EPA 600-6-87-007a
                                                           PB88-127105
                   INVESTIGATION OF CANCER RISK ASSESSMENT METHODS:
                   SUMMARY
                   Clement  Associates, Incorporated
                   Ruston,  LA
                   Sep 87

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                                   TECHNICAL REPORT DATA          PB88-127105
                            tricase read Imuiiclium on the ret trie before completing/
I  REPORT NO
  EPA/600/6-87/007a
TITLE AND SUBTITLE
 Investigation of Cancer Risk Assessment  Methods;
 Summary
                                                         3. RECIPIENT'S ACCESSION N
                                                           5 REPORT DATS
                                                             September  1987
                                                           6. PERFORMING ORGANIZATION CODE
7  AOTMOR1S> Bruce C. Allen,  Annette M. Shipp, Kenny  S.
  Crump, Bryan Kilian, Mary Lee Hogg, Joe Tudor,
  Barbara Keller	
                                                           8. PERFORMING ORGANIZATION REPORT NO
9 PERFORMING ORGANIZATION NAME AND ADDRESS
                                                           10. PROGRAM ELEMENT NO.
  Clement Associates,  Inc.
  1201 Gaines Street
  Ruston, LA  71270
                                                          11. CONTRACT/GRANT NO.

                                                              68-01-6807
12 SPONSORING AGENCY NAME AND ADDRESS
  Office of Health and  Environmental  Assessment
  Carcinogen Assessment Group (RD-639)
  U.S.  Environmental Protection Agency
  Washington, DC  20460
                                                           13. TYPE Of REPORT AN.1 PERIOD COVERED
                                                          14. SPONSORING AGENCY CODE
                                                            EPA/600/?!
IS. SUPPLEMENTARY NOTES
                    EPA  Project Office*:  Chao Chen,  Carcinogen Assessment Group
  Office of Health and Environmental Assessment, Washington, DC  (382-5719)
is.ABSTRACT jhe major focus  of this study is upon making  quantitetive comparisons  of
  carcinogenic potency  in animals and humans for 23  chemicals for which suitable
  animal  and human data exists.   These comparisons  are  based upon estimates  of risk
  related doses (RRDs)  obtained from both animal and human data.  An RRD represents
  the average daily dose per body weigh", of a chemical that would result in an  extra
  cancer risk of 25%.   Animal  data on these and 21 other chemicals of interest  to the
  EPA and the 000 are coded into  an animal data base that permits evaluation  by
  computer of many risk assessment approaches.
       This report is the result  of a two-year study to  examine the assumptions,
  other than those involving low  dose extrapolation, used in Quantitative cancer  risk
  assessment.  The study was funded by the Department of Defer.se [through an  inter-.
  agency transfer of funds  to the Environmental Protection Agency (EPA)J, the EPA,
  the Electric Power Research Institute and, in its  latter stages, by the Risk  Science
  Institute.
                                KEY WORDS ..NO DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTlFIEHS/OPEF-' ENDED TERMS  C. COSAT' Field/Group
                              REPRODUCED BV
                                   U.S. DEPORTMENT OF COMMERCE
                                         MATIONAL TECHNICAL
                                         0- f-OBMATION SERVICE
                                         Sf HINGFIELD. VA. 22161
13. DISTRIBUTION STA"6H6NT

  Distribute  to public
                                            19. SECURITY CLASS 
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                                 DISCLAIMER

     This document has been reviewed in accordance with the U.S. Environmental
Protection Agency's peer and administrative review policies and approved for
publication.  Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.   The information in this document has
been funded by the U.S. Environmental Protection Agency, the Department of
Defense (through Interagency Agreement  Number RW97075101), the Electric
Power Research Institute, and the Risk  Science Institute.

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                                CONTENTS
                                                                   Pogs

B-ief Summary of Major Conclusions                                    1
Introduction                                                          3
Data Bos*                                                             5
Analysis of Epidemiologicol Onto                                      9
Analysis of Animal Data                                              13
Investigation of Component -Specific Uncertainty                      18
Methods for Comparison of Animal and Human Results                   19
Results of Animal and Human Comparisons                              22
     Correlation Analyses                                            22
     Prediction Analyses                                             26
Discussion                                                           32
     General Considerations                                          32
     Directions for Future Research                                  33
                               m

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                              ILLUSTRATIONS
1  B«ftt Estimates and Upper and ! ower Bounds                          53
   for RRDs From Each Human Study
2  Correlation of Animal, and Human RRDs - Analysis 0                  95
3  Correlation of Animal and Huiitan RRDs - Analysis 3b                 56

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                                TABLES
                                                                   Poqe
 1   Approaches  to  RisK Assessment Components                          40
 2   Summary  of  Animal Data  by Chemical                                42
 3   Chemicals for  Which Minimal  Human and  Animal  Data                 44
    Exist  for Quantifying Carcinogenic  Potency
 4   Descriptions of  Initial Analyses                                  45
 5   Descriptions of  Supplemental Analyses                             47
 6   Ranks  Based on Length of Experiment and                           48
    Number of Treated Animals
 7   Component-Specific Uncertainty: Modes  and Dispersion             49
    Factors  for Ratios of RROs,  by  Supplemental  Analysis
 8   Correlation Coefficients and Associated  p-values,                 5C
    by Analysis Method
 9   Conversion  Factors Corresponding  to Various  Dose Units,           51
    by Method of  Analysis
10   Comparison  of  Results for  Selected  Analyses                       52

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                   BRIEF SUMMARY OF MAJOR CONCLUSIONS
The major focus of this study is upon making quantitative comparisons of
carcinogenic potency in animals end humans for 23 chemicals for which
suitable animals and human data exists. These comparisons are based upon
estimates of "RRDs" obtained from both animal and human data.  An RRD
represents th-j average daily dose per body weight of a chemical that
would result in an extra cancer risk of 25%.  Animal data on these and
21 other chemicals of interest to the EPA and the DCD are coded into an
animal data base that permits evaluation by computer of many risk
assessment approaches.

The major findings of this study are as follows:

1.  Animal and human RRDs are strongly correlated.  The knowledge that
    this correlation exists  between animal  and  human carcinogenicity
    data should strengthen the  scientific basis for cancer risk assess-
    ment and cause increased confidence to  be placed in estimates of
    human cancer  risk made from animal data.

2.  In the majority of  cases considered,  analysis methods  for  bioassay
    data that  utilize  lower  statistical confidence  limits  as predictors
    yield better  predictions of human  results than  do  the  same methods
    using maximum likelihood estimates.

3.  Analysis methods  for  animal data that utilize median  lower bound
    RRDs determined from  the ensemble of  data for a chemical generally
    yield better  predictions of human  results then  analyses  that  utilize
    minimum RRDs  calculated  from  all the  studies available.

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4.  Use of the "mg intoke/kg body weight/doy" (body weight) method for
    animl-to-human extrapolation generally cause* RRDs estimated from
    animal and human data to correspond more closely than th* othsr
    methods evaluated,  including the "mg intoko/m2 surface area/day"
    (surface area) method.

5.  The risk assessment approach for animal data that was intended to
    mimic that used by the EPA underestimates the RRDs (equivalent to
    overestimating human risk) obtained from the human data in this
    study by about an order of magnitude,  on overage.  However, it
    should be understood that the risk assessment approaches implemented
    in this study are computer automated and do not always utilize the
    same data or provide the same result as the EPA approach.

6.  Reasonable risk analysis methods can be defined for the chemicals in
    this study that reduce  the residual loss (roughly the average
    multiplicative factor by which  the RRD predictors obtained from  the
    animal  data are inconsistent with the ranges  of human RRDs consis-
    tent with the  human  data) to  1.7.  This  is  not the  srme as saying
    that the  predictors  are accurate to within  a  factor of  1.7,  because
    the estimated  ranges of human RROs that  are consistent with  the
    human  data cover  an  order of  magnitude or more for  most chemicals.

 7.  It has been  possible to identify  a  set  of analysis  methods using the
    median lower  bound estimates that  are  most  appropriate for extrapo-
    lating risk  from animals  to humans,  given the current state  of know-
    ledge and data analysis.   It is possible to use the information and
    results presented in this investigation to  calculate ranges  of risk
    estimates that are consistent with the data and also incorporate
    many uncertainties associated with the extrapolation procedure.

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8.  The many components of risk assessment are interrelated and evalua-
    tion of risk assessment methods should focus on the complete risk
    assessment process rather than on individual components.

9.  The data base and methods used in this study can provide a useful
    basis for evaluating various risk assessment methods.

This study only compared human and animal results for a relatively high
risk level.  It did not examine the uncertainty inherent in the low dose
extrapolation process.

                               INTRODUCTION

This report is the result  of a two year study to examine the assump-
tions, other than those involving low dose extrapolation,  used in
quantitative cancer risk assessment.  The study was funded by the
Department of Defense  [through an interagency transfer of  funds to the
Environmental Protection Agency (EPA)], the EPA, the Electric Power
Research  Institute and, in its latter stages, by the Risk  Science
Institute.  The objectives of  the study are as follows:

     1.   To identify and express quantitatively uncertainties that are
          involved in the process of risk estimation, excluding the
          uncertainties in  the  low dose extrapolation model;
     2.   To examine the impact of the different assumptions that ars
          made in risk  estimation;
     3.   To compare results calculated  from human  and  animal data,
          including the identification of the  assumptions  that  produce
          the best correlation  of risk estimates between  humans and
          animals;
     *».   To develop guidelines for  presenting a range  of  risk  estimates
          based  on  different but  scientifically  acceptable assumptions or

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         assumption* that have  considerable  backing  in  the scientific
         community.

These objectives are pursued using empirical methods in which carcino-
genicity data fcr H chemicals  are analyzed  systematically in a variety
of ways.  Particular attention  is placed on  those 23 chemicals for which
there exist data from both animal and human  studies  suitable for making
quantitative comparisons.

Table 1 contains a list of components of a quantitative risk assessment
based upon animal data.  Each component requires a decision on the part
of the  risk assessor for which there is no unique "correct" choice.
Also listed in Table 1 are various possible approaches to each compo-
nent.   The choices that a risk assessor makes for these components
effect  the resulting estimates of risk.  The choices for these compo-
nents therefore  are related to the uncertainty in assessment of risk
from animal data.

Objective 2 is pursued by making different risk estimates for the ^4
chemicals in the study by systematically varying the approaches to the
components listed in Table  1.  Examination of the distributions of the
changes in tne estimates  associated with different approaches to the
various components  permits  the examination of the impact of  the various
approaches (assumptions).   These  distributions also relate to the
uncertainties in the process of  risk estimation, so this work also
applies to Objective  1.

A major part  of  the study involves making comparisons  between  risk
estimates  derived  from animal  data and those derived from human  data for
those 23 chemicals for which suitable  data  are  found to exist for  both
animals and  humans.  This work addresses the question  of whether
 correlations exist between animal and  human data and therefore is of

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fundamental importance to the scientific validity of quantitative risk
assessment.  The practice of making quantitative estimates of human risk
from animal data is based upon the hypothesis (heretofore essentially
untested) that such correlations do in fact exist.  If quantitative
correlations can be shown to exist, then these correlations can provide
a stronger scientific basis for risk assessment.  Further, evaluation of
the correlations and determination of those approaches to the components
listed in Table 1 that produce the best correlations can suggest better
risk assessment methods and assist in evaluating and presenting the
uncertainty in risk estimates derived using those methods, in accordance
with Objectives 3 and 4.

                                DATA BASE

At  the beginning of the project EPA provided  a  list of <»0 chemicals  for
inclusion  in the project  that are  of interest to  the agency.  This list
was supplemented by adding  additional chemicals for which suitable quan-
titative data  are available from both animal  and  human studies  and
deleting a few chemicals  from the  original  list for which suitable
animal bioassay data  could  not  be  located,  which  brought the total
number of  chemicals  studied to  4
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official organizations (IARC monographs,  EPA heulth assessments and
similar documents,  and NCI and NTP technical reports) and a corcino-
genicity data base complied by Gold «t  al.  (1).   The relevant articles
were obtained and summary information extracted from them was coded into
a computerized data base called the Data Matrix.

The Data Matrix includes information on species,  sex, route of exposure,
length of exposure, length of observation,  whether a positive carcino-
genic response was observed and whether a data set is suitable for
quantitative risk estimation.  Data sets on animal studies that satisfy
this latter condition are coded into a  more detailed data base colled
the Animal Data Base.  A list of the chemicals included in the study,
the number of carcinogenicity data sets summarized in the Data Matrix,
and the number of those in various categories that are coded into the
Animal Data Base is given in Table 2.  As can be seen from this table,  a
total of 1233 data sets (a data set is generally composed of all the
dose response data from a given sex and species of animals exposed  via  a
reasonably common  protocol in a study) from 736 studies (a study
generally consists of all of the  data in a single  primary reference)  are
summarized in the  Data Matrix.

Animol  Data  Base:  All  of the  bioassays  that  are  considered  to be  at
 least  minimally  acceptable  for  quantitative risk  estimation  are coded
 into the computerized Animol  Data Base.  The  criteria that a data  set
 needs  to satisfy for inclusion  are as  follows:

      * the  test  species is  a non-human mammalian  species;
      • the  protocol  includes matched controls',  preferably vehicle  (or
        sham inhalation) treated animals;
      • dosing is consistent within a dose  group,  with dosages and  dosing
        pattern clearly stated;

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     •  a single route of exposure  is  employed (early in the project it
       was decided not to continue to code experiments that exposed the
       animals by skin painting or subcutaneous injection;  therefore the
       Data Base is not complete with respect to these routes of
       exposure);
     •  the test compound is administered alone or in an acceptable
       vehicle, without pretreatment  or concurrent treatment of any
       kind;
     •  tumor incidence is reported as number of tumor-bearing animals as
       opposed to number of tumors.

Table 2 provides a summary of the date included in the Animal Data Base
for each of the 
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     • the combination of  all  significantly  increased  malignant tumors;
     • all tumors1;
     • all maligno.it tumors1;
     • the tumor considered to be the response of interest in humans (if
       known).

Early in the study individual  animal pathologies were  coded whenever
possible, which would make possible time-to-tumor analyses.  However,
this work was discontinued due to limited resources after such data had
been coded for about about five chemicals.

Selection of Chemicals for Animal-Human Comparisons: For a chemical to
be included in the analyses comparing results in animals and humans,
data had to be available from both human and animal studies that would
support the quantitative comparisons conducted and for which reasonably
strong positive evidence ef carcinogenicity exists in either the animal
or the human data.  A list of the chemicals satisfying these require-
ments and which are therefore included in the comparative analyses is
presented in Table 3   Thirteen industrial chemicals are included in
this list, seven drugs, a food contaminant (aflatoxin), a food additive
(saccharin), and tobacco smoke.

It is neither necessary nor sufficient that a chemical be unequivocally
carcinogenic in humans in order to  be included.  Thus, a chemicnl such
as saccharin, which has been  associated with cancer only in  laboratory
rodents,  is  included  while bis(chloromethyl) ether  is  not  included,  even
though  sufficient evidence apparently exists to establish  that
bis(chloromethyl) ether is carcinogenic  in  humans  (2).  The  reasons  such
 1Interstitial  cell  tumors of  the  testes  in  male F3M»  rats,  mammary gland
  benign tumors in female Sprague-Dawley  rats,  malignant lymphomas in AKR
  and AKR/J mice,  and mammary  tumors  in MTV+ mice are  not included in
  these groups.  These tumors  have o  very high  background rate of occur-
  rence in the  indicated species,  which would tend to  obscure dose-
  related effects at other sites.

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chemicals are not included generally relate to limitations regarding the
data on human exposure*.  Of the 23 chemicals or chemical groups that
IARC considered in 1982 to hove "sufficient" evidence of l-uman carcino-
genicity, 11 are included in this study.  Twelve other eht>micals are
included; three are considered to provide "limited* evidence, eight to
provide "inadequate* evidence in support of hurran carcinogenic effects,
and cigarette smoke has not been formally evaluated by IARC.

It was considered important that the study not be limited to chemicals
whose carcinogenicity in humans has been firmly established.  One of the
ultimate goals of the study is to compare the predictions of carcino-
genic potency of chemicals derived from animal data with the correspond-
ing potency  in humans.  If such comparisons are restricted  to confirmed
human carcinogens, the  ability of the animal data to  predict human
results might be overestimated.  The same would be true  if  the  study is
restricted to confirmed animal carcinogens.  Although a  similar study  by
the National Academy of Sciences was restricted to conf in.ied human
carcinogens, the authors  recognized the potential for bias  in this
approach  (3).

A  thorough search was conducted for useful  epidemiological  data on  the
chemicals selected.  Individual researchers were queried regarding
unpublished  data that would be helpful  in our analyses,  possible updates
of their work and, particularly, additional  information  on  exposure.
 ANALYSIS OF EPIDEMIOLOGICAL  DATA

 Calculation of Risk Related  Doses  (RRDs):  The epidemiological  data  on
 the 23 chemicals in Table 3  vary greatly in format and quality.   Three
 distinct types of studies are represented:  prospective cohort  studies
 (including clinical trials),  case-control studies, and (in the case of

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aflotoxin) a cross-sectional comparison of concur rotas and levels of
exposure in different populations.   Even within one of these categories,
the individual studies differ considerably with respect to such factors
as duration of exposure, latency,  and methods for reporting results.
Because of the wicie variations in data from the epidemiological studies,
a systematic, standardized method of recording the human data (like that
developed for the bioascay data base) is not considered feasible.
Instead, the epidemiologic data for each chemical is considered as a
whole and risk estimates are developed using general guidelines whose
purpose is to insure that, to the extent possible, the methodology  1)
can be employed with a minimal amount of data, 2) makes best use of the
data, and 3) ensures that risk estimates made from data of differing
types and quality are comparable.

The majority of epidemiological studies considered are prospective
studies.  The minimum amount of information  required  for  an analysis  of
a  prospective study  consists of a single  group with known cumulative
dose  (expressed in ppm-years,  for example) and observed and expected
numbers of  cancers.  Additional information  on observed and expected
responses categorized by  exposure group  is accommodated whenever
available and may  provide better estimates of  carcinogenic potency.
Using  the  linear dose response model  for  relative risk of RR  •  1  +  /Jd,
where  d  is  cumulative dose,  the potency  parameter 0 is estimated  by
fitting  this model to the epidemiologic  data by  the method of maximum
likelihood.   Comparable linear dose response approaches are applied to
case  control and cross-sectional epidemiological studies.
 The parameter ft is used in conjunction with a life table analysis that
 employs U.S. sex- and age-specific mortality rates for the cancer in
 question to estimate the "extra risk" of daoth by cancer from a speci-
 fied human exposure pattern.   Extra risk is defined as (P - PQ)/(I -
 where P is the lifetime probability of death from the cancer under
                                 10

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consideration in the presence of the postulated exposure and PO io the
background lifetime probability in the absence of exposure.  Extra risk
may be interpreted as the probability of death from the cancer under
consideration, given that without the exposure death Mould have been due
to some other cause.

A constant daily exposure for 45 years beginning at age 20 is used as
the reference human exposure pattern for the calculation of human risk.
This pattern  is taken as a compromise between the exposure patterns
found in most of the epidemiological studies (which are of occupation-
ally exposed  cohorts for the most part), and constant lifetime exposure
beginning early in  life that is typical of animal bioassays.  The
endpoint estimated  is the daily dose rate in mg/kg/day under this
exposure pattern that will produce an extra risk of 0.25.  This daily
dose rate is  called a "risk related dose* (RRO).  Since the extra risk
measured in most of the epidemiological studies  is less than 0.25,
estimation of RRDs  will generally require extrapolation beyond the  dose
ranges  of the epidemiological  data.  On the other hand, an extra  risk  of
0.25 can generally  be measured directly in standard animal bioassays;
consequently, use of 0.25 as a reference risk  should make  the analyses
of  the  animal data  robust with respect  to the  dose response model
selected.  The  choice of a reference  risk of  0.25 therefore represents  a
compromise designed to minimize the extrapolation required beyond the
dose and response  ranges  in  the animal  and human studies.

Exposures  in  the epidemiologically  studied cohorts are  frequently the
source  of  considerable uncertainty  in  the analyses.  For  example,
exposuras  in  occupational cohorts are  often measured infrequently and
those measurements  that  are  made are  sometimes of uncertain relevance  to
exposures  of  specific workers.  It  is  considered to  be  important  to
quantify this uncertainty, although  such  quantification is difficult.
The approach  adopted is  to estimate  uncertainty factors that  represent
                                 11

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our impression of the uncertainty of the dot* estimates for any given
study.  These factor* ore applied to estimate upper and lower bounds for
the exposures in the epidemiological studies.  To promote uniformity in
determining these factors,  fairly specific guidelines for their calcula-
tion* were adopted a priori and followed consistently for each chemical.
A single investigator (B.A.) developed the bounds for each chemical and
for each study.  As additional studies were analyzed, the uncertainty
bounds derived earlier were reviewed and occasionally revised.  To
minimize the possibility of unintentional bias, all of the analyses of
the epidamiological data wer« performed independently of the analyses of
the animal data.

The upper and  lower bounds on exposures in the epidemiological cohorts
are applied, along with statistical confidence limit procedures, to
estimate upper and lower bounds for ft.  These bounds or* then translated
into  upper and lower  bounds for the RRO.  The analysis of each epidemio-
logical study  therefore produced a best estimate RUD and corresponding
lower and upper  bounds, RRD|_  and RRDy, that  reflect  both the statistical
uncertainty  in the obsarved cancer responses in the  epidemiological
studies end  the  uncertainty in the exposure  levels.

 In many cases, more  than one  triple  (RRDj_, RRD, RRDg)  for  a chemical ir.
 available from the  epidemiologic  literature, either  because of  more  than
 one study or more than one carcinogenic  response  analyzed.   Rather than
 combining results for different  responses or from different studies,  a
 single triple is selected  to  represent the potency of  a  given chemical.
 The triple  that  in  selected is one  that corresponds best with the
 consensus  of opinion about the carcinogenic  effect of  the chemical
 determined  froir all  the literature  reviewed.  Howaver.  the results from
. a study or  particular response in a study are not used if the dose-
 response modal provided o poo* fit  to the data or if the study is deeded
 to be markodly inferior to other studies providing RRD estimates.  In
                                 12

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the ease of vinyl chloride,  for example,  a liver cancer response is
chosen since ongiosarcoma of the liver i« considered to be undeniably
linked to vinyl chloride exposure whereas respiratory cancer, another
endpoint analyzed, is net so cltarly linked.  Another example is
provided by isoniazid.  Overall, the literature on ieoniar'c d's's not
conclusively demonstrate its carcinogenicity i-» humans le*  »lr RRDA'  ""DAU^ obtained
from  the animal  data.   If the correlation analysis is positive, then it
is reasonable to ask  if particular RRO estimates obtained from animal
data  are good predictors of the results obtained directly from epidemio-
logical studios.  At  this stage one can also  examine the magnitude of
errors, i.e. the uncertainty that results from the use  of any predictor.
Both  correlation and  prediction analyses require RRDs from  animal  data
that  ar« similar to those obtained from the epidemiological  data.

Calculation of  RRDs from Animal Data.  For each carcinogenic response
coded from  a study testing  the chemical of interest,  a  multistage  model
is fit to the  dose-response data  (<»).  The model  is  fit by  an  updated
                                 13

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When averaging is carried out at every level - over sex,  study,  and
species (Analyses 12 through 2Ud) the averaging serves to define a
unique triple for each chemical   For the remaining analyses, the
collection of RRDs must be further condensed to obtain a unique triple
for each chemical.

For analyses in which no averaging is conducted (Analyses 0 - Be and
25), two predictors from the lower bounds on RRDs are selected: one, LM,
by taking the minimum of the lower bound RRDs, and the other, I-2Q, by
taking the second quartile  (median) of the  lower bound RRDs, first within a
species, and then taking the median of the  species-specific medians.
This approach to computing  medians is similar  to the method of averaging
described above, and  is  designed  to  insure  that different species
contribute equally  to the RRDs.   The maximum likelihood  RRDs and upper
bound  RRDs are  similarly combined and consequently two different types
of  triples are  produced:  (L^,  MLE^.  UM)  and (LZQ-  MLEgg, UJQ).   For
analyses in  which  only partial averaging is conducted  (Analyses  9  -lib),
the approach token  can be roughly described as the some  as  that  just
described for  the case of no averaging,  except applied to those  RRDs
remaining after the appropriate averaging process  is  complete.   Thus two
sots of triples from the animal data are produced  for  all analyses
except those for which averaging is  carried out at every level  (Analyses
 12  - 2
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higher quality.  To address this problem,  a data sieve was designed such
that, when applied, only higher quality data are used in an analysis.

The sieve is composed of two screens that can operate either separately
or in tandem.  The first, the significance screen, examines each data
tet for a statistically significant (p < 0.05) increase in responses at
any treatment group over that in the control group by Fisher's exact
test, or for a statistically significant dose-response trend by the
Cochran-Armitage test.  If at least one of the data sets for a chemical
eligible 'or an analysis satisfies this condition, all data sets for
that chemical not satisfying the condition are deleted from the
analysis.  If no data sets for a chemical satisfy the condition, then
none of the  data sets for that chemical are deleted on the basis of the
significance screen.

The  second screen, called the quality screen, screens on the basis of
the  length of observation and the number of dosed animals.  Each data
set  is assigned a  rank  according to the scheme depicted in Table 6.  All
data sets assigned a  rank that  is higher than the lowest rank of any
data set otherwise eligible  for an analysis are  excluded from the
analysis.

The  sieve is applied  to the  data sets that would otherwise be eligible
for  a  particular  analysis.   When both screens ore employed, the signifi-
cance  screen is applied first.  The  sieve  is  designed  to  select the best
data sets pertaining  to a  chemical  among  those  eligible for a particular
analysis, but  not to  be the  basis  for  the  exclusion of any  chemical from
an analysis.  Note in this  regard  that  there  is  no  way that use of
either screen  can cause all  of  the data for  a chemical to  be  eliminated
from an  analysis.
                                 17

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INVESTIGATION OF COMPONENT-SPECIFIC UNCERTAINTV

The importance of individual components and choices for those components
(listed in Table 1) to risk assessment are investigated by constructing
histograms of the ratios RRDx/RRDjo of RRDs obtained from animal data
for the various chemicals, where RRDjg represents on RRD obtained from
Analysis 30, and RRDX represents an RRO obtained from an analysis that
differs from 30 with respect to an approach to a single risk assessment
component.  Specifically, x is allowed to range over Analyses 31 to 50,
as each of these differ from Analysis 30 only in the approach to a
single component.  Since human data are not required for this investi-
gation, data for all 4
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Analyse* *5 - 47 eoeh differ from Analysis 30 only in the manner in
which results from different studies are combined, and each is
associated with a relatively small dispersion factor.  This indicates
that the manner used to combine data is relatively unimportant; all
approaches considered give roughly comparable results.

The remaining analyses differ from Analysis 30 with respect to compo-
nents that relate to length of study (Analysis 37), length of dosing
(Analysis 38), exposure route (Analyses 37 and 38), tumor type to use
(Analyses 
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A stotisticol test was conducted for each of the selected methods of
bioassay analysis to determine if the RRDs estimated from animal data
were significantly correlated with those estimated from human data.
Specifically, the test determined whether the intervals defined by the
upper and lower bounds for the human RRDs were significantly correlated
with the corresponding intervals calculated from the animal data.  A
generalization of Spearman's rho statistic (5) was used that applies to
intervals rather than individual points.  In -:his statistic, the inter-
val for one chemical was considered to ranK higher than that for a
second chemical if both the lower and upper bounds of the first  interval
were larger than the respective bouncis for the second interval.  The
statistical significance of a particular analysis was evaluated  by
randomly reassigning the human  intervals to chemicals while keeping the
animal intervals assigned to the correct chemicals (a permutation  test).
The p-value of the statistical  test represents the probability  that,
given the animal and human  intervals calculated,  a correlation  as  large
or  larger than that observed could  have  occurred  by  ~ random assignment
of  these intervals to  chemicals.

Prediction Analysis.   If the correlation  analysis just  discussed finds a
positive correldtion  between the animal  and  human RRDs,  it  is  reasonable
to  determine which particular estimates  derived from the animal data
best predict  the  results obtained directly  from the  epidemiological
data, and to determine how  well these estimates predict the animal
results.  The prediction analysis therefore  selects  a  single estimator
from the bioassay  results as  the  estimate of RRD  for each chemical.
Four types of estimates are investigated:  the minimum  and median of the
 lower bound  estimates (LM and  LJQ)  and  the minimum  and median  of the
maximum likelihood estimates  (MLE^  and
                                 20

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                   or* not distilled to o single point, but rather the
                   , and the interval [RRDHL, RRDHU] are used to
                   •or s.  In these evaluations, a straight  liae with
                   -> the base ten logarithmic transform of  predictor
                   e human RRDe.  Plots of these fits are  produced with
                  lotted vertically and the predictors derived from the
                te
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                 RESUL"   c ANIMAL AND HUMAN COMPARISONS

CORRELATION ANALYSES

Table 8 contains the correlation coefficients and their associated
p-volue* corresponding to each of the initial 38 methods of analyzing
the bioassay data studied.  Figures 2 through 8 contain graphs of
selected analyses.  This summary reports only results from analyses that
applied the data sieve described earlier.  Use of the sieve gave a
higher correlation in 28 of the 38 analyses and in each of the 10
exceptions the reduction in the correlation was marginal.

The results in Table 8 provide a strong indication of a positive corre-
lation between the animal and human RRD estimates.  Thirty-five of the
38 analyses had a p-value less than 0.05, indicating a statistically
significant positive correlation between the animal and human RRDs.
Fifteen of the analyses had a p-value of 0.0001 or smaller, including
the Base Case analysis which attempts to mimic the analysis method used
by the USEPA.  Not only are the correlation coefficients statistically
significantly positive, but they are  sizable in an absolute snnse as
well.  Twenty-six of the analyses yield a correlation coefficient larger
than  0.7.

Given these results,  it is  highly unlikely  that these correlations are
due to chance.   It  is  also highly unlikely  that they are due  to bias  in
the methods employed.  Unlike the earlier study by the  National Academy
of  Sciences  (6),  this  study was not  limited to chemical*, that were
unequivocally carcinogenic in both animals  and humans;  thus  this
potential  source of bias  was  avoided.  All  animal analyses were
conducted  using a computer program that avoided chemical-specific
 decisions  by  an investigator  that might perhaps unconsciously be  biased
 towards improving the correlations.   Although the analyses of the human
                                 22

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data did require judgement* involving individual chemicals, these
judgements were made blind, without knowledge of the outcome of the
animal analyses.  Thus, by any reasonable standard, the animal RROs are
substantially correlated with the- human RROs.  This correlation is very
important because it destionstrates that it is scientifically feasible to
estimate human risk from animal data.

Discussed below are highlights of the correlation analysis results as
they relate to specific individual or groups of analyses.

Analyses that Average  Over  -.ex, Study, and Species  (Analyses  12-2
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both the cam* rout* and response os in humans has a somewhat larger
correlation than Analysis 0.   These mixed results suggest that,  given
the uncertainties in the present study with respect to the human RRDs,
it does not appear necessary to base a risk assessment on a lesion known
to result in humans from exposure to the chemical in question.
Similarly, it does not appear to be essential to limit animal data to
experiments employing the same route of exposure as humans experience.

Analyses Based on Only Malignant Tumors (Analyses 7, TO.  These
analyses provide essentially the same correlations as their counterparts
(Analyses 0 and 12) that use both benign and malignant tumors, despite
the fact that the human results are for malignant tumors exclusively.
This suggests that there is no claarcut choice between use of malignant
tumors  only and use of both benign and malignant in risk assessment  and
that reasonable risk assessment methods could be based upon either
approach.

Analyses  Restricted to Specific Species  (Analyses  lib, lie. 11d).
Analycis  11b  that  averages results from mice and rats provides  essen-
tially  the  same correlation  as  Analysis  11a  that averages  results  from
all species.   This may  be a  reflection that  the  vast majority of  the
data in the Animal Onto  Base is from either  mouse  or  rat studies  (cf.
Table  2).   RRDs  from  rat studies  (Analyses 11c), mouse studies  (Analyses
lid),  and both mouse  and rat studies (11b) give  nearly identical
results.

Choice of Dose Units  (Analyses fro,  frb.  »c. frd.  2»o.  2»b.  2»c. 2<»d).
 Selection of dose units for  assumed animal-human equivalence  has  very
 little effect upon the correlations; this is expected because relatively
 few studies in the Animal Data Base include study-specific data on body
weight, food consumption,  and other variables that affect calculation  of
 the dose measure.   However,  this choice can have a major effect upon the

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actual extrapolated human estimate* derived from animal data.  This
important i«su« will be explored in connection with the prediction
analyse* in the next section.

Identification of Analyses Yielding Higher Correlations. Analysis 3b
(Figure 3) yields t:ie highest correlation, f • 0.90.  Interestingly,
this analysis is tho least restrictive of all, being the only one that
involves instillation, injection, and implantation studies as wall as
the more standard gevage, inhalation, and oral studieu.  This analysis
was the o/ily one that included chlorambucil, chromium, and melphalan,
since data from experiments using the standard routes of exposure were
not available for those chemicals.  The correlation analysis was
repeated for Analys.it 3b with these three chemicals omitted to determine
if the high correlation is related to the addition of these chemicals to
the analysis.  The resulting correlation was 0.88, which is very close
to the original value, t * 0.90, and is still notably better than the
correlation obtained from any other analysis.

Aside from Analysis 3b, no other analysis stands out from the others.
The next highest correlation is 0.81 (Analysis 25) and another 16
analyses yield correlations  between 0.76 and 0.81.  The higher
correlation obtained from Analysis 3b which employs routes of exposure
not normally used for risk assessment suggests that inclusion of these
routes may allow improved estimates for some human carcinogens that, for
some  reason, are not easily  shown  to be carcinogen  :  in animals via
routes through which humans  are  normally  exposed.  Further investigation
of this  issue may  be v ,rranted.
                                 25

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PREDICTION ANALYSES

In the prediction analyses a single RRO estimated from the animal data
is used to predict the RRDs obtained from the human data.  The fidelity
of the prediction is measured by three loss functions: DISTANCE2,
CAUCHY. AND TANH.  Thus, whereas the correlation analyses consider only
whether higher ranked animal RRDs are associated with higher ranked
human RRDs, the prediction analyses examines the ability of the cnimal
bioassays to predict human risk.  It also includes an examination of the
magnitude of the errors resulting in prediction of human RRDs from
animal RRDs.

As in the correlation analysis, the use of the sieve to screen the data
appears to be appropriate and useful.  This is particularly true when
predictors other than the lower bound median, LJQ, ore used.  While
application of the sieve increased average loss for -some analysis
methods when Lgo was the predictor used, this con probably be largely
attributed to confounding associated with use of the sieve and to random
factors.   It is  concluded that  definition and application of some data
screening  procedure that eliminates from consideration experiments of
lesser  quality should accompany assessments  of  risk  that depend  on
animal  data.

Evaluation of  Animal  to Human  Conversion Methods.   Heretofore, animol-
to-human  extrapolation  has  generally  been  conducted by  assuming  that
equal doses /ill produce the same lifetime risks in animals  and  humans
when both animal and  human  doses  ore measured in the same  particular
 units.   The dose units  studied in this report (mg/kg body  weight/day,
 mg/m2 surface area/day, ppm in air or water, and mg/kg body
 weight/lifetime) have all been applied in the past.  Because of
 differences between animals and humans in body weights,  life spans,
 etc., use of different units will produce different estimates of human
                                 26

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risk.  There i« limit»d scientific support for use of any particular
dose unitti (7).  However, result* Vrom the present study can be used to
empirically evaluate these different conversion approaches.  Specifi-
cally the "conversion factor" 10C, where c is the y-intercept from the
best fitting line on the log-log plots of human and animal RRDs, is an
estimate of che amount the RRD* obtained from the animal data would have
to be multiplied by in order to agr«e, on overage, with the RROs
obtained from the human data.  A conversion factor larger than 1
indicates that the RRDs obtained from animal data tend to underestimate
those obtained from human data and vice-verso.

Table 9 contains these conversion factors for two loss functions
(CAUCHY AMD TANK) and for three different sets of analyse* chosen such
that the analyses within o set differ only with respect to the dose
units assumed  to yield equivalence between animals and hurrans.  These
sets are {ti,d}, C\2,2ka,2<*b,2kc.2kc\), and  (31,30,32,33.34).
This table indicates that use of  the  mg/kg/lifetime  dose measure leads
to  overestimation of the human risk,  for  all  analysis methods
considered, by estimated factors  ranging  from 10  to  150.   Similarly,
use of mg/tt?  surface ar«a/doy also leads  to  overestimation of  risk,  by
factors ranging from 1.6 to  12.   This is  significant because this  is the
dose measure  generally  usea  by EPA to estimate human risk.  Actually,
the extent of overvstimation by  EPA may  be greater  that  indicated  in
this table (cf. Tab.Ve  10); EPA'a  analysis method  generally uses
additional conservative assumptions  (such as taking  the  animal  data
indicative of the highest risk rather that using  medians  or averaging
over studies) not applied in the  analysis methods listed  in Table  9.
(However  it should  be  kept in mind that  non«< of the  analyi«s methods
studied will  faithfully reproduce EPA's  risk assessment  results.)

Table 9 indicate* that  the dose  measure  mg/kg/oay provides more nearly
unbiased  estimates  of  human  risk  wHen the most appropriate analysis
                                 27

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method at determined in the prediction analysis (i.e.  method 30) is
used.  Interestingly, this measure also generally provided about the
smallest loss among the five dose measures, although the differences in
loss were small, as expected.

There is no obvious a priori reason why any particular dose measure is
the "correct1 one to use for animal-to-human conversions.  Results from
the present study can be used empirically to determine appropriate
conversion methods.  Specifically, multiplication of trie animal RRO by
the conversion factor, 10C, provides an estimate of the human RRD in
which the bias due to systematic differences in animal and human risk
estimates found in this study have been eliminated.  With this approach,
the  dose units can be selected on the basis of those that, along with
other facets of an analysis, produced the best correlations between
animals and humans (or smallest  losses).  Application of the correction
factor 10C eliminates the  bias associated with any method by correcting
for  any overestimation or  underestimation  produced, on average, by that
method.
 Predictors.   Of the four  types  of  predictors  investigated
 MLEffl,  MLEjo).  the lower bound median  is  clearly  superior to the others.
 This is the indicated by  all three loss  functions  used.  Consider the
 twenty analyses 0-11d (cf.  Table 4).   With DISTANCE2 loss,  LjQ 9av* °
 smaller loss than LM in every case (ML EM and  MLEjQ are not  considered
 with this loss function); with  TANH loss, LJQ gave a smaller loss than
 the other three typos of  predictors in 18 analyses; with  CAUCHY loss,
 L20 9°v* ° smaller loss  then the other three  types of predictors in 15
 cnolyses.

 The superiority of LJQ over the predictors based on maximum likelihood
 estimates may be related to the fact that stnall  changes in the bioassay
 data con result in sizable changes in MLE estimates of RRDs.  This
                                 28

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suggests that the large-sample theoretical properties of MLEs (such as
consistency and asymptotic efficiency) are not operative to any
practical extent in this situation,  given the usual sample sizes
encountered in bioassays.  The lack of stability of the MLEs is even more
of a problem when extrapolating to low dose or low risk.  Regulatory
agencies have in the past relied more heavily on lower bound RRDs than
on maximum likelihood estimates, mainly in the interest of being
protective of human health.  This study provides additional support for
that policy since the lower bound median is, in fact, a better predictor
of human risk estimates than are the MlE predictors (in the sense of
providing smaller lost).

Comparison of Analysis Methods.  Given that the superiority of LJQ over
the other predictors has been established, it is desirable to identify
which analysis methods based upon this predictor provide the best
estimates.  This task is complicated by the fact that three different
loss functions have been defined, and these do not agree completely with
respect to the analysis  yielding smallest loss.  Moreover, it seems
unlikely that there would  exist a single  "best" method.  Consequently,
we hove identified a small  set  of analysis methods that perform
relatively well with respect to all three Iocs functions.

Several such analysis methods,  along with others that ore  of general
interest are listed  in  Table  10.  All of  the  results in this table are
from applying the  LJQ estimator,  except  in  the one case noted on  the
table.  The  "incremental normalized  loss" presented  in  this  table is  a
summary  loss measure synthesized  from all three  loss functions.   For
each  loss  function separately,  it is  possible to determine for  a
particular analysis  the amount of additional  loss  over  the minimum
contributed  by  that  analysis.   The  sum  of these  additional losses over
the  three  loss  functions defines  the total  incremental  normalized loss.
The  "corversion  factors* listed in  Table 10 arc  the  average factors,
                                 29

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10C.  by which RRDs obtained from the animal data would have to be
multiplied by in order to agree, on average, with the RRDs obtained from
the human data; these factors-were discussed in an earlier section.  The
last column in Tcble 10 contains values of the residual error, which
represents the average distance on a log-log plot from the interval
defined by the human RRDs to the line that fits best, given the animal
RRD predictors and the intervals determined by the human RRDs.  This
residual error represents roughly the average multiplicative error in
estimating the human RRDs from the animal data that is not explainable
by the uncertainty in the human RRDs (this uncertainty being expressed
by the intervals  [RRD|_, RRDy] estimated from the human data).  The
residual error is in essence an additional expression of loss.

The Base Analysis (Analysis 0) employing the minimal lower bound
estimator, LM  (second row of Table 10) has both the largest normalized
loss and the largest residual error.  Moreover, RRDs derived from  this
analysis underestimate the human RRDs on average tv a factor of 12.  By
all standards, this method is the poorest of those listed.  This method
is also perhaps most like that  presently employed by EPA.  Modification
of this method by using the median lower bound estimator, LJQ. rather
than LM, as  represented in the  first row of Table 10, provides an
improvement  in terms of normalized loss, residual error, and  requiring a
smaller conversion factor.   These  results  illustrate  further  the finding
discussed  earlier that analysis methods that  use median  lower bound  RRDs
as estimators  provide  smaller  losses than  analysis methods  that  use
minimum estimates.

 Use  of malignant tumors  only,  rat data only,  or mice data only
 (Analyses 7, 11c, and 11d,  resoectively)  did not provide clear  improve-
 ments over estimates that included data on normalignant tumors  and data
 from different species.
                                 30

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Analyses 30, 31, 42.  45.  and 47 or* presented as a group of analyses
thnt generally perform well.  All of these analyses use the mg/kg/day
method of extrapolating from animals to humans (except 31, which
utilizes the mg/m^/day method), and all include routes of exposure
(instillation, injection, and implantation) not normally used in
quantitative risk assessment.  Analyses 30, 45, and 47 differ only in
the way RRDs are combined and give fairly comparable results; Analysis
45 which averages RRDs from different sexes in the same study, migM be
considered  to perform the best over-all, as it has both the smallest
normalized  loss and residual uncertainty.  This analysis also had the
largest correlation (u.91) of those in Table 10.  Analysis 43 employs a
different carcinogenic endpoint than the others, namely total tumor-
bearing animals.  Although this analysis has a small normalized loss,
its residual uncertainty factor is 401( larger than any from  Analyses 30,
45 and 47.

Options for Presenting a Range of Risk Estimates.  Guidelines ore
provided for presenting a range or risk estimates for a risk assessment
based on Analyses 30, 31, 43,  45, and 47.  Three options are conuidered.
The first entails selecting, a priori, one method from the recomnended
set.  The results of that method, including the uncertainty  quantified
by the residual uncertainty  factor, are taken as the representative
range of risk estimates.  The  second option uses all the methods.  The
range it produces includes  any value that  could be obtained  from any one
or more of  the  methods,  and  so can be considered to give  the maximum
range consistent with the recommended set.  Although the  third  option
also considers  all methods  in  the recommended  set, it summarizes the
results by  the  smallest  range  of estimates that  is consistent with  the
predictions of  all the analyses.   As wit*  the  first option,  the last two
incorporate the residual  uncertainty factors  to  define  the ranges of
estimates.
                                 31

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                               DISCUSSION

GENERAL CONSIDERATIONS

The animal data base and the methods used in this study provide a useful
basis for evaluating quantitative risk assessment.   Their use in the
present context has demonstrated ths strong positive correlation between
the animal and human risk estimates and hence relevance of animal
carcinogenicity experiments to human risk estimation.  Moreover, it has
been possible to identify methods of analysis of trie biocscay dato.
including the choice of the median lower bound predictor, that
satisfactorily predict risk-related doses in humans.  Application of
these methods has led to suggested guidelines concerning the prediction
of human risks and the presentation of ranges of estimates incorporating
the relevant uncertainties.

There ore, however, certain features of  this investigation that  should  be
borne in mind when evaluating  the results of this study.  These  are
summarized below.

      •   A risk  level  of  0.25 is  used  throughout.
      •   The  b&oassay  data  is rather crude  in several respects.   We have
         already referred to the  data  deficiencies and their  impact on
         the  ability  to  perform some analyses.
      •   The  epidemiological data is of variable  quality.  Some degree of
         subjectivity is  inherent in the estimates of uncertainty
         associated witti  the epidemiological RRDs.
      •   Different forms  (complexes) of some chemicals were  grouped
         together.
      •   Other  approaches to  the components could be defined and
         investigated.

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     •  The three loss functions employed in the prediction onolysis
        lock an underlying statistical development and so have been used
        merely to rank the analysis methods.
     •  Many other analysis methods could be investigated.
DIRECTIONS FOR FUTURE RESEARCH

In the course of the previous discussion, several proposed extensions of
this project have been mentioned.  Several fall under the heading of
sensitivity analyses of the results already obtained.  These include
investigation of the robustness of the results to reasonable alternative
choices for the epidemiological estimates; examination of other means to
analyze bioassay data, including time-to-tumor analyses; and
investigation of the effect of using lower levels of risk, say 10~e,
which ere of direct regulatory concern.  A detailed statistical
development of the loss functions used hare (or a general development
for certain classes of loss functions) might be of general interest.
The data that is available from  this project could provide ?n
interesting and pertinent example to which that development could apply.

Also discussed in connection with component-specific uncertainty are
effort* directed at reducing or  explaining that uncertainty.  The
greatest uncertainties are related  to  the components specifying how to
handle experiments of different  length*;  of dosing, routes of exposure,
or test species and specifying the  carcinogenic responses to use.  Many
aspects of  these components  and  their  uncertainties  can  be addressed  in
an investigation of pharmacokinetics.   The data  base contains detailed
data on th» timing and  intensity of exposure  for  each  bioassay,  so a
pharmacokinetic study, which  requires  such information,  is entirely
feasible with the currently  collocted  data.   Two  specific proposals are
discussed  here.
                                 33

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Risk estimates incorporating pharmacokinetic data could be used to
determine appropriate surrogate doses.   It is sometimes assumed that a
given dose measured as average concentration of t!ie active metabolite at
the target tissue will produce the same risk in animals and humans.
However, given the many differences between animals and humans (size,
life span, and metabolic rates, to mention a few), it is not clear
which, if any, surrogate dose is the most appropriate.  This issue is
similar to that of choice of the most appropriate surrogate dose measure
for animal to human extrapolation (e.g. mg/kg/day versus mg/m2/day)
considered in this study and can be studied in a similar manner.  Risk
estimates using pharmacokinetic data could be used to determine
empirically the most appropriate surrogate dose.  Even though the range
of RRDs consistent with the human data generally cover a range of an
order of magnitude or greater, the potential surrogate doses cover an
even wider range.  Just as the present study indicates that certain  dose
measures appear to predict human results well in conjunction with
appropriate choices for other  risk assessment components, a study using
pharmacokinetic data should allow similar conclusions regarding the
surrogate dose.   A preliminary investigation indicates that possibly 18
of  the  23 chemicals with suitable human data used  in  this study might
also  have data that would support a risk  assessment that  incorporates
pharmacokinetic data.

A second potentially  useful  investigation incorporating  pharmacokinetic
data  involves using  the data  in  the  data  bcse  on different  routes of
exposure to study the  best  means of  extrapolating from route  to route in
animal  studies.   Risk  assessment methods, including the ones  examined in
this  study,  often assume a  given dose  rate involves the same  risk,
 regardless  of route.   This  clearly is  a gross  oversimplification.  The
 animal  rtata collected for this study contains  numerous examples of
 carcinogenicity studies on  the same rnemical and animal species,  but for

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which exposure is through different routes.  Those studies could be used
to determine how phornacokinetic data could best be applied to perform
route-to-route extrapolation.  Since human data would not be essential
in these investigations, our total data base that encompasses 4ft
chemicals could be used.

The question of different chemical classes and the consistency that may
be apparent within any of the classes is deserving of further study.  It
would be reasonable to couple this work with pharmacokir.etic methods.
In the present data base, several classes are represented.  However, the
number within any particular class is somewhat limited.  An expanded
data base may be necessary for a thorough investigation.

In fact, one desirable goal  in and of itself, but one that would enhance
the prospects for successful completion of these other proposals,  is the
maintenance and updating of  the bioassay data base.  All aspects of
this, including accumulation of more data sets for the chemicals already
included and addition of more substances, may be necessary.  Some
revamping of the data coding format may also make future analyses  easier
and more accurate.  Especially for pharmacokinetic studies, for
instance, dose patterns could be recorded on a daily rather than weekly
basis.

As a counterpart to the bioassoy data base enhancement, updating and
augmenting  the epidemiological  data  is  essential.  Since  the
epidemiological  data  (in  particular, data  on exposure)  is  the  single
most  limiting factor  preventing  use  of  human data, any  hope of
 increasing  the  size of  the  sample  of chemicals  useful  in  estimating
conversion  factors  and  residual  uncertainty  must  be  based on  an  effort
to  acquire  such  data.   For  those chemicals already analyzed,  more
 specific  exposure  data  would reduce the uncertainty  bounds surrounding
 epidemiological  RRD estimates and refine our estimates.   As is the case
                                 35

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with the bioassay data, much of the limitation or uncertainty is solely
a matter of inadequate reporting of data.

It should be noted in passing that the methods and portions of the
computer programs developed and applied in this project may be useful in
other contexts.  Of particular interest is a study of other types of
health effects, e.g. reproductive effects.  The investigation of these
issues could include determinations of uncertainty as well as
identification of the most appropriate methods.  Other projects,
including investigation of other types of extrapolations, e.g. from one
temporal dosing pattern to another or from rats to mice, could also be
facilitated by use of  the data base, methods, and programs developed  in
the  present work.

Finally, one would  like to  investigate cancer risk assessment methods
appropriate when  data  available  to a particular assessment are  limited.
We have  mentioned this problem in connection with component-specific
uncertainty  (i.e. noting that confounding like that  affecting those
uncertainty  calculations will often be present in any  given  risk
analysis setting) and  in connection with the  set of  recommended bioassay
analysis methods.   In  the  latter instance,  it was pointed  out that  each
analysis in  the  recommended set,  save for Analysis  17,  is  capable of
being applied  to any data  base but that  data  limitations due to
 incomplete data  presentation may entail  that  Analyses  20 and 43 are  not
possible.   The remaining analyses (30, 31,  45, and  47) can be performed
 no matter what the  data  set contains,  but they may  be  seriously affected
 by the extent  and nature of the contents.

 Consequently,  the following investigation is  proposed  as a mt>ans  of
 studying the effects of the limitations  on  the data for any  chemical of
 interest and of determining how best to  extrapolate risks  to humans.
 Pick the data in the data base that most nearly matches the data for the
                                 36

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chemical in question.  The matching may be based on species, routes of
exposure, and quality of the data.   Moreover,  one may wish to restrict
attention to chemicals that are in  the same class of the substance of
interest.  Suppose, for example,  a  volatile organic chemical is under
investigation and that the only data available are from rat inhalation
studies.  Then, the proposed procedure would first select rat inhalation
bioassays conducted using appropriate chemicals (i.e., perhaps limited
to volatile organics).  The components of risk assessment not fixed by
the selection could be varied and the method that works best with the
selected data would be the basis for extrapolating to humans risks due
to the chemical in question.  Since we also have a recommended set
consisting of methods that appear to perform well for the data and
chemicals considered as a whole,  the risks estimated on that basis (i.e.
using the recommended set) would be available for comparison.  Those
estimates reveal what would happen if other species, other routes, and
other chemicals are  included.  The relationship between the estimates
obtained by the two  approaches would suggest a general type of
uncertainty attributable to use of a limited data base (in this example,
rat inhalation studies).  A pilot study could investigate the
feasibility of such  a chemical-specific approach to risk assessment.
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REFERENCES

1.  Gold, 1., Sawyer,  C.,  Magow,  R.,  Bookman,  6., de Veciana, M.,
    Levinson, R.,  Hoooper, N., Havender, W.,  Bernstein, L., Peto, R.,
    Pike, M., and Ames, B. (198<*)-  A carcinogenic potency database of
    the standardized results of animal bioassays.  Environmental Health
    Perspectives 58:9-319.

2.  International Agency for Research on Cancer  (1982).  Chemicals,
    industrial  processes and industries associated with cancer  in
    humans.  IARC Monographs on the Carcinogenic Risk  of Chemicals to
    Humans Supplement  4.

3.  National Academy of Sciences  Executive Committee (1975).
    Contemporary Pest  Control Practices and Prospects.  Pest  Control:
    An  Assessment of Present  ond  Altar-native Technologies, Vol.  1.

4.  Howe, R. and Crump, K.  (1982).  GLOBAL 82:   A Computer Program to
    Extrapolate Quantal Animal Toxicity data to  Low Doses.   Prepared for
    the Office  of Carcinogen  Standards, OSHA,  U. S. Department  of  Labor,
    Contract 41USC252C3.

5.  Ng,  T.  (1985).  A  Generalized Ranking  on Partially Ordered  Sets  and
    It* Applications to Multivoriote  Extensions  to  Some Nonparametric
    Tents.   Unpublished report.

 6.  National Academy  of  Sciences Executive Committee  (1975).
    Contemporary  Pest Control Practices ond Prospects.  Pest Control:
     An Assessment of  Present ond Alternative Technologies, Vol. 1.
                                 38

-------
7.  Crump. K.,  Silvers, A.. Ricci. P.. and Wyzgo. R. (1985).
    Interspecies comparison for carcinogenic pctency to humans.
    Principles of Health Risk Assessment.  Ricsi, P. (ed.).  Prentice
    Hall.  pp. 321-372.

8.  U. S. Environmtneal Protection Agency. Addendum to the  Hea?.th
    Assessment Document for Dichlo^-omethane (Methylene Chloride).
    EPA-600/8-82-004FF.
                                 39

-------
                                Table 1

               APPROACHES TO RISK ASSESSMENT COMPONENTS
1    Length of experimen*
    o^  U
-------
                           Table 1  (continued)

                APPROACHES TO RISK ASSESSMENT COMPONENTS
 9.   Combining data from males and female*
     o_._  Use data from each sex within a study separately.
     b.  Average the results of different sexes within a study.

TO.   Combining data from different studies
     a_._  Consider every study within a species separately.
     b.  Average the results of different studies within a species.

11.   Combining data from different species
     a.  Average results from all available species.
     b.  Average results from mice and rats.
     c.  Use data from a single, presel«cted species.
     (T.  Ut» all species separately.

NOTE:  Underlines indicate approach used in base analysis (Analysis 0).

-------
             Table 2




SUMMARY OF ANIMAL DATA BY CHEMICAL
No. Reviewed
Chemical
Acrylonitrile
Af latoxin
Allyl Chloride
4-Aminobipnenyl
Arsenic
Asbestos
Benzene
fanzidine
Benzc[a]pyrene
Cadmium
Carbon Tetrachloride
Chloromt>jcil
Oh lor done
Chloroform
Chromium
Cigarette Smoke
3. 3-Oichlorober.ridens
1 ,2-Dichloroethane
Dichloroirethane
Diethylstilbestrol
Diphenylhydrazina
Epichlorohydrin
Estrogen
Ethylene Dibromide
Ethylene Oxide
Formoldehyde
Studies0
10
62
2
8
16
39
13
8
42
26
8
3
3
12
12
37
6
5
6
61
2
7
24
7
10
9
Data
Sets0
19
86
6
8
33
84
26
10
51
30
21
6
8
31
16
41
8
14
14
81
2
7
34
19
15
15
Number of
Data Sets Coded in Animal
Oral
Rb
9
23
2
0
7
1
0
0
0
3
0
0
2
1
1
0
4
0
2
0
0
1
1
0
0
0
Mb
0
0
2
2
2
0
0
0
0
0
0
0
6
1
0
3
0
0
2
2
0
0
0
0
0
0
0"
0
3
0
0
0
8
0
0
0
0
0
0
0
2
0
0
1
0
0
0
0
0
0
0
0
0
R
4
3
0
0
0
0
6
1
1
1
2
0
0
3
0
0
0
2
0
0
0
0
0
2
1
0
Gavage
M
0
1
0
0
0
0
2
0
2
1
4
0
0
13
0
0
0
2
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Datnbase
Inhalation
R
6
0
0
0
0
11
2
0
0
1
0
0
0
0
0
3
0
2
6
0
0
2
0
4
9
5
M
0
1
0
0
0
0
4
0
0
0
0
0
0
0
0
0
0
2
2
0
0
0
c
2
0
4
0
0
0
0
0
0
9
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
1
R
0
0
0
0
5
17
0
1
3
1
0
0
0
0
6
1
0
0
0
2
1
0
0
0
0
0
Other
M
0
2
0
0
2
0
1
1
2
1
0
1
0
0
1
0
0
0
0
9
0
0
0
0
0
0
0
0
0
0
0
1
18
0
0
6
0
0
0
0
0
0
1
0
0
0
3
0
0
1
0
0
0
Total
19
33
4
2
17
64
15
3
14
8
6
1
8
20
8
9
5
8
12
16
1
3
2
10
10
10

-------
                                         Table 2  (continued)

                                  SUMMARY OF ANIMAL DATA BY CHEMICAL
No. Reviewed
Chemical
Hexoch lorobenzene
Hy*«-nrine
Isoniazid
Lead
Melphalan
Methotrexate
Mustard Gas
2-Naphthylomine
Nickel
Nitrilotriacetic Acid
Phenacetin
Polychlorinated
Biphenyls
Re.-erpine
Saccharin
2.3.7.8-Tetrochloro-
dibenzo-p Di*>xin
Tetrachloroethylene
Toxaphene
Trichlo»~oethylene
2.4, 6-Tr ichlorophenol
Vinyl Chloride
Vinyl idene Chloride
TOTAL
Studies0
4
15
23
22
4
9
2
23
37
7
13
9

2
19
11

5
1
39
1
35
17
736
Data
Sets0
7
31
66
33
7
16
4
37
77
18
21
12

6
27
19

14
4
34
4
65
46
1233
Number of
Data Sets Coded in Animal
Oral
"R6
2
0
4
9
0
0
0
1
0
9
5
3

2
14
3

0
2
0
2
4
2
119
' M°
2
7
17
2
0
2
0
1
0
6
6
.1

2
1
0

0
2
0
2
0
0
73
Ob
2
0
4
2
0
2
0
9
1
0
0
0

0
1
0

0
0
0
0
0
0
35
R
0
4
0
0
0
0
0
1
0
0
1
0

0
0
2

2
0
4
0
4
3
47
Gavage
M
0
8
11
0
0
0
0
4
0
0
0
0

0
0
3

2
0
8
0
0
2
65
0
0
0
0
0
0
0
0
1
0
0
0
0

0
0
0

0
0
0
0
0
0
1
Database
Inhalation
R
0
0
0
0
0
0
0
0
5
0
0
0

0
0
0

2
0
3
0
23
10
94
M
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0

2
0
3
0
20
15
55
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0

0
0
2
0
1
0
14
R
0
0
0
0
0
2
0
0
20
0
0
0

0
0
0

0
0
0
0
4
0
G3
Other
M
0
0
4
1
1
0
4
4
1
0
0
0

0
2
2

0
0
2
0
0
0
41
0
0
0
0
1
0
0
0
0
1
0
0
0

0
0
6

0
0
0
0
0
0
32
Total
6
19
40
15
1
6
4
21
28
15
12
6

4
18
10

8
4
22
4
56
32
631
°A study is generally comprised of all information contained in a single primary  reference on a
 simple chemical.  A data set generally comprises oil of the dose response data fron a given
 sex and species to animals via a common protocol in a study.
bR - rat; M • mouse;  0 > other species.

-------
                                Table 3

             CHEMICALS FOR WHICH MINIMAL HUMAN AND ANIMAL
            DATA EXIST FOR QUANTIFYING CARCINOGENIC POTENCY
                                          Evidence for Carcinogenicity
                                          (IARC classification scheme)
Chemical
Aflotoxin (AF)
Arsenic (AS)
Asbestos (AB)
Benzene (BN)
Benzidine (82)
Cadmium (CO)
Chlorambucil (CB)
Chromium (CR)
Cigarette smoke (CS)b
Diethylstilbestrol (DS)
Epichlorohydrin (EC)
Estrogens (ES) (conjugated)
Ethylene oxide (EO)
Isoniazid (IS) (isonicotinic
acid hydrozide)
Melpholon (ML)
Methylene chloride (MC)
Nickel (NC)
Phenacetin (PH) (analgesics
containing phenacetin)
Polychlorinoted biphenyls (PC)
Reserpine (RS)
Saccharin (SC)
Trichloroethylene (TC)
Vinyl Chloride IVC)
Use0
F
1C
1C
1C
1C
1C
D
1C

D
1C
D
1C
D

D
1C
1C
0

1C
D
F
1C
1C
In Humans
Limited
Sufficient
Sufficient
Sufficient
Sufficient
Limited
Sufficient
Sufficient
- -
Sufficient
Inadequate
Sufficient
Inadequate
Inadequate

Sufficient
Inadequate
Limited
Sufficient

Inadequate
Inadequate
Inadequate
Inadequate
Sufficient
In Animals
Sufficient
Inadequate
Sufficient
Limited
Sufficient
Sufficient
Sufficient
Sufficient
- -
Sufficient
Sufficient
Inadequate
Limited
Limited

Sufficient
Sufficient0
Sufficient
Limited

Sufficient
Limited
Limited
Limited
Sufficient
°IC • industrial chemical;  0 • drug;  F • food additive or contaminant.
"Not considered in IARC monographs,  although tobacco smoke is
 acknowledged by IARC as a known human carcinogen.
cAlthough classified as "Inadequate" by IARC (2).  results of studies
 completed since IARC evaluation indiwate that the evidence for the
 carcinogenicity of methylene chloride in animals is now "Sufficient*
 (8).

-------
            Table <»




DESCRIPTIONS OF INITIAL ANALYSES
Anolysis
0

1
2
3o
3b
ka
4b
kc
ka
5
6
7
80
8b
6c
9
10
110
•Mb
11C
lid
12
13

Ik
15

1ti
17

18

19

20
21

22
23

Tetnplote0
Base
Analytic
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
12

12
1*

12
16

12

18

12
20

12
22

Differences^
[described in Table 1]

limited to experiments of long observation
limited to experiments of long dosing
route like human route only
any route
mg/kg/day
ppm diet
ppm air
mg/kg/lifetime
doses averaged over first 80* of experiment
early deaths eliminated
malignant responses only
combination of significant responses only
total tumor-bearing animals only
response that human get only
results averaged over sex within study
results averaged over study within species
results averaged over all species
results averaged over rats and mice only
rot data only
mouse data only
results averaged over sex, study, and species
limited to experiments of long dosing and
observation
malignant responses only
limited to experiments of long dosing and
observation
combination of significant responses only
limited to experiments of long dosing and
observation
combination of malignant significant responses
only
limited to experiments of long dosing and
observation
total tumor-bearing animals only
limited to experiments of long dosing and
observation
total malign— sy-bearing animals only
limited to experiments of long dosing and
observation

-------
                           Table k (continued)

                    DESCRIPTIONS OF INITIAL ANALYSES
Analysis	Template0	Differences13
2i*o
2<*b
2
-------
                                 Table 5

                  DESCRIPTIONS OF SUPPLEMENTAL ANALYSES
Analysis   Template0	Differencesb
30
31
32
33
34
35
36
37
38
41
42
43
44
45
46
47
48
49
50
0
30
30
30
30
30
30
30
70
30
30
30
30
30
30
30
3J
30
30
mg/ky/day; any exposure route
mg/m^/day
ppm diet
ppm air
mg/kg/lifetime
limited to experiments of long observation
limited to axperiments of long dosing
route like humans only
oral, gavace, inhalation, or route like humans
malignant responses only
combination of significant responses only
total tumor-bearing, animals only
response that humans get only
results averaged over sex within study
results averaged over study within species
results averaged over all species
results ai/erged over rats and mice only
rat data only
mouse data only
°The template is the analysis which o given analysis most closely
 resembles.
bThe differences listed are the ways in which the analysis in question
 differs from its template.
                                47

-------
                                Table  6

                   RANKS  BASED  ON  LENGTH  OF  EXPERIMENT
                      AND NUMBER OF  TREATED  ANIMALS
Length of
Experiment0
> 75*
50-75*
< 50*
Number
50+
1
3
6
of Dosed Animals
15-49 <
2
4
8

15
5
7
9
°These values are expressed as percentages of the standard experiment
 length of the test specias.

-------
                                 Table  7

          COMPONENT-SPECIFIC  UNCERTAINTY:  MODES AND DISPERSION
         FACTORS  FOR  RATIOS OF  RRDS°, DY  SUPPLEMENTAL  ANALYSIS"
Analysis
31
32
33
34
35
36
37
38
41
42
43
44
45
46
47
48
49
50
Number of
Chemicals
44
44
44
44
40
34
24
40
39
29
31
37
44
44
44
43
39
36
Mode of
Histoqram
.05
.2
.2
.02
.8
.8
.8
.8
.8
.8
.8
.8
.8
.8
.8
.8
.8
.8
- .1
- .5
- .5
- .05
-1.25
-1.25
-1.25
-1.25
- 1.25
-1.25
-1.25
- 1.25
- 1.25
- 1 25
- 1.25
- 1.25
- 1.25
- 1.25
Dispersion
Factor0
2.3
1.7
1.8
1.3
28.5
86.0
5.3
33.7
290.6
75.6
39.6
54.1
1.2
1.7
2.2
23.2
39.6
335.6
°The ratios are of the chemical-specific RRD estimates from the
 indicated analysis to those of Analysis 30 (cf. Table 5).
bThe analyses were performed with the L2Q predictor and using the full
 sieve.
cThe dispersion factor is the average fas-tor by which the ratios differ
 from tlie mode.
                                49

-------
                                Table S

                CORRELATION COEFFICIENTS AND ASSOCIATED
                     p-VALUES, BY ANALYSIS METHOD"3
Analysis
0
1
2
3a
3b
40
4b
4c
4d
5
6
7
8a
8b
Be
9
10
11a
lib
11c
11d
12
13
14
15
16
17
18
19
20
21
22
23
24a
24b
24c
24d
25
Number of
Chemicals
20
18
19
17
23
20
20
20
20
20
6
19
13
17
18
20
20
20
20
19
13
20
18
19
18
13
11
10
9
17
13
15
13
20
20
20
20
16
*
.78
.68
.49
.73
.90
.78
.76
.78
.78
.79
.79
.76
.56
.66
.76
.76
.77
.76
.76
.79
.76
.75
.43
.71
.46
.49
.58
.73
.79
.63
.38
.35
.18
.75
.74
.74
.75
.81
P-
value
.0001
.0015
.0153
.0007
<.0001
.0001
.0001
<.0001
<.0001
<.0001
.0342
.0001
.0214
.0022
.0001
.0003
.0002
<.0001
<.0001
<.0001
.0023
<.0001
.0416
.0005
.0316
.0436
.0301
.0090
.0058
.0043
.1023
.1036
.2821
.0001
.0001
.0001
<.0001
.0002
°A sieve to screen the data has been used.
                                50

-------
                                 Table  9

              CONVERSION FACTORS0 CORRESPONDING TO VARIOUS
                   DOSE UNITS,  BY METHOD OF ANALYSIS"
   Units
Analysis Method
mg/m^/day    Restricted routes,  unaveraged (0)
             Restricted routes,  averaged (12)
             Unrestricted routes,  unaveraged (31)

mg/kg/day    Restricted routes,  unaveraged (4a)
             Restricted routes,  averaged (24a)
             Unrestricted routes,  unaveraged (30)

ppm diet     Restricted routes,  unaveraged (4b)
             Restricted routes,  averaged (24b)
             Unrestricted routes,  unaveraged (32)

ppm air      Restricted routes,  unaveraged (4c)
             Restricted routes,  averagod (24c)
             Unrestricted routes,  unaveraged (33)

mg/kg/life   Restricted routes,  unaveraged (4d)
             Restricted routes,  averaged (24c!)
             Unrestricted routes,  unaveraged (34)
                                 1.58 -  2.07
                                 3.47 -  5.61
                                 8.45 - 12.02

                                 0.28 -  0.40
                                 0.43 -  0.61
                                 1.08 -  1.70

                                 0.59 -  1.17
                                 1.77 -  2.95
                                 4.52 -  5.94

                                 0.83 -  1.06
                                 1.82 -  2.96
                                 1.89 -  6.61

                                10.40 - 16.67
                                19.63 - 23.12
                                72.95 - 79.62
°The multiplicative factor by which bioassay-based RRDs overestimate, on
 average, RRDs obtained from human data.
bThe range given is that suggested by the CAUCHY and TANH loss func-
 tions; all results based upon median lower oound (LJQ) estimator.
                                 51

-------
                                Table 10

              COMPARISON OF  RESULTS FOR SELECTED ANALYSES0
                                                       Bias-
                                                    Correcting   Residual
          Number of  Correlation  Total Incremental Conversion  Uncertainty
Analysis  Chemicals  Coefficient   Normalized Lossb  Factors0	 Factor*3
0
0°
7
11c
11d
17
20
30
31
43
45
47
20
20
19
19
13
11
17
23
23
17
23
23
0.78
0.78
0.76
0.77
0.76
0.58
0.67
0.91
0.90
0.74
0.91
0.89
1.15
1.71
1.40
0.62
1.01
0.27
0.62
0.39
0.53
0.28
0.27
0.28
1.6 -
12
1.6 -
0.81 -
3.7 -
2.8 -
0.69 -
1.1 -
8.5 -
0.18 -
1.2 -
1
2.1
12
3.6
1.9
4.3
2.8
0.78
1.7
12
0.29
1.7
1.7
5.3
16.2
5.4
4.5
3.1
4.2
7.1
2.0
2.0
2.8
1.7
1.8
°The results correspond to the member of the pcir (with sieve, without
 sieve) that gives best results.  For Analyses 11c, 20, and 43 this is
 without the sieve; for other analyses this is -.with the sieve.  The
 median lower bound predictor, l_2Q. is used in all analyses except for
 the exception noted.
bThis  value is not the same as that in Table 2-8 because the  inclusion
 of the supplemental analyses reduced the minimum average  loss for two
 of the three loss functions and  increased the maximum  loss for all
 three of  the functions.
cThese values ore the factors, 10C, based on the y-intercepts from the
 CAUCHY and TANK loss functions (cf. Tables 2-13 and  2-17) and represent
 the average ratio of human RRDs  to animal RROs.
dResidual  uncertainty is  from Table 2-21 or 2-22.  It is the  factor
 computed  for all chemicals and represents the average  factor by  which  a
 prediction must be multiplied or divided in order to eliminate
 uncertainty not due to uncertainty in the human estimates.
"Using minimal  lower bound estimator LM-
                                 52

-------
                   10(11-13) 1'»»r
                                  AHATOXIN
                            « (14)
                           -<0« (15)
          ARSENIC

                respiratory
"    }
« O6)J
                                  ASBESTOS
                               HO (17) ill
                               — • - 1(17) long
                                   BENZENE
                                   {(18)
                                      "
                                   .(20)

                                •rm« I
                 (18) I
             (19)01—
             (20)1	
          BENZIDINE

          CADMIUM
       «1H24)I-
                                 CHIORAMBUCIL
                           49 (23) Wukrmu (morb«)i
-------
                               ETHYLENE OXIDE
                              	•      I (40) «tl
                                I	•	I (41)
                                                    Vuttrni*
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                                  MELPHALAN
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                             MET HYLENE CHLORIDE
                                               (4«) t-
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               f (31 .32)1
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              .  /(3 1 ,32) I -
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                                        tw,r (41) « h
           -3     -2     -\
                             L««|0IRRD(m«/M/<««>l
Figure 1.  Beat estimates and upper and lover bound) for RRDs
           from each human studg.


        O  harks the data selected to represent the chemical when comparisons
           with bioassag-based estimates are made.

        * Marks poor fit of linear dose-response model to data.

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                                       Correlation  of Anin.i]  find H.inan  F'tHI'a -  Anrlvris 0
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                      Base  <"ase
                                                         Log of AnlMl RRO ErtlM

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                                                         Firure 3


                                    Correlation of Animal and Hunan PPPs - Analysis  3b
                                                   Log «>H  AniMl RRO E*tiMt»»
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         ~4

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                           Correlation of Animal an-1 Hunan f?RDs - Analysis 7
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                                            Log of An I Ml  RRO  E»t !••!••

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                                         jrrelation of  Anin.-il an-l  ffi^nan f-irTlG - Analysis  lie
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                                       "nrrelation of Ar.ir.al  .-in i Mum-in "-H';; -  Anrilvsir,  lid
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                                                     Figure T



                                  Correlation of Animal and Human  RRDc - Analysis  1?
      I"
        -2
        -3
        -4
                 Average Over f'ex, P

                    and Species
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                                 S
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                                                       Fipure 8


                                   Correlation of Animal and Human 3PDs  -  Analysis 25
                  Pane Route and Pesponse  as Humans
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