resort to a default is described.
26              Throughout these guidelines, major defaults are noted in the context of risk
27       assessment subjects. Most major defaults covered in the guidelines arise as a consequence of
28       either using animal toxicity data as a model for human toxicity or in the extrapolation of
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 observed dose-response relationships to lower dose levels associated with environmental -
 exposures of interest.  Other default assumptions may be applied in practice that are not
 within the scope of coverage of the guidelines.   When these are applied, they are similarly
 explained.  An example of such a default is use of an exposure factor such as food or water
 consumption, typical of an adult in the United States. Such factors are often taken from
 published compendia that contain numerous exposure factors based on general population
 data. These factors are used to apply to specific populations.

                              2.  HAZARD ASSESSMENT

 2.1.  OVERVIEW OF HAZARD ASSESSMENT AND CHARACTERIZATION
                                   Hazard Assessment
       The purpose of hazard assessment is to  review and evaluate data pertinent to two
 questions:  (1) whether an agent may pose a carcinogenic hazard to human beings, and (2)
 under what circumstances an identified hazard may be expressed.  The ingredients of hazard
 assessment are reviews of a variety of kinds of data that may range from observations of
 tumors to analysis of structure-activity relationships.  The purpose of the assessment is not
 simply to assemble these separate reviews; its purpose is to construct  a total case analysis
 examining the biological story the data reveal as a whole about carcinogenic effects, mode of
 action of the agent, and implications of these for human hazard and dose-response evaluation.
 For example, interpretation of studies on human effects considers structure-activity
 relationships and experimental data on animal effects.  Similarly, interpretation of animal
 tumors considers other relevant data such as effects at the cellular level, comparative
 metabolism, and non-cancer toxicity. The reliability of conclusions comes from the
 combined strength and coherence of inferences appropriately drawn from all of the available
 evidence.
      If studies reveal that an agent affects carcinogenic processes under one set of
circumstances, the next question is whether one  can infer that the effects will occur under
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 1         other or all circumstances. For instance, are effects seen in one species likely to occur in
 2         another species? Are effects that occur by one route and level of exposure likely to occur by
 3         another route and level? It would take an extraordinary amount of work to empirically
 4         address every question involved in these extrapolations. Realistically, hazard assessments
 5         must address these issues with the data that are practicably obtainable, combined with
 6         inferences drawn from a basic understanding of biological and chemical processes relevant to
 7         carcinogenesis and to exposure.  Extrapolation of responses from  one species to another and
 8         from high to low dose can be much stronger if there is  information on the mode of action of
 9         the agent. Such information can enable greater concentration on particular lines  of evidence.
 10       To the extent data permit, hazard assessment addresses the mode of action question both as a
 11       part of identifying human hazard potential and as an initial step in considering appropriate
 12       approaches to dose-response assessment.
 13
 14                                       Hazard Characterization
 15             The hazard characterization develops conclusions on the questions of human hazard
 16       potential and circumstances of its expression.  Developing conclusions involves integrating
 17       the salient outcomes of analyses of all of the data.  This, in turn,  involves considering the
 18       inferences drawn from data, their strengths and weaknesses in light of the uncertainties of the
 19       available data and the state of current scientific knowledge.  Presentation of the results of
20       hazard characterization includes:
21        •     summarizing the evaluations of hazard  data,
22       •     expressing the reasoning from the data  to conclusions, and
23        •     explaining significant strengths or limitations of the  conclusions given the limits of
24             available data and knowledge.
25              The discussions that follow cover analysis of tumor data, both animal and human, and
26        analysis of other key evidence about properties and effects that relate to carcinogenic
27        potential.   The'discussion covers aspects of evidence pertinent to mode of action and how
28        mode of action can influence thinking about the dose-response relationship.  The  last part of
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 Section 2 describes hazard characterization.  It discusses the characterization, how the
 likelihood of carcinogenic hazard is categorized,  and the use of a hazard narrative as a
 summary.

 2.2.  ANALYSIS OF TUMOR DATA
       Evidence of carcinogenicity comes from finding tumor increases in humans or in
 laboratory animals exposed to a given agent or from finding tumors following exposure to
 structural analogues to the compound under review. The significance of the observed or
 anticipated tumor effects is evaluated in reference to all of the other key evidence on the
 agent. This  section contains guidance for analyzing human and animal studies to decide
 whether there is an association between exposure to an agent or a structural analogue and
 occurrence of tumors.  (The use of the term "tumor" here  is  generic, meaning malignant
 neoplasms or a combination of malignant and  corresponding benign neoplasms.)

 2.2.1. Human Data
 2.2.1.1.  Types of Studies
       Human data may come from  studies that select and compare exposed and unexposed
 (or less-exposed) populations or from investigations of cases in specific  settings,  e.g.,
 workplace or clinical.  Formal studies include cohort, case-control, proportionate ratio,
 clinical trial,  and correlational studies.   Each has  well known strengths and weaknesses that
 affect interpretation of results (Kelsey et al., 1986; Lilienfeld and Lilienfeld,  1979; Mausner
and Kramer,  1985; Rothman,  1986).  Reports  of cancer cases can identify associations
particularly when there are unique features such as association with an uncommon tumor
(e.g., vinyl chloride and angiosarcoma or diethylstilbestrol and clear cell carcinoma of the
vagina).
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1        2.2.1.2. Study Design and Conduct
2               In cancer epidemiologic studies, unlike laboratory experiments, the exposures of the
3        study and the control (referent) populations are not controlled. Because most studies are
4        retrospective, and cancer effects are latent for many years,  the exposure estimates are usually
5        a reconstruction of what exposures may have been many years in the past.  Moreover, the
6        fact that most human cancers have more than one potential  cause creates both design and
7        analytical problems of distinguishing among possible causes for an observed effect.  These
8        features mean that drawing causal inferences depends on an analysis of many factors.  The
9        following discussions cover factors included in an analysis of human data:
10
11                                           Population Issues
12              The ideal  comparison would be between two populations that differ only in exposure
13       to the agent in question. Since this is seldom the case, it is important to identify any sources
14       of bias  that are inherent in a study's design or data collection methods.  Bias can arise from
15       several  sources, including non-comparability between populations of factors  such as general
16       health (McMichael,  1976), diet, lifestyle or geographic location; differences in the way case
17       and control individuals recall past events; differences in data collection that result in unequal
18       ascertainment of health effects in the populations; and unequal follow-up of individuals.
19       Both  acceptance of studies for assessment and judgment of  their strength or weakness
20       depends on identifying sources of bias and their effects on results.
21
22                                            Exposure Issues
23               Questions to address about exposure are:  What can one reliably conclude about the
24       level, duration, route, and frequency of exposure of individuals in one population as
25       compared to another? How sensitive are study results to uncertainties in these parameters?
26               Surrogates are often used to reconstruct exposure parameters when historical
27       measurements are not available.  These may take the form  of attributing exposures to job
28       classifications in  a workplace or to  broader occupational or geographic groupings.  Use of
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 surrogates carries a potential for misclassification in that individuals may be counted in the
 incorrect exposure groups.  Misclassification generally leads to reduced ability of a study to
 detect differences between study and referent populations.
        When either current or historical monitoring data are available,  the exposure
 evaluation includes consideration of the error bounds of the monitoring and analytic methods
 and whether the data are from routine or accidental exposures.  The potentials for
 misclassification and measurement errors are amenable to both qualitative and quantitative
 analysis. These are essential analyses for judging a study's results since exposure estimation
 is the most critical, but weakest, part of a retrospective study.
        Biological markers of exposure or effect potentially offer excellent measures of
 exposure (Hulka and Margolin,  1992; Peto and Darby, 1994).  Validated markers of
 exposure such as alkylated hemoglobin from exposure to ethylene oxide (Callemen et al.,
 1986; van Sittert et al., 1985) or urinary arsenic (Enterline et al.,  1987),  can greatly improve
 estimates of dose.  Markers closely identified with effects promise to greatly increase the
 ability of studies to distinguish real effects from bias at low levels of relative risk between
 populations (Taylor et al., 1994; Biggs et al., 1993) and to resolve problems of confounding
 risk factors.
       In deciding whether there is an association between health effects and exposure to an
 agent, the evaluation gives studies with more precise and specific exposure estimates greater
 weight.

                                   Confounding  Factors
       A confounding variable is a risk factor, independent of the putative agent, that is
distributed unequally among the exposed  and unexposed populations.  Adjustment for
possible confounding factors can occur either in the  design of the study  (e.g., matching on
critical factors) or in the statistical analysis of the  results.  The latter may not be possible due
to the presentation of the data or because needed information was not collected during the
study.  In this case, indirect comparisons may be possible.  For example,  in the absence of
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1         data on smoking status among individuals in the study population, an examination of the
2         possible contribution of cigarette smoking to increased lung cancer risk may be based on
3         information from other sources such as the American Cancer Society's longitudinal studies
4         (Hammand, 1966; Garfmkel and Silverberg, 1991). The effectiveness of adjustments
5         contributes the ability to draw inferences from a study.
6                Different studies involving exposure to an agent may have different confounding
7         factors. If consistent increases in cancer risk are observed across a collection of studies with
8         randomly distributed confounding factors, the inference  that the agent under investigation
9         was the etiologic factor is strong, even though complete adjustment for confounding factors
10        cannot be made and no single study supports a strong inference.
11               Biological evidence on confounding factors, such as animal data, structure-activity
12        relationships, and metabolism data, is analyzed. The analysis compares such evidence on the
13        agent under study with evidence on identified confounders to test the plausibility of
14        associating observed  human effects either with the agent or with confounding factors.
15
16                                               Sensitivity
17               Sensitivity, or the ability of a study to detect real effects, is a function of several
18        factors. Greater size of the study population(s) (sample size) increases sensitivity as does
19        greater exposure (levels and duration) of the population members. Because of the often
20        lengthy latency period in  cancer development, sensitivity also depends on whether adequate
21        time has elapsed since exposure began for effects to occur.  A unique feature that can be
22        ascribed to effects of a particular agent (such as a tumor type that is seen only rarely in the
23        absence of the agent) can increase sensitivity by permitting separation of bias and
24        confounding factors from real effects. Similarly, a biomarker particular to the agent can
25        permit these distinctions.  These are all factors to explore in statistical analysis of the data.
26
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 2.2.1.3.  Analysis of Causality
                                 Statistical Considerations
        The analysis applies appropriate statistical methods to ascertain whether or not there is
 any significant association between exposure and effects.  A description of the method or
 methods includes the reasons for their selection. Statistical analyses of the potential effects
 of bias or confounding factors are part of addressing the significance of an association, or
 lack of one, and whether a study is able to detect any effect.
        The analysis augments examination of the results for the whole population with
 exploration of the results for groups with comparatively greater exposure or time since first
 exposure.  This may support identifying an association or establishing a dose-response trend.
 When studies show no association, such exploration may apply to determining an upper limit
 on potential human risk for consideration alongside results of animal tumor effects studies.
        Statistical methods for examining several studies in combination are commonly termed
 "meta-analysis."  Meta-analysis evaluates whether study results differ randomly from the
 hypothesis of no effect (Mann, 1990). If an effect is not present, the observed results ought
 to appear to be randomly distributed and cancel each other when studies are combined.
 Meta-analysis is an appropriate tool to use if several studies are available.  Before applying
 meta-analysis, several issues are addressed to decide if the analysis will be meaningful.
 These include: controlling for bias and confounding prior to combining studies; establishing
 and  meeting appropriate criteria for study inclusion; assigning weights to individual studies;
 arid  anticipating possible  publication and aggregation bias (Greenland, 1987; Peto, 1992).

                                  Criteria for Causality
       A causal interpretation is enhanced for studies to the extent that  they meet the criteria
described below.  None of the criteria is conclusive by itself, and the only criterion that is
essential is the temporal relationship.  These criteria are modelled after  those developed by
Bradford Hill in the examination of cigarette smoking and lung cancer (Rothman, 1986), and
they  need to be interpreted in the light of all other information on the agent being assessed.
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 1         •      Temporal relationship: The disease occurs within a biologically reasonable time after
 2                initial exposure.  This feature must be present if causality is to be considered.  The
 3                initial period of exposure to the agent is the accepted starting point in most
 4                epidemiologic studies.
 5         •      Consistency:  Associations occur in  several independent studies of a similar exposure
 6                in different populations, or associations occur consistently for different subgroups in
 7                the same study.
 8         •      Magnitude of the association:  A causal relationship is more credible when the risk
 9                estimate is large  and precise (narrow confidence intervals).
 10        •      Biological gradient: The risk ratio increases with  increasing exposure or dose.  A
 11               strong dose-response relationship across several categories of exposure, latency, and
 12               duration is supportive  for causality given that confounding is unlikely to be correlated
 13               with exposure. The absence of a dose-response relationship is not by itself evidence
 14               against a causal relationship.
 15        •      Specificity of the association:  The likelihood of a causal interpretation is increased if
 16               an exposure produces a specific effect (one or more tumor types also found in other
 17               studies) or if a given effect has a unique exposure.
 18        •      Biological plausibility:  The association makes sense in terms of biological
 19               knowledge. Information is considered from animal toxicology, pharmacokinetics,
20               structure-activity relationship analysis, and short-term studies of the agent's influence
21               on events in the carcinogenic process considered.
22        •      Coherence:  The cause-and-effect interpretation is  in logical agreement with what is
23               known about the  natural history and biology of the disease,  i.e., the entire body of
24               knowledge about the agent.
25
26        2.2.1.4. Conclusions
27               Critical evaluation of each human study includes the exposure-effect relationship,
28        exposure assessment, selection and comparison of groups, sample size, and handling of
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 latency, confounders, and bias as discussed under section 2.2.1.2.  The weight of a study in
 providing inferences about human carcinogenicity depends upon this evaluation, the statistical
 confidence in conclusions, and biological plausibility of findings.  Greater plausibility and
 stronger inferences come from meeting criteria for causality.  The plausibility of an
 exposure-effect finding can be increased or decreased by other relevant findings such as
 evidence of structure-activity relationships with other agents, studies of mode of action,
 understanding of metabolic pathways, and animal toxicology findings.
        The above considerations of the studies available are integrated in a summary  of
 results.

 2.2.2.  Animal Data
        Various kinds of whole animal test systems are currently used or are under
 development for evaluating potential carcinogenicity.  Standardized, long-term studies
 involving chronic exposure for most of the lifespan of an animal are generally accepted for
 evaluation of tumor effects (Tomatis et al., 1989; Rail,  1991; Allen et al., 1988; but  see
 Ames and Gold, 1990).  Other studies of special  design are useful for observing formation of
 preneoplastic lesions or assaying agents for specific modes of action.

 2.2.2.1.  Long-Term Studies
       Current standardized long-term studies in rodents test at least 50 animals in each of
 three treatment group and in the control group usually for 2 years (US EPA,  1983a,b,c).
 Other, similar protocols have been and continue to be used by many laboratories.  Studies
 are examined for production of tumors and preneoplastic lesions, as well as for toxicity
 reactions that may give clues to the mode of action of the agent in producing tumors.
 Analyses of study results are by dose, sex, species and route of exposure.  Analysis of
 toxicity covers both its potential role in carcinogenicity and its separate potential  for causing^
effects in humans. The assessment may identify general toxicity as  a more important end
point for consideration than carcinogenicity.
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1               All available studies of tumor effects in whole animals are considered, at least
2         preliminarily. The analysis discards studies judged to be wholly inadequate in protocol or
3         conduct and carries forward the remainder.  Studies for analysis include both those that are
4         optimal in terms of current protocols and conduct, and studies whose adequacy is limited in
5         some respect. Limitations may be in aspects such as duration, dosing, or sensitivity. Such
6         limited studies can contribute as their deficiencies permit.
7               Evaluation of tumor effects includes both biological significance and statistical
8         significance (Haseman, 1984, 1985, 1990).
9
10                               Statistical Significance of Animal Responses
11              Statistical analysis of a long-term study considers  each tumor type separately.  Benign
12        and malignant lesions of the same cell type, usually within a single tissue or organ, are
13        combined (McConnell, 1986).  Trend tests and pairwise comparison tests are the
14        recommended tests for determining whether chance, rather than a treatment-related effect, is
15        a plausible explanation for an apparent increase in tumor incidence.  A trend test such as the
16        Cochran-Armitage test (Snedecor and Cochran, 1967) asks whether  the results in all dose
17        groups together increase as dose increases. By convention, a trend is  statistically significant
18        if the  probability that an effect seen would have occurred by chance is 5% or less
19        (p<0.05).  A pairwise comparison test such as the Fisher exact test (Fisher, 1932) asks
20        whether an incidence in one dose group is increased over the control group.  Again, by
21        convention, a statistically significant comparison is one for which p<0.05 that the increased
22        incidence is due to chance. Significance in either kind of test is sufficient to reject the
23        hypothesis that chance accounts for the result. A statistically significant response may or
24        may not be biologically significant and vice versa.
25              The standard comparison is tumor effect in dosed animals as compared with
26        concurrent control animals. Additional insights about both statistical and biological
27        significance can come from an examination of historical control data (Haseman et al., 1984).
28        If such data are used,  the discussion needs to address  several issues  that affect comparability
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 of historical and concurrent control data.  Among these issues are the following:  genetic
 drift in the laboratory strains; differences in pathology examination at different times and in
 different laboratories (e.g., in criteria for evaluating lesions; variations in the techniques for
 preparation  or reading of tissue samples among laboratories); comparability of animals from
 different suppliers.  It is most desirable to compare historical and current data from the same
 laboratory and supplier, gathered closely in time.  Always, the discussion of results covers
 issues of comparability.
       Historical control data can add to the analysis particularly by enabling identification of
 uncommon tumor types or high spontaneous incidence of a tumor in a given strain.
 Identification of common or uncommon situations prompts further thought about the meaning
 of the response in the current study in context with other observations in animal studies and
 with  other evidence about the carcinogenic potential of the agent.  These other sources of
 information may  reinforce or weaken the significance given to the response in the hazard
 assessment.

                             Evaluation of Animal Responses
       Observation of tumor effects under varying circumstances (e.g.,  test species or strain,
 route of administration, sex, replication in different laboratories) lends  support to
 significance of findings for animal carcinogenicity.  Progression of lesions observed in
 subchronic studies or in the chronic study, greater ratio of malignant to  benign tumors, dose-
 response trend, or reduced latency of neoplastic lesions are among the findings that also lend
 support.  Finding a very uncommon tumor type suggests biological significance even if the
 increase in incidence is  not statistically significant, particularly if the increase is dose-related.
       The high dose in long-term studies is generally selected to provide maximum
 statistical ability to detect treatment-related effects.  Two or more additional doses,
reasonably spaced, are at some fraction of the high dose. The high dose, in  EPA
requirements, is one that, in an animal lifetime, produces some toxic effects without either
unduly affecting mortality from effects other than cancer, or producing significant adverse
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1         effects on the animals' health (see generally NRC, 1993b).  Dose selections for long-term
2         studies are based on results of subchronic studies along with any available information on the
3         disposition, metabolism, and pharmacokinetics of the test agent.  The aims in selecting dose
4         levels are both adequate sensitivity and the opportunity to observe tumor effects specific to
5         the agent.  Failure to reach an adequately high dose reduces the sensitivity of the study.  On
6         the other hand, excessive general toxicity, or toxicity in a target tissue for tumor effects,
7         raises the question whether tumor effects are specific to the agent or are nonspecific effects
8         secondary to the toxicity.  There is no completely satisfactory answer to the possible conflict
9         between these aims.  For instance, reducing the high dose to avoid  any toxicity would reduce
10        the sensitivity of a protocol that is at best able to detect an increase of tumor incidence of
11        10%, if there is no spontaneous background incidence (Haseman, 1983). Reliable detection
12        of a  1 % increase would  require using thousands of animals, which is not a feasible option.
13              Any of the following  treatment-related findings may indicate that other, noncancer
14        toxicity may confound results of the cancer studies:
15        •     A 10%, or greater, increase in mortality  due to toxicity
16        •     Significant toxicity manifested by a decrement in body weight greater than  10 to 15%
17              (not due to reduced food consumption from impalatability)
18        •     Significant toxicity manifested by clinical signs, hematological or chemistry measures,
19              or changes in organ weight, morphology, and histopathology that may interact with
20              the carcinogenic process  or obscure interpretation of the results
21        Absence of tumor effects in an adequately sensitive study that is well conducted is accepted
22        as a negative finding.  Studies with undue effects on mortality or health that show no tumor
23        effects are accepted as negative, if lower doses are appropriately  spaced and mortality does
24        not remove too many animals from the study. Studies of inadequate sensitivity may be used
25        to bound the range of potential risk.  Studies that show tumor effects only at doses with
26        undue effects on mortality or health are compromised and may or may not  contribute to the
27        analysis, depending on interpretation in the context of other study results and other lines of
28        evidence. The effect of toxicity is examined,  even when it is not excessive.  In all cases, the
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 strength of inferences to be drawn about human carcinogenic potential from the statistical, and
 biological  significance of animal tumor effects is judged in conjunction with all other
 available data.

 2.2.2.2. Special Studies
       Specialized short-term studies often use protocols that screen for effects, usually
 preneoplastic effects, in a single tissue. The selected tissue is, in a sense, the test system.
 Certain systems of this kind are thought to be particularly informative about carcinogenic
 potential of defined chemical classes or agents,  or modes of action (reviewed in Vainio et al.,
 1992).  Other experimental systems such as strain A mice that are bred to be particularly
 sensitive may  also provide some information. Nevertheless, limitations in experimental
 protocol, such as short duration, limited histology, or lack of complete  development of
 tumors, make results from these studies correspondingly limited in their contribution to
 assessment. Their results are appropriate for identifying subjects of further research and for
 considering the effects seen in context with other evidence, especially regarding potential
                                     i
 modes of action. Transgenic animals carrying introduced proto-oncogenes, or activated
 oncogenes  or tumor suppressor genes are promising experimental systems for probing mode
 of action questions when experience that supports their interpretation is  in place.  The
 strength of inferences that such studies  support rests on their contribution to the congruity of
 evidence about an agent.

 2.2.2.3.  Significance for Human Hazard
       These guidelines adopt the science policy position that tumor findings in animals
 indicate that an agent may produce such effects in humans.  Moreover,  the absence of tumor
 findings in  well-conducted, long-term animal studies in at least two species provides
 reasonable assurance that an agent may  not be a carcinogenic concern for humans.  Each of
these is a default assumption that may be adopted, when appropriate, after evaluation of
tumor data  and other key evidence.
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 1               Several kinds of observations from animal studies can contribute to the judgment
 2         whether animal responses indicate a significant carcinogenic hazard to humans.  Significance
 3         is a function of the number of factors present and, for a factor such as malignancy, the
 4         severity  of the observed pathology.  The following observations add significance:
 5         •     uncommon tumor types
 6         •     tumors at multiple sites
 7         •     tumors by more than one route of administration
 8         •     tumors in multiple species, strains, or both sexes
 9         •     progression of lesions from preneoplastic to benign to malignant
 10       •     reduced latency of neoplastic lesions
 11        •     metastases
 12       •     unusual magnitude of tumor response
 13       •     proportion of malignant tumors
 14       •     dose-related increases
 15             These features or their absence also may provide useful suggestions about a possible
                                                 *
 16       mode(s)  of action of an agent. For example, multisite and multispecies effects are often
 17       associated with genotoxic agents.  Effects restricted to one sex may suggest an influence
 18        connected with gender-related biological differences such as hormonal status.  Late onset of
 19        tumors that are primarily benign, or reversal of lesions on cessation of exposure, may point
20        to a growth-promoting mode of action.  Similarly, a general increase in incidence of a
21        tumor with a high spontaneous background with no increase in malignancy, may indicate a
22        growth-promoting activity. The possibility that an agent may act differently in different
23        tissues or have more than one mode of action in a single tissue is kept in mind.
24              Site concordance of tumor effects between animals and humans is an issue to be
25        considered in each case.  Thus far, there is evidence that growth control mechanisms at the
26        level of the cell are homologous among mammals, but there is no evidence that these
27        mechanisms are site concordant.  Moreover, agents observed to produce tumors  in both
28        humans and animals have produced tumors either at the same (e.g., vinyl chloride) or
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 different sites (e.g., benzene) (NRC, 1994).  Hence, site concordance is not assumed a
 priori. On the other hand,  certain processes with consequences for particular tissue sites
 (e.g., disruption of thyroid  function) may lead to an anticipation of site concordance.
       Relevance of tumor  responses in nonhuman species to human hazard is an integral
 judgment in analysis of bioassay results.  The assumption of relevance is less appropriate
 when a body of evidence supports a mode of action in animals that would not be seen in
 humans under the same conditions of exposure.  The Agency will undertake analyses of
 relevance issues as needed in reports to be published from time to time (e.g., U.S. EPA,
 1991b).

 2.3.  ANALYSIS OF OTHER KEY EVIDENCE
       Certain structural, chemical, and biological attributes of an agent provide key
 information about its potential to cause or influence carcinogenic events.  These attributes
 along with comparative studies between species also provide clues as to the potential mode
 of carcinogenic action and the potential dose-response relationship. The following sections
 provide guidance for analyses of these attributes.

 2.3.1. Physicochemical Properties
       Physicochemical properties affect an agent's absorption, tissue distribution
 (bioavailability), biotransformation, or degradation in the body.  These dispositions are
 important determinants of hazard potential.  Properties to analyze include, but are not
 limited to, the following:  molecular weight, size, and shape; valence state; physical state
 (gas,  liquid, solid);  water or lipid solubility that can influence retention and tissue
 distribution; and potential for chemical degradation or stabilization in the body.
       An agent's potential for chemical reaction with cellular components, particularly with
DNA and proteins, is also important. The agent's molecular size and shape, electrophilicity,
and charge distribution are considered to decide whether they would facilitate such reactions.
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1         2.3.2.  Structure-Activity Relationships (SAR)
2                Results of SAR analysis may strengthen or weaken the concern for an agent's
3         carcinogenic potential, depending on confidence in the SAR analysis.  SAR analysis supports
4         evaluation of carcinogenic potential of both tested and untested chemicals.
5                Currently, SAR analysis is most useful for chemicals that are believed to produce
6         carcinogenesis, at least initially, through covalent interaction with DNA (i.e., DNA-reactive,
7         mutagenic, electrophilic, or proelectrophilic chemicals) (Ashby and Tennant, 1991). The
8         following parameters are useful in comparing an agent to its structural analogues and
9         congeners that have tumor effects and effects on related biological processes such as receptor
10        binding, genotoxicity, and general toxicity (Woo and Arcos, 1989):
11        •      nature and reactivity of the electrophilic moiety  or moieties present
12        •      potential to form electrophilic reactive intermediate(s) through chemical,
13               photochemical, or metabolic activation
14        •      contribution of the  carrier  molecule to which the electrophilic moiety(ies) is attached
15        •      physicochemical properties (e.g., physical state, solubility, octanol-water partition
16               coefficient, half-life in aqueous solution)
17        •      structural and substructural features (e.g., electronic, stearic, molecular geometric)
18        •      metabolic pattern (e.g., metabolic pathways and activation and detoxification ratio)
19        •      possible exposure route(s)  of the agent
20               Suitable SAR analysis of non-DNA-reactive chemicals and of DNA-reactive chemicals
21        that do not appear  to bind  covalentiy to DNA requires knowledge or postulation of the
22        probable mode(s) of action of closely related carcinogenic structural analogues (e.g.,
23        receptor-mediated, cytotoxicity related). Examination of the physicochemical and
24        biochemical properties of the agent may then  allow one to assess the likelihood of its activity
25        by that mode of action.
26
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 2.3.3.  Metabolism and F'harmacokinetics
       Studies of the absorption, distribution, biotransformation and excretion of agents
 permit comparisons among species to assist in determining the implications of animal
 responses for human hazard assessment, to support identification of active metabolites,  to
 identify changes in distribution and metabolic pathway or pathways over a dose range and
 between species,  and to make comparisons among different routes of exposure.
       If data are available (e.g., blood/tissue partition coefficients and pertinent
 physiological parameters of the species of interest), physiologically based pharmacokinetic
 models can be constructed to assist in determination of tissue dosimetry, species-to-species
 extrapolation of dose, and route-to-route extrapolation (Connolly and Andersen, 1991; see
 section 3.2.2.).  Without such data, it is necessary to assume that pharmacokinetic and
 metabolic processes are qualitatively comparable between species if this appears generally
 reasonable.
       Adequate metabolism and pharmacokinetic data can be applied toward the following
 as data permit. Confidence in conclusions is greatest when  in vivo data are available.
 •      Identifying metabolites and reactive intermediates of metabolism and determining
       whether one or more of these intermediates are likely to be responsible for the
       observed effects.  This information on the reactive intermediates will appropriately
       focus  SAR analysis, analysis of potential modes of action, and estimation of internal
       dose in dose-response assessment (D'Souza et al., 1987; Krewski el al., 1987).
 •      Identifying and comparing the relative activities of metabolic pathways in animals
       with those in humans.   This analysis can provide insights for extrapolating results of
      animal studies to humans.
•     Describing anticipated distribution within the body, and  possibly identifying target
      organs.  Use of water solubility, molecular weight, and  structure analysis can support
      qualitative inferences about anticipated distribution and excretion.  In addition,
      describing  whether the agent or metabolite of concern will be excreted rapidly or
      slowly or will be stored in a particular tissue or tissues to be mobilized later can
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1               identify issues in comparing species and formulating dose-response .assessment
2               approaches.
3         •     Identifying changes in pharmacokinetics and metabolic pathways with increases in
4               dose. These changes may result in the formation and accumulation of toxic products
5               following saturation of detoxification enzymes.  These studies have an important role
6               in providing a rationale for dose selection in carcinogenicity studies.  In addition, they
7               may be important in estimating a dose over a range of high to low exposure for the
8               purpose of dose-response assessment.
9         •     Determining bioavailability via different routes of exposure by analyzing uptake
10              processes under various exposure conditions. This analysis supports identification of
11              hazard for untested routes.  In addition, use of physicochemical data (e.g.,  octanol-
12              water partition coefficient information) can support an  inference about the likelihood
13              of dermal absorption (Flynn, 1990).
14              In all of these areas, attempts are made to clarify and describe as much as possible
15        the variability to be expected because of differences in species, sex, age, and route of
16        exposure.  Utilization of pharmacokinetic information takes into account that there may be
17        subpopulations of individuals who are particularly vulnerable to the effects of an agent
18        because of pharmacokinetic or metabolic differences (genetically or environmentally
19        determined).
20
21        2.3.4. Short-Term Studies
22              Results from short-term in vitro and in vivo studies of effects that relate to
23        carcinogenic events are  useful in the interpretation of epidemiological and animal data on
24        tumor effects.  They are often the primary source of information about possible modes of
25        action.
26              A large number of short-term assays exist for examining biological activities relevant
27        to the carcinogenic process (e.g., mutagenesis, tumor promotion, aberrant intercellular
28        communication, increased cell proliferation, malignant transformation, immunosuppression).
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 These assess a variety of end points; confidence in the inferences to be drawn from results of
 each assay varies according to experience with the test system and its interpretation.  Both
 the relevance of tested end points to potential carcinogenicity and confidence in interpretation
 are issues explicitly evaluated.

 2.3.4.1. Genotoxicity Information
       "Genotoxicity" is an inclusive term that refers to effects of agents that interact with or
 alter the genome.  "Mutagenicity" constitutes the part of genotoxicity associated with
 heritable changes in DNA structure or content.  Mutations, including changes in DNA
 sequence and gene amplification,  and structural and numerical chromosome aberrations are
 attributes of tumor cells and of predisposing genetic diseases.  Recent studies on oncogenes
 provide additional evidence for the linkage between mutation and cancer (Bishop, 1991).
 Activation of proto oncogenes to oncogenes can be triggered, for example, by point
 mutations, DNA insertions, or chromosomal translocation (Bishop,  1991).  In addition, the
 inactivation of tumor  suppressor genes can occur by chromosomal deletion or loss or by
 mitotic recombination (Bishop, 1989; Varmus, 1989;  Stanbridge and Cavenee, 1989).
 Mutagenic endpoints are, therefore, of obvious interest.
       The process by which an agent brings about mutations is also of interest,  in part
 because different processes have different implications for the dose-response relationship.
 Agents may react directly with DNA as evidenced by DNA adducts, strand breakage, and
 intercalation between  bases. Alternatively, they may react with other cell components, with
 DNA damage as an indirect consequence, e.g., interfere with spindle formation or with
 repair or recombination processes. Different numbers of chemical reactions during critical
periods of the cell cycle are inherent in direct versus indirect processes, with implications for
linearity or nonlinearities in the dose-response relationship.
       The EPA has published testing protocols and guidelines for detection of mutagenicity
(U.S. EPA,  199la).  A method to portray data graphically is the genetic activity profile
methodology (Garrett  et al., 1984; Waters et al.,  1988).
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1               A higher level of confidence that an agent is a mutagen is assigned to agents that
2        consistently induce sequence or structural changes in DNA in a number of test systems.
3        Although important information can be gained from in vitro assays, a higher level of
4        confidence is given to a data set that includes in vivo data because many agents require
5        metabolic conversion to an active intermediate for biological activity.  Metabolic activation
6        systems can be incorporated into in vitro assays, but they may not mimic mammalian
7        metabolic activation and inactivation.  If available,  human genetic toxicity end points relevant
8        to carcinogenesis are important in vivo data.
9               Because mutagenic carcinogens have been observed to induce tumors across species
10       and at multiple sites, evidence of both mutagenicity and tumor responses in multiple species
11       or sexes significantly increases concern for the human carcinogenic potential of an agent.
12       Agents that induce mutations in the germinal cells of animals are similarly of concern.
13       About 30  agents, many of which are carcinogenic to humans, have been shown to induce
14       germ cell  mutations in animals and may be anticipated to do so in somatic cells. Absence of
15       mutagenicity in several test systems, preferably including in vivo tests for genotoxicity in the
16       tumor target tissue (e.g., DNA alkylation,  unscheduled DNA synthesis) suggests that another
17       mode of action may be important (Ashby,  J., chapters in Vainio et al., 1992).   The absence
18       of evidence of mutagenicity in an adequate data base and the lack of responses in a chronic
19       rodent bioassay gives reasonable confidence that an agent is not a human cancer hazard
20       unless there is human evidence to the contrary.
21
22       2.3.4.2. Other Short-Term Test Information
23              Nongenotoxic agents are also known to affect carcinogenesis. For example,
24       hormones and growth factors or agents that mimic them alter DNA functions that are critical
25       in the cell cycle.  Other agents may cause  cell toxicity which results in compensatory cell
26       replication or selectively promotes growth  of initiated cells. Dose-response relationships for
27       some agents may be tied to their cell toxicity.
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        The relationship of dose and response is more complex for agents that affect the
 function of cell cycle controls, encountering issues of human variability in endocrine and
 exocrine balance and background exposures (U.S. EPA, 1994).
        Clues about nongenotoxic modes of action can come from tests for increased cell
 proliferation, cell transformation, aberrant intercellular communication, receptor mediated
 effects, or changes in gene transcription.
        Cell proliferation plays a key role at each  stage in the carcinogenic process, and it is
 well established that increased rates of cell proliferation are associated with increased cancer
 risk. An agent may produce cellular toxicity with compensatory cell proliferation or act as a
 mitogen directly or indirectly  (e.g., by affecting endocrine  function).  Increased risk may be
 due to bypassing DNA repair  checkpoints or to interference with apoptosis or differentiation
 resulting in an  increase in the number of proliferating cells  at risk of spontaneous and
 induced genetic damage.  Evidence for an increased rate of cell division may be determined
 by measuring the mitotic index,  or by supplying a specific DNA precursor to cells (e.g., 3H-
 thymidine or bromodeoxyuridine) and counting the percentage of cells that have incorporated
 the precursor into replicating DNA, or by immunodetection of proliferation-specific antigens.
 These analyses  can be carried  out in vitro, or during prechronic animal studies, or as part of
 long-term animal studies.
       Assays for measuring perturbation of gap-junctional  intercellular communication may
 provide an indication of carcinogenicity, especially promotional  activity (Yamasaki, 1990).
 Cell transformation  assays have been widely used  for studying mechanistic aspects of
 chemical carcinogenesis because in vitro cell transformation is considered to be relevant to
 the in vivo carcinogenic process.  Both of these kinds of assays have been proposed as tests
 for identifying nongenotoxic carcinogens (Swierenga, S.H.H.  and Yamasaki, H.,  chapter in
 Vainioetal., 1992)
      There is as yet a paucity of standard tests for effects  specifically on the cell cycle,
although as the  fields of cell cycle and cancer research merge, more  cell cycle study methods
may become available for screening  agents for such effects.
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1        2.3.4.3. Biomarker Information
2               Several genotoxicity end points and other measurements can serve as biological
3        markers of events in biological systems or samples.  In some cases, these molecular or
4        cellular effects (e.g., DNA or protein adducts, structural chromosomal aberrations, levels of
5        thyroid stimulating hormone) can be measured in blood, body fluids, and cancer target
6        organs to serve as biomarkers of exposure (Callemen et al., 1978; Birner et al.,  1990).  As
7        such they can do the following:
8        •     act as an internal, surrogate measure of chemical dose,
9        •     help identify doses at which elements of the carcinogenic process are operating,
10       •     aid in interspecies extrapolations when data are available from experimental animal
11              and human cells, and
12       •     under certain circumstances,  provide insights into the shape of the dose-response
13              curve below levels where tumor incidences are observed (e.g., Choy, 1993).
14              Genetic and other findings (like changes in proto-oncogenes and tumor suppressor
15       genes in neoplastic tissue or measures of endocrine disruption) can indicate the potential for
16       disease and  as such serve as biomarkers of effect. They, too, can be used in different ways:
17       •     The  spectrum of genetic changes in tumors following chemical administration to
18              experimental animals can be  determined and compared to those in spontaneous tumors
19              in control animals, in animals exposed to other agents, and in persons exposed to the
20              agent under study.
21       •     As with biomarkers of exposure, it may be justified in some cases to use these
22              endpoints to provide insight into the shape of the dose-response curve at doses below
23              those at which tumors are induced.
24
25       2.3.4.4. Confidence in Conclusions
26              All data from short-term studies become part of the overall evaluation. It is
27       recognized that agents will not typically produce uniform responses in all short-term tests.
28       The reviewer is  often left with a mix of responses in different tests.  To the extent data
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1        permit, the reviewer makes judgments as to genotoxic and nongenotoxic effects, the degree
2        to which the effects may influence observed tumor formation, and the influence of effects in
3        judging human hazard potential and dose-response implications.  Considerations and elements
4        of confidence in such judgments include, but are not limited to, the following:
5        •     spectrum of endpoints relevant to carcinogenicity
6        •     number of studies of each endpoint
7        •     consistency of results in different test systems and different species
8        •     in vivo as well as in vitro observations
9        •     reproducibility of results in a test system
10       •     existence of a dose-response relationship for effects
11     , •     tests  conducted in accordance with generally accepted protocols  .
12       •     degree of consensus and general experience among scientists regarding interpretation
13              of the significance and specificity of the tests
14       At the end of the evaluation, when conclusions are offered, the conclusions are accompanied
15       by a statement of the confidence supported by the data base.
16
17       2.4. MODE OF ACTION-IMPLICATIONS FOR HAZARD CHARACTERIZATION
18       AND DOSE-RESPONSE
19              The analysis of the entire range of data reviewed in the assessment of tumor effects
20       studies and other key evidence is the support for arriving at a judgment about the potential
21       mode(s) of action of an agent.  The purpose for analyzing the mode of action is to make a
22       reasoned judgment about the ways agents appear to be producing carcinogenic effects.  This
23       judgment affects the  ways of characterizing hazards to humans and means of evaluating
24       potential dose-response relationships.  Given the gaps in the general understanding of
25       carcinogenesis, these analyses and judgments do not lay out detailed molecular mechanisms.
26       Nevertheless, commonly available data support general views as to physical, chemical, and
27       biological factors that appear to be influencing the carcinogenic process and are
28       acknowledged by scientists as playing a role. For hazard characterization,  these analyses
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 1         address the relevance of the animal tumor model to humans and the conditions of expression
 2         of potential hazard (see, for example, Appendix A, Narratives 1 and 4).  For dose-response
 3         assessment, these analyses help to guide the development of biologically based models and,
 4         in the absence of detailed information, to select among different default techniques for low-
 5         dose extrapolation.
 6                The analysis reviews all the relevant information on the agent including observed
 7         tumor responses and other key evidence. The entire list of factors to be considered in this
 8         analysis would be beyond the scope of these guidelines to list.  Some of the important ones
 9         include the following:
 10        •      number of tumor sites, sexes, studies, and species affected or unaffected
 11        •      nature of tumor sites, e.g., responsive to endocrine influence or not
 12        •      route of exposure effects
 13        •      target organ or systemic effects (e.g., target organ toxicity, urinary chemical changes
 14               associated with stones, effects on immune surveillance)
 15        •      progression of lesions from preneoplastic to benign to  malignant
 16        •      early or late appearance of tumors after exposure
 17        •      proportion of malignant to benign tumors
 18        •      tumors invading locally, metastasizing, producing death
 19        •      tumors at sites in laboratory animals with high or low  spontaneous historical incidence
20        •      biomarker of effect in tumor cells, such as  mutation spectra (like or unlike
21               spontaneous tumors), DNA or protein adducts, chromosome changes
22        •      shape of the dose response in the range of tumor observation
23        •      structural relationship of the agent or its metabolites to mutagenic  carcinogens
24        •      structural relationship of the agent or its metabolites to agents that are non-DNA-
25               reactive, or influence other processes (e.g., hormone disruption)
26        •      genotoxic effects
27        •      effects on cell proliferation (e.g., mitogenic effects,  effects on differentiation or
28               apoptosis, response to toxicity)
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 •     effects on intercellular communication
 •     evidence of initiating or promoting activity in two-stage assays in vitro or in vivo
        Dose-response default positions include low-dose linear extrapolation, nonlinear, and
 both procedures. Both procedures are warranted when (a)  tumors at different sites appear to
 have different modes of action (see, for example, Appendix A,  Narrative 4), (b) there is
 evidence in support of both default procedures (see, for example, Appendix A, Narrative 5),
 and (c) there is considerable uncertainty as to potential mode of action (see, for example,
 Appendix A, Narratives 3 and 6).
        Many combinations of data elements are possible. For example, a data set that might
 lead to a conclusion that a linear dose-response default is reasonable might include:  tumors
 at multiple sites, sexes, and species, with structural alerts and good evidence of DNA-
 reactivity in short-term tests (e.g.,  Appendix A,  Narrative 7). Finding that there are tumor
 responses in two species at sites that have high spontaneous rates of tumor incidence, the
 effect at each site being to accelerate appearance of tumors without altering the spontaneous
 proportion of benign to malignant tumors coupled with finding no structural alerts or
 evidence of genotoxicity in extensive short-term testing, would support a nonlinear dose-
 response default procedure.

 2.5.  HAZARD CHARACTERIZATION
 2.5.1.  Carcinogenic Potential for Humans
       The hazard characterization  summarizes and evaluates the analyses of pertinent data
 concerning carcinogenic hazard potential and applies them to make a conclusion as to
 carcinogenicity to human beings.  The conclusion regards both the general population and
 subpopulations identified as particularly sensitive.  Evaluation addresses the significant
 strengths and weaknesses of existing data.  It also explains the reasoning that supports data
 interpretation, including the use of default assumptions, and  weighs the coherence of
 implications of different kinds of data.  The central purpose of evaluation is to explore and
explain how the available empirical evidence may relate to biological activity in humans.
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       No single kind of evidence can reveal the whole biological story otherwise told by
bringing together all of the available information.  Moreover, the kinds of evidence that are
the most telling are different from case to case.  Some illustrations of this are well known:
       Metabolism information~the presence or absence of a single enzyme—was the key to
explaining why certain aromatic amines cause bladder cancer in dogs and humans, but not in
rodents.  The activity and high levels of a small protein, alpha  2u globulin, in male rats was
the key to finding that a particular kidney tumor in these animals has no relevant parallel in
humans.  Appendix A contains several examples highlighting key roles for other kinds, of
information:
•      Narrative 4 illustrates that data on an agent's homology in biological effects and
       chemical structure to a carcinogenic analogue can support the conclusion that the
       agent is likely to be carcinogenic, although there are no tumor effects data on the
       agent itself.
•      Narrative  1 illustrates how information on physiological perturbation and physical
       irritation can explain mode of action sufficiently to define dose as a limiting factor on
       potential expression of carcinogenic effects.
•      Narrative 6 shows that information on  absorption and toxicity can lead to different
       conclusions about carcinogenic potential by different routes of exposure.

2.5.2. Conditions of Expression
       A characterization qualitatively describes the conditions  under which the agent's
effects may be expressed in human beings.  The description includes routes of exposure and
dose levels and durations of exposure.
       Discussion of approaches to quantitative  assessment of internal or delivered dose
according to  route of exposure appears in section 3 below. Qualitative characterization
describes whether the route of exposure is likely to be a limiting factor on expression of
effects.  The supporting data include studies hi which effects of the agent or analogues on
animals or humans have been observed by differing routes, or physical-chemical properties,
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 or pharmacokinetics studies. For certain agents there may be enough known about properties
 of their class to make confident conclusions regarding absorption by different routes.  For
 others, more data on the specific agent may be necessary as conclusions may be less
 confident, or not possible, without such information.  Discussion of these issues is part of the
 characterization.
       Relationship of dose level, pattern, and duration of exposure to effects can
 theoretically take many forms.   Hazard assessment examines all of the kinds of evidence to
 see what processes or events in carcinogenesis a specific agent appears to affect.  This
 information is used to relate the mode of action in general  terms to  the approach to
 quantitative dose-response assessment. The mode of action may imply a linear or a non-
 linear dose-response relationship, or a threshold of dose below which effects will not occur
 in an individual. The implications of available information about human variability in
 sensitivity or with respect to threshold effects are important elements.  These implications
 relate to both the qualitative characterization of hazard and the quantitative assessment of
 dose-response.

 2.5.3. Descriptions of  Weight of Evidence
       The hazard narrative, described in the following subsection, presents the weight of
 evidence in terms of likelihood  of human carcinogenicity using descriptors. The descriptors
 are not meant to replace an explanation of the nuances of the biological evidence, but  rather
 to summarize it.  Each descriptor spans a wide variety of data  sets and weights of evidence.
There will always be gray areas, gradations, and borderline cases.  The narrative preserves
and presents this complexity, which is an essential part of the hazard characterization.
Applying a descriptor is a matter of judgment and cannot be reduced to a formula. Risk
managers should consider  the entire range of information included in the narrative rather than
focus simply on  the descriptor.
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       Note that one agent may fit more than one descriptor, if, for instance, the agent were
likely to be carcinogenic by one route of exposure and not by another.  Use of the
descriptors is illustrated hi Appendix A.
       The descriptions below are intended only as guidance and provide some typical
examples; the examples are not exhaustive or comprehensive.

                                  "Likely" or  "Known"
       These descriptors are appropriate when the evidence provides a  reasonable assurance
of carcinogenic potential for human beings and supports proceeding  with the  risk assessment.
"Likely" is the descriptive term generally used.   "Known" is used when the weight of
evidence gives especially high assurance because either an association between
carcinogenicity and a specific route  of exposure is drawn from human data, or conclusions
from other kinds of data give confidence that is equal to having human  data.

                                "Cannot be determined"
       "Cannot be determined" is appropriate whenever support for  a conclusion about
carcinogenic potential for human beings is not sufficient to proceed with the assessment.
Where appropriate, the narrative explains the situation.  Examples may  include the
following, among others.
•      The evidence raises a concern for carcinogenic effects, but falls  short  of supporting a
       conclusion about the likelihood of effects.  The narrative provides a summary of the
       research or testing needed  to explore the issue further.  The added descriptor,  "testing
       candidate" is appropriate in these cases to flag the agent for attention by testing
       programs.
•      The data are inadequate to perform an assessment.
•      The information is inconclusive or conflicting, e.g., some evidence is  suggestive of
       carcinogenic effects, but other equally pertinent evidence does not confirm any
       concern.
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                                       "Not Likely"
        "Not likely" is appropriate whenever evidence about an agent generally, or about a
 condition of exposure, is satisfactory for deciding that there is not a basis for concern.
 Again, the narrative explains the conclusion.  Examples may include the following:
 •      The agent has been adequately characterized empirically, and the conclusion is
        negative, or the only positive data are not considered relevant to human beings.
        Adequate empirical characterization generally  includes well conducted, long-term
        animal studies on an agent or its structural analogue with consistent findings from
        analysis of other key evidence.
 •      The evidence shows that under certain conditions of exposure, no expression of
        carcinogenic effects is anticipated.  The agent's carcinogenic potential is categorized
        as "not likely" for those conditions, e.g., a route of exposure or a defined dose level.
 •      The agent  has been adequately characterized empirically, and the only positive
        indication of effects was seen under experimental circumstances that are implausible
        for raising an environmental concern, e.g., injection of a polymer.

2.5.4.  Hazard Narrative
       A narrative summarizes the results of hazard characterization.  The narrative,
optimally two pages or less in length, explains an agent's human carcinogenic potential and
the conditions of its expression.  If data do not allow a conclusion, the narrative explains this
determination.  Examples of narratives appear in Appendix A below as guidance for format
and content.  The  items regularly included are these:
•      name of agent and Chemical Abstracts Services number, if available
•      a brief identification of the kinds of data available
•      conclusions (by route of exposure) about human carcinogenicity, described as
       "known" or " likely,"  "not likely," or "cannot be determined"
•      summary of tumor data, human  or animal, on the agent and/or its structural
       analogues, their relevance, and biological plausibility
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1        •     Other key evidence, e.g., structure-activity data, pharmacokinetics and metabolism,
2               short-term studies, other relevant toxicity data
3        •     effect of route of exposure
4        •     discussion of possible mode(s) of action and appropriate dose-response approaches)
5        •     strengths and weaknesses of the evidence and assumptions significant to the case
6        The following items may be added if justified:
7        •     depiction of the evidence as particularly strong or weak as compared to other cases.
8        •     a description of  one or more research approaches or tests that can be anticipated to
9               resolve a critical question identified in the assessment.
10
11                                3.  DOSE-RESPONSE ASSESSMENT
12
13              Dose-response assessment addresses both the relationship of dose2 to degree of
14       response observed empirically and the nature of this relationship at environmental exposure
15       levels of interest below the range of observation.  Analysis of responses includes tumor
16       responses in human and animal studies and the agent's effects on macromolecules involved in
17       growth control or other toxic effects  that may play a role in carcinogenesis.  Analyses of
18       dose use available metabolism and pharmacokinetic data to identify appropriate measures of
19       applied dose and, as data permit, improve the analysis by  identifying measures of internal or
20       delivered dose.  If empirical  data are from animal studies,  the analysis extrapolates animal
21       doses to human equivalent doses.  Depending on the availability of data, dose-response
22       assessments are carried out for any effect associated with an agent's carcinogenicity to  assess
23       potential for effects from environmental exposure.
24          2For this discussion, "exposure" means contact of an agent with the outer boundary of an
25       organism.  "Applied dose" means the amount of an agent presented to an absorption barrier
26       and available for absorption.  "Internal dose" means the amount crossing an absorption
27       barrier (e.g., the exchange boundaries of skin, lung, and digestive tract) through uptake
28       processes.  "Delivered dose" for an organ or cell means the amount available for interaction
29 •      with that organ or cell (U.S. EPA,  1992a).
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 1         3.1. RESPONSE DATA
 2                Response data of interest for analysis include tumor incidence data from human or
 3         animal studies.  They also include data on other responses as they relate to an agent's
 4         carcinogenic effects, for instance, effects on growth control processes or cell macromolecules
 5         or other toxic effects. Tumor incidence data is ordinarily the basis of dose-response
 6         assessment, but availability of other response data can augment such assessment or provide
 7         separate assessments of other important effects.  Data on carcinogenic processes underlying
 8         tumor effects may be used to support biologically based models.  If confidence is high in the
 9         linkage of a precursor effect and the tumor effect, the assessment of tumor incidence may be
 10       extended to lower dose levels by linking it to the assessment of the precursor effect
 11       (Swenberg et al., 1987).  Linking analyses may not be appropriate; even so, the assessment
 12       for a precursor effect may provide a view of the likely shape of the dose-response curve for
 13       tumor incidence below the range of tumor observation (Cohen1 and Ellwein, 1990; Choy,
 14       1993).  The effects of an agent on cell macromolecules  may be used as markers of
 15       carcinogenic effect for which a separate dose-response assessment may be done, or such
 16       effects  may provide markers  of exposure in  support of dose analysis.  In some cases, the
 17       dose-response relationship for a response other than tumor incidence may be more useful
 18       than tumor incidence to assess potential effects associated with environmental exposure.  For
 19       example, if it is concluded that the carcinogenic effect is secondary to another toxic effect,
20       the dose-response for the other effect will likely be more pertinent for risk assessment. The
21        dose-response relationship for a precursor effect may also  be more useful, for example,
22       disruption of hormone activity when this is considered the key mode of action  of an agent.
23        These kinds of supplementary analyses are presented and evaluated whenever data are
24        available  to support them.
25              If adequate positive human epidemiologic data are available, they provide an
26        advantageous basis for analysis since concerns about interspecies extrapolation  do not arise.
27        Adequacy of human exposure data for quantification is an  important consideration in deciding
28        whether epidemiologic data  are the optimal basis for analysis in a particular case.  Positive
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 1         data are analyzed to estimate response to environmental exposure in the observed range.
 2         (U.S.  EPA,  1992a).  Extrapolation to lower environmental exposure ranges is carried out, as
 3         needed. Analysis of associated responses as described in the paragraph above supplements
 4         analyses of human tumor data as well as those of animal tumor data.  If adequate exposure
 5         data exist in  a well-designed and well-conducted  epidemiologic study that detects no effects,
 6         it may be possible to obtain an upper-bound estimate of the potential human risk to provide a
 7         check on plausibility of available estimates based on animal tumor or other responses.
 8               When animal studies are used, response data from a species that responds most like
 9         humans should be used, if information to this effect exists. If this is unknown, and an agent
 10        has been tested in several experiments involving different animal species, strains, and sexes
 11        at several doses and different routes of exposure, all of the data sets are considered and
 12        compared, and a judgment is made as to the data to be used to best represent  the observed
 13        tumor incidence data Snd important biological features such as mode of action. Appropriate
 14        options for presenting results  include use of a single data set, combining data  from different
 15        experiments (Stiteler et al., 1993; Vater et ah, 1993),  showing a range of results from more
 16        than one data set, showing results from analysis of more than one tumor response based on
 17        differing modes of action, representing total response in a single experiment by combining
 18        animals with tumors, or a combination of these options.  The approach judged to best
 19        represent the data is presented with the rationale for the judgment, including the biological
20        and statistical considerations involved. The following are some points to consider:
21        •     high quality  of study protocol and execution
22        •     malignancy of neoplasms
23        •     latency of onset of neoplasia,
24        •     number of data points  to define the relationship of dose and response
25        •     background incidence in test animal
26        •     most sensitive responding species
27        •     data on a related effect (e.g., DNA adduct formation) are available to augment the
28              tumor effect data
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       Analyses of carcinogenic effects other than tumor incidence are similarly presented
 and evaluated for their contribution to a best judgment on how to represent the biological
 data for dose-response assessment.

 3.2.  DOSE DATA
       Whether animal experiments or epidemiologic studies are the sources of data,
 questions need to be addressed in arriving at an appropriate measure of dose and,  in case of
 animal data, a measure of dose appropriate to humans—human equivalent dose—that is
 matched to the anticipated route of environmental exposure.  Among these are: (1) Is the
 parent compound, a metabolite, or both, active in the process? and (2)  How well do data at
 hand measure available dose and support pharmacokinetic modeling of internal or  delivered
 dose?
       In practice, there may be little or no information on the concentration or identity of
 the active form at a target; being able to compare the applied and delivered doses  between
 routes and species is the  ideal, but is rarely attained.  Even so, the objective is to  use
 available data to reach a  measure of internal or delivered dose if possible.
       Even  if pharmacokinetic and metabolic data are sufficient to derive a measure of
 delivered dose to the target, the dose-response relationship is also affected by kinetics of
 reactions at the target (pharmacodynamics) and by other steps in the development of
 neoplasia. With few exceptions, these processes are currently undefined, and this  is a
 limitation to the ultimate aim  of dose analysis which is to have a measure of effective dose to
 the target.
      The following discussion assumes that the analyst will have data of varying detail in
different cases about pharmacokinetics and metabolism.  Discussed below are approaches to
basic data that are most frequently available, as well as approaches and judgments  for
improving the analysis based on additional data.
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 1         3.2.1. Basic Analyses
 2                When there are insufficient data available to compare dose between species,  the
 3         default assumption is that delivered doses through oral exposure are related to applied dose
 4         by a power of body weight. This assumption rests on the similarities of mammalian
 5         anatomy, physiology,  and biochemistry generally observed across species.  This assumption
 6         is more appropriate at low applied dose concentrations where sources of nonlinearity, such as
 7         saturation or induction of enzyme activity, are less likely to occur.  To derive a human
 8         equivalent oral dose from animal data, the default procedure is to scale daily applied doses
 9         experienced for a lifetime in proportion to body weight raised to the 3/4 power (W3/4).
 10       Equating exposure concentrations in parts per million units for food or water is an alternative
 11        version of the same default procedure because daily intakes  of these are in proportion to
 12       \y3/4. The rationale for this factor rests on the empirical observation that rates of
 13       physiological processes consistently tend to maintain proportionality with W3/4. A more
 14       extensive discussion of the rationale and data supporting the Agency's adoption of this
 15       scaling factor can be found  in (U.S. EPA, 1992b). Information such as blood levels or
 16       exposure biomarkers that are available for interspecies comparison is used  to improve the
 17       analysis when possible.
 18              The default procedure to derive a human equivalent concentration of inhaled particles
 19        and gases is described in  U.S. EPA (in press) and Jarabek (in press).  The methodology
20        estimates respiratory deposition of inhaled particles and gases and provides methods for
21        estimating internal doses of gases with different absorption characteristics.  The method is
22        able to incorporate additional pharmacokinetics and metabolism to improve the analysis if
23        such data are available.
24              The differences in biological processes among routes of exposure (oral, inhalation,
25        dermal) can be great because of, for example, first pass effects and differing results from
26        different exposure patterns.   There is no generally applicable method for accounting for these
27        differences in uptake processes in quantitative route-to-route extrapolation of dose-response
28        data in the absence of good  data on the agent of interest. Therefore, route-to-route
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 extrapolation of dose data relies on a case-by-case analysis of available data.  When good
 data on the agent itself are limited, an extrapolation analysis can be based on expectations
 from physical chemical properties of the agent, properties and route-specific data on
 structurally analogous compounds, or in vitro or in vivo uptake data on the agent.  Route-to-
 route uptake models may be applied if model parameters are suitable for the compound of
 interest.  Such models are currently considered interim methods; further model development
 and validation is awaiting the development of more extensive data  (see generally, Gerrity
 and Henry, 1990).

 3.2.2.  Pharmacokinetic Analyses
       Physiologically based mathematical models are potentially the most comprehensive
 way to account for pharmacokinetic processes affecting dose.  Models build on physiological
 compartmental modeling and attempt to incorporate the dynamics of tissue perfusion and the
 kinetics of enzymes involved in metabolism of an administered compound.
       A comprehensive model requires the availability of empirical data on the carcinogenic
 activity contributed by parent compound and metabolite or metabolites and data by which to
 compare kinetics of metabolism and elimination between  species. A discussion of issues of
 confidence accompanies presentation of model results (Monro, 1992). This includes
 considerations of model validation and sensitivity analysis that stress the predictive
 performance of the model.  Another assumption made when a delivered dose measure is used
 in animal-to-human extrapolation of dose-response data is that the pharmacodynamics of the
 target tissue(s) will be the same in both species. This assumption is discussed, and
 confidence in accepting it is considered in presenting results.
       Pharmacokinetic data can improve dose-response assessment by accounting for
 sources of change in proportionality of applied to internal or de21ivered dose at
various levels of applied dose.  Many of the sources of potential nonlinearity involve
saturation or induction of enzymatic processes at high doses.  An analysis that accounts for
nonlinearity (for instance, due to enzyme saturation kinetics) can assist in avoiding over-
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1        estimation or under-estimation of low dose-response otherwise resulting from extrapolation
2        from a sublinear or supralinear part of the experimental dose-response curve. (Gillette,
3        1983). Pharmacokinetic processes tend to become linear at low doses,  an expectation that is
4        more robust than low dose linearity of response (Hattis, 1990). Accounting for
5        pharmacokinetic nonlinearities allows better description of the shape of the curve at higher
6        levels of dose, but cannot determine linearity or nonlinearity of response  at low dose levels
7        (Lutz, 1990; Swenberg etal., 1987).
8
9        3.2.3.  Additional Considerations for Dose in Human Studies
10             The applied dose in a human  study has uncertainties because of the exposure
11       fluctuations that humans experience compared with the controlled exposures received by
12       animals on test.  In a prospective cohort study, there is opportunity to monitor exposure and
13       human activity patterns for a period of time that supports  estimation of applied dose (U.S.
14       EPA, 1992a).  In a retrospective cohort study, exposure may be based  on monitoring data,
15       but is often based on human activity  patterns  and levels reconstructed from  historical data,
16       contemporary data, or a combination of the two.  Such reconstruction is accompanied by
17       analysis of uncertainties considered with sensitivity analysis in the estimation of dose
18       (Wyzga,  1988;  U.S. EPA, 1986a). These  uncertainties can also be assessed for any
19       confounding factor, for which a quantitative adjustment of dose-response  data is made (U.S.
20       EPA, 1984).
21             Exposure levels of groups of people in the study population often  are represented by
22       an average when they are actually distributed in a range.  The full extent of data are
23       analyzed  and portrayed in the dose-response analysis when possible  (U.S. EPA, 1986a).
24             The cumulative dose of an agent is commonly used when modeling human data. This
25       can be done, as in animal studies, with a default assumption in the absence of data that
26       support a different dose surrogate. Given data of sufficient quality, dose rate or peak
27       exposure can be used as an alternative surrogate to cumulative dose.
28
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 3.3.  SELECTION OF QUANTITATIVE APPROACH
        The goal in choosing an approach is to achieve the closest possible correspondence
 between the approach and the view of the agent's mode(s) of action.  For this purpose, it is
 appropriate to analyze the dose-response of observed tumor  incidence and other carcinogenic
 effects as discussed above, in section 3.1. Pharmacokinetic analysis or interspecies scaling or
 other appropriate methods are used to derive human-equivalent measures of the animal-
 administered dose.  If the hazard assessment describes more than one mode of action as
 plausible and persuasive given the data available, corresponding alternative approaches for
 dose-response analysis are considered.

 3.3.1. Analysis in the Range of Observation
        The analysis first addresses responses  in the observed range.   The responses include
 tumor incidence as well as other responses relevant to carcinogenicity.  The latter may
 enlighten judgment about extrapolation or extend the range of observation (see section
 3.3.1.).
       If data are sufficient to support a biologically based model specific to the agent, this
 is the first choice for both the observed tumor data and for extrapolation to the range of
 environmental exposures of interest.  Dose-response models based on general concepts of a
 mode of action are next in amount of information required.   For a specific agent, model
 parameters are obtained from laboratory studies. Examples are the two-stage models of
 initiation plus clonal expansion and progression developed by Moolgavkar and Knudson
 (1981) and Chen and Farland (1991).  Such models require extensive data to build the form
 of the model as well as to estimate how well it conforms with the observed carcinogenicity
 data.   Theoretical values for parameters, e.g., theoretical cell proliferation rates, are not used
 to enable application of such a model (Portier, 1987).  If data are not available for such a
 model to be applied to  observed tumor incidence data,  a multistage model is appropriate for
curve-fitting as a default approach (Zeise et al., 1987), unless characteristics of the data
make another model  more appropriate.  For instance, when longitudinal data on tumor
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1        development are available, time-to-tumor or survival models may be appropriate and
2        necessary to fit the data.  Analyses of responses other than tumor effects are individually
3        designed and used to inform the extrapolation approach or used in lieu of tumor data if they
4        better portray  the biology.
5               The ED10 (dose associated with a 10% response) of the observed dose-response for
6        tumor incidence (or another effect related to carcinogenesis) or is identified.  This level is
7        adopted as a matter of Agency policy in order to remain consistent and comparable from case
8        to case; the rationale supporting this  choice is that 10% is the limit of sensitivity of most
9        studies of tumor incidence. Determination of the ED10 is a matter of judgment. Because
10       statistical considerations (e.g., the number and spacing of dose levels,  sample sizes, and the
11       precision and accuracy of dose  measurements) can affect the precision of model estimates,
12       upper and lower confidence limits are stated with the ED,0. The divergence between upper
13       and lower confidence bounds provides a sense of the precision with which the modeling can
14       make projections in that range.   The ED10 provides a point  of departure for extrapolation of
15       tumor incidence data (or a related effect) and is an estimate that can  be used for comparison
16       with similar analyses of the observed range of noncancer effects of an agent (U.S. EPA,
17       199 If) or to support hazard ranking among carcinogenic agents.  It is also employed in the
18       dose-response and risk characterizations as a basis for describing the magnitude of
19       extrapolation needed to reach the range of environmental exposure of interest.
20
21       3.3.2. Extrapolation
22              If a biologically based or mode of action-based model has been used to portray the
23       observed data and confidence in the model is good, it may be extended to the level of
24       environmental exposure of interest.  The reliability of the model is appropriately examined
25       by considering the point at which the upper and lower confidence bound on the curve diverge
26       to an unacceptable extent.  If data are insufficient to support this  extension, extrapolation
27       relies on a default procedure reflecting the general mode(s)  of action supported by the
28       available biological information.  The Agency adopts the three default procedure options
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 described below as matters of policy based on current theory of the likely shapes of dose-
 response curves for differing modes of action.  If a carcinogenic agent acts by accelerating
 the same carcinogenic process that leads to the background occurrence of cancer, the added
 effect on the population at low doses marginally above background level is expected to be
 linear. Above background level, the population response may continue to be linear (e.g., in
 the case of an agent acting directly on DNA),  or be nonlinear reflecting complex
 physiological processes or events caused by multiple reactions (e.g., numerical chromosomal
 changes following reactions with spindle proteins, interrupting spindle formation).  If the
 agent acts by mode of action  with no endogenous counterpart, a population response
 threshold may exist (Crump et al., 1976; Peto, 1978; Hoel, 1980; Lutz, 1990).  The Agency
 reviews each assessment as to the evidence on  mode of action and other biological or
 statistical evidence that indicates  the suitability of a particular procedure.  In all cases, a
 rationale is  included to justify the use of the selected procedure.

                                         Linear
       If the mode of action being considered leads to an expected linear low dose-tumor
 incidence relationship, a straight line is drawn from the EDi0 to the origin (zero dose, zero
 response) (Flamm and Winbush,  1984 ; Gaylor and Kodell, 1980; Krewski et al., 1984).
 This approach is generally conservative of public health, particularly in the absence of
 information about the extent of human variability in sensitivity to effects.

                                       Nonlinear
       The mode of action being  considered may project that the dose-response relationship
 is nonlinear or is most influenced by individual differences in sensitivity.  In this case, a
 model incorporating nonlinearity may be used to provide estimates of the proportion of the
population at risk for specific doses of interest,  e.g.,  1/1000, 1/10000 lifetime risk levels.  If
an appropriate model is not available, a margin of exposure analysis may be used as
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1        described below.  The margin of exposure is the EDJO divided by the environmental exposure
2        of interest.
3               The mode of action may be one that involves a population threshold, e.g., the
4        carcinogenicity may be a secondary effect of toxicity that is itself a threshold phenomenon.
5        In these cases, the risk is not extrapolated as a probability  of an effect at low doses.
6        Instead, a margin of exposure presentation is made in the risk characterization.  The
7        environmental exposures of interest may be  actual levels, projected levels after control, or
8        potential environmental standards. The risk manager decides whether a given margin of
9        exposure is adequate under applicable management policy criteria. The risk assessment
10       provides supporting information to assist the decision maker.  Analysis to support
11       consideration of the margin of exposure conveys as much as possible about the anticipated
12       dose-response relationship in humans.  This includes consideration of comparative sensitivity
13       of animals and humans, where animal data are the observed data, and consideration of human
14       variability in sensitivity to the putative mode(s) of action.
15
16                                       Both Linear and Nonlinear
17              Both linear and nonlinear procedures may  be used in a particular case.  If differing
18       modes of action appear to be involved in effects at different target tissues, the tissues may be
19       dealt with separately by linear and nonlinear procedures.  If a mode of action analysis finds
20       equal support for modes of action with differing implications, both linear and nonlinear
21       procedures may be used.
22              If a dose-response assessment relies on data for an endpoint other than cancer, for
23       example, endocrine disruption, the assessment is individually  designed and a rationale is
24       presented. The margin of exposure procedure is used when appropriate.
25
26       3.3.3.  Issues for Analysis of Human Studies
27              Issues and uncertainties arising in dose-response assessment based on epidemiological
28       studies are analyzed in each case.  Several sources of uncertainty need to be addressed in the
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 dose-response analysis.  Consideration needs to be given to the data on the exposure and
 mortality experience of the study population and of the population that will represent the
 background incidence of the neoplasm(s) involved.  In this area, there are potentials for
 mistakes or uncertainty in the data or adjustments to the data concerning the occurrence or
 level of exposure of the population members, mortality experience of a population,
 incomplete follow-up of individuals, exposure (or not) of individuals to confounding causes,
 or consideration of latency of response. These are assessed by analyzing the sensitivity of
 dose-response study results to errors where data permit.   Other kinds of uncertainty can
 occur because of small sample size which can magnify the effects of misclassification or
 change assumptions about statistical distribution that underlie tests of statistical significance
 (Wyzga, 1988). These uncertainties are discussed.  Where possible,  analyses of the
 sensitivity of results to the potential variability in the data in these areas are performed.
       The suitability of various available mathematical procedures for quantifying risk
 attributed to exposure to the study agent is discussed. These  methods (e.g., absolute risk,
 relative risk, excess additive risk) account differently for duration of exposure and
 background risk, and one or more can be used in the analysis as data permit.  The use of
 several of these methods is encouraged when they can be used appropriately in order to gain
 perspectives on study results.

 3.3.4.  Use of Toxicity Equivalence Factors and Relative Potency Estimates
       A toxicity equivalence factor (TEF) procedure is one used to derive quantitative dose-
 response estimates for agents that are members of a category or class  of agents. TEFs are
 based on shared characteristics that can be used to order the class members by carcinogenic
potency when cancer bioassay  data are inadequate for this purpose (U.S. EPA, 1991c).  The
ordering is by reference to the characteristics and  potency of a well-studied member or
 members of the class.  Other class members are indexed to the reference agent(s) by one or
more shared characteristic to generate their TEFs. The TEFs are usually indexed at
increments of a factor of 10.  Very good data may permit a smaller increment to be used.
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1        Shared characteristics that may be used are, for example, receptor-binding characteristics,
2        results of assays of biological activity related to carcinogenicity or structure-activity
3        relationships.
4               TEFs are generated and used for the limited purpose of assessment of agents or
5        mixtures of agents in environmental media when better data are not available.  When better
6        data become available for an agent, its TEF should be replaced or revised.  Criteria for
7        constructing TEF's are given in U.S. EPA (1991b). The criteria call for data that are
8        adequate to support summing doses of the agents in mixtures.
9               Relative potencies can be similarly derived and used for agents with carcinogenicity
10       or other supporting data.  The criteria for these basically the same as for TEF's with the
11       exception that data of a quality that will support summing doses of agents in a mixture are
12       not required.
13              The uncertainties associated with both TEF's and relative potencies are explained
14       whenever they are used.
15
16       3.4. DOSE-RESPONSE CHARACTERIZATION
17              The conclusions  of dose-response analysis are presented in a characterization section.
18       Because alternative approaches may be plausible and persuasive in selecting dose data,
19       response data, or extrapolation procedures, the characterization presents the judgments made
20       in such selections.  The results for the approach or approaches chosen are presented with a
21       rationale for the one (or more than one if they are equally supported) that is considered to
22       best represent  the available data and best correspond to the view of the mechanism of action
23       developed in the hazard assessment.
24              The exploration of significant uncertainties  in data for dose and  response and in
25       extrapolation procedures is part of the characterization. A distinction is made in the
26       presentation between model uncertainty and measurement uncertainty.  Model uncertainty is
27       an uncertainty about  a basic biological question. For example, a linear dose-response
28       extrapolation may have been made based on tumor and other key evidence supporting the
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  view that an agent's mode of action is through mutagenicity.  Discussion of the confidence in
  this approach is appropriately done qualitatively, it is not amenable to useful quantitative
  uncertainty analysis. Measurement uncertainties deal with numbers representing statistical or
  analytical measures of variance or error in data or estimates.  Uncertainties in measurement
  are described quantitatively, if practicable, through sensitivity analysis and statistical
  uncertainty analysis.  With the recent expansion of readily available computing capacity,
  computer methods are being adapted to create simulated biological data that are comparable
  with observed information.  These simulations can be used for sensitivity analysis, for
  example, to analyze how small, plausible variations in the observed data could affect dose-
  response estimates. These simulations can also provide information about experimental
  uncertainty in dose-response estimates, including a distribution of estimates that are
 compatible with the observed data.  Because these simulations are based on the observed
 data, they cannot assist in evaluating the extent to which the observed data as a whole are
 idiosyncratic rather than typical of the true situation. If quantitative analysis is not possible,
 significant measurement uncertainties are described qualitatively.  In either case, the
 discussion highlights those uncertainties that are specific to the agent being assessed, as
 distinct from those that are generic to most assessments.
       Numerical dose-response estimates are presented to one significant figure and
 qualified as to whether they represent central tendency or statistical upperbounds, and
 whether the method used is Inherently more likely to over-estimate, or under-estimate
 (Krewski etal., 1984).
       In cases where  a mode of action or other feature of the biology has been identified
 that has special implications for early-life exposure, differential effects by sex, or other
 concerns for sensitive subpopulations, these are explained.  Similarly, any expectations that
 high dose-rate exposures may alter the risk picture for some portion of the population are
 described.  These and other perspectives are recorded to guide exposure assessment and risk
characterization.  Special problems arise when the human exposure situation of concern
suggests exposure regimens, e.g., route and dosing schedule that are substantially different
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1        from those used in the relevant animal studies. The cumulative dose received over a
2        lifetime, expressed as average daily exposure prorated over a lifetime,  is generally
3        considered an appropriate measure of exposure to a carcinogen particularly for an agent that
4        acts by damaging DNA, if consistent with available data.  The assumption is made that a
5        high dose  of a carcinogen received over a short period of time is equivalent to a
6        corresponding low dose spread over a lifetime; this is based on theoretical considerations.
7        This approach becomes more problematic as the exposures in question  become more intense
8        but less frequent, or when there is evidence that the agent acts by a mode of action involving
9        dose-rate effects.  These issues are explored and pointed out for attention in the exposure
10       assessment and risk characterization.
11
12                   4.  EXPOSURE ASSESSMENT AND CHARACTERIZATION
13
14              Guidelines for exposure assessment of carcinogenic and other agents are published in
15       U.S. EPA (1992a) and are to be used in conjunction with these cancer risk assessment
16       guidelines. The  exposure characterization is a key part of the exposure assessment; it is the
17       summary explanation of the exposure assessment.  Major points of exposure characterization
18       are reiterated here to be considered in the cancer risk assessment context. The
19       characterization—
20       •      provides a statement of purpose,  scope, level of detail,  and approach used in the
21              assessment;
22       •      presents the estimates of exposure and dose by pathway and route for individuals,
23              population segments, and populations in a manner appropriate for the intended risk
24              characterization;
25       •      provides an evaluation  of the overall quality of the assessment and the degree of
26              confidence the authors  have in the estimates of exposure and dose and the conclusions
27              drawn;  and
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 •     communicates the results of exposure assessment to the risk assessor, who can then
       use the exposure characterization, along with the characterization of the other risk
       assessment elements, to develop a risk characterization.
       In general, the magnitude, duration, and frequency of exposure provide fundamental
 information for estimating the concentration of the carcinogen to which the organism is
 exposed.  These data are generated from monitoring information, modeling results, or
 reasoned estimates.  The potential for exposure via ingestion, inhalation, and dermal
 penetration from relevant sources of exposures, including  multiple avenues of intake from the
 same source, are appropriate matters  to consider in cancer risk assessment.

                           5. RISK CHARACTERIZATION

 5.1.  PURPOSE
       The risk characterization summarizes and integrates the major results of the risk
 assessment in a way  that makes them understandable for all interested readers.  Since the risk
 characterization provides a transition between risk assessment and risk management,  one of
 its objectives is to be an appraisal of the science that the risk manager can use, along with
 other decision making resources, to make public health decisions.  A complete
 characterization presents the risk assessment as an integrated, and balanced, picture of the
 analysis of the hazard, dose response, and exposure.  It is  the risk analyst's obligation to
 communicate not only summaries of the evidence and results, but also perspectives on the
 quality of available data and the degree of confidence to be placed in the risk estimates.
 These perspectives on the science include explaining the constraints of available data and the
 state of knowledge about the phenomena studied.  All of this is in aid of a major aim of
 characterization which is to explain not only significant scientific issues, but also the
 significant science and science policy choices made when alternative interpretations of data
exist.
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                                  DRAFT-DO NOT QUOTE OR CITE
1        5.2. APPLICATION
2               A risk characterization is a necessary part of any Agency report on risk, whether the
3        report is a preliminary one prepared to support allocation of resources toward further study
4        or a comprehensive one prepared to support regulatory decisions.  In the former case, the
5        detail and sophistication of the characterization are appropriately small in scale, in the latter
6        case, appropriately extensive.  Even if only parts of a risk assessment (hazard and dose-
7        response analyses for instance) are covered in  a document, the risk characterization matches
8        the extent of coverage of the document.
9
10       5.3. CONTENT
11              Each of the following subjects should be covered in the risk characterization.
12
13       5.3.1.  Presentation
14              The presentation of the results of the assessment should fulfill the aims as outlined in
15       the purpose section above. The summary draws from the key points of the individual
16       characterizations of hazard, dose response, and exposure analysis performed separately under
17       these guidelines.  The summary integrates these characterizations into an overall risk
18       characterization (AIHC, 1989).
19              The presentation of results clearly explains the numerical estimates of risk.  For
20       example, when estimates of individual risk or population risk (incidence) are used, there are
21       several features of such estimates that risk managers need to understand.  They include, for
22       instance, whether the numbers represent average exposure circumstances or maximum
23       potential exposure.  The size of the population considered to be at risk and the distribution of
24       individuals' risks within the population should be given.  When risks to a sensitive
25       subpopulation have been identified and characterized, the explanation covers the  special
26       characterization of this population.
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        The presentation identifies and explains the significant issues encountered when the
 data support alternative interpretation, describes the choice made and the scientific or science
 policy rationale for the choice.

 5.3.2.  Strengths and Weaknesses
        The risk characterization summarizes the kinds of data brought together in the
 analysis and the reasoning upon which the assessment rests.  The description conveys the
 major strengths and weaknesses of the assessment that arise from availability of data and the
 current limits of understanding of the process of cancer causation.  Health risk is a function
 of the three elements of hazard, dose response, and exposure.  Confidence in the results of a
 risk assessment is,  thus, a function of confidence in the results of the analyses of each
 element.  The important issues and interpretations of data are explained, and the risk
 manager is given a clear picture of consensus or lack of consensus that exists about
 significant aspects of the assessment.  In addition, the peer-reviewed conclusions of other
 governmental or international bodies are provided for information.  Whenever more than one
 view of the  weight of evidence or dose-response characterization is supported by the data and
 the policies  of these guidelines, and when choosing between them is difficult, the views are
presented together.  If one has been selected over another, the rationale is given; if not, both
are presented as plausible alternative results.  If a quantitative uncertainty analysis  of data is
appropriate, it is presented in  the risk characterization; in  any case, qualitative discussion of
important uncertainties is appropriate.
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Thompson, T. C.; Southgate, J.; Kitchener, G.; Land, H. (1989) Multistage carcinogenesis
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1                             APPENDIX A:  EXAMPLES OF NARRATIVES
2
3                                              Narrative # 1
4                                              CAS#XXXX
5
6                The main kinds of evidence available for consideration of potential human
7         carcinogenicity of this metal conjugated aliphatic phosphonate are animal studies of
8         tumorigenicity, short-term tests of genotoxicity and animal studies of toxicity.  No human
9         data are available.  The animal studies provide a reasonable basis for understanding the
10        reasons for carcinogenic effects of the compound in laboratory animals and their
11        applicability for judging potential human carcinogenicity.
12               Metal conjugate  caused a statistically significant increase in the incidence of urinary
13        bladder hyperplasia and tumors (urinary bladder transitional cell papillomas and carcinomas)
14        in male, but not female, Charles River CD rats at 30,000 ppm in the diet in a long-term
15        study.  Some high dose animals had urinary tract stones.  No tumors, hyperplasia or stones
16        were seen in two lower dose groups (2,000 and 8,000 ppm) in the same study.  A study in
17        Charles River CD-I male and female mice at similar dietary doses to those hi the rat study
18        showed no tumor response or urinary  tract effects.  A two-year study in dogs at doses up to
19        40,000 ppm showed no urinary tract effects. A major metabolite of metal conjugate that
20        contains the phosphonate moiety caused no tumor response or urinary tract effects in a well-
21        conducted two-year bioassay hi rats.
22               In a 90-day study hi the same rat strain, observations of urinary tract function and
23        histopathology revealed a pattern of physiological changes hi both males and females at doses
24        in the same range as the chronic bioassay (8,000, 30,000, 50,000 ppm).  These included
25        proteinuria, increased blood phosphorus and urinary calcium, diuresis, and a sharp drop in
26        urine pH.  The calcium effects and diuresis were seen only at doses at or above 30,000 ppm,
27        and were more pronounced hi the males.  Histopathology evaluation revealed a pattern of
28        cytotoxicity hi the urinary tract with hyperplasia hi the urinary bladder that was seen at doses
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 at or above 30,000 ppm and significantly more extensive in the males.  In males, but not
 females, urinary bladder stones containing calcium and phosphorus  were observed in
 association with bladder hyperplasia.  Treatment of male rats for at least eight weeks
 followed by a return to normal diet for up to 21  weeks showed significant reversibility in the
 frequency  of both stones and bladder hyperplasia.  A three-generation reproductive study hi
 rats showed urinary tract toxicity consistent with the results of the 90-day study: stones,
 cytotoxicity, and hyperplasia at 24,000 ppm; no urinary tract effects at 6,000 or 12,000 ppm.
       Short-term studies including an in vivo mouse micronucleus test, gene mutation tests
 in Salmonella, and DNA damage tests hi yeast indicate that metal conjugate is not genotoxic.
 Confidence hi the extent and nature of this data set is considered medium for supporting this
 conclusion. Metal conjugate is not hi a structural chemical category characterized as having
 carcinogenic effects hi the urinary tract.
       The results of the tumorigenicity, toxicity, and genotoxicity studies support a
 conclusion that the male rat tumors were the result of high dose toxicity hi the urinary tract.
 It is clear that formation of stones hi the male rat caused profound hyperplasia which, in
 turn, led to tumor formation.  The  corollary  would be: No stones, no tumors.
       It is concluded that metal conjugate is likely to be carcinogenic to humans only under
 conditions  that repeat the pattern of effects seen in the male rat at high doses and not likely
 without those conditions.  Likewise, it is unlikely to be a human carcinogen under conditions
 hi which bladder stone formation is unlikely to develop.  Certain observations suggest that
 humans are much less sensitive to this particular carcinogenic process than are male rats.
 First, of the several species and sexes  studied at high doses, only the male rat responded with
effects hi the urinary tract.  Second, in rodents, bladder stones  of any composition including
inert materials like glass frequently lead to tumor development.  Third, there is little
indication that humans with bladder stones have a corresponding tumor response in the
bladder.  As the data support the view that carcinogenicity would be secondary to toxicity of
the chemical, it is recommended that metal conjugate dose-response and human exposure
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analyses of high exposure scenarios be developed to support a margin of exposure approach
to human risk characterization.
       Uncertainties include (1) incomplete data on the relationship between stone formation
and neoplasia in the human bladder, (2) whether the observations in the rat are biologically
relevant to humans.  Overall, the conclusions drawn about the process  of carcinogenesis in
the male rat are strongly based.  The inference that this process would occur in humans is
weak.

                                     Narrative # 2
                                      CAS# XXX

       The potential for human carcinogenicity of aromatic alkene (ar-alkene) cannot be
determined from the available data. However, evaluation of animal studies and short-term
studies on ar-alkene and its metabolite suggest an hypothesis as to potential carcinogenicity
that requires further research, and the chemical is a testing candidate.  Epidemiologic studies
performed on ar-alkene are considered inadequate for evaluation.
       In a two-year gavage bioassay hi F344/N rats and B6C3F1 mice, male mice showed a
statistically significant, increased incidence of combined adenomas and carcinomas  of the
lung. However, the NTP, sponsor of the bioassay, considered the response equivocal
because of experimental design problems.  Two inhalation studies hi Sprague-Dawley female
rats showed increased incidence of mammary tumors which was  considered equivocal
because of lack of a dose-response trend and high historical incidence of this response.
Studies hi these rats by gavage or ip injection were negative.  The metabolite is rapidly
broken down at the pH of the glandular stomach; thus, no internal dose is expected from
administration by this route.
       Ar-alkene is mutagenic hi bacterial test systems only with metabolic activation.  Both
positive and negative responses were seen hi mammalian cells in  vitro.  The metabolite is
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 clearly mutagenic in numerous in vitro tests. Both ar-alkene and its metabolite produce
 inconsistent results in in vivo test systems.
        Ar-alkene is fat soluble and readily absorbed by all exposure routes. It is distributed
 generally in the body. The kinetics of conversion of ar-alkene to its metabolite and the
 bioavailability of the metabolite have not been well characterized. ,If ar-alkene has
 carcinogenic potential, the long-term animal studies and the mutagenicity tests suggest that
 this potential will depend on the bioavailability and activity of the metabolite.  At present,
 the data on these factors are not strong enough to support a conclusion.  Depending on the
 pharmacokinetics of ar-alkene  and  its metabolite, carcinogenicity may result from
 bioavailability of the metabolite at  the site of administration or at internal tissues sites.
 Further study, preferably by inhalation, is needed.

                                      Narrative #3
                                       CAS# XXX

       Information on this chlorinated cyclic hydrocarbon includes case histories of exposed
humans, tumor findings  in the  liver of mice but not hi rats, and the absence of genotoxic
effects hi short-term tests.
       Some persons with aplastic  anemia have reported exposure to the chemical; some of
these people have also developed leukemia.   No other information on humans exists as to
potential carcinogenic effects.
       Multiple feeding  studies in males and females of several strains of mice indicate that
exposure to the chemical leads  to hepatocellular tumors. Tumors were not found at other
anatomical sites in mice  or at any site in two chronic rat feeding studies.
       The chemical is a potent inducer of liver microsomal enzymes at doses associated
with liver cancer  in mice.  Chemical administration leads to liver enlargement due hi part to
increases in liver cell size; this enlargement persists until tumor development.  The extent to
which the chemical leads to increases in cell proliferation has not been established. Some
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1          studies indicate that the chemical may increase the amount of reactive oxygen radicals and
2          lipid peroxidation at high doses.  It promotes liver tumors in mice following initiation by a
3          genotoxic agent at doses associated with tumors from exposure to the chemical alone.
4                Testing for genotoxicity has generally led to negative findings, and there are no
5          structural alerts.  The chemical does not increase the frequency of gene mutations in bacteria,
6          fungi and algae; there is a questionable increase in cultured mouse lymphoma cells.  No or
7          marginal increases in structural aberrations were noted in two studies of cultured Chinese
8          hamster cells and in a study of Syrian hamster bone marrow cells in vivo; there was no
9          increase in sister chromatid exchanges in the cultured hamster cells.
10               Uncertainties include the finding that the only indication of a carcinogenic response
11         comes from the mouse liver, the most common cancer site in rodents and the  one that is
12         uniquely positive with many other chlorinated hydrocarbons. Other  sites in the mouse and
13         all of them in the rat fail to indicate a carcinogenic potential.  There is no significant
14         genotoxic potential or structural indicators of carcinogenicity.   Cancer responses are
15         associated with high doses that lead to induction of liver microsomal enzymes and potential
16         reactive oxygen species.
17               It is hard to interpret the carcinogenic findings; there are cancer responses in the
18         mouse liver, but they occur at high doses of this nongenotoxic compound that are associated
19         with demonstrable effects on the liver, doses that are far above anticipated human exposures.
20         Overall, the evidence is on the border between a likely human carcinogen and cannot be
21         determined.  Further mechanistic work is needed to  differentiate these alternatives. Until
22         such time, it will be assumed that the chemical is likely to be a human carcinogen. Cancer
23         risks should be evaluated by a margin of exposure evaluation.
24
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                                     Case Study # 4
                                      CAS# XXX
       There are no tumor data on this bis-benzenamine. Evaluation of its carcinogenic
 potential comes from tumor studies on structural analogues and toxicity information on the
 chemical and its analogues.  The chemical is considered likely to be carcinogenic to humans
 by all routes of exposure. Mechanistic information helps to associate findings in animals
 with those in exposed humans.
       Close structural analogues produce thyroid follicular cell tumors and hepatocellular
 tumors hi rats and mice following ingestion. The thyroid tumors are associated with known
 perturbations in thyroid-pituitary functioning. These  compounds inhibit the accumulation of
 iodide into the  thyroid gland, apparently due to inhibition of the enzyme that synthesizes the
 thyroid hormones.  Accordingly, blood levels of thyroid hormones decrease,  which induce
 the pituitary gland to produce more TSH, a hormone that stimulates  the thyroid to produce
 more of its hormones. The thyroid gland becomes larger due to increases in the size of
 individual cells and their proliferation and, upon chronic administration, tumors develop.
 Thus, thyroid tumor development in rats is significantly influenced t>y disruption in the
 thyroid-pituitary axis.
       Human  and rat thyroid glands respond similarly to short-term exposure.  Worker
 exposure has not been well characterized or quantified, but recent medical monitoring of
 workers exposed over a several year period has uncovered decreases in thyroid hormones,
 increases hi TSH and symptoms of hypothyroidism. A urinary metabolite of the chemical
has been monitored in the workers. Its concentration was only about 2-fold lower  than that
hi rats receiving the chemical for 28-days,  which led to similar changes in thyroid  and
pituitary hormones.  In addition, the dose of the chemical given to rats hi this study was
essentially the same as that of an analogue that had produced thyroid tumors hi rats.
Although the human thyroid responds as does that of rodents following limited exposure, it is
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 1          not well established that thyroid-pituitary imbalance leads to cancer in humans as it does in
 2          rodents.
 3                 The chemical is an aromatic amine, a member of a class of chemicals that has
 4          regularly produced carcinogenic effects in rodents;  some have produced cancer in humans.
 5          Structural analogues are genotoxic; they produce gene mutations in cultured bacteria  and
 6          mammalian cells and structural chromosome aberrations and DNA damage in mammalian
 7          cultured cells; these are characteristics of chemicals that produce cancer hi multiple
 8          anatomical  sites and species.  The genotoxic effects could influence the development  of
 9          tumors in the thyroid and liver.
 10               Given the information at hand on potential thyroid and liver tumors hi rodents among
 11        close structural analogues, it is reasonable to conclude that the chemical is likely to be a
 12        human carcinogen.  Biological information on the compound leads one hi differing directions
 13        as to how to quantitate potential cancer risks.  The  information on disruption on thyroid-
 14        pituitary status argues for using a margin of exposure evaluation, whereas that bearing on the
 15        chemical's being an aromatic amine and having gene and structural chromosome mutation
 16        activity, coupled with a lack of mode of action information on the liver tumors, points
 17        toward a low dose linear approach. In recognition  of these differences,  it is appropriate to
 18        quantitate thyroid tumors using both a nonlinear or  margin of exposure and linear techniques;
 19        liver tumors should be evaluated by the linear approach. Tumor data on the close analogues
20        should be utilized in projections of potential risks from exposure.  Given the absence of
21         direct tumor information on the chemical per se, potential risks should only be presented as
22        screening estimates with rough order-of-magnitude values.  The chemical can be absorbed by
23         the oral, inhalation and dermal routes of exposure.
24              Uncertainties include (1) the lack of carcinogenicity studies on the chemical, (2) the
25         employment of data on structural analogs, (3) the lack of established information on the
26         relevance of thyroid-pituitary unbalance for human  carcinogenicity, and  (4) the different
27         potential mechanisms that may influence tumor development and potential risks.  Overall,
28         this is a strong inferential case for potential human  carcinogenicity.
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                                      Narrative #5
                                      CAS#XXXX

        The main evidence available for consideration of potential human carcinogenicity of
 chlorinated alkene (cl-alkene) includes animal studies of tumorigenicity, short-term tests of
 genotoxicity, and studies of metabolism and toxicity of this and related chlorinated aliphatics.
 Epidemiologic studies have been made of workers exposed to cl-alkene, but the studies do
 not demonstrate either an association or lack of one between cancer and exposure to cl-
 alkene.  The chemical is considered likely to be carcinogenic to humans by all routes of
 exposure.
        Administration of cl-alkene by gavage (corn oil vehicle) or by inhalation to B6C3F1
 mice in long-term studies caused statistically significant, dose-related increases in
 hepatocellular carcinomas hi both sexes as well as reduced time-to-tumor hi the gavage
 studies.  Doses were 0,  100, 200 ppm hi the inhalation study; time-weighted average doses
 hi the gavage studies were 536 or 1072 mg/kg and 300 or 600 mg/kg to male  and female
 mice, respectively.  In long-term inhalation studies hi F344/N rats (0, 200, 400 ppm)
 tubular cell hyperplasia was observed hi male rats and hi one high dose female. Renal tubule
 neoplasms were observed in male rats.  The response was not statistically significant by
 pairwise comparison, but there was a statistically significant, positive dose-response trend.
 The historical control incidence of renal tubule tumor in F344/N males is less  than 1/2%.
 The probability of observing two such rare tumors in 50 animals is less than 0.001.  A
 second response observed hi the rat study was an increased incidence of mononuclear cell
 leukemia.  Analyses of the incidence of disease in the study and supplementary analyses of
the progression of the disease showed that there was  a statistically  significant,  increased
incidence in low dose males and females, in high dose males and, marginally,  hi high dose
females. In addition, there was a  significant increase in extent of the disease hi treated
animals of both sexes and a significant shortening of the tune of disease onset  in females.  In
long-term studies hi Sprague-Dawley rats by gavage and inhalation, slight, but not
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statistically significant, increases in kidney tumors were noted; there were no observations of
mononuclear cell leukemia.  In chronic and subchronic studies,  cl-alkene has demonstrated
nephrotoxicity in both rats and mice.
       Cl-alkene has been tested in numerous test systems for mutagenic effects; results
indicate that the compound is not genotoxic.  Primary metabolites of cl-alkene also test as not
genotoxic.  A pathway of metabolism identified in the rat generates a secondary mutagenic
metabolite in the rat kidney at high doses; this pathway is also active in humans.  In general,
cl-alkene shares chemical characteristics of related chlorinated ethanes and ethenes in toxicity
and tumorigenicity particularly, but not exclusively, toward the  mouse liver and rat kidney,
and in lack of DNA reactivity or mutagenicity in short-term studies.  Similarly, the primary
metabolites of these compounds are not notably genotoxic.
       More than one mechanism has been proposed by which cl-alkene might cause each
tumor response; available data do not clearly support any of the various mechanistic views.
If a single mechanism accounts for the compound's activity, it is not genotoxicity.  The
mononuclear leukemia and liver responses in rodents  suggest a general accelerating
influence on underlying neoplastic processes.  The kidney response might be associated with
the toxic effects of cl-alkene in the kidney or with mutagenic activity of the secondary
metabolite; the  data do not show an answer.   As a whole the data do not point to the linearity
at low doses generally expected of mutagenic compounds, nor are the data  strong enough to
describe how cl-alkene might have a threshold or non-linear dose response relationship  at low
doses. It is recommended that two assessments of dose response and of exposure to cl-
alkene be developed;  one using a model that assumes  linearity  at low  dose, a second to
support a margin of exposure approach to human risk characterization.
       Uncertainties include (1) how the compound acts to  influence carcinogenic processes
in animals, and how it might act in humans, and (2) implications of the data for dose
response assessment.
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                                       Narrative # 6
                                        CAS#XXX

        Human and animal studies indicate that this metal is likely to be carcinogenic to
 humans by inhalation and not likely to be carcinogenic via oral or dermal exposure.
 Absorption of compounds of the metal varies significantly by route of exposure:  inhalation
 > oral > >  dermal.  Toxic  mechanisms are not established, but interference with essential
 metals and complexes with certain proteins may be operative.  There is some evidence for
 genotoxic effects in cultured cells, but it is not expected that the metal  would directly react
 with DNA.
        Several epidemiologic studies of workers exposed to the metal in the air have been
 conducted. Increases  in lung and prostatic  cancer have been reported in some but not all
 studies. Interpretation is hindered by the presence of concomitant confounding workplace
 exposures (e.g., arsenic)  and  influences of smoking.
        In the only rodent inhalation study, rats developed significantly increased incidences
 of lung cancer. In contrast to these findings, multiple feeding and drinking water studies in
 rodents have failed to  indicate carcinogenic responses from daily doses  up to over 100-times
 those in the inhalation study.  Increases in testicular interstitial cell tumors have been found
 in rodent injection studies of soluble metal salts.  These compounds lead to  necrosis of the
 testicular germ cell epithelium due to changes in the blood supply with  corresponding
 increases in hormones that stimulate the interstitial cells; such studies are not considered to
 be applicable to human exposures.
       Compounds of the metal vary significantly in their solubility:  the metal and many
 salts are very insoluble, whereas a few of the salts are readily soluble.  Following inhalation,
 about 50% of the metal is absorbed into the body, while only about 5%  is absorbed from the
gut (10-fold lower than via inhalation). Dermal absorption is insignificant.
       The metal may have  genotoxic potential as well -as other toxic properties; both should
be considered in evaluating potential risks of exposure.  It competes and interferes with the
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1         functioning of a number of requked metals; it also can bind to certain parts of proteins
2         (sulfhydryl groups) and interfere with their activity.  In genotoxicity studies, it is generally
3         negative for gene mutations hi bacteria but positive hi cultured mammalian cells.  Although
4         conflicting observations for structural chromosome aberrations have been found in human
5         lymphocytes cultured from exposed workers and hi cell lines exposed in culture, negative
6         findings have  been noted hi mouse bone marrow studies. It is not expected that the metal
7         would directly interact with and damage cellular DNA.  The evidence does not support a
8         conclusion as  to the mode of action; it is recommended that both a linear and nonlinear or
9         margin of exposure approach be taken to dose-response assessment.
10
11                                             Narrative # 7
12                                              CAS # XXX
13
14               There  is strong evidence that short-chain alkene (SCA) is likely to be a human
15        carcinogen via the inhalation pathway. This conclusion is based on an inhalation animal
16        bioassay (involving both sexes of two species) of SCA showing an unambiguous positive
17        responses and is supported by genotoxicity and metabolic data.  We can infer that SCA is
18        also likely to be a human carcinogen for the ingestion and dermal pathways.  Some human
19        studies were positive, but methodological problems make them inconclusive.
20               In the  animal bioassay, rats and mice were exposed  hi air on a schedule simulating
21        occupational exposure.  Exposure levels were 625 and  1,250 ppm for mice, and 1,000 and
22        8,000 ppm for rats.  Statistically significant increases hi tumor rates were observed hi
23        multiple sites  hi both sexes of both species.  In the case of  the mice, early high mortality due
24        to the tumors  was observed.
25               SCA and its metabolites are positive in several genotoxicity tests, including mutage-
26        nicity tests hi bacteria with metabolic activation.  Several metabolites of SCA are alkylating
27        agents and are directing  acting mutagens hi bacterial tests.  Moreover, metabolism experi-
28        ments hi both rats and mice using radio-labeled SCA show  binding to nucleoproteins and
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 DNA. SCA is also structurally related to other compounds which are positive in animal -bio-
 assays.
        There have been five occupational epidemiology studies involving inhalation exposure
 to SCA.  Three of them showed statistically significant risks of cancer; however, hi two of
 them, workers were also exposed to solvents and the third did not control for smoking.  The
 two negative studies were flawed by low power and possible bias. Thus, the human studies
 considered together are inconclusive.
        The direct evidence for carcinogenicity of SCA is based on inhalation exposure.
 However, since the observed tumors in the animal bioassay  occurred at several sites distant
 from the  portal of entry, and since the compound can be absorbed through the
 gastrointestinal tract and the skin, we assume that it is also likely to be a human  carcinogen
 through these pathways as well.
       Based on pharmacokinetic, metabolism and genotoxicity data, linear extrapolation of
 response to low doses is felt to be appropriate.  Studies of the pharmacokinetics of SCA hi
 rats and mice indicate first-order kinetics below a saturation  level. Metabolites of SCA are
 genotoxic and are likely to be carcinogenic, and, although the metabolic pathway is
 saturable, tumors were observed in the bioassay at exposure  levels lower than the saturation
 level.
       Although the case for carcinogenicity of SCA is very strong, there are some
uncertainties.  Since the epidemiological data are inconclusive, we face the usual
uncertainties  in extrapolating from animals to humans. We have an unusually strong set of
mechanistic data supporting linear extrapolation, but uncertainties  hi extrapolating from high
to low doses  remain, as always.
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1                                              Narrative # 8
2                                               CAS # XXX
3
4                Organophosphate has been tested in several animal bioassays, one of which produced
5         positive results but was possibly flawed, and others which were negative or provide limited
6         support for those results.  Genotoxicity and metabolism data also include some that support a
7         concern about carcinogenicity but do not constitute a consistent pattern. No human data are
8         available.  Thus, from the data, one cannot determine the likelihood of human
9         carcinogenicity.
10               Three chronic feeding studies have been performed with rats.  In a study with
11        Osborne-Mendel rats, statistically significant increases were observed hi combined benign
12        and malignant kidney tumors in both dose groups for males and hi high-dose females, as
13        compared with pooled controls.  A statistically significant trend hi malignant pancreatic
14        tumors and benign thyroid tumors was found hi males only.  Concerns were raised in audits
15        of the test facility where this study was performed.  In a second study with Sprague-Dawley
16        rats, a non-statistically-significant increase  hi benign  thyroid tumors was observed in males.
17        In a third study with Wistar rats, a statistically significant increasing trend was observed in
18        benign pancreatic tumors in males.
19               Two studies have been performed with mice.  In the first, no excess of tumors  was
20        found, but the study was  flawed.  In the second, statistically significant increases were
21        observed of benign lung tumors in males and of malignant lymphomas in females, both at a
22        low dose,  but similar increases were not found  at two higher doses.
23               Evaluating the rat data together, we see  that the strongest result was observed in the
24         Osborne-Mendel rat study, about which doubts  have  been raised hi an audit.  In the Sprague-
25         Dawley rat study, an increase, although not statistically significant, was observed in the same
26         type of tumor hi the same sex as one of the Osborne-Mendel rat responses.  Similarly, in the
27         Wistar rat study, a statistically significant trend was  observed hi the same sex and site as one
28         of the Osborne-Mendel rat responses, although only  benign tumors were seen in  this study.
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 The latter two studies have limited weight in reaching a conclusion that the compound is
 carcinogenic in humans, since only benign tumors were found, but they tend to confirm the
 results of the first study because the tumors were observed hi the same sites. The sort of
 problems noted hi the audit of the facility where the Osborne-Mendel rat study was
 performed - poor record keeping, possible misdosing of the animals - are more likely to
 mask a positive result than to create a false positive, but they do raise a concern about
 reliance on the results.
       The two studies hi mice can be discounted, the first because of flawed methodology,
 the second because the response was seen only at one low dose.
       In genotoxicity testing, the compound was found to cause unscheduled DNA
 synthesis, but other tests were negative or (hi one case) equivocal. This forms the basis for
 some concern, but is not strong enough or consistent enough to contribute significantly to a
judgment on human carcinogenicity. The compound is not structurally related to known
 human or animal carcinogens.
       In summary, there are one positive, but possibly flawed, animal feeding study and
 two other animal studies showing weakly positive results hi the  same sites. No human data
 are available,  and the other data are inconclusive.  This set of data as a whole does not
 support a  determination of human carcinogenic potential.
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                                                          3S-U.S. GOVERNMENT PRINTING OFFICE: 1994 - 550-064/80017

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