RISK ASSESSMENT
                                FOR
                      4,4'-METHYLENEDIANILINE
                         CAS NO.  101-77-9
                    OFFICE OF TOXIC  SUBSTANCES
               U.S. ENVIRONMENTAL PROTECTION AGENCY
                         FEBRUARY  2, 1985
J. W. Hirzy, J.A. Wiltse, D. Eberly, B. Cook, G. Grindstaff,
K. Hammerstrom, D. Heggem, J. Helm, R. Kuchkuda, C.R.  Mathiessen,
H. Milman, S. Ng, J. Remmers, C. Scott-Siegel, J.  Springer,
S. Strassman-Sundy, G. Thies, A. Auletta.

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                         TABLE OP CONTENTS
      LIST OF FIGURES AND TABLES	iv
      ACKNOWLEDGEMENTS   	  vi
      EXECUTIVE SUMMARY  	  vii

  I.  INTRODUCTION   	  1

 II.  CHEMICAL IDENTITY  	  5

III.  HEALTH EFFECTS	.  .  8
      A.  Absorption and Distribution 	  9
          1.  General	9
          2.  Inhalational and Dermal Absorption   	  10
              a.  MBOCA Data	10
                    i.  Percutaneous Penetration   	  10
                   ii.  Gastro-Intestinal Tract
                          Penetration	11
                  iii.  Respiratory Tract Penetration  ....  12
              b.  Inferences About 4,4'-MDA 	  13
              c.  Limits of this Analysis	14
      B.  Mutagenicity	15
      C.  Carcinogenicity	17
          1.  Human Data	17
          2.  Animal Data	21
              a.  NTP Studies	21
              b.  Hiasa Study	23
              c.  Deichmann Study	24
              d.  Schoental Studies 	  25
              e.  Griswold Study	26
              f.  Fukushima Studies 	  27
              g.  Steinhoff and Grundmann Study 	  28
              h.  Zylberszac Study  	  29
              i.  Munn Studies	29
              j.  Gohlke Studies	30
          3.  Structural-Activity Relationships 	  32
          4.  Summary of Animal Data	35
          5.  Weight of Evidence	36
              a.  Animal Studies	.37
              b.  Epidemiological Studies 	  38
              c.  Structure-Activity Relationships   	  39
              d.  Absorption	40
              e.  Mutagenicity	  .  40
      D.  Other Human Health Effects  	  41

IV.   EXPOSURE ASSESSMENT	  .  43
     A.   Workplace Exposure—4,4'-MDA/MDI Manufacturing ...  44
         1.   Production Processes  ...»	..44
             a.   4,4'-MDA	'	44
             b.   MDI	49
         2.   Production History and Forecast	  50

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         3.  Characterization  of Non-MDI  uses  of  4,4'-MDA .  .  54
         4.  Exposure  Levels and Duration 	  54
             a.   4,4'-MDA  and  MDI  Production Workers   ....  57
             b.   Non-MDI Uses  of 4,4'-MDA	61
                    i.   Epoxy Curing	61
                        a.  Exposures  Related to the Curative
                             Package	61
                        b.  Exposures  Related to Handling/Use
                             of Complete  Epoxy Resin
                             Formulations 	  66
                        c.  Exposure  in  an Un-Characterized
                             Setting	70
                  ii.   Co-reactant in Polyurethanes 	  71
                  iii.   Wire Coating,  Polyimides
                         and PMR-15	73
                  iv.   Other Uses	74
     B.  Potential  Exposure Related  to  Consumer Contact  With
           4,4'-MDA-Containing Articles or Products 	  76
     C.  Potential  Exposure Related  to  Drinking Water  and
           Ambient  Air  Contamination   	  80
         1.  Releases  from 4,4'-MDA Manufacturing  	  83
         2.  Releases  from 4,4'-MDA Use as a Feedstock   ...  85
             a.   Releases  from MDI Manufacturing	86
             b.   Releases  from Other  Product
                    Manufacturing   	  87
         3.  Releases  from Use of  MDI in  Polyurethane
               Manufacture	.88
         4.  Releases  from Polyurethane Products   	  91
         5.  Releases  from Disposal of  Wastes	91
         6.  Potential  Releases from  Degradation
               of Polyurethane	93
         7.  Environmental Fate and Transport  of 4,4'-MDA
               Releases	94
             a.   Environmental Transport  of 4,4'-MDA   ....  94
             b.   Photodegradation  	  95
             c.  Oxidation	96
             d.   Hydrolysis	96
             e.  Volatilization	  .  96
             f.   Sorption	97
             g.   Bioaccumulation	97
             h.   Biodegradation	97
             i.   Summary	98
         8.  Estimated  Surface Water  Concentrations
              Of  4,4'-MDA	.98
         9.  Populations Potentially  Exposed to Contaminated
               Surface Waters  	  98
             a.   Potential Drinking Water  Exposures 	  99
             b.   Potential Ambient Environmental
                    Exposures	99

V.  QUANTITATIVE  RISK ESTIMATION	103
    A.  Introduction	>	103
    B.  Methods and Results	105
        1.   High-Dose to Low-Dose  Extrapolation Model  ....  105

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        2.  Animal to Human Extrapolation	107
            a.  Dose-Response  in  the Bioassays	107
            b.  Extrapolation  of  Human  LADDs  to
                  Animal LADDs	  108
        3.  Tumors Observed in  the  Bioassay	109
        4.  Exposure Situations  	  lid
            a.  Workplace Situations   	  119
                i.  Case 1:  4,4'-MDA/MDI
                      Manufacturing	120
                ii-vii.  Case  2-7:   4,4'-MDA
                            Using/Processing   	  121
                viii.  Case 8:  MDA Using/Processing  	
                          Hypothetical  Workplace  Standard  .  .  125
            b.  Drinking Water Case	126
        5.  Estimation of Risks for Exposed Populations  ...  126
            a.  Workers . .•	  126
            b.  People Drinking Contaminated  Water   	  126
    C.  Risk Characterization	127

VI.  DISCUSSION	135
     Appendix A	139
     Appendix B	143
     Appendix C	157

     REFERENCES	167

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                     LIST OP  FIGURES AND TABLES


Figures                                                 Page

 1.   4,4'-MDA/MDI  Flow  Diagram     	,45

Tables

 1.   Comparison of  Results of Chronic NCI/NTP  Studies
       on 4,4'-MDA  and  Related Compounds   	  33

 2.   Estimated 4f4'-MDA Production  1976-1980   	  52

 3.   Producers of 4,4'-MDA and MDI  Plant Locations and
       Estimated Capacity  	  53

 4.   Non-MDI Uses of  4r4'-MDA	55

 5.   Annual Production  of 4,4'-MDA  for  Non-MDI Uses  	  56

 6.   4,4'-MDA Manufacturing Workplace Airborne
       Exposure Levels   	  59

 7.   Estimated Dermal Doses in 4,4'-MDA
       Manufacturing Plants 	  59

 8.   Estimated 4,4'-MDA Manufacturing Workplace LADDs .  .  .  .61

 9.   Estimates of MDA Available for Absorption by
       Non-MDI Use	63

10.   4,4'-MDA Using/Processing Workplace LADDs  	  77

11.  Estimated 4,4'-MDA Levels in Surface Waters  	  82

12.  Populations Potentially Exposed to 4,4'-MDA in
       Drinking Water Downstream of 4,4'-MDA
       Manufacturing Plants 	  101
   s
13.  Populations Swimming in Surface Water Near
       4,4'-MDA Manufacturing Plants  	  102

14.  Tumor Incidence by Speciesf  Sex and Site of Tumor   .  .  .  Ill
      2
15.  X*  Goodness-of-Fit Test, p-Values  for Each Tumor
       Type  in Table 14	115

16.  Historical Incidences of Primary Tumors in Untreated
       Control B6C3F1/N Mice	116

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17.  Historical Incidence of Primary Tumors  in Untreated
       Control F344 Rats	117

18.  Incidence of any Malignancy  in F344/N Rats  and
       B6C3fl/N Mice by Sex for Different Dose Levels
       from NTP Bioassays on 4,4'-MDA	118

19.  Estimated Extra Lifetime Risk of  Cancer for Workers   .  .  132

20.  Estimated Extra Lifetime Risk of  Cancer
       from Drinking Water Exposures   	  .  134

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ACKNOWLEDGEMENTS








     The authors are grateful for the highly competent and



innovative work that Dr. Mark Boeniger of the National Institute



of Occupational Safety and Health (NIOSH) contributed to this



investigation, for the dedication, competence, and good cheer of



Paulette Grimes who put this document into print, and for the fine



editing work of Karen Flagstaff.
                                VI

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EXECUTIVE SUMMARY
     This document characterizes  the cancer  risks  posed  by
4,4'-methylenedianiline  (4,4'-MDA).
     4,4'-MDA is considered to be  a probable  human carcinogen  (B2)
using the criteria of the Revised  Interim Guidelines  for  the
Health Assessment, of suspect Carcinogens.  Evidence for  this
classification includes observation of elevated tumor  incidence  at
multiple sites in rats and mice in NTP bioassays,  observation  of
an elevated incidence of bladder  tumors  in a  group of  exposed
workers, observation of the chemical's ability to  react with
genetic material in short-terra studies,  indications that  the
chemical is rapidly absorbed and distributed  in mammals,  and a
structual relationship with a number of  2-ring aromatic diamines
that are known carcinogens in animals and/or  humans.
     4,4' -!*iDA is produced at an annual volume of 400-500  million
pounds in the United States.  About 97%  of production  is  converted
to methylene aiphenyldiisocyanate, a ployurethane  intermediate,
and about 60U workers are exposed  through these processes.  The
remaining '6% of productioji is used as a  component  of epoxy resins
or other polymer systems, and about 13,000 workers may be exposed
tnrouyh these uses.
                   f
     There appears to be little or no consumer use of  products
containing free, un-reacted 4,4'-MDA, although some adhesives  and
sealants used in such trades as foundation wall crack  patching are
known to contain the chemical.
     Based on the available information, risks of  tumor
development in workers exposed to  4,4'-MDA appear  to be
                                VII

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                        RISK ASSESSMENT OP



                4,4'-METHYLENEDIANILINE (4,4*-MDA)





I.  INTRODUCTION



     In 1979, the Interagency Testing Committee (ITC), established



under section 4 of the Toxic Substances Control Act (TSCA),



recommended that 4,4'-MDA (CAS No. 101-77-9) be considered for



testing for carcinogenicity, teratogenicity, mutagenicity, other



chronic effects, environmental effects and epidemiology (44 PR



31885, June 1, 1979) under authority of section 4 of the Toxic



Substances Control Act (TSCA).  In making this recommendation, the



ITC cited sketchy toxicity information that included some cancer



studies, along with concern about high production volume and



reports of adverse health effects among exposed humans.



     The Office of Toxic Substances (OTS)  within the Environmental



Protection Agency (EPA) then undertook a review of available



information on 4,4'-MDA.  Contractors were employed to gather this



information, and by 1982 most of it had been summarized in five



reports by Springborn Laboratories (Springborn, 1982), JRB



Associates (JRB, 1980, 1981), MathTech (MathTech, 1982), and



Environmental Science and Engineering, Inc. (ESE, 1981).



     In mid-1982, the Chemical Manufacturers Association (CMA)



established a 4,4'-MDA- Project Panel consisting of



representatives of BASF Wyandatte Corp., The Upjohn Co., Mobay



Chemical Corp. Olin Corp., Rubicon Chemicals (ICI Americas

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Inc.), and Uniroyal, Inc.*  The Panel began to gather production,

use and exposure information for submission to EPA and to develop

a voluntary testing program.

     In June 1982, EPA made 4,4'-MDA subject to the reporting

requirements of section 8(a) of TSCA. As a result, manufacturers

and importers were obligated to report on the amount of the

chemical produced or imported and on certain other information

related to uses and releases to the environment (47 PR 26992,

June 22, 1982).  In addition, a rule issued under section 8(d) of

TSCA in September 1982 (47 FR 38780, Sept. 2, 1982) required

reporting of unpublished health and safety studies.

     As all of this information was being studied by OTS, the

preliminary results of National Toxicology Program (NTP)

carcinogenesis bioassays on the dihydrochloride salt of 4,4'-MDA

became available.  This information, coupled with exposure

reports, led the Administrator of EPA in early 1983 to find that

there is a reasonable basis to conclude that 4,4'-MDA may present

a significant risk of serious harm to humans from cancer.  This

finding resulted in the invocation of section 4(f), the priority

review provision of TSCA, and a 180-day priority review of the

reasonableness of the cancer risks associated with 4,4'-MDA began

in March (48 FR 19078, April 27, 1983).

     Since most of the identified exposure to 4,4'-MDA occurs in

the workplace, EPA contacted the Occupational Safety and Health

Administration (OSHA), and the two agencies agreed that any
* Shell Chemical Co., CIBA-GEIGY Corp., and Pacific Anchor Corp.
  subsequently became members of the Panel.

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action needed to control the chemical would be undertaken



jointly.



     The National Institute of Occupational Safety  and Health



(NIOSH) was contacted in May 1983, and plans to  increase the



amount of information on workplace exposures were. made.



Subsequently, NIOSH independently decided to determine whether  an



epidemiology study of 4,4'-MDA was feasible.



     At the end of the 180-day priority review period, EPA and



OSHA published Advance Notices of Proposed Rulemaking (ANPR)



(OSHA:  48 PR 42836; EPA:  48 PR 42898; Sept. 20, 1983),



announcing a joint effort by the agencies to initiate regulatory



action to determine and implement the most effective means of



controlling exposures to the chemical under TSCA  and/or the



Occupational Safety and Health Act.



     During the 180-day priority review, EPA published its



decision not to pursue further testing of 4,4'-MDA  at that time



because of the apparent need to control exposures to the chemical



to lower risks from cancer (48 PR 31806, July 11, 1983).



     The present assessment uses the information  obtained by EPA



during the period described above, monitoring information  •



obtained by NIOSH from two plant visits, information submitted  in



response to the April 1983, section 4(f) designation and the



ANPRs of September 20, 1983, and product use information obtained



by a CMA sponsored survey of firms that use and/or  process 4,4'-



MDA commercially.  Since the information obtained so far is still



incomplete, especially regarding workplace exposure levels,

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potential surface water contamination and skin penetration



potential, the risk assessment will be augmented.by further



analysis as those data become available.

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II.  CHEMICAL IDENTITY (ESE, 1981)

     The name approved by the International Union for Pure and

Applied Chemistry for 4,4'-MDA is 4,4l-diaminodiphenylraethane.

Other synonyms and common names are:

       4,4'-methylenedianiline

       4,4'-methylenebisaniline

       4,4'-methylenebisbenzeneamine

       p,p'-methylenedianiline
                                  /
       methylenedianiline

       dianilinomethane

     Trade names for the compound and for mixtures containing it

are (CMA, 1983d):

       97% Minimum Assay 4,4'-MDA

           p,p'-Methylene Dianiline

           Phenyl Base G

           Laromin B-250

           Hardner HT 972

           Eposand 112 B

       Crude 4,4'-MDA (Mixture with Isomers and Oligomers)

           Curithane 103

           Curithane 116

           Tonox

           Tonox R

           Tonox 22

           Tonox M

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       Modified Raw Materials Containing Free 4,4'-MDA


           Tonox 60/40


           Tonox JB


           Tonox LC


           Araldite Hardener 830


           Araldite Hardener 850


           HY 932 (XU 205)


           HY 2969


           Ancamine LO


           Ancamine LOS


           Ancamine LT


           Ancamine TL


           Ancamine TLS


           Ancamine 1482


           Curing Agent Y


           Curing Agent Z


The structure of the compound is:
            H
                            C13  H14 N2


     The compound in commercially pure form is a light brown to


white crystalline solid with a  faint amine-like odor.  It is


prepared commercially by the acid-catalyzed condensation of


formaldehyde and aniline.

                         H+
   2 CgH5NH2 + H2CO 	___^_>.H2NC6E?4CH2C6H4NH2 * H2°

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     In addition to the 4,4'-product, some 2,2'- and 2,4'- by-
products are formed, as are  isomeric polycondensates.
2X CgH5NH2 + 2X -1 H2CO 	> H2NCgH4 (CHjCgH^Hj)^^  +  2X -1 H20

     The physical properties of 4,4'-MDA follow:

Molecular weight                    .                  198.3
Boiling range (768 mm Hg),  °C                         398-399
Melting point, °C                                     91-92
Density at 100°/4°C                                   1.056
Viscosity at 100°C (cP)                               8*04
Flash point, °C                                       221.1
Fire point, °C                                        248.9
Heat of vaporization, kJ/mole (kcal/mole)             95.4 (22.8)
Specific heat at 29°C (solid), J/(g°C)  [cal/(g °C)]   1.46 (0.35)
Specific heat at 109°C (liquid), J/(g °C)
  [cal/(g °O]                                         2.01 (0.48)
Heat of fusion,  kJ/mol (kcal/mole)                    19.6 (4.7)
Log P                                                 1.76-2.52
Approximate solubility, g/100 g of solvent at 25° C
  Acetone                                             273.0
  Benzene                                             9.0
  Carbon tetrachloride                                0.7
  Ethyl ether                                         9.5
  Methanol                                            143.0
  Water                                               0.1

Source:  Moore (1978), Windholz (1976),  as reported in ESE (1981).

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                                 8
III.  HEALTH EFFECTS



     Information relating  to  the  ability of  4f4'-MDA  to  be



absorbed by mammals and then  to interact with genetic material



will be presented in this  chapter  along with summaries of studies



on animals aimed at determining the chemical's carcinogenic



potential.  Additionally,  information  from an epidemiology study



and a structure-activity analysis  will be given.  Then all the



evidence relating to the carcinogenic  potential of  4,4'-MDA  will



be pulled together in .a weight-of-evi'dence summary.



     Since the purpose of  this assessment is to investigate  the



cancer risks associated with  4,4'-MDA, the principal  thrust  of



the health effects review given here will be on that  topic.



However, it should be noted that 4,4'-MDA has been  recognized as



a causative agent in acute liver toxicity in humans and  animals



(NIOSH, 1976a, 1976b).  Liver toxicity in humans has been



observed following oral exposure  in the so-called "Epping



Jaundice" incident in which people in  Epping, England consumed



bread made with flour contaminated with 4,4'-MDA (Kopelman et



al. , 1966a).  Kopelman (1966b) reported a 2-year follow-up study



on 43 of the 84 persons known to have  suffered injury in the



case.  While no evidence of progressive liver disease was seen,



some patients reported fat, fruit  or alcohol intolerance, weight



loss or other troublesome symtoms.





     Dermal exposure to 4,4'-MDA also  has been associated with



acute liver toxicity.  McGill and  Motto (1973) and  Williams  et



al. (1974) reported on dermal exposures in the workplace which



resulted in liver toxicity.  Additional information on these



incidents is given in Section IV.

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     Retinopathy has also been cited  as  a  toxic  effect (Schilling



v. Constatt _et^_al_. , 1966; NIOSH,  1981; Leong _e_t  _al_. ,  1984), as



has acute myocardiopathy  (Brooks  et_ a±., 1979) and  allergic



derraititis (Emmett, 1976).   Retinopathy  has  been observed in the



cat and the guinea pig and may have occurred  in  humans,  while



myocardiopathy has been seen in humans.



     A.  Absorption and Distribution  (Thies,  1983)



         1.  General



     Tor tore to ot_ jal_. (1961)  administered  pure  (100%)  or



technical grade (56%) 4,4'-MDA to male BecSFj^ mice



intraperitonealy in corn oil  at the maximum  tolerated  dose of 250



mg/kg.  Animals were examined at  intervals between  5 minutes and



12 hours after administration'of  4,4'-MDA  for distribution of the



chemical to the blood, liver, kidneys, lungs and spleen.



     These workers found that 4,4'-MDA is  rapidly absorbed and



reaches peak concentrations  in the blood between 10 and  20



minutes after administration.  They found  the half-life  in blood



to be about 6 hours and the  rate  constant  for the beta



(elimination) phase to be about 2 X 10"^ minutes.



     They found that 4,4'-MDA is  distributed preferentially to



the liver and kidneys arid is  eliminated  from all examined organs



at similar rates.  No notable difference in distribution was seen



between the pure and technical grades.



     This study shows that 4,4'-tMDA is rapidly absorbed  and well



distributed and that impurities up  to 44%  have negligible effect



on blood partitioning of the  chemical.   The  liver appears to be



the organ receiving the greatest  systemix;  dose.

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                                 10
         2.  Inhalational and Dermal Absorption

     For the purposes of this analysis,  the  structural  analogue,

methylenebis (ortho-chloroaniline)  (MBOCA) ,  is  used  to  predict

the behavior of 4,4'-MDA while more data  on  the latter  are  being

obtained.  MBOCA is a good structural analogue  for 4,4'-MDA,  and

-it has similar physicochemical properties  so  that  it can  be used

to make inferences regarding the behavior  of  4,4'-MDA.

     Some physicochemical properties of  4,4'-MDA and MBOCA

follow:



                          4,4' -MDA                   MBOCA

                    CAS No.:  101-77-9        CAS Ho.:  101-14-4

Molecular Weight:     198.26                         259.06
Log P:                  1.84*                         1.38**
     (estimated):       4.89                          3.13
     It is generally recognized that compounds which exhibit  some

degree of lipid and water solubility, which are predominately  in

an un-ionized state at physiological pH values, and which  have

sufficiently low molecular weight  (less than 500) will tend to be

more easily absorbed.

             a.  MBOCA Data

                 i.   Percutaneous Penetration

     Several studies show that MBOCA binds to and penetrates

through human and animal skin.

     Chin_e_t^l_. (1983) demonstrated in vitro percutaneous

absorption by, accumulation in, and penetration through  neonatal

human foreskin by radiolabelled MBOCA.
 * See Section IV.
** Glowinski et al. , 1978.

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                                 11
     Workers exposed during  the  manufacture of  MBOCA were shown
by Linch jet _al_.  (1971)  to  demonstrate measurable levels of the
chemical in urine.
     Radiotracer studies by  several  groups  (Braselton et al.,
1982; Groth as reported by Morton,  1981;  Tobes  j§_t _al_. ,  1983)
using 14C labelled MBOCA demonstrated that  MBOCA penetrates human
and animal skin.
     Based, on these studies, which,  show  a range of  skin
penetration rates from  about 0.13 to about  8% of the applied  dose
per hour, a logarithmic mean of  1%  absorption per hour  can be
used as the dermal penetration rate  of MBOCA for humans (Beal,
1982).
                 ii   Gastro—Intestinal  Tract Penetration
                      ———————-—————————————— \
     MBOCA, its metabolites, or  both,  penetrate through gastro-
intestinal tract tissue.
     Stula ot_ al. (1975 and  1977) and Kommineni _e£ _aJL.  (1979)
conducted long-term feeding  studies  in mice, rats,  and  dogs  that
resulted in production  of  malignancies in the lungs  and urinary
bladder, demonstrating penetration of MBOCA through  gastro-
intestinal tract tissue.
     Oral LDcQ studies  in  male rats  by Miller and Sherman (1965)
and Reinke (1963) demonstrated that  MBOCA,  its  metabolites,  or
both, penetrate gastro-intestinal tract  tissue.
     Recent single- and multiple-dose pharmacokinetic studies in
rats by Morton _e_t _al_. (1981) and Groth (1981., as cited  by Morton
et_ al_., 1981) showed that  MBOCA  penetrates  gastro-intestinal
tract tissue.

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                                 12
     Barnes  (1964) reported  profound  effects  on  the  blood  of dogs



orally exposed  to MBOCA,  and demonstrated  recovery of  MBOCA and



its metabolites  in urine,  thus  showing  gastro-intestinal  tract



absorption.



     After oral  administration  of  MBOCA, the  major route  of



elimination  is via the feces, which may indicate that  the  gastro-



intestinal tract does not  completely  absorb MBOCA or its



metabolites, or  that absorption is followed by some  degree of



biliary cycling  as shown  by  Morton'_e_t _al_.  (1981).



                 iii. Respiratory  Tract Penetration



     No test data are available regarding  the penetration  of



MBOCA or its metabolites  through respiratory  tract tissue.   But



based on the knowledge that  MBOCA  penetrates  other biological



membranes and its physicochemical  properties, it can be assumed



that if MBOCA reaches the  alveolar regions of the lung, it will



be absorbed, but to an unknown  extent.



     A critical  factor in  estimating  the potential for



penetration of substances  through  lung  tissue is particle  size.



Particles of MBOCA (or 4,4'-MDA) greater than 5  microns in size



will not be expected to reach the  alveolar regions where



extensive absorption could occur;  however, such  material could



still reach systemic circulation due  to  the generally capillary-



laden nature of  the nasopharyngeal region.  Particle sizes



greater than 2, but less  than 5 microns  will  deposit in the upper



respiratory  tract, where very little  may be absorbed via alveolar



or capillary diffusion; most will  be  cleared  by  mucocilliary



movement with subsequent  swallowing,  and^absorption  via gastro-



intestinal tract tissue.

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                                 13
     Particle size less than  2 microns stand the best  chance  of



reaching the alveolar regions and, depending on lipid  solubility,



crossing the alveolar membrane.  MBOCA or  4,4'-MDA  in  the  vapor



phase can be expected to penetrate lung  tissue fairly  well. This



conclusion is based on knowledge that MBOCA can cross  other



biological membranes and on its solubility characteristics.   It



is assumed that this penetration may reach at least 50%  of the



inhaled material.  This assumption is based on gastro-intestinal



absorption of radiolabelled MBOCA in rats  of approximately 30%



(Morton _e_t_al_. / 1981).



             b.  Inferences About 4,4'-MDA



     As previously stated, MBOCA is an acceptable analogue to



4,4'-MDA and provides adequate information to conclude that 4,4'-



MDA has a high potential to penetrate biological membranes.



     NTP bioassays (NTP, 1983a), on 4,4'-MDA dihydrochloride



indicate the probability that 4,4'-MDA itself will  cross gastro-



intestinal tissue.  In these studies, rats and mice  received  the



dihydrochloride salt of 4,4'-MDA in drinking water.  The



dihydrochloride moieties would be expected to dissociate rapidly



in the gastro-intestinal tract, leaving  4,4'-MDA as  the  essential



toxicant.  From the NTP studies it is clear that orally



administered dihydrochloride of 4,4'-MDA is a carcinogen in rats



and mice.  This provides indirect evidence that 4,4'-MDA,  its



metabolites, or both, penetrated gastro-intestinal  tract tissue.



     while 4,4'-MDA would be almost entirely un-ionized  in the



gastro-intestinal tract, it is difficult to support  the  concept



of 100% absorption, especially when dose levels are  not  defined

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                                 14
by pharmacokinetic studies.   Furthermore,  Morton  et  al.  (1981)




demonstrated that the major  route  of  MBOA  excretion  was  via the




feces, which may indicate  incomplete  absorption from the gastro-




intestinal tract. , It can  probably be assumed  that gastro-



intestinal tract absorption  of  4,4'-MDA may  be approximately 50%.



     The assumption that absorption through  lung  tissue  is



roughly equivalent to gastro-intestinal absorption is  plausible,



especially if 4,4'-MDA  is  in the vapor phase or has  a  particle



size of less than 2 microns.




     In addition to the inferences about 4,4'-MDA's  ability to  be



absorbed by humans that are  based  on  structural analogy  with



MBOCA, further direct evidence  for 4,4'-MDA's  absorption



potential is given by Vaudaine  et  al.  (1982),  Williams et al.



(1974), McGilT and Motto (1974), Dunn and  Guirguis (1979) and



Brooks (1979).  These workers reported that  4,4'-MDA was found  in



the urine of industrial workers who were exposed  to  the  chemical



(Vaudaine et_ _al_. ) or that  various  toxic manifestations of



exposure occurred in industrial settings.  Further information  is



given in Section IV.  Additional evidence  of absorption  of  4,4'-



MDA by humans is given by  Kopelman et_ _al_.  (1966a, 1966b) , who



reported on cases of liver toxicity in people  who had eaten  bread



contaminated with the chemical.



             c.  Limits of this Analysis



     As with rnost structure  activity  relationship analyses,



conclusions must be made with the  understanding that nothing is  a



good substitute for actual testing.   while MBOCA  appears to be  a



good analogue, it is not known what specific effects the two

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                                 15
chlorine molecules may have on penetration characteristics.  The




strongest conclusion that can be  inferred based on  the  available



information is that 4,4'-i4DA crosses biological membranes.




Quantitative estimates of the"rate of  this absorption require



testing, and such testing is being done  in an EPA-sponsored



dermal penetration study using radio-labeled 4,4'-MDA.




     For the purpose of this assessment, a dermal absorption rate




of 1% per hour of deposited material is  assumed, based  on MBOCA



data.




     B.  rtutagenicity



     4,4'-MDA induces mutation in the  Salmonella typhimurium/



mammalian microsomal assay (Ames assay), induces sister chroraatid



exchanges (SCE) in femoral bone marrow of male mice  and binds



covalently to DNA in vivo in the livers  of treated mice.  It does



not  induce chromosomal aberrations in  vitro in human peripheral



lymphocytes and is reported to be negative in a Drosophila



melanogaster sex-linked recessive lethal assay, the details of



which were not available for review and  whose validity,



therefore, cannot be assessed.



     Since the human peripheral leukocyte assay does not measure



the same endpoint as the Ames and SCE  assays, a mixture of



positive and negative results is not unusual, and the positive



results seen in the latter are, thus not negated by  the negative



results seen in the former.  Although  not a test for genotoxicity



per se, covalent binding to DNA demonstrates that 4,4'-MDA is



capable of interaction with macromolecules in vivo.  Such binding



may be indicative of the ability of this"^ agent to induce

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                                 16
mutations and cancer.  Taken  together  the  weight  of  evidence from




all these studies supports  the  conclusion,  reached on the basis



other evidence too, that 4,4'-MDA  is an  oncogen.




     4,4'-MDA has repeatedly  been  found  to be  mutagenic in tests




with b. typnimurium strains TA-98  and  TA-KJO with metabolic




activation (Godek et_ al_. , 1982;  Rao ^t_ _al_. , 1982; Parodi et al. ,



1981; Darby _e_^ a±. , 1978; and Brusick, 1976.   While  Brusick



(1976) reported positive results with  metabolic activation in a



test on strain TA-1538, other workers  have  found  that 4,4'-MDA is



not active in that strain or  in  strains  TA-1535 and  TA-1537,



either with or without metabolic activation.



     The Ames assay is known  to  correlate  with in vivo



oncogenicity with approximately  81% reliability.  In a review



performed for the Gene-Tox Program (EPA, 1933), 122/151 (81%)  of



the oncogens which were tested  in  the  Ames  assay  were correctly



identified.



     Parodi _e_t _al_. (1983) reported that  4,4'-MDA  induced SCE in



the femoral bone narrow of male  mice.  Although SCE  formation



cannot be used as a quantitative measure of carcinogenic potency,



it can be used as a qualitative  indicator  of potential in vivo



oncogenicity.  In the Gene-Tox Review  referred to above, 17/17



(100%) oncogens were correctly  identified  in this assay.  While



adrnitedly a limited data base,  it  does appear  that the in vivo



SCE assay is a sensitive indicator of  potential in vivo



oncogenic ity.



     Pantarotto (1983) and Parcdi _e_fc _al_. (1981) have both



reported that 4,4'-iv1DA. is capable  of covalent  binding in vivo to

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                                 17
mouse liver DNA.  While not a test  for genotoxicity  per  se,  these



results do show that 4,4'-MDA is capable of  reaching  target




tissue in vivo and once there of interacting with  cellular




macro-molecules in a manner which may  lead  to mutations or cancer.



     Although Ho et_ jaJ^. (1979) reported that tfDA did  not induce



sex-linked recessive lethal mutations in Drosophilay  the cited




study is an abstract with no experimental  data.  In  the  absence



of such data, no conclusions can be drawn  about the  validity of



the study.




     Nunziata (1983) reported that  4,4'-MDA did not  induce



chromosomal aberrations in vitro in cultured human lymphoctes.



The negative results in this study  do not  lessen the  weight  of



evidence presented by the studies cited above.



     4,4'-MDA induces gene mutation, SCE,  and DNA damage.  Gene



nutation and chromosomal aberration are separate endpoints.   It



is not unusual for a chemical to induce one but not  both of  these



enopoints.  Based upon the results of the  studies summarized



above, 4,4'-MDA should be considered a probable oncogen.



     C.  Carcinogenic ity



         1.  Human Data (Scott-Siegel, 1984)



     The National Institute of Occupational Safety and Health



(NlOSh) conducted a health hazard evaluation of workers  employed



by the Boeing Vertol Company, a manufacturer of helicopters  and



helicopter parts (NIOSH, 1983).   NIOSH evaluated exposures in two



buildings, the blade and pattern shop, where exposure to 4,4'-



MDA, epoxy resins, and solvents (toluene, methyl isobutyl ketone,



and eyelohexanone) were known to occur.  "A medical evaluation of

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                                 18
workers who had been employed  in these areas was also done  in  two




parts:  a medical study of dermatologic conditions  and  an



epidemiologic evaluation — a  proportionate mortality (PMR)  and




proportionate cancer mortality (PCMR) study.  Among a group  of



179 "exposed" worker deaths, NIOSH observed in the  PMR  study



statistically significant elevations  in mortality from  cancer  of



the bladder, large intestine,  and lymphosarcoma/ reticulosarcoma.




The elevation in bladder cancer mortality remained  significant in



the PCMR study.  This epidemiologic evaluation of the pattern and



blade shops suggests the existence of an increased  risk of



mortality from bladder cancer.  NIOSH, additionally, conducted



environment monitoring in the  pattern and blade shops to



determine current exposure.  They found detectable  levels of



4,4'-MDA, epoxy resins, and solvents  (See section IV).



     Analysis of deaths in the "exposed" group show significant



elevations in site-specific mortality from cancer of the bladder



(PMR=374, 3 observed, p<0.05), large  intestine (PMR=226, 7



observed, p<0.05), lymphosarcoma/reticulosarcoma (PMR=343, 3



observed, p_<_0.05), and skin (PMR=343, 3 observed, p<_0.05).  No



significant excesses in mortality were observed for non-



neoplastic sites.  In the PCMR analysis, the excess in bladder



cancer mortality remained significantly elevated (PCMR=341,



p<0.f)5).



     Apart from the mortality  studies, interviews with  living



current and living former employees who worked in either



"exposed" areas or "non-exposed" areas were conducted.  Two



additional bladder cancer cases were found in a living current

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                                 19
and a living former employee.  Both employees had worked  in




either the pattern or blade shop, where measurable  levels  of



4,4'-MDA were detected.  A history of cancer was reported  by  no



workers in a comparison group who worked  in packing  and storeroom




areas with virtually no exposure to 4,4'-MDA.



     PMP and PCMR analyses measure the relative frequencies of



different causes of deaths occuring in a  study population.




Limitations of the PMR and PCMR study designs are that they



provide no information on the total force of mortality, the



ratios across diseases are not independent, and the  distribution



of deaths not included in the analysis may differ from the



distribution of those included.  Proportionate analyses are most



effective when tne disease of interest is relatively rare.  Thus,




the above biases may be reduced when a PCMR analysis is employed.



     LiKewise, the ability or power of a particular  study  to



detect an increase in risk depends upon several factors.   These



tactors are sample size, magnitude of the increased  risk,



background incidence of the disease, desired statistical



significance, and type of analysis.  Thus, a study might not



observe significant increases in mortality, when in  fact an



increased risk exist, if any one of the above factors is



unfavorable to the study.



     Given the discussed design constraints, the epidemiologic



evaluation of the blade and pattern shops suggests the existence



or an increased risK of mortality from bladder cancer.  This



finding confirmed the a priori concern for bladder cancer  based



on 4,4'-MDA's stuctural analogy to benzidine, a known human

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                                 20
bladder carcinogen.  However, since two of the three bladder




cancer deatns had latencies of 10 years or less, one cannot



completely discount the possibility of these deaths being  a



random cluster, unrelated to 4,4'-MBA exposure.




     Exposure monitoring revealed detectable levels of  4,4'-MBA,



methyl isobutyl ketone, toluene, cyclohexanone, and butyl



glycidyl ether.  All were found below OSHA and ACGIH standards,




but NIOSH reported that it appeared as though former work



practices may have resulted in exposure levels higher than those.



measured in this study (NIOSH, 1983).



     Epoxy resins and 4,4'-MDA have been shown to cause cancer in



laboratory animals.  Separating the influences of these two



exposures to identify an etiologic agent of the excess bladder



cancer would be difficult..  However, as NIOSH pointed out  in



their conclusion,  the following factors lend weight in



implicating 4,4'-MDA as the etiologic agent:  1) detectable



airborne levels of 4,4'-MDA and suggestion of greater exposures



in the past (dermal contact was also a route of exposure); 2)



known toxicological evidence; 3) similarity of 4,4'-MDA to known



human bladder carcinogens such as benzidine; 4) the bladder site



was of concern a priori;  and 5) the fact that there were cases of



bladder cancer among living employees with longer exposures and



compatible latency.



     In summary, while the confounding exposure to epoxy



compounds and the study, design render this epidemiology work



inadequate for establishing a causal relationship between



exposure to 4,4'-MDA and increased incidence of bladder cancer,

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                                 21
tne data are suggestive of such a  relationship.   This  is




especially so because of  1) evidence  of  higher  exposure levels



existing at the Boeing plant  in prior years;  2)  the  close



structural relationship between 4,4'-MDA  and  benzidine -- a




chemical known to produce bladder  cancer  in humans;  and 3)



4,4'-i*iDA caused urinary bladder tunors in rats  in the  NTP



bioassay.  The evidence presented  in  this section, along  with




that in tne following section which is adequate  to establish



4,4'-MDA's carcinogenlcity in animals,  leads  to  classify  the



chemical as a probable human  carcinogen,  (B2).



         2.  Aninal Data



             a.  NTP Studies



     The Mational Toxicology Program  tested 4,4'-iiiDA



a inycirocnioriae ( 4 , 4 '-inDA* 2HC1) for carcinogenicity  by



anninistering the chemical in drinking  water  to  both sexes of



Fischer 3*4 rats and B6C3K1 mice (NTP 19fl3a).  Fifty rats and



mice of each sex received drinking water  containing  150 ppn  or



SOU ppm 4,4'-iMDA*2HC1 for 104 weeks,  ad  libitum.  Fifty controls



tor each species and sex received  no  4,4'-MDA*2HC1.



     These studies were selected as the basis for a  quantitative



estimate of possible human risks of contracting  cancer from



exposure to ^,4'-MCA because .1) the design is far superior to the



otiiers cited in this section, and  2)  the  results lend  themselves



"/ell to statistical analysis.  Statistically  significant,



treatment-related increases in malignant  and  non-malignant



tuiaors, including several rare tumor  types, were seen  at  multiple



sites  in both sexes cf both species (Mil&an,  1984).- A discussion

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                                 22
of the statistical analysis of  the  results  of  these  bioassays is



given in Section V of  this assessment.   A summary  of the results



is given here.



     Results observed  included  compound-related, non-neoplastic



lesions of the thyroid  in both  sexes of  rats and mice including



follicular cysts and hyperplasia.   An  increase  in  the incidence



of thyroid neoplasms was observed in the  high-dose groups



compared to control groups for  both sexes of both  species.   Liver



degeneration was observed in 80% of the  low-dose and 60% of  the



high-dose male mice, but not in controls.



     Thyroid follicular-cell carcinomas  were seen  in male  rats  at



rates of:  0/49 control, 0/47 low-dose,  and 7/48 high-dose.



Combined thyroid follicular-cell carcinomas and adenomas in  male



rats occurred with incidences of:   1/49  control, 4/47 low-dose,



and 10/48 high-dose.  Liver neoplastic nodules occurred  in male



rats with incidences of:  1/50 control,  12/50 low-dose,  and  25/50



high-dose.   In female rats, combined thyroid follicular-cell



carcinomas and adenomas showed  incidences of:  0/47  control,  4/47



low-dose, and 19/48 high-dose.  These animals also showed



incidences of thyroid C-cell carcinomas  and adenomas of:   1/47



control, 5/47 low-dose, and 7/48 high-dose.  Male mice displayed



incidence of liver -hepatocellular carcinomas of:   10/49  control,



33/50 low-dose, and 29/50 high-dose.  Combined incidences of



liver hepatocellular carcinomas .and adenomas in male mice were:



17/49 control, 43/50 low-dose, and  37/50  high-dose.   In  male mice



adrenal pheochromocytomas were seen at rates of:  2/48 control,



12/49 low-dose, and 14/49 high-dose.  Female mice had  lung-

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                                 23
alveolar/bronchiolar adenomas  and  carcinomas  at  rates  of:   2/50


control, 3/50 low-dose,  and  8/49 high-dose.   Malignant lymphomas


occurred in these animals  with incidences  of:   13/50 control,


28/50 low-dose, and 29/50  high-dose.   Liver  hepatocellular


carcinomas were seen in  female mice at  rates  of:   1/50 control,


6/50 low-dose, and 11/50 high-dose.   Combined  liver


hepatocellular carcinomas  and  adenomas  occurred  in these mice  at


rates of:  4/50 control, 15/50 low-dose, and  23/50 high-dose.


And, finally, thyroid follicular-cell adenomas and carcinomas


occured in female mice at  rates of:   0/50  control,  1/47 low-dose,


and 13/50 high-dose.


     Several extremely rare  tumor  types, the probability of  whose


spontaneous occurrance is  discussed in  Section V,  were also


observed.  These include one bile  duct  adenoma in  a male rat


(none previously diagnosed in  3,633 NTP controls),  transitional


cell papillomas of the urinary bladder  in  three  female rats  (3


previously diagnosed in 3,644  NTP  controls), and granulosa-cell


tumors,  including one carcinoma in five female rats (11 such


tumors and 1 such carcinoma previously diagnosed in 3,462  NTP


controls).                                   ,  .          .


             b.  Hiasa et  al.  Study


     Hiasa ^t^ al_. (1984) treated male inbred Wistar rats i.p.


with a subeffective dose of N,N-bis(2-hydroxypropyl) nitrosamine


(DHPN) namely, 280 mg/100 g body weight followed by a  diet


containing 1,000 ppm 4,4'-MDA  for  19 weeks.  The incidence of


follicular-cell carcinomas of  the  thyroid  was 2/21  (9.5%)  and
                                        •.

that of  total thyroid tumors was 19/21  (90%).  DHPN alone

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                                 24
produced only 6/21  (28%) thyroid  tumors,  and  these  were  all


beniyn neoplasms, while rats  receiving  4,4'-KDA  alone  or saline


controls had no thyroid tumors at  the end  of  the study.   The


authors concluded that 4,4'-MDA promoted  the  action of DHPN,  an


initiator of thyroid tumors in this test.   Similar  results were


seen by these authors with phenobarbital  and  barbital, known


promoters of hepatocarcinogenesis, and  with 3-amino-l,2,4-


triazole a goiter-causing agent (Hiasa _et^ _al_.  1982a, 1982b).


     It should be noted that  4,4'-MDA is also  a  goiter-inducer


(MTP, 1983a). .Thus tne findings of Hiasa  et  al.  in this  limited


bioassay of 4,4'-MDA are consisent with the findings of  studies

        >
on other known tumor promoters and goiter-causing agents.


             c.  Deichmann Study


     Deichmann _e_t _al_. (1978)  studied the carcinogenic  potential


of purified 4,4'-MDA and crude 4,4'-MOA by  oral  administration  to


dogs,  t-iine female beagle dogs, five to six months  of  age,


received doses of 70 mg by gelatin capsule  three days  a  week


until deatn or termination of the  study at  86  months.  No control


groups were reported.  Study  parameters included body  weight


gain, cystoscopic examination of the urinary  tract  (started after


two years of dosing and made  at 15-month  intervals  until


tsrmination), and serum biochemical tests,  which  included fasting


blood sugar, blood urea nitrogen,  creatinine,  uric  acid,  albumin,


total protein, and alkaline phosphatase activity.


     Moderate to severe histopathological  changes occurred in the


livers of all dogs.  These changes included "swollen hepatic


cells, moderate disruption of the  lobular  patern, passive

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                                 25
congestion, fatty  infiltration  distorting  the  lohular pattern,




hepatic cell degeneration,' Aortal  fibrosis,  central  zonal fatty




degeneration with  hepatic  cell  necrosis, heraosiderosis,  and




lymphoreticular cell  infiltration  of  the portal  areas,  and bile



ducts distention."  Less severe changes were observed in the



kidneys, spleen, and  lungs.  The authors concluded  that  purified




and cruae 4,4'-HDA produced no  tumors  in the urinary bladder or



liver of any dog.



     The small number of animals,  the  lack of  controls,  and the



less-than-lifetime duration of  the  study render  this study of




limited value in assessing  carcinogenic risk.



             d.  Schoental  Studies



     Schoental (1968a anc  1968D) prepared  a  purified 4,4'-MDA



sample from an epox.y resin  hardener containing 54% 4,4'-!"iD.A



dissolved in ganma-butyrolactone.   The epoxy resin hardener was



known to have contaminated  flour used  in bread that  had  oeen



eaten by tue "Lpping jaundice"  patients (see above)  (Kopelman et



al. , i^bba and ly^fib).  Two to  five 50 mg doses  of 4,4'-HDA in



arachis oil were administered by stomach tube  to eight male and



eignt female weanling rats  (strain  not specific), weighing 45 to



60 g.



     Ail rats were maintained until they became  ill  or died,  at



which time they were autopsier!.  A  liver hepatoiua with many cells



in mitosis and a kidney tumor having a hemangioma-like appearance



were observed in one nale  that  received five doses.   An



adenocarcinoma of  the uterus was found in one  female 24  months



after the first dor?e.  Pituitary tumors were observed  in five

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                                 26
females and one male.   Non-neoplastic lesions of the kidneys,




liver, and lungs  were  found  in most rats.




     Twelve white CFW  mice,  about one month old (sex not



specified), were  given a  single subcutaneous injection of 5 to 10




my 4,4'-«iDA in arachis oil  (50 mg/ml) (hchoental 1968b).  Seven



nonths later  one  mouse "was  killed.   No tumors were found.  The



remaining 11  IP ice were given a second dose of 5 mg 4,4'-MOA in



arachise oil  by stomach tube.   Nodular hyperplasia of the liv<3r



and a possible nepatoma were observed in one mouse that was



killed when it was 18.5 months old.   Wo other lesions were



considered to be  compound-related.



     Tiiese studies are of extremely  limited value  for assessing



cancer risks.  The  number of  animals  used  was small  and the




dosing was for a  very  snort  period.



              e.   Griswold Study



     Griswold _et_ _al_. (196H)  evaluated the  carcinogenic potential



of 3.b aromatic ainin.es  including 4,4'-;-1D£.   The  induction of



mammary gland tumors in female Sprague-Dawley rats was the test



system.  Twenty female  Sprague-Oawley eats,  40  days  of age,



received 10 mg doses of 4,4'-MDA  in  1 ml sesame oil  by stomach



tube at three-day  intervals  for 30 days,  then were observed for



an additional eight months without  treatment.   A negative control



:jroup of 140  rats  received sosane oil,  and a positive control



^roup of *HJ rats  received a  single  dose of 1H mg of  7,12-



diiv,ethylbenz [a] antnracene (Df'i.&A).   4,4'-HDA did not  induce tumors



in this test.

-------
      The  limited  number  of  animals,  the short duration of the




 study,  the  low  number  of doses administered and the lack of a




 complete  pathology  study of the animals riake this study of low




 value for assessing  carcinogenic risks.



               f.   Fukushima  Studies




      Five Croups  of  taale Wistar rats were fed 1,000 ppm 4r4'-MDA



 in the  diet  for 3,  16, 26,  32,  or 40 weeks (r'ukushima et al.,




 1979).  Within  eacn  group,  three to  six rats were killed at



 eight-week  intervals after  cessation.of 4,4'-MDA feeding until



 termination  of  the  study at 40 weeks.   A control group (eight



 rats) received niet  alone for  40 weeks.  One rat from the control



 group and one from each  treated group were killed on the first



 day of  the study.  ^io  tumors were reported in any organ.



      The  less-tnan-lifetime duration of this study, along with



 tne limited  pathology  information reported,  hinders its use in



. assessing carcinogenic risk.



      Fukushima _et_ ^al_.  (1977) studied the effect of prior



 administration of 4,4'-iviDA  on  colon  cancers  produced by 1,2-



 aimethylhydrazine (DMH)  in  rats.   Two  groups of eight-week-old



 male Wistar  rats  were  fed 4,4'-MDA (concentration unspecified) in



 their diets  for eight  weeks.   After  eight weeks,  one group (24



 rats) received 4,4'-piDA-containing diet only.   The second group



 (30 rats) received 12  weekly subcutaneous injections of 10 m.g/kg



 U'ir), starting two weeks  after  d,4'-MDA was removed from the



 diet.   A  third group (24 rats)  received untreated diet and 12



 weekly  suncutaneous  injections  of 10 rag/kg DMH, starting at 13



 weeks of  age.  £  control group (13 rats)-received only untreated

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                                 28
diet.  All rats were killed  52 weeks  after  the  first  injection of



DMH  (70 weeks of age).



     Tia 4,4'-MDA-treated groups  showed  evidence  of  liver



toxicity but tumorigenic activity was  not demonstrated.



     The design of  this study, especially  its  limited  duration



and enapoint, limits its utility  in assessing  cancer  risks



associated with exposure to  4,4'-MDA  alone.



             g.  Steinhoff and Grundraann Study



     Steinhoff and Grundraann  (1970) reported that 4,4'-MDA  was a



weak carcinogen when injected subcutaneously into rats.  A  group



ot 25 nale and 25 fenale Wistar rats  (age unspecified) received



subcutaneous injections of 30 to 50 mg/kg 4,4'-MDA at  intervals



ot one to three weeks, up to  a total  of  1.41 g/kg.  A  control



group (specifics not given) received  subcutaneous injections of



saline.'  The rats were maintained for  their lifetime.  The  mean



lire span of male 4,4 ' -MDA-treated rats  was 970 days,  for fpir.ales



l,ubO days, ana for controls "(sex not  specified)  1,007 days.   The
                                                       /


4, 4'-HLj.A-treated rsts had 33 malignant and  29 benign  tumors and



four hepatomas, while the control had  16, 15, and 0,



respectively,  statistical analysis was  not provided.  The



authors concluded that 4,4' -i>!DA nad weak carcinogenic  activity.



     wnile carcinogenic activity was observed  in  this  study, the



sraali number of animals useo, the shcrt  treatment time,  and the



lack of complete pathology information limit its  utility in. a



quantitative estimation of rissc.

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                                 29
             h.  Zylberszac Study



     Zylberszae  (I9bl) reported cirrhosis  of  the  liver  after




implantation of crystals of 4,4'-MDA under  the  skin  of  25  male




rats of mixed strain, weighing between  150  and  220 g.   Each



.inplanation was 25 rig, and seven implantations  were  made  in  five




months.  The time of sacrifice was  not  specified.  The  surface  of



tne livers appeared granular and nodular,  but no  hepatomas were



found.




     The route of p»xposurs and limited  information on study



execution make this study of little value.



             i.  Munn Study



     Munn (1967) administered 4,4'-MDA  dissolved  in  arachis  oil



by ydvaye in nalo rats five days per week  for 121 days,



delivering a total of 330 rig/100 g.  Of 24  treated rats,  three



•••/ere lost cnrouyh cannibalism.  Of  the  remaining  21  animals,  12



survived wore than two years.  All  animals  had  cirrhosis  of  the



liver, but none developed turaors during the first two years  of



che study.  Two rats, however, killed at 792 days and 947  days,



respectively, had hepatomas, while  a variety of miscellaneous



tumors (not specified) were observed in older animals.



     A second experirient was periormsd  (neither dosing  regimen



nor number of animals specified) during which treatment continued



ror Id nonths.  The total cJose ct 4,4'-MPA  per  animal averaged



600 mg/iOO g.



     Two liver tumors were obs^rvec1.  on?;  tumor  (unspecified)



occurred at the end or the tirst year,  while  the  second appeared



more than two years after treatment began.  In  addition,  one

-------
                                 30
intestinal turaor, one pituitary  tumor,  and  two subcutaneous



tibromas were observed more  than two'years  after teatment began.




     The small number of. animals used  and  incomplete pathology



information limit the utility  of this  study in quantitative risk



assessment.




             j.  Gohike Study



     Gohlke (1978) conducted a chronic  study  on the oncogenic



effects of 4,4'-MDA.  Male albino rats  were divided into four



groups of 120 each and treated as negative  controls, positive



controls, or with 4,4'-iwDA (H or 20 mg/ky)  by stomach tube five



days/week tor 16 weeks.  Ten animals from each group were killed



after ten days and six weeks or  treatment,  or at termination (16



v/eeKs).  In each group, 56-68 additional animals were examined at



their natural death.



     In another experiment, 50 animals  were divided into two



-jroups ot 30 eacn and used as positive  controls, or given 3.2



rrn-j/ky 4,4'-Mf.!A, five days/week for 16 weeks.   After six weeks of



treat/merit, at termination, ot treatment  (16  weeks),  and at 20



weeks, between four and nine animals were killed from both the



control and. 4 , 4 ' -r-iDA-treated groups' for histological examination.




     i-io differences were observed between livers of animals given



4,4l-f-iDA at 3.:> mg/kg and controls at up to ten weeks of



exposure.  At R p.g/ky, increased hepatocyte mitoses were seen



atter ten clays ot exposure.  After six  weeks  of exposure to 8



mg/kg, 50% of the animals showed hepatocyte swelling with



disseminated isolated fatty degeneration, increased mitoses, and



enlarged nuclei.   Increased mitoses also occurred in the bile



ducts.  At 16 weeks, no changes  were reported.

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                                31
     At 20 mg/ky, a decrease in glycoyen  in all animals,



proliferation in bile ducts, and large vesicular.'bile  duct  nuclei




were ooserved after ten days of exposure.  After  six weeks,  50%



of the animals showed the following effects:   increased



nepatccyte and bile duct mitoses; hepatocytes  with  triple nuclei;




bile duct proliferation with large vesicular nuclei; expanded



fibrous connnective tissue in the portal  fields;  and septal



interlobular and intralobular connective  tissue bridges.  After



16 weeks of treatment, bile duct proliferation and  the connective



tissue changes were still apparent in 50% of the  animals.



     Hyperplasias developed after four months  and were present




mainly in 4,4'-MDA-treated animals.  These were benign, localized



reticular hyperpiasias, benign hepatornas, excessive bile duct



proliferations,  and benign vascular tumors of  the liver.



     ot a total  of 437 animals examined,  17 developed  16 tumors



and six systemic diseases, waile seven developed partly tumor-



iike hyperplasias.



     The life-span of the aninals (groups unspecified) used  in



these experiments was low cue to pulmonary and otogenic



inflammation tnat extended into the meninges.  tThe  average age at



death was ll.J montns (11.3 months in 4, «i'-MDA-treated, 12.5



montns in controls).  All four animal groups had similar growth



curves.



     This study  clearly demonstrtes- tne hepatotoxicity of 4,4'-



MUA, r>ut the short duration of exposure (16 weeks)  puts a severe



limitation on the use of this study for quantitative risk



estimation.

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                                 32
         3.  Structure-Activity Relationships



     Evidence  from NTP/NCI  studies  suggests that compounds




belonging to the class of bis-benzenanines  separated by -£#2' ~°



or -s are carcinogenic for  the  tnyro.id  gland of rodents.   As can



be seen 'in Table 1,  the National  Cancer Institute tested  three




additional analogues of 4,4'-MDA  [CI i973b).



     Tite carcinogenicity of this  class  of compounds for the



thyroid gland is of particular  interest since these chemicals



b^ar a structural resemblance to  the  thyroid  hormones



triioootnyronine and thyrcxine  shown  below.   Thus  4,4'-lMDA may be



upsetting the hormone balance in  tne  thyroid  or be  interfering



with the gland's nornal functioning  in  some other way.

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                      OSi UP RESULTS OF CHBDN1C NCI/fcflP STUDIES ON  4,4t-HDA
                                  2ND KEIATED CDHFDUNEb


Test substance Structure Species
4,4' -!"!L& Rat
(Current btuay) A^^. ^^ (F344)
H2N-/C jVcH2Af JV-NH2 M^tl
Vs-"»/A Vs — 'V
4,4' -iviethy lenebis Wat
( N , iv-O iiuB thy i ) ( F3 44 )
oenzencffiUPe ivicuse
(NCI, iy?3a) ^"^ /'/^^V (6&C3F1)
(CH3)2N-/f )VcH2-Hnr JN-N(CH3)2
vLer ' s rietone i"NH2 '"C3n)


Sex
M
F •
M
F
M
F
M
F
j
C1
i-! '
F
ivi
r
M
K
M
f
H
H'

Dose
(ppm)
300(a)
300
300
300
750(0
750
2500
2500
50(j(c)
1000
2500
2500
50n(c)
500
800
800
3000 (c)
3000
5000
5000
Site of Neoplast:
Lesion Observed
Liver Thyroi^
M(b> N
M
N N
Cyl
Ni

N
N
N

N
b! N
i\i t\'

1M LV
N M
N
w N
N N

In
            water.
N - isiecplastic lesion ocojrrecl  at  statistically significant incidence (P<0.025 by the Pish
exact test.
in reed.

-------
                                  34
                               NH-
                               I
                            -CH2CHC02H
                                                    :H2CHC02H


                             I "          . I

                                  Triiodothyronine


     The tnyroia  gland is also the target organ  for non-

neoplastic  effects  of  bis-benzenanines.  Kor  example,  4,4'-MDA,

<±, 4 '-oxyaianiline ,  * , 4 ' -thior. ianiline and 4 , 
-------
                                 35
         o   With the exception of  Michler's  ketone,  all  the



             tested  analogues  of  the  class  of bis-benzenaminesf



             including  4,4'-MDAf  are  carcinogenic  for the thyroid



             gland of mice.



         o   All the tested analogues of  the  class  of bis-



             benzenamines, including  4,4'-MDA,  are  carcinogenic



             for the liver of  rats  and mice.



         o  ,4,4'-MDA is also  structurally  related  to benzidine



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



             compounds  are associated with  cancer of  the  urinary



             bladder in rats (i.e., 4,4'-MDA)  or humans [i.e.,



             benzidine, 4,4'-methylene bis-(2-methylaniline)  and,



             possibly,  4,4'-MDA].



         o   All the tested analogues of  the  class  of  bis-



             benzenamines, including 4,4'-MDA,  also produce non-



             neoplastic effects in  the thyroid  gland  (i.e.,



             follicular-cell or papillary hyperplasia).



             Additionally, at  least two analogues,  including



             4,4'-MDA,  are goiterogenic in  mice and rats.



         4.  Summary of Animal Data



     There is sufficient evidence from the  NTP  bioassays,  other



whole animal studies, mutagenicity  studies, and structural



analogy with other compounds that have been shown to  be



carcinogenic in animals to classify 4,4'-MDA  as a carcinogen  in



animals.

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                                 36
         5.  Weight of  Evidence

     Taken together, the strongly positive  results  in  the  NTP

cancer bioassays on the dihydrochloride  salt of  4,4'-MDA,

evidence of the carcinogenicity  in  animals  and humans  of 4,4'-MDA

structural analogues, the demonstrated ability of 4,4'-MDA to

induce bladder tumors in animals and  suggestive  evidence of MDA-

induced bladder tumors  in humans, and data  indicating  the  ability

of 4,4'-MDA to interact with genetic material, lead  to the

conclusion that this chemical is carcinogenic in animals and is

probably carcinogenic in humans.

     In conducting risk assessments of suspect carcinogens,  EPA

generally evaluates the overall weight of evidence  including both

primary and secondary evidence of carcinogenicity.   As specified
                                    »
in the draft EPA Guidelines for the Health  Assessment  of Suspect

Carcinogens (EPA, 1984), primary evidence derives from long-term

animal studies and available epidemiological data.   Secondary, or

supplemental, evidence  includes structure-activity  relationships,

the results of short-term tests, pharmacokinetic studies,

comparative metabolism studies, and other toxicological responses

which may be relevant.

     Based upon the weight of available  evidence, EPA  classifies

4,4'-MDA as a probable human carcinogen  and places  it  in category

(B2).  The Guidelines cited above give this classification when:

          evidence of carcinogenicity from

          epidemiological studies ranges from

          almost 'sufficient' to 'indequate.'  To

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                                 37
          reflect this range, the category  is


          divided into higher (Group  Bl)  and  lower


          Uirouy 62) degrees of evidence.


          Usually, category Bl is reserved  for


          agents for which there is at  least


          limited evidence of carcinogenicity to


          nunans front epideniological studies.  In


          the absence of adequate data  in numans


          it is reasonable, for practical
                                              *
          purposes, to regard agents  for  which


          tnere is sufficient evidence  of


          carcinogenicity in animals  as  if  they

          ^resented [sic] a carcinogenic  ris.K to


          hunans.   Thererore, agents  j:or  which


          there is inadequate evidence  frop hmian


          studies and sufficient evioence from


          aninai studios, [as with 4 , 4 '-f«iDA ] would


          usually result in a classification of

          u'2.


             a.  Animal Studies


     There is sufficient evidence of  carcinogenicity  in  aninals


to support the cited classification of  4,4'-MDA.  Jn  NTP


hioassays, the aihydrochlor.i.de of the chemical was  found to  be


carcinogenic upon oral administration in  hoth sexes of two


species (rats arnJ nice) ana caused turoors at multiple sites  in


each species.  Significantly increased  incidences of  tutors  were
                                        •.
observed in the thyroid and 'the liver irf  both species.   The  sites

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                                 33
of  response  in  the  mouse-also included the adrenal glands




(males),  and  the  lung  and ly-irpnatic 'system (females).  Several




extremely rare  tumor  types with very low spontaneous incidence



were  also observed.   These included one bile duct adenoma in a




i-iale  rat  (spontaneous  incidence in historical control rats of




(j/3633),  transitional  cell papillomas of the urinary bladder in



tnree  female  rats  (spontaneous  incidence in historical controls




or  3/3644),  and granulosa-cell  tumors, including one carcinoma,



in  five female  rats  (il  such  tumors and one such carcinoma in



3462  historical control  rats).   observation of these rare tumors



in  these  studies  in  test groups consisting of only 50 animals is




a sign of  chemical  specificity  and is highly significant evidence



or  tne carcinogenic  potential of 4,4'-.M|j£.  Thyroid tumors in



rat:i  were also  observed  in a.  limited bioassay performed by Hiasa



_^t_ _al_. (Iy>i4).  In  another study or rats treated with ^, d'-MDA by



suocutaneoiio  injection,  Steinnoff and (irundnann (1°>70)  concluded



that  the  results suggested carcinogenic activity.   This study was



limited in value by  cne  sw.ail number of test anxrnals (50) and.



incomplete pathology reporting.  other studies on  the



carcinogenic  potential of 4,4'-iMDA nave been conducted, but were



not adequate  in design or performance for conclusions to be



reached.



              b.   Epideniolocjical Studies



      only one epidemiology study is available.  This proportional



mortality  study 'was  reported  in 1.983 by Niosh (19H3).  It was



conducted at  a  site  of manufacture of helicopters  where exposure



to  4 , 4 '-rtL'A ard otner  cneiaicals was measured.  NIOSH studied

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                                 39
 information  on 179 white  male deaths that occurred among these



 workers  from all causes and found a significant excess over the



 expected  proportion of  bladder cancer-related deaths.  This



 excess remained significant in analysis of only the cancer



 deaths.   In  addition, two cases of bladder cancer were found in



 4,4'-MDA  - exposed living persons.  4,4'-MDA could not be



 definitively concluded  to be  the causative agent because of



 confounding  exposure, but the evidence  is suggestive given the



 corresponding  observation of  urinary bladder tumors in the NTP



 bioassay  in  rats  cited  above,  and 4,4'-MDA's structural



 similarity to  benzidine — an agent known to produce this type of



 tumor in  humans.



              c.   Structure-Activity Relationships



     Structure-activity considerations  are strongly supportive



 evidence  of  the human carcinogenic potential of 4,4'-MDA.   The



 chemical  is  a  member of the structural  class of bis 4-



 aminobenzenes  in  which  two benzene rings  are separated by -Ct^-,



 -O-, or -S- groups.  Members  of  this  structural class include



 4,4'-oxydi'aniline,  4,4'-thiodianiline,  and 4,4'-methylenebis



 (N,N-dimethylaniline),  all of  which  have  been found to cause



 neoplasms in the  liver  and thyroid of rodents,  as  does 4,4'-



 MDA.  Other members of  this class,  4,4'-methylene  bis (2-



methylaniline), and benzidine,  the  structual  analogue of  4,4'-MDA



 in which  the methylene  bridge  between the  aromatic  rings  is



 absent,  have been  associated with  an  increased  risk of bladder



 tumors in humans.

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                                 40
              d.   Absorption



      Further  support for EPA's conclusion that the chemical poses



a risk  of  cancer  to humans is the fact that the chemical is



absorbed by the human body.  4,4'-MDA is known to be absorbed by



humans  through the  skin in workplace settings.  Information from



the United States,  Canada and France attests to the dermal



.absorption of the chemical, and the scientific literature



documents  cases of  the liver toxicity of 4,4'-MDA following



dermal  exposure along with detection of  the chemical in the urine



of workers exposed  by this route.



      Since the chemical has been  shown to penetrate human skin



and to  be  absorbed  through the human gastrointestinal tract (in



the so-called Epping  Jaundice Incident),  EPA believes it



reasonable to anticipate that the  chemical will penetrate lung



tissue  as  well.



             e.  Mutagenicity



      In short-term  tests,  4,4'-MDA has been shown to be a gene



mutagen in prokaryotic  systems.  The chemical  induces sister



chromatid  exchanges  in  femoral bone marrow of  male mice; it does



not induce chromosomal  aberrations in  vitro in human peripheral



lymphocytes.  (A mixture of positive and  negative results is not



unusual in tests for  genotoxicity  since  the tests for gene



mutations  and chromosomal  aberrations  measure  different



endpoints.)  In addition,  the  compound binds covalently to  DNA in



vivo  in the livers of  treated  mice,  indicating its ability  to



interact with macromolecules  in vivo.

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                                 41
      0.   Other Hunan Health Effects



      This section presents a summary of reports  of  adverse



effects  that  4,4'-r-lOA exposure has caused  in hunans.




      /•;opeiman _a_t  _a_^.  (196fia, 196(>b) reported that H4  people who



nad eaten bread contaminated with 4,4'-MD£ developed  jaundice,




with  nepatoeellular damage evidenced by biochemical  tests  and




neec.ie biopsy examinations.



      •.;il liains et  al.  (ly?4)  reported six cases of hepatitis ariong



workers  using 4,4'-ivii.)/» in a  surface coating operation at a




construction  sice,  and McGill and riotto (1974) reported  13 cases



of nepatitis  anong  workers exposed inhalationally (at 0.1  ppn in



air)  and  dermally while producing on epcxy resin compound.   Of



special  significance  in the  Mcuill and. iviotto report  is the fa.ct



that  workers  who  were 3xposed only via the inhalation route (at



u. i ppn  in air),  in the sane work stations as those wtio also were




exposed  oernally  ?nd  expT)rienct?A to ^enetrata !iunan s
-------
     These reports indicate  that  4,4'-ML>A. can be absorbed by




humans in ruoloc_,ically significant  amounts,  anri that apparent




exposure at n.l ^Pri i-n air Goes not  result in overt signs of



acute hepatotoxicity, thus there  ^ay be  no warniny of exposures




tnat could present Giynificant cancer risk.i.   (bee Section v).

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                                43
IV.  EXPOSURE ASSESSMENT
     In this section  information on  the  potential  for  exposure to
4,4'-MDA by workers,  consumers and the general  public  will  be
given.  This information will  include the  production and  use
patterns for the chemical and exposure levels,  durations  and
routes for workers classified as to  the  various uses of 4,4'-
MDA.  Also included will be estimates of releases  of 4,4'-MDA
into the air, water and land, the fate of  such  releases,  and the
levels of the chemical that might occur  in certain drinking water
supplies.
     Humans may be exposed to 4,4'-MDA in  the workplace,  through
contact with articles or other products  containing the chemical,
or through consumption of contaminated water or food.  In order
to assess these possible exposures,  EPA, in conjunction with
NIOSH, has gathered data on work practices and  exposure levels in
                                     v
facilities that manufacture, process or  use 4,4-MDA.   In
addition, the Agency  has gathered information on the types  of
articles and products that may contain the chemical, and  on the
amount and rate of releases of 4,4'-MDA  to the  environment
throughout its commercial life cycle.
     The assessment indicates 1) that exposures experienced in
some workplace situations are significant  and 2) that  exposures
through drinking contaminated surface water are probably  not
significant.
     It is important  to note tnat several  different analytical
methods for determining levels of 4,4'-MDA in air,  water, and
biological samples have been used, and that a systematic  attempt

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                                44
at concordance among these methods  is underway.   Appendix  A



summarizes the methods  that have been used  to measure  airborne



concentrations of 4,4'-MDA.   In particular,  the  Marcali



colorimetric method for 4,4'-MDA, used by some 4,4'-MDA



manufacturers who reported levels of the chemical  to EPA,  suffers



from interference from  aromatic amines and  isocyanates,  both  of



which can be present in the air of  4,4'-MDA/methylene  diphenyl



diisocyanate (MDI) manufacturing facilities.  Such interferences



are less likely to occur at 4,4'-MDA user and processor



facilities.  This assessment  is based on the assumption  that  the



exposure levels reported in the literature  or to  EPA are



accurate.



     Information regarding exposure of workers to  4,4'-MDA is



derived from anecdotal reports cited in Versar (1983a),  data



voluntarily submitted by the  Chemical Manufacturers Association



(CMA, 1983a), individual companies  (Docket  No. OPTS 64,000a), a



report prepared by PEDCo Environmental, Inc. (PEDCo, 1983)  and



the National Institute for Occupational Safety and Health  (NIOSH,



1983 and 1984a,b).



     Information regarding exposure of the  general public  is



derived from a draft report prepared by Versar Inc. (Versar



1983b).



     A.  Workplace Exposure—4,4*-MDA/MDI Manufacturing



         1.  Production Processes



             a.  4,4'-MDA (PEDCO, 1983)



     4,4'-MDA is produced commercially by the acid-catalyzed



condensation of aniline and formaldehyde.   The initial product is



acidified, crude 4,4'-MDA, almost all of which is  purified as

-------
figure |.  A,A'-HDA/MIU Flow Diagram.  (PBOCo. 1983)

-------
                                46
outlined below  for  use  as  an  intermediate  for raethylenediphenyl

diisocyanate  (MDI)  at  the  same  production  facilities.*  Figure 1

As a flow diagram for  this  process/  and  for conversion of 4,4'-

MDA to MDI.

     The production  process can be either  continuous or batch.

Acid is added to the aniline/ followed by  addition of

formaldehyde under  agitation.   The reaction occurs in a closed

vessel at atmospheric pressure  and a  temperature  of 60° to

100°C.  The only product is acidified crude 4,4'-MDA;  there  are

no significant  byproducts,  except that up  to 40-50% of the crude

4,4'-MDA consists of isomers  and.higher  homologues.

     There are  no 4,4'-MDA  exposure points  other  than those  that

might occur as  a result of  fugitive emissions  or  malfunction of

the vessel or its plumbing.   There are no  purge or off-gas

streams.

     In the neutralization  step, the  reaction  mass from the

reactor tank is neutralized with caustic soda  to  produce  crude

4,4'-MDA.  Two  layers are formed, a lower  layer containing water

and'salt, and an upper layer  containing  the  product and unreacted

aniline.  The organic layer is  w.ashed with  water  in a  closed,

stainless steel tank at ambient pressure and  temperature.

     The input materials are  the acidified  reaction mass,  aqueous

sodium hydroxide, and water.  The principal  output is  crude  4,4'-

MDA,  which may either be further purified or  used  for  the

production of MDI.   A large quantity  of  sodium chloride is also


* One domestic plant further  processes the  polymeric  4,4'-MDA  to
  yield a purified  product  that finds a  number of  specialized  end
  uses.

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                                47
 formed  and  removed in an aqueous purge stream likely contaminated



 with  4,4'-MDA and other organics.



      The  potential for worker exposure in this process is



 expected  to be limited.   The purge stream likely contains some



 4,4'-MDA, so exposure could  occur  in an "open" system around



 holding ponds.   Neutralizer  purge  stream levels of 4,4'-MDA are



 not well  documented  in the literature,  but monitoring work now in



 progress  is expected  to  provide  some information on 4,4'-MDA



 levels  in total  process  effluent streams'.



      The  crude  4,4'-MDA  from the neutralizer is subjected to



 distillation  to  separate  unreacted aniline.   The distillation



 process is  conducted  at  atmospheric pressure at temperatures



 above 185°C  in a  closed,  stainless steel distillation column.



The residual  product  which solidifies  to a hard waxy material at



 temperatures  below 89°C,  may be  drummed  for  distribution  and sale



or further  purified.



     The only  input to this  step is crude 4,4'-MDA.   The  product



 is a  technical grade  4,4'-MDA, which  is  about 50%  4,4'-MDA plus



oligomers.  The process by-products are  water and  aniline.   The



latter is recycled to  the reactor  vessel.



      Liquid  and solid  wastes  containing  4,4'-MDA are produced in



this process.  Liquids may be  retained  in holding  ponds and the



solids sent  to landfills.  No  data are  currently available



regarding 4,4'-MDA levels in  either stream.



     Because  the  distillation  system  is  closed,  worker exposure



is not expected except in the  case  of system disruption.



Filling, sealing,  storage, and distribution  activities could

-------
                                48
result  in  inhalational  or  dermal exposure to 4,4'-MDA at various


points.


      High-purity  (97-99% assay)  4,4'-MDA can be isolated from


technical  grade 4,4'-MDA.  A re-crystallization process (PEDCo,


1983) involves the  reformation of the hydrochloride salt of 4,4'-


MDA,  followed by  filtration and  neutralization with sodium


hydroxide.  The product 4,4'-MDA is packaged for distribution and


sale.   The equipment  that  would  be used is not described in the


literature, but would probably be a closed/  stainless steel


tank.   The process  would take  place at ambient pressure and


temperature.  The input materials would be technical grade 4,4'-


MDA,  hydrochloric acid/ sodium hydroxide,  and  water.  The product

would be purified 4,4'-MDA in  the form of  tan  flakes.  There


would be an aqueous contaminated salt stream that may contain


some  4,4'-MDA.

      The system would be closed  until output,  so worker exposure
                                         •
during purification would  be unlikely,  although dermal exposures


during manufacture  and  packaging of the purified form of  the


chemical have been  reported  (NIOSH,  1984a).  Subsequent purge


stream holding and  disposal operations  could also result  in


inhalational or dermal  exposure.

     Technical grade  and purified 4,4'-MDA is  used in a number of

non-MDI processes.  It  is  packaged  and  sold  as  a viscous  liquid


or lumps in the technical  grade  form,  or as  flakes or granules in


the purified form.  Liquid  4,4'-MDA is  sold  in  bulk (tank cars or

tank wagons) or in  55-gallon drums.   The lump  form of 4,4'-MDA is


sold  in bags.  Purified 4,4'-MDA is  available  in bags or  kegs.

-------
                                49
     Workers  who  fill  the  containers  with liquid or solid 4,4'-



MDA are  subject to  potential  exposure,  though 4,4'-MDA's vapor



pressure  is low even  in  the  liquid  state  (0.2 mm Hg for Tonox®,



Uniroyal's  trade  name  for  4,4'-MDA,  in  the melt range).



Inhalation  of  dust  or  skin contact  from a bagging or drum-filling



operation represent potential risk  to the worker.  NIOSH (1984a)



reports  that  such exposure occurs.



     Workers  may  also  be exposed  to 4,4'-MDA,  via inhalational



and dermal  routes when handling the filled containers.   Drums  and



bags must be  relocated,  stored, and placed on  trucks for



shipment.   Damage to the container  in any of  these  operations



could expose  workers to  4,4'-MDA



            b.  MDI



     Technical grade 4,4'-MDA is  reacted  with  phosgene  to produce



the desired product, a crude  MDI  known  commercially as  PAPI®.



4,4'-MDA and  phosgene  are dissolved in  a  solvent,  and the two



solutions are mixed and allowed to react  for  several hours.  The



reaction occurs in  a series of closed,  agitated,  stainless  steel



reactor vessels at  ambient pressure and a temperature of 200°C.



     Input materials are polymeric 4,4'-MDA, phosgene,  and  a



solvent such  as xylene, monochlorobenzene,  dichlorobenzene, or



1,2,4-trichlorobenzene.  Outputs  are  the  product  isocyanate



mixture and a  liquid waste stream containing hydrogen chloride,



solvent, and miscellaneous organics.  The reaction  is reportedly



capable of a  90% yield of isocyanate  mixture.   Theoretically,  the



waste streams  generated could  contain some  unreacted 4,4'-MDA,



although this  is unlikely.

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                                50
     Workers may be exposed to  4,4'-MDA  through  dermal  contact
with the liquid product or waste  streams,  or  through  inhaling  MDI
vapors that could be hydrolyzed in  the body to 4,4'-MDA.
     Crude MDI may be fractionated  through several  intermediate
grades to a high-purity MDI. Dimers and  trimers  can also  be  made
through use of a catalyst, triethyl phosphate.   The process  takes
place in a closed, stainless steel  distillation  column, the
operating conditions for which  are  not reported  in  the
literature.  Temperatures would be  elevated.
     Input material is crude MDI.   The outputs are  higher grades
of MDI, as well as recyclable hydrogen chloride  and solvent,
which are diverted to a purge stream.  This stream  also contains
additional organic distillation residue.   The product MDI is a
very dark amber, viscous liquid with very  low volatility.
     The amount of unreacted 4,4'-MDA remaining  through this step
depends upon the purity of the  MDI  produced.  There is  virtually
no unreacted 4,4'-MDA with high-purity MDI.  Waste disposal
consists of extraction of hydrochlogen chloride  for process
reuse, disposal t'o holding ponds, and finally municipal
wastewater treatment.
        2.  Production History  and  Forecast
     U.S. production of 4,4'-MDA  has been  increasing  steadily
since the early 70's.  Production is driven primarily by  the
demand for MDI, manufacture of  which consumes about 98% of 4,4'-
MDA production (JRB, 1981).  Since  no production data for 4,4'-
MDA have been published in recent years, the estimates  presented
                                        •»
in Table 2 below are based on published MDI production  data.   CMA

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                                51
has estimated that 230 million pounds of  4,4'-MDA  were  produced



in 1981 by all manufacturers except DuPont  (Cox, 1982).   Since  it



has been reported that DuPont produces approximately  10  million



pounds/year, this would amount to an estimated  240 million



pounds/year 4,4'-MDA production.  The difference between CMA's



estimate and that of PEDCo  is probably due  to the  former's



reporting only the production of the 4,4'-isomer,  while  the



latter includes all isomers and oligomers in technical  grade



4,4'-MDA which is converted to commercial grade MDI.



Consolidated data received  under the TSCA section  8(a)  Level  A



reporting rule (47 FR 38780, September 2, 1982) indicate that



between 209 and 286 million pounds were produced in 1981



(Knutson, 1983).  Estimates thus range from 209 to 414 million



pounds/year.



     Polymeric MDI is used  in polyurethane production; demand is



increasing for two major reasons (JRB, 1981):



     o  Increased substitution of MDI for toluene diisocyanate



(TDI) in the production of  polyurethanes due to concern  about the



toxicity of MBOCA in MBOCA/TDI systems.



     o  Increased demand for polyurethane in automotive  body



interior applications as a  result of Federal regulations for



impact resistance, improved vehicle safety, and improved gas



mileage.

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                                 52
                               TABLE 2
           ESTIMATED 4,4'-MD& PRODUCTION 1976-1980 (PEDCo, 1983)

                         Production (millions of pounds)
      Year	MDI  (USITC)	4,4'-Mm (MATHTEC, 1982)
1976
1977
1978
1979
1980
1981(a)
312.2
352.3
439.5
487.7
511.1
517.9
249
289
352
390
409
414
    PEDCo update to referenced data.

     MDI production  is  projected to increase steadily  through
1985 at an annual  rate  of 9% (Mannsville, 1980).   Consumption for
the non-MDI uses of  4,4'-MDA are estimated in Table  5.
     Imports  of 4,4'-MDA have been small, accounting for  less
than 0.4% of  total supply (1977-1979)  (MATHTEC, 1982).   Export
data are not  published  separately for 4,4'-MDA and are  assumed to
be small.  Exports of MDI, however, accounted for  15 to 18%  of
MDI production in  1980  (Mannsville, 1980).  Several  foreign  MDI
plants are expected  to  begin operation,  and this will probably
reduce the demand  for MDI exports (MATHTEC, 1982).
     4,4'-MDA is currently manufactured by six companies  at  seven
locations in  four  states, as shown in Table 3.  One additional
company (BASF), which produced 4,4'-MDA in the past, is presently
importing the  chemical  and plans to open a manufacturing  facility
in the future.  Three of  these companies—Mobay, Rubicon,  and
Upjohn—appear to  account for over 90% of 4,4'-MDA production
(Springborn,  1982, 1983).

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                                     53
                                               TABLE 3

                                    PRODUCERS OP 4,4'-MDA AND MDI
                       PLANT LOCATIONS AND ESTIMATED CAPACITY (MATHTEC, 1982)
Company
Olin Chemical
BASF Wyandotte
E.I. duPont
itobay Chemical

Rubicon Chemical
(ICI Americas)
Uni royal
Upjohn
location
Moundsville, WV
Geismar, LA
belle, WV
New Martinsville, WV
Bay town, TX
Geismar, LA

Nauytuck, CT
LaPorte, TX
1UTALS
197y-1980
blDPi Capacity
(million
NA
NP
10-50
79
79
79

NA
213
460-500*
1979-1980
MDI Capacity
pounds )
NP
NP
NP
100
100
100

NP
270
570
1985
MDI Capacity
(estimated)
	
150
	
100
200
250

NA
270
970+
NA = Not available
NP = Not a producer

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                                54
         3.   Characterization of  Non-MDI Uses of 4 ,,4'-MDA



     Information  from  several sources  (CMA 1983a; ICF,  1983;



Springborn,  1982,  1983)  was  used to  characterize the  commercial



fate of  the  4,4'-MDA that  is not converted to MDI.   Table 4 (ICF,



1983)  summarizes  the  information from  these data sources.



Additional information  from  a CMA-sponsored  survey  of users and



processors of 4,4-MDA  is in  general  agreement with  the  material



presented in Table 4 (CMA, 1984).



     For each of  the ICF (1983)  categories in Table 4,  exposure



level information  is presented below.   The amounts  used in  each



ICF (1983) category are shown  in Table  5.



        4.  Exposure Levels  and  Duration



     Two populations of potentially  exposed  workers are of



concern:  workers who manufacture  4,4'-MDA and  convert  it to  MDI,



and workers who use or process MDA for  other than MDI



applications.



     Two major sources of exposure information  are  used in  this



assessment:  1)  data submitted voluntarily by manufacturers and



processors, and data compiled by  PEDCo  (1983),  summarized in



Tables 6 and 9;  and 3)  measurements made by  NIOSH representatives



during visits to a 4,4'-MDA manufacturing  plant  that  makes  99%



assay product (NIOSH, 1984a)  and  to a facility  that uses  4,4'-MDA



as a curing agent for epoxy-coated,  filament-wound  pipe (NIOSH,



1984b),  which are summarized  in  the  text of  Section V below.

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                                           55
                                        TABLE 4
                                NGN-MDI USES OF 4,4'-MD&
Springborn  (1983)
   Categories
                  ICF  (1983)
                  Categories
CMA  (1983a)
Categories
Epoxy curing
Urethane curing
MBOCA production
Ketiinine production

Wire coating production
Production of coatings
for circuit boards and
aircraft parts
Dye intermediate
Qiana® intermediate
   (not used)(a)

Rubber processing
chemical (not used)
Anti-oxidant in
lubricating oil
(not researched)
(b)
                  Epoxy uses
                  Co-reactant in
                  polyurethane


                  Wire coating
                  PMR-15 as a
                  polyimide
                  Dye intermediates
Epoxy curing

Producing of TGMDA

Co-reactant in
polyurethane
Polyester- imide
wire coatings

PMR 15 polyimide
MDA as an inter-
mediate for polybis
maleimides
MDA as an inter-
mediate for dyes
and pigments

Qiana® intermediate
(not used)(a)

Rubber Processing
Chemical (not used)
                                                                    (a)
Corrosion inhibitor
(not researched)^  '
  Reporting entites indicate that 4,4'-MDA has been, or could  be,  used for
  this purpose, but is not presently so used.
  Springborn (1982) shows zero pounds used.

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                                  56
                               TABLE 5
         NQXJKL PRODUCTION OP 4,4'-MD& FOR NON-HDI USES (ICF, 1983)
      Use	Thousands of Pounds

     Epoxy Curing                               5,000-7.000(a)
     Wire-Coating                                 200(b)
     Coreactant in Production
      of Polyurethane                             250
     Dyes                                      1,500-2,000
     Nuclear Weapons Production^0'                   10
     PMR-15                                       N/A

             TOTAL                            6,950-9,450
         High estimate consists of 4 million Ibs. of crude (65% 4,4'-MDA)
         and 3 million Ibs.  pure 4,4'-MDA (97-100% 4,4'-MDA).
     b   Springborn (1983).
     (c;> DOE (1983b).


     The  estimates of dermal  exposure  to  4,4'-MDA used in this

assessment  in  both MDI-  and non-MDI manufacturing facilities  are

based on  data  from the NIObH  visits just  described.   The

conclusion  should not be drawn that the exposures — and the

estimated doses and risks  derived from those  exposures — are

identical to  those in all  workplaces.  There  are  not enough data

points  to permit such a  conclusion.  Nevertheless, the data used

in this preliminary assessment to estimate dermal exposures were

obtained  using reasonable  industrial hygiene  and  analytical

procedures,  and this analysis assumes  that they  are  reasonable

estimates of  the kind of exposures that may  occur in many

workplaces.   The information  submitted to  EPA by  users and

processors  of  4,4'-MDA (Docket No. 64000a) and that  obtained  from

the open  literature (Dunn  and Guirguis, 1979;  Vaudaine et al.,

1982; Brooks  et al., 1979; McGill and  Motto,  1974; Dunn, as cited

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                                57
in NIOSH, 1976a; Emmett,  1976;  NIOSH,  1976b)  supports  this

conclusion.

            a.   4y4'-MDA  and  MDI  Production  Workers

     As described above,  4,4'-MDA is produced in  the United

States by six companies at  seven  locations  (PEDCo,  1983).  At

these facilities, 284 workers are exposed to  4,4'-MDA  for  less

than 8 hours per week, 159  are  exposed  for 9  to 20  hours per

week, and 13'3 are exposed for more  than  20 hours  per week.  This

information, aggregated here, was submitted to EPA  by  the  CMA

project panel on 4,4'-MDA under claims of confidentiality  for

data from individual companies  (CMA, 1983c) and is  in  substantial

agreement with information  submitted under section  8(a) of TSCA

(Knutson, 1984).

     These workers are exposed  to 4,4'-MDA chiefly  through

inhalation of vapors or particles,  or through dermal contact with

the chemical*.  Levels of exposure  for both routes  have been

measured, although there are uncertainties in these measurements.

     Chief among the uncertainties  in inhalation  exposure

measurements is the accuracy of analytical methods  used (see

Appendix A).  For the dermal route, the  rate  of absorption is the

least accurately known factor.  A dermal absorption study  is

planned for completion in 1984, and work is proceeding  in  several

laboratories toward resolving analytical difficulties.

     A reasonable estimate  of the exposures that  these  workers

experience can be made using  information supplied by the


* Ingestion, via contaminated smoking mat-erial or food, could
  occur, but is not considered  here due  to lack of  data on this
  route of exposure.

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                                58
manufacturers of 4,4'-MDA  (CMA,  19<83c)  and  information  obtained



during a visit by NIOSH  industrial  hygienists  (NIOSH,  1984a)  to  a



4,4'-MDA manufacturing plant.  The  former data  include  ranges  and



average 8-hour Time Weighted Average  (TWA)  measurements of  air



levels of 4,4'-MDA in the  workplace,  while  the  latter  include  the



results of dermal studies.



     Table 6 presents estimates  of  airborne exposure that workers



in the less than 8 hours-, 9 to  20  hours- and more  than 20  hours



per week categories may  experience.



     Table 7 gives the dermal dose  estimates for  4,4'-MDA



production workers.  These estimates  are based  on the assumption



that the exposure experienced by the  chemical operator  studied in



NIOSH (1984a) is a reasonable estimate  of exposures that may



occur under similar working conditions.  This worker was supplied



with new gloves at the beginning of his snift,  and  under the



glove were mounted pads  on the palm and back of the hand, using  a



golf-glove-like device,  which collected 4,4'-MDA during  the



shift.  It should be noted that  NIOSH representatives observed



conditions, such as apparently routine  re-use of gloves, that



might result in higher doses than those calculated  here.

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                                      59
                                   TABLE 6
     4r4'-MD& MEG. WORKPLACE AIRBORNE EXPOSURE LEVELS  (PPM)  (CMA,  1983c)
Sample
Conpany(a) Type(b) <8 hrs/wk

A bz
B a
C bz
D a
E bz
Range
<.0002
ND-0.6
<.005
.001-. 89
•-"-"»
Ave.
.
0.07
<.005
.06
— "•-•
DURATION
9-20
Range
___
.001-0.7
<.005
.001-. 89
^•^HM
hrs/wk
Ave.
__
.02(2)
<.005
.06
"««•
>20 hrs/wk
Range
<.001-.009
ND-0.6
	
.001-. 89
.01-. 10
Ave.
.004
.07
	
.06
.05
(b)
The sixth domestic 4,4'-MDA manufacturer is not a member of the CMA Panel
and did not .submit monitoring information to EPA.
a = area, bz = breathing zone.
                                   •RBLE 7

               ESTIMATED DERMAL DOSES IN 4,4'-MD& MFG PLANTS(a)
          8 HRb/WK
          0.40 mg/day
                               20 HRS/WK
                               2.3 mg/day
40 HRS/WK
4.9 mg/day
     Calculations  shown in Appendix B.   Workers  classified in the <8 hr/wk
     group are assigned 8  hr/wk exposure;  those  in the 9-20 hr/wk group are
     assigned  20 hr/wk; etc.

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                                60
     Table  8  shows  lifetime  average  daily doses (LADDs)* based on

the combined  inhalational  and  dermal exposures presented in

Tables 6 and  7.   The  inhalational  component of these LADDs is

based on the  highest  reported  average 8-hour TWA,  not the highest

range, reported  in  CMA  (1983c).  An  average is considered more

representative of actual exposures than  a high range number would

be, and the use  of  the  highest reported  average from all

reporting manufacturers is a conservative measure  in this risk

assessment.   The  analytical  method used  to determine the TWA used

here is subject  to  interference  from aniline also  known to be


*LADDs are a  tool that  makes possible the quantitative  estimate
of risk to humans using the  results  of studies on  animals.   In
most cancer studies using animals, the animals are exposed to a
known level of the  test chemical at  a known frequency for their
entire lifetime, and  this results  in some incidence of  cancer.
Some comparable  expression of  the  dose received by exposed humans
is required to translate the dose-response seen in animals  to the
human case, and  this  comparable  expression,  the LADD,  is but an
imperfect estimate  of exposure,  since humans are almost never
exposed in exactly  the  same  way  as the test animals.   For
instance, in  the  4,4'-MDA case,  animals  were exposed to the
chemical each time  they drank  water,  over their whole lifetime,
while workers are exposed, at  most,  for  8 hours per day, 250
workdays per  year for as long  as they work — perhaps as long as
40 years.  Some workers may  be exposed for fewer years  than
others, some may experience  higher' or lower levels of  exposure,
and some may  be exposed  for  fewer  days or a different  number of
hours each workday.   These various factors are combined as
illustrated in Appendix B to produce  a LADD.

     The artificiality  of the  LADD can be exemplified  by looking
at the Epping Jaundice  Incident  which people ate 4,4'-MDA-
contaminated  bread.   Surely  these  people  are at higher  risk of
cancer from 4,4'-MDA  than they would  have been had they not been
exposed.  In  order  to quantitatively  estimate what their elevated
risk is, one  would  have  to translate  the  dose they received into
terms that could make use of the dose-response seen in  the  animal
bioassay.  That would be an  LADD.  We are virtually certain that
they are not  being  exposed anymore,  so to say that they are
receiving X mg/kg/day,  as a  LADD does, even now, is pure
artifice.  One notes, nevertheless,  that" those people did suffer
from liver disease, and  this illustrates  that a short  term,  high
level exposure to 4,4'-MDA does  have  a different outcome from „
chronic, low-level  exposure  (See subsection  b,  below)..

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                                 61
present  in the workplace.  Because  of  this possible interference,



the  TWA  value used here may be high (by  as much as a factor of 10



 [CMA,  1983c]).  This would reduce the  LADDs given in Table 8 by



from about 50% (for 8 hours/week duration)  to about 25% (for 40



hours/week duration).
                                   8




                 ESTIMATED 4,4'-MD& MEG. VOFKPLACE LADDs
LADD(a) by Route          _ DURATION

Inhalation (mg/kg/day)
Dermal (mg/kg/day)
Total (mg/kg/day)
8 hrs/wk
0.0031
0.0020
0.0051
20 hrs/wk
0.0064
0.014
0.020
40 hrs wk
0.015
0.027
0.042
    Lifetime Average Daily Dose.  Calculations shown in Appendix B.






              b.   Non-MDI Uses of 4,4'-MDA



                  i.   Epoxy Curing



                      a.   Exposures Related  to the  Curative



                            Package



     Epoxy curing  uses of 4,4'-MDA can result in exposures during



the' formulation,  packaging,  and subsequent  handling  of  the



curative  "package",  which would consist typically  of pulverized



4,4'-MDA, fillers  and pigments, and during  handling  and uses of




the blended epoxy  resin/curative mixture. These two  types  of



exposures are  discussed  below.   The total number of  workers



exposed is not known, but could range from  about 1,500  to  about

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                                62
13,000  (NOHS,  1983).   Exposure  durations  are  not  known,  but have



been estimated based on  assumptions  outlined  in Section  V below.



Exposure levels  for the  non-MDI  uses that were reported  by



manufacturers or processors  are  summarized in Table  9.



     The number of firms engaged  in  formulating epoxy curative



packages is not known.   One  such  firm responded to EPA's 4(f)



notice on 4,4'-MDA and submitted  information  on its  products  and



on worker exposure levels  (Ameron, 1983).   Among  other products,



this firm manufactures curatives  for epoxy coatings  used to



protect concrete structures  in  nuclear power  plants, steel



members in certain marine  structures, and  chemical tanks.  From  10



to 20 employees are reportedly exposed to  airborne concentrations



of 4,4'-MDA ranging from 0.073 to 0.68 mg/m3.

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63
                      TABLE 9
     ESTIMATES OF M» AVAILABLE FOR ABSORPTION
                  BY NUN-MDI USE
                   (PEDOO, 1983)
Process
Reprocess ing
of MDA



Epoxy uses








Polyurethane
curing

Operation

Dumping
Mixing
Packaging
Unspecified
Mixing of MDA
to make fila-
ment-wound
pipe
Manufacture
of TGMDA
Pulverization
of MDA
Unspecified

Potting roan
near oven
Exposure
route

Inhalation
Inhalation
Inhalation
Dermal



Inhalation

Inhalation

Inhalation
Dermal

Inhalation
dermal
Measured
ppm

0
-
U
(a)



0.0125

0.0075

0.1
Unknown

0.01
(a)
level
mg/m

.12-3.11
0.48
.53-0.68
(a)



0.10

0.06

0.82
-

0.08
(a)
Estimated
exposure time
hrs/day

1
1
6
8



2

8

1
-

8
8
day/yr

250
250
250
250



250

250

250
250

250
250
Amount available
for absorption
Inhalation
mg/kg/yr

7
2
16
N/A



1

2

4
N/A

3
N/A
Dermal
mg-hr/kg/yr

N/A
N/A
N/A
3,600la'



N/A

N/A

N/A
-

N/A
3,600la'
                   CONTINUED

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                                       64
                                                   TABLE 9 - CONTINUED
Process
Operation
 Exposure
  route
                                                    Measured  level
                                                          Estimated
                                                         exposure time
                                                                                                   Anount available
                                                                                                    for absorption
          mg/nT
firs/day     day/yr
Inhalation

 mg/kg/yr
  Dermal

mg-hr/kg/yr
Intermediate
  for poly-
  imides for
  wire coating

Intermediate
  for poly-
  male imides
  for aircraft
  parts
Intermediate
  for dyes
Intermediate
  for rubber
  additive
Dumping of MDA   Inflation
                Unknown
                                  100
                                         N/A
Unspecified
Dumping of
 MDA into
Dumping of
 MDA into
 reactor
Inhalation/
 dermal
Inhalation/
 dermal
Inhalation
 dermal
Unknown
Unknown
              40
Unknown
             250
N/A - Not applicable
                                                                                                            2
(a) Based on wipe  samples taken of a similar chemical, MBOCA,  used to cure polyurethane,  averaging 72 ug/cm  (17 samples)
    Other estimates of  the amount of 4,4'-MDA available for absorption in some of these settings are given  in Section V.

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                                65
     Eleven cases of acute  jaundice  related  to  4,4'-MDA  exposure



in a curative formulation plant  between  1967 and  1976  were



reported by Dunn and Guirguis  (1979).  At  this  plant,  located  in



Ontario, Canada, previously ground and screened 4,4'-MDA was



received, blended with silica  sand,  and  packaged.   Blending was



carried out in two blenders located  in a separate  room with roof



exhaust.  The materials were mixed for 20  minutes,  then  packaged.



Five to seven workers were employed  in the manufacturing area  at



any one time.  Workers wore respirators  when adding  4,4'-MDA and



sand to the mixer.  After 1976,  the  company  began  providing



workers with coveralls, gauntlets, shoe  covers, head and neck



covers, and positive-pressure  airline breathing apparatus.



Despite these changes, some workers  were still  affected,



indicating that special care in  the  use  of protective  clothing



and equipment must be taken to ensure against inadvertent



contamination that can lead to exposures via dermal,



inhalational, or ingestion routes (see the report  of Vaudaine  et



al., 1982, below).



     Air sampling data (15-minute samples) taken during  charging



of 4,4'-MDA to the blender ranged from 0.2 to 3.11 mg/m  ; during



mixing the measurement was 0.48 mg/m ; and during  packaging the



measurement ranged from 0.53 to  0.68 mg/m  .   Improper  gasketing



of equipment accounted for a large proportion of dust  during the



blending.  A flexible exhaust  hose (20 cm  in diameter) placed



near the operation during charging and bagging  was  found to have



a large hole and was replaced.   During production, the workers



wore coveralls which were changed twice  a  day,  a hat with a wide

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                                66
brim,  impervious gloves,  and  an  airline  respirator.   Coveralls



were found not  to  be  impervious  to  4,4'-MDA.   (  While Dunn and



Guirguis reported  no  quantitative information  of the  penetration



of coveralls by 4,4'-MDA,  this permeability  is used  as one of the



assumptions in  applying NIOSH (1984a,  1984b) dermal  exposure  data



to calculation  of  dermal  LADDs in Appendix 3.)



     Additionally/ the armpits of affected workers were stained



with 4,4'-MDA because these individuals  had defeated  the



protection of the  coveralls by making  cuts in  the material to



relieve the heat stress of summer days.  The main route of entry



of 4,4'-MDA to  the affected persons was  believed to  be dermal.



     The type and  extent  of controls used by other curative



formulators is not known,  though investigation  of both controls



and exposure levels are currently being  investigated.



             b.  Exposures Related  to  Handling/Use of Complete



                   Egoxy  Resin Formulations



     Epoxy resins  are used in a variety  of applications



including:  coatings, laminates and composites,  casting and



molding, flooring, and adhesives.   4,4'-MDA has  been  used  in



epoxy molding powders, stick  solders,  fiberglass cloth-epoxy



laminates, and casting compounds (Springborn,  1982).



     Since the applications for epoxies  are so  varied,  there  is



no simple process  or operation that can  be described  for curing



of epoxy resins with 4,4'-MDA.  In general, either purified or



polymeric 4,4'-MDA is added to the epoxy resin  and mixed just



prior to use of the polymer.  This can be done  at a construction



site, as with use  of the  epoxy as a concrete coating,  or in a

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                                67
 closed  and  automated process,  as in the manufacturing of filament



 windings.   In  all  cases,  the process involves adding the 4,4'-



 MDA, mixing  with the epoxy resin,  and applying the mixture to a



 surface or  forming the product.   All three steps are potential



 points  of worker exposure,  but most information, including NIOSH,



 (1984b)  indicates  that the addition of 4,4'-MDA to the resin is



 the operation  of greatest  concern,  because of the propensity for



 4,4'-MDA, especially the  high  assay material, to "dust"  and



 contaminate  nearby surfaces  during  such handling.  The epoxy



 cross-linking  reaction forming the  epoxy is exothermic,  and the



 mixing  and curing  processes  are  usually at elevated temperatures.



     4,4'-MDA  is used  as  a  curing agent for epoxy resins in a



 wide variety of structural  laminates  including filament  winding,



 wet lay-up laminates,  and  potting,  casting,  and encapsulation



 (CMA, 1983a).  Filament-wound  epoxy pipe cured with 4,4'-MDA has



 numerous uses  including casings  of  rockets (Trident,  Pershing,



 MX, and space  shuttle), oil  drilling  pipe,  pipes for  chemicals,



 and fuel tanks for military  aircraft  (CMA,  1983a).   CMA  (1983a)



 reports exposure in  a  European filament winding plant ranged from



 0.002 mg/m3  to 0.1 mg/m , with the  high value during  the



 preparation  of the  mixture of  epoxy resin  and 4,4'-MDA.



     Wet lay-up laminates cured  with  4,4'-MDA are used as



 structural parts for aircraft.   The epoxy  is  used to  impregnate  a



 reinforcing  fiber  cloth.  The  impregnated  cloth,  called



 "pre-preg",  is then  refrigerated  to arrest curing until  final



molding occurs under heat and  pressure.   CMA  (1983a)  reports



 4,4'-MDA concentrations below  the detection  limit of  0.001  mg/m

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                                 68
 in  the  pressroom.   No measurements are given for the mixing



 operation.   NIOSH,  however,  reports that breathing zone



 measurements done on a molder of helicopter blades showed



 concentrations  of 0.23,  less than 0.022, and 0.46 mg/m3 of 4,4'-



 MDA for three different 20-minute periods in one shift (NIOSH,



 1983).



      Liquid  epoxy resins cured with 4,4'-MDA are used in the



 potting,  casting, and encapsulation of electrical components.



 4,4'-MDA is  preferred because of excellent insulation



 characteristics  and  low  shrinkage of the polymer it produces.



 Casting  and  curing occur in  closed vacuum chambers (CMA,



 1983a).   4,4'-MDA has been specified in numerous nuclear  power



 plant applications  (CMA,  1983a;  Brechna, 1965).   One manufacturer



 of  4,4'-MDA-cured epoxy  concrete coatings ships  the amine in a



 screw-top container  into which the liquid epoxy  resin is



 poured.   [Mixing  thus  occurs  in the same vessel  in which the 4,4'-



 MDA  is  shipped,  reducing  dusting and worker exposure.  However, in



 one  report (Williams  e_t_ _al_. ,  1974),  6  of approximately 300  men



 who  applied  epoxy resins  containing  4,4'-MDA to  concrete  walls at



 a nuclear power  plant  developed  clinical hepatitis 2 days to 2



 weeks after  starting  work.   4,4'-MDA had been mixed with  liquid



 epoxide  at the work  site  and  applied to walls with trowels  or a



 spray gun.   Exposure  levels  were not reported.



     Special  epoxy resins described  as  tetraglycidyl-



methylenedianiline (TGMDA)-derived resins,  are reinforced with



glass, graphite, boron,  or aramide fiber?  and used in  aerospace



and  leisure  products,  structural adhesives,  laminates,  tooling

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                                69
and casting  applications,  and  structures  such as  aircraft wings



and fuselages  (Kirk-Othmer,  1980).   The only point of exposure is



the introduction  of  the  4,4'-MDA  into  the process vessels.  The



synthesis  reaction  is  carried  out in closed  vessels,  and the



4,4-MDA  is consumed.   Controls used  in the operation  are not



known.   The  maximum  concentration reported in TGMDA manufacture



.was XJ.06 mg/m  , but  no further data  were  provided (CMA,  1983a).



     A second  reported incident of human  exposure involved



production of  a component  of an insulating material (McGill  and



Motto, 1974).  Between 1966 and 1972,  twelve male workers whose



job it was to  manually mix 4,4'-MDA  into  an  epoxy resin



contracted hepatitis.  A thirteenth  individual  also contracted



hepatitis; his 4,4'-MDA exposure  reportedly  occurred  during  the



pulverization  of  4,4'-MDA  flakes  for the  process.  Atmospheric



4,4'-MDA levels were measured  at  0.1 ppm  (analytical  method  not



reported) during  the first survey.   Workers  who experienced  only



inhalational exposure  did  not  contract  hepatitis.   Each  worker



who did contact the  disease had at least  one hand exposed to the



mixture for  several  hours  per  shift.   Thus,  the probable critical



exposure to  4,4'-MDA by the affected workers was  through skin



contact.  This is a  consistent  theme throughout the investigation



of workplace exposure  to 4,4'-MDA.



     About 100 employees were  potentially exposed to  4,4'-MDA  at



the facility.  Various means were undertaken to reduce 4,4'-MDA



levels, including construction  of exhaust ports and respiratory



protection described as breathing helmets.   The process  has



subsequently been automated to  prevent  worker skin exposure  to



4,4'-MDA (McGill  and Motto, 1974).

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                                70
             c»  Exposure  in  an  Un-Characterized Setting

     Vaudaine ^t^ ^1_.  (1982) described  a  toxic  agent  monitoring

program at a Rhone-Poulenc  Industrie facility,*  focussing  on

4,4'-MDA.  Rather than monitor air  levels  of  the chemical,  these

researchers chose to monitor  workers'  urine  for  4,4'-MDA on a

"present" or "not-present"  basis.

     During the  period of  1970 to 1978,  the  chemical was handled

by workers in full protective 'suits  ("divers'  suits"),  yet

workers' urine showed levels  of  4,4'-MDA of  at least 200 ug/1 in

144 of 965 samples (14.9%)  in 1970.  Dust  from inside the  suits

showed "fairly significant" levels of  the  chemical.

     As the decade wore on, the  need to  avoid  dust contamination

was gradually recognized,  resulting  in lower percentages of 4,4'-

MDA-positive urine samples  and reduced levels  of the chemical in

those samples that were positive.  By  1978,  the  threshold of

detection of the amine in urine  was lowered  to 20 ug/1,  and 2.7%

of samples contained 20 to  80 ug/1, 2.0% contained 80 to 200

ug/1, and 4.0% contained over 200 ug/1 —  for  a  combined 8.7%

"positivity index."

   /From 1978 through 1980, "there was  an improvement  in working

conditions brought about by cooperation  among  the company

physician, the manufacturing engineer  and  the  shop personnel."

In 1980, the sampling program found 0.9% of  urine samples

contained 20-80 ug/1, with  no samples  showing  higher
* The report did not state the type of use or processing of  4,4'-
  MDA carried out at the facility, but did mention empty drums
  and 4,4'-MDA powder as being exposure concerns.  Contact with
  the authors is being sought.

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                                71
concentrations.  This  case  clearly  demonstrates  that an informed



workforce and committed management  can  reduce  exposure



significantly.



                 ii.   Co-reactant  in  Polyurethanes



     A small quantity  of  4,4'-MDA,  estimated at  50 thousand



pounds/year, is used as a polyurethane  curing  agent (Springborn,



1982).  The primary use of  4,4'-MDA as  a  polyurethane curing



agent is with aliphatic isocyanates,  in which  system pot  life is



long enough to permit  use in  spray  applications.



     The options for adding 4,4'-MDA  to polyurethane batches are



the same as for epoxy  curing.  However, due to the smaller



quantities used, it is more likely  that the operation may be done



by hand.  This increases  the  opportunity  for dermal and



inhalation exposure.   Unit operations are  the  same as for epoxy



curing:  addition of the  4,4'-MDA,  mixing, and application  or



formation of the product.  There is no  estimate of the  number of



workers involved nor of the frequency and  duration of exposure.



     All three operations involve potential worker exposure  to



4,4'-MDA, with the potential  for skin contact  and  inhalation



depending on the work  practices at  the  individual  facility.



Controls used in these operations are not  known.   However,  it is



likely that cloth gloves, at  least, are used for protection  from



heat from the 4,4'-MDA melting pot, hot molds, and other



equipment in the work  place.  As note above, cloth gloves are



permeable to 4,4'-MDA.

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                                72
      Three  cases  of worker exposure to 4,4'-MDA during



 polyurethane  molding have been reported.  In one case reported in



 1976,  during  a 6  month period at least 8 employees in a



 polyurethane  molding plant developed dermatitis on skin areas



 exposed  to  4,4'-MDA, usually during the second or third week of



 work  (Emmett,  1976).  Four other employees who worked as molders



 during  this time  did not  develop symptoms.  No measurements of



 exposure  levels were.reported.



      In  another case,  also reported in 1976,  workers requested



 that  NIOSH  inspect  the facility  due to the presence  of a wide



 variety  of  toxic  chemicals,  including  4,4'-MDA (NIOSH, 19765).



 The 4,4'-MDA  was  used  in  the formulation of a polyurethane resin



 used  to make  plastic belts.   The operation involved  preparation



 of special molds, mixing  of  the  polyurethane,  and curing of the



 polyurethane  in molds  to  form belts.   Liquid  polyurethane resin



 containing free methylene  bis(4-cyclohexyl isocyanate) was mixed



 with  heated liquid  4,4'-MDA.   The  storage,  heating,  and mixing of



 the chemicals  were  performed  in  closed,  highly automated



 systems.  On  the  initial  visit NIOSH industrial  hygienists



 noticed that conditions and  work practices were  not  consistent



with good industrial hygiene  practices.   Uncovered containers of



 4,4'-MDA were  left  open in the work area,  and  open containers of



waste chemicals were discarded in  wastepaper  baskets,  exposing



 janitorial workers  to  skin contact  with  these  materials.   During



a second visit, three  months  later  in  May  of  1975, the work area



and work practices  had been  improved.   Local  exhaust  ventilation



was being installed  at the pouring  and  curing  stations.   Twelve

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                                73
air samples were collected  on  this  visit  and  analyzed  for 4,4'-



MDA.  All samples  showed  4,4'-MDA below  the detectable limit of



0.05 mg/sample.  Samples  ranged  from  2.9  to 13.42  liters.   Thus,



airborne concentrations were below  3.8 mg/m .   Dermal  exposure



measurements were  not made.



     In a third case, NIOSH was  asked by  the  Independent  Union of



Rotameter Workers  to investigate the  health effects  of asbestos



fibers and organic vapors upon workers at  the  Fischer  and  Porter



Company in Warminster, Pennsylvania (NIOSH, 1980).   4,4'-MDA was



being used to cure polyurethane  that  covered  an  epoxy  system



employed to hold and encapsulate water flow measuring  instruments



in water pipe.  The 4,4'-MDA was weighed,  heated in  an oven,



mixed with the isocyanate, and poured on  the previously set



epoxy.  The molding was then ground and sprayed with enamel.   Of



three ambient measurements taken by NIOSH, the highest 4,4'-MDA



level was 0.08 mg/m  in the potting room near  the oven.



                 iii.  Wire Coating, Polyimides and PMR-15



     Methylenedianiline is used as an ingredient in  the



production of polyester-polyimide electrical conductor coatings



and polymeric amide-imide-ester wire enameling compositions.



4,4'-MDA is also used to produce a high-temperature-resistant



polyimide,  PMR-15.  PMR-15 is beginning to be  used commercially



as a replacement for titanium in jet engine components.   It  is



planned for use in the engines of the F-18 fighter, the B-l



bomber, and new versions of the Boeing 747 and 767 airplanes



(CMA, 1983a).

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                                74
     There are  no  quantitative  data  on  exposure  leve^-3 f°r these

uses of 4,4'-MDA.   The  processes  involved indicate that partially

cured, or B-stage,  resin  systems  are handled  by  wire coaters or

aircraft workers.   The  B-stage  systems  are then  heated to effect

complete polymerization to  cross-linked material.   There would be

potential inhalational  and  dermal exposure to 4,4'-MDA if some of

that monomer were  present in  the  B-stage resin.

     Additionally,  workers  who  charge 4,4'-MDA to  the reactors in

which the B-stage  polyimide is  produced may be exposed to the

chemical at levels  comparable to  those  experienced by epoxy

curative workers (see above).

                 iv.  Other Uses

     4,4'-MDA is used as a  curing agent for polymer systems used

in fabricating  nuclear  weapons  (DOE,  1983a, b, c,  d).   About

10,000 pounds/year  of the amine is used at six sites,  with the

greatest (>90%) usage at the Bendix  Corp.  facility at Kansas

City, Missouri  (DOE, 1983b).

     Personal air monitoring at the  Bendix plant failed  to show

detectable levels of 4,4'-MDA, while  the  highest recorded levet

(DOE, 1983c) at any DOE facility  was  0.232 mg/m3.   However,  DOE

states that respirators are worn  for  the  operation that  involved

this exposure level in  ambient air,  and that  dermal exposure is

prevented by the use of protective equipment.

     Information on the quantity  of  4,4'-MDA  used  in synthesis of

antioxidants for lubricating oils and greases  and  general

descriptions of the processes involved  can be  found in PEDCo
                                         •»
(1983), though CMA  (1984) indicates  that  no 4,4'-MDA is  currently

being used for  these purposes.

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                                75
      in some of  the  non-MDI  uses  the  purified  form of 4,4'-MDA is



required, and  the  physical  form may  result in  some "dusting"



during use.  There are  virtually  no  data  on the  extent of such



"dusting" in these workplaces.  In order  to estimate  the extent



of possible dermal exposure  to workers  in these  situations,



several different  hypothetical cases  are  considered in



conjunction with dermal monitoring data (NIOSH,  1984a and b).   In



one'scenario,  worker protection is assumed to  be equivalent  to



that  of workers packaging pure 4,4'-MDA at the manufacturing



site, and 4,4'-MDA would be  handled  throughout the shift.   For



this  scenario, dermal exposure calculations are  made  in the  same



way as in the  4,4'-MDA manufacturing  section.  However,  actual



exposures, especially dermal exposures, may be higher if



management and workers are less aware of  the hazards  of 4,4'-MDA



than  their counterparts in the manufacturing setting,  and



separate exposure calculations have been  made  for  these



conditions.   Another situation covers workers  in Department  of



Energy contractor facilities where nuclear  weapons  are



fabricated.



     As in the manufacturing setting, workers  in these



processing/using cases may be exposed to  4,4'-MDA  intermittently



or continuously as they handle the chemical  while  charging



reactors, mixing batches of  ingredients for  repackaging, etc.



Recognizing  these variables, Table 10 presents lifetime  average



daily dose estimates (LADDs) for workers  in  these  cases  of varied



exposure durations and settings.  Details  of each  setting



considered here are given in Section V  and  in Appendix  B.

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                                76
     The inhalational component of  the exposures  and  LADDs  in



Table 10 is based on the mean of  airborne  exposure  level



measurements reported by Ameron (1983) and cited  in subsection  a.



above.  These measurements were made  in  the vicinity  of a work



station where dry ingredients for a protective coating resin



system were packaged.  For the DOE workplace no dermal component



is included.  Information received from  DOE (DOE, 1983 a,b,cfd)



indicates that special care is taken  in  these workplaces, where



handling of highly toxic or otherwise hazardous substances  is



routine, to preclude dermal contact with 4,4'-MDA.  Monitoring



data from DOE (1983c) were used to estimate inhalational



exposures and LADDs.  The highest recorded exposure level,  0.232



mg/m , was not used in the calculations  since DOE indicates (DOE,



1983c) that respirators are worn during  this operation.  Exposure



to 0.02 mg/m  tor 0.2 hours/day was used in the calculations.



     B.  Potential Exposure Related to Consumer Contact With



           4,4*-MDA-Containing Articles  or Products



     There is no evidence that 4,4'-MDA  is used in consumer



products.  The Chemical Manufacturers Association recently



sponsored a survey (CMA, 1984) of 312 companies,  that buy 4,4'-



MDA from U.S. producers.  Sixty-one companies, representing 47%



of the merchant market of 2.64 million pounds in  1982, responded.



The results indicated no consumer products containing the



unreacted chemical.  With 53% of the merchant market  unaccounted

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                                               77
                                             TABLE 10

                            4r4'-MD& USING/PROCESSING WORKPLACE LADDs
                                          2.5  hrs.
                                                          Exposure Duration Per Week
                8 hrs.
              20 hrs.
               40 hrs.
Minimal Dermal Exposure^a'
Duration (Appendix B, Section 2)
  LADD by Route in mg/kg/day
    Dermal
    Inhalational
    Total

Continuous Exposure
(Appendix B, Section 3)
  LADD by Route in Jig/kg/day
    Dermal
    Inhalational
    Total

Variable Exposure Durations
(Appendix B, Section 4)
  LADD by Route in mg/kg/day
     Dermal
    -Liihalational
    Total

bhort-Term Exposures
(Appendix Bf Section 5)
  LADD by Route in mg/kg/day
    Dermal
    Inhalational
    Total
DOE contractors
(Appendix B, Section 6)
  LADD by Route in mg/kg/day
    Dermal
    Inhalational
    Total
Short-Term Intermittent
Exposure-Best Industrial Hygiene
(Appendix Bf Section 7A)
  LADD by Route in mg/kg/day
    Dermal
    Inhalational
    Total
0.00040
0.00066
0.0011
0.000016
0.00066
0.00068
0.0032
0.0021
0.0053
0.0067
0.0052
0.012
0.0010
0.0021
0.0031
                0.0011
                0.00066
                0.0018
                nil
                0.000013
                0.000013
0.0042
0.0052
0.0094
        (b)
                              0.000028
                              0.0052
                              0.0052
0.010
0.010
0.020
                                              0.16
                                              0.010
                                              0.17
0.0095
0.010
0.020
                             0.000028
                             0.010
                             0.010

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                                               78
                                      TABLE 10 — CONTINUED
                                         2.5 hrs.
Exposure Duration Per week
3 hrs.        20 hrs.        40 hrs.
Appendix B, Section 7B)
  IADD by Boute in mg/kg/day
    Dermal
    Inhalational
    Total

Hypothetical Workplace
Standard in Effect
(Appendix B, Section 8)
  IADD by Route in mg/kg/day
    Dermal
    Inhalational
    Total
              0.00028
              0.0013
              0.0013
0.00028
0.0026
0.0026
                             0.00011
                             0.00022
                             0.00033
    The Exposure Duration Headings for this case correspond to various delay periods between
    time of dermal exposure and removal of the 4,4'-MDA by washing.  Thus,  2.5-,  8-, 20- and
    40- hours per per week headings correspond, for the dermal component of the LADD,  to
    wash-up 0.25, 2, 4 or 6 hours after exposure.
(b)
    Exposure is for 1 hour per week.

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                                79
 for,  however,  it is not possible to state absolutely that no


 4,4'-MDA is  present as such in consumer products,  although use of


 4,4'-MDA in  production of TGMDA appears to account for most of


 the  "missing"  material.   Aggregated data from the  TSCA section


 8(a)  reporting rule,  reported  by 4,4'-MDA manufacturers,  indicate


 that  in  1982,  660  to  2,600 pounds of the chemical  may have been


 used  by  their  downstream customers to manufacture  consumer


 articles from  which "limited release" of 4,4'-MDA  might occur


 (Knutson,  1984).   It  does not  appear that this  quantity of 4,4'-


 MDA,  even  were it  in  fact finding its way into  "limited release"


 consumer articles,  would lead  to chronic levels of exposure that


 could cause  significant  cancer risks.


     Two patents have  been issued for products  containing 4,4'-


 MDA for  the  purpose of  treating  hair.  Available information does


 not indicate whether  4,4'-MDA  is actually being used  in this


 application, although,  as  stated above,  4,4'-MDA suppliers claim


 that there are no consumer uses  for 4,4'-MDA  (Springborn,  1983).


     The Color Index  lists two dyes made using  4,4'-MDA,  CI 24750


 (Acid Red 9, Milling Red R) and  CI  42500 (Basic Red 9,


pararosaniline), but  indicates that only CI 42500  is  currently


being manufactured.  The  manufacturer listed  is American  Cyanamid


Organic  Chemicals Division at  the Bound  Brook Works in  New


Jersey.  However, contact  with the  facility indicated  the  dye  is


no longer produced. Contacts at  the Dyes Environmental  and


Toxicology Organization  stated that they knew of no dyes  being


produced using 4,4'-MDA  (PEDCo,  1983).   However, information
                                        •»

submitted by CMA (1983a)  indicates  that  4,4'-MDA is a  non-


 isolated intermediate  in  production.

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                                80
      C.   Potential Exposure Related to Drinking Water and



            Ambient Air Contamination



      There  is,  at  this time,  no evidence that any drinking water



 supply  is contaminated with 4,4'-MDA.   Surface waters that are



 used  for  drinking  water supply, however, do receive effluents,



 directly  or indirectly,  from  4,4'-MDA,  MDI and polyurethane



 manufacturing operations,  which could  contain 4,4'-MDA.   [MDI can



 hydrolyze to  4,4'-MDA when a  large  excess of water and favorable



 mixing  conditions  are present.   It  is  converted to a stable area



 derivative  under other conditions  (CMA,  1983b)].



      Likewise,  groundwater used for drinking water supply might



 be contaminated through  migration of 4,4'-MDA from various



 wastes.  At present,  EPA has  no information indicating that such



 contamination has  occurred, so  no risk estimate for this



 potential route of  exposure can be  made  beyond that given in the



 text  discussing Table 11.



      EPA  is studying  the potential  for exposure through surface-



 supplied drinking  water  by measuring the amount of 4,4'-MDA



 discharged  from the treatment works  of a 4,4'-MDA/MDI



 manufacturing plant.   If significant levels  are found, steps will



 be taken to determine the  fate  of the discharged  4,4'-MDA.   The



 Agency is taking this  approach,  rather than  attempting to measure



 4,4'-MDA levels at drinking water intakes,  because of  the current



 limitations on analytical  sensitivity.   A level of about  0.3 ug/1



 in drinking water produces an estimated  added  lifetime risk of



developing  cancer by  humans of  about one in  one million (see



Table 11),  whereas current analytical methods  have a practical



detection limit of about 1-10 ^ug/1.

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                                81
     If a significant level of  4,4'-MDA  is  being  discharged,  data



on stream dilution and environmental  fate will  be obtained  and



used together with discharge data  to  calculate  possible  doses of



4,4'-MDA received by people drinking  contaminated water.



     In the interim, while this  investigation proceeds,  estimates



of 4,4'~MDA releases and the associated, consequent doses and



risks have been made.  These release  estimates  are summarized in



Table 11 and explained in further  detail below.   Because some of



the information used in these estimations has been claimed



confidential, the identities of  the companies involved are  not



disclosed.  Only four of the seven 4,4'-MDA manufacturing plants



discharge waste water into streams that provide drinking water



supplies.  These four sites are designated Plants A through D.

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                                82
                             TABLE 11
           ESTIMATED  4,4'-MDA  LEVELS IN  SURFACE WATERS
                                             Concentration
Plant	Estimation	mg/1	

  A                    Worst  Case              5.0 X  10~4
                       Best Estimate           1.8 X  10~4

     a)                Worst  Case              1.2 X  10~3
                       Best Estimate           3.0 X  10~4

                       Worst  Case              4.8 X  10~3
                       Best Estimate           1.2 X  10~3

                       10"6 Excess  Risk        2.8 X  10~4
 a'  Both plants discharge  into  the  same  stream.


     The concentrations presented as  "Worst  Case"  and  "Best

Estimate" are derived from  assumptions about production  volume,

process losses, and operating schedules,  detailed  in Versar,

(1983b), coupled with information on  each plant site,  such as

total plant effluent flow rate (from  waste water discharge

permits) and hydrologic characteristics of the receiving

streams.  Instantaneous and complete  mixing  is assumed to take

place as the effluent enters the river, and  no partitioning  to

suspended solids or degradative  processes are assumed  to operate

to remove the 4,4'-MDA from the  water column.  Since it  is

expected that some degradation in the receiving stream,

especially photo - and chemical-oxidation, does occur  (EPA,

1982), and since these plants treat  their effluent  prior to

discharge (CMA, 19835), these estimated concentrations are

believed to be considerably higher than those that  are actually

occurring.

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                                83
     The concentration estimation  titled  "10    Excess  Risk"  is  a



calculated value, derived by assuming a 70-year lifetime



consumption of 2 liters/day of contaminated water  by a person



weighing 70 kg and using tumor incidence  of hepatocellular



carcinomas and adenomas in female  mice with the multistage model



(Crump, 1980) upper 95% confidence limit.  This tumor  type was



selected because it afforded one of  the highest estimated risks



of all observed tumor types in the bioassay (NTP,  1983a), and



represents a conservative assumption.



         1.  Releases from 4,4'-MDA Manufacturing  (Versar,



               1983b)



     During manufacturing, it is expected  that  nearly  all of the



4,4'-MDA releases will occur from  neutralization,  aniline



separation, and product purification.  These production



procedures, described in Section IV  A above, are briefly



summarized below.



     Neutralization;  The crude reaction  product is acidic and



must be neutralized.  It is piped  to a tank where  concentrated



aqueous sodium hydroxide is added  (Moore,  1978).   The  water and



salt created in this step are not  released at this point, but



piped, with the product, to the next step.



     Aniline separation;  During aniline  separation, the organic



layer is separated and washed with water  and then  sent to a



distillation facility which removes  unreacted aniline  (Moore,



1978).  This step probably releases  the largest quantity of 4,4'-



MDA in the form of contaminated wastewater.

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                                84
     Purification;  Not all  4,4'-MDA  is  purified.   Little



information  is available on  this  step.   Either  distillation or



re-crystallization processes could be employed.   Some  releases,



in the form  of contaminated  water and organic wastes,  are



possible.



     Gaseous wastes contaminated with 4,4'-MDA  have  been reported



to be insignificant (JRB, 1980; ESE,  1981).  Furthermore,  it is



expected that 4,4'-MDA will  not volatilize  from  the  aquatic



environment  because of its extremely  low Henry's  law constant



(ratio of vapor pressure to  aqueous solubility).   It is therefore



assumed that airborne 4,4'-MDA emissions will be  negligible.



     No information could be found quantifying 4,4'-MDA water



releases from manufacturing.  These releases will  depend on



several factors, including:  production  level, water



requirements, processing conditions, and the level of  pollution



control.  Since most of these data are unavailable,  it was



necessary to use a number of simplifying assumptions in



estimating releases, and these are presented below.  Again,  the



effluent monitoring work,  now underway,  is expected  to provide



data in this area.



                  a.  The ratio of grams of process  and wash



water to grams of product is 4.3 to 1 (Perkins,  1968;  Ramney,



1972; Powers, 1970; MATHTECH, 1982).  The assumptions  used  to



derive this  value are presented in Appendix A of Versar (1983b).



                  b.  It is assumed that both the  process-  and



the wash water will be saturated with MDA (1 gm of MDA/liter of



water).

-------
                                85
     Therefore, total MDA water  releases  from  manufacturing

become:



     187,988 kkg of MDA  x   4.3   gm H20    x   1000      liters .
                 yr               gm MDA              kkg  of  water

     x 1 x 10"6  kkg     =    808  kkg of  MDA released
                 gm                       yr


     This is a worst-case estimate.  In another  estimate,  it was

assumed that the 4,4'-MDA concentration in  the wastewater

(process and wash water) will reach only  10% of  the maximum

solubility (0.1 gm MDA/liter of water) due  to  the salt  effect and

the dilution of process water with relatively  uncontaminated wash

water.   For this latter case, the total MDA releases  are 80.8

kkg/yr*.   It should be noted, however, that it is possible for

sodium chloride to complex 4,4'-MDA (CMA, 1983a) under  certain

conditions,  and, thus, sodium chloride might enhance, rather than

diminish,  the aqueous solubility of 4,4'-MDA.

        2.  Releases from 4,4'-MDA Use as a Feedstock (Versar,

              1983b)

     Most of the 4,4'-MDA produced in the United States (about

90%) is captively converted to MDI at the manufacturing site;

approximately 9% of the total production  is converted to MDI at

other locations, and the remaining production  is used in other

applications (Springborn, 1982; ESE, 1981).

     Background data and some release estimates  for the use  of

4,4'-MDA as a feedstock are discussed below.   Most of the
* Aggregated data reported by manufacturers undei TSCA Section
  8(a) indicate that up to 180 kkg of 4,4'-MDA is lost during
               ^ _ ,-) 1.U-.

-------
                                36
discussion  deals  with  the  production of  MDI;  however,  some



information is  also  presented  on the other uses.   It was



estimated that  in 1981-/  the  4,4'-MDA releases to  air and water



from MDI manufacturing  range from 26.9  to 269 kkg.



              a.   Releases  from MDI Manufacturing



     In 1982, approximately  361,000 kkg  of MDI were produced;



this material was used  to  manufacture rigid and semiflexible



polyurethane  foams -and  urethane elastomers.



     MDI releases from  manufacturing could significantly affect



4,4'-MDA releases, since MDI can hydrolyze to 4,4'-MDA under



certain conditions.  However,  no quantitative data  could be found



concerning  MDI manufacturing releases.   Therefore,  release



estimates were based on a  number of simplifying assumptions.



Assumptions for air and water  releases are presented below.



     Because the  vapor  pressure  of  MDI is  low (5  x  10~  mm Hg at



25°C) (Woolrich,  1982), it was  assumed that air releases of MDI



leaving the manufacturing  facility  will  be very small.



     Water  releases were estimated  based on the data found in



three patents concerning MDI manufacturing  (Beck, 1958,- Hidetosh



et_ _ad_. , 1968; Pistor ^t_ _al. , 1977).   These patents  indicated that



process water is  not used  in the  manufacture  of MDI.   One  patent



(Hidetosh,  1968)  called for  the  use of non-contact  cooling water,



which is expected to remain  uncontaminated.



     Since MDI is known to react  with water,  no water  is used to



wash MDI.   However, it  is expected  that  some  water  will  be used



for maintenance,  equipment cleaning,  and work  area  washdowns.  It



has been assumed  that such water  requirements  for MDI  production

-------
                                87
will be  the  same  as  those  of  4,4'-MDA production.   This is a

worst-case assumption  since the  organic  4,4'-MDA layer is known

to be washed  with water.   Wash water  constitutes one-third of the
                                                    g
water used in 4,4'-MDA manufacturing,  i.e.  8.1 x 10  1/yr.

Therefore, the  water requirements  for  MDI manufacturing are
                       o
assumed  to be 2.7 x  10  1/yr.

     As  a worst case estimate, it  is  assumed .that  any MDI

contacted by  wash water  would be immediately hydrolyzed to 4,4'-

MDA, and that sufficient 4,4'-MDA  would  be  produced for the water

to become completely saturated.    As a more realistic case,  it  is

assumed  that  the  water would only  reach  one-tenth  of the

saturation point.

     According  to the  worst-case assumptions,  4,4'-MDA releases

from MDI manufacturing become:

          2.7 x 108 1/yr x 1 gm 4,4'-MDA x 1  x  10"6 kkg  =
                                liter                 gm

          270 kkg/yr of 4,4'-MDA released

     For the  more  realistic case,  the total releases of 4,4'-MDA

are estimated to  be 27 kkg/yr*.

              b.   Releases from Other Product Manufacturing

     Releases from the manufacturing of  the IGF  category  products

listed earlier  in Table 4 could not be estimated because  of  the

lack of  information on the various manufacturing processes.
* At this time there are no TSCA Section 8(a) data on losses
  during manufacture of MDI; however, EPA's monitoring of
  effluents from a 4,4'-MDA/MDI manufacturing site is expected to
  help determine the accuracy of release estimates made  in  this
  section.

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                                88
         3.   Releases  from Use  of  MDI in Polyurethane Manufacture



               (Versar,  1983b)



     No  information could be located that  quantified the MDI



 (4,4'-MDA) releases from  polyurethane  manufacturing.   However,



 one report (Smith  and LaSalle,  1974) provided  total  air  emissions



 data from polyurethane  resin manufacturing  for a  chemical



 analogous to MDI,  toluene diisocyanate (TDI).   Smith and LaSalle


                                       8
 (1974) reported emissions of 1.8  x  10    Ibs  TDI released/lb  of



 polyurethane foam  produced.  Assuming  that  MDI and TDI emissions



 are about the  same, airborne MDI  releases  from a  given



 manufacturing  site would  be under 1  kg/yr,  since  MDI  is  used to



 produce only a portion  of polyurethane foams manufactured at



 various sites.  Thus, the MDI/4,4'-MDA air  emissions  from a



 particular foam manufacturing  site would be  relatively



 insignificant, especially since MDI  has  a  lower vapor pressure



 than TDI.



     Numerous  factors influence water  releases of MDI/4,4'-MDA



 including the  following:   production volume, manufacturing



process, amount of excess  diisocyanate,  water  requirements,



processing conditions,  ratio of other  constituents to MDI, and



 level of pollution control.  Information on  these factors, as



they relate to quantitative releases,  could  not be found.



Therefore, the following  assumptions were  necessary  to roughly



estimate MDI/4,4'-MDA water releases from polyurethane



manufacturing:



     o  From the patent literature  (Metzler, 1971),  it was



estimated that the water  requirement for polyurethane

-------
                                89
manufacturing  is  between  0  and  10%  of  all  other ingredients.  The

exact percentage  depends  on the type of  polyurethane foam being

manufactured and  the  production process.   The worst case scenario

was assumed to  require  10%  water.

     o  The amount  of process water consumed  during the

production of  polyurethane  foam is  not known.  As a worst-case

scenario, it was  assumed  that a negligible amount of water will

actually be consumed  in this process.  Therefore, process water

releases were  still assumed to  be 10%  of all  other- raw materials.

     o  Also from the patent literature  (Metzler, 1971),  it was

found that more than  the  stoichiometric  amount  of diisocyanate
        >
(MDI) was required  to complete  the  reactions  and  ensure proper

foaming. As a worst case, it was assumed that MDI will rapidly

hydrolyze to 4,4'-MDA and that  there will  be  sufficient excess

MDI present for the resulting 4,4'-MDA to  reach maximum

concentration  (1 gm of  MDA/liter) in the process  water.

     o  According to  Youer  (1969),  in  conventional  polyurethane

processing, the finished  yolyurethane  foam is steam cured and

washed.   Furthermore, the manufacturing  site  will use  water for

maintenance, equipment  cleaning, and work  area  washdowns.   It  is

assumed that the miscellaneous  water requirements will be  equal

to 50% of the process water requirement.   This  is the  same worst

case assumption used  for  4,4'-MDA manufacturing.   It was  assumed

that the 4,4'-MDA concentration  in  this wash  water  (from

hydrolysis of unreacted MDI) is  10% of the  maximum  solubility,

i.e. 0.1 gm MDA/liter of  water.  This  is a worst  case  assumption
                                         •»
since actual emissions  from polymer formation operations  are

expected to be  insignificant (Hedley _et_ _al_.,  1975).

-------
                                90
     o  It was assumed that MDI is used to produce approximately

40% of all polyurethane products manufactured  in  the United

States.  This is based on information that indicates TDI  is used

in slightly more than 50% of all polyurethane  products and that

other non-MDI isocyanates are used in approximately 10% of all

polyurethane products (Suh, 1980).  Based on this information,

MDI is used to manufacture approximately 501,600  kkg of
                                                    <
polyurethane foam.

     o  MDI and 4,4'-MDA are not removed from  the effluent during

waste treatment.

     The calculations for 4,4'-MDA releases from  polyurethane

manufacturing are given below:

     Releases from process water

     Amount of wastewater:

     501,600 kkg x 0.10 = 50,160 kkg x 1000 liters/1 kkg

     =  50,160,000 liters

     Releases:

     50,160,000 liters x 1 gm 4,4'-MDA/liter = 50,160,000 gm
     = 50.2 kkg of 4,4'-MDA released in process wastewater

     Releases from wash water

     Amount of wash water:   25,080,000 liters

     Releases:

     25,080,000   x 0.1 gm 4,4'-MDA/liter = 2,508,000 gm
     = 2.5 kkg of 4,4'-MDA released in wash water

     Total release (from all polyurethane manufacture)
     =50.2 kkg +2.5 kkg =52.7 kkg of 4,4'-MDA

-------
                                91
     As a more realistic case,  it was  assumed  that  all  the



process water is consumed during the  foaming reaction or recycled



during the production of polyurethane  foam.  Therefore,  the  only



water releases would be from wash water.   The  wash  water releases



for this case are assumed to be the same  as those  in  the worst-



case scenario.  Consequently,  for the  more realistic  case,  2.5



kkg of 4,4'-MDA are assumed to  be released to  surface waters.



        4.  Releases from Polyurethane Products  (Versar, 1983b)



     One report (David, 1969)  stated that  there  may be  trace



quantities of isocyanate encapsulated  in polyurethane foam.



However, most of this isocyanate, especially MDI which  has a low



vapor pressure,  is expected to  remain  in  the foam polymer



matrix.  Thus, it was assumed  that 4,4'-MDA releases  from such



polyurethane products will be  insignificant.



     NIOSH (1981)  reported finding 4,4'-MDA in the  off-gas from a



spandex fiber sample heated to  200°C to simulate a  heat-forming



operation in the apparel industry.  This report  is  being



investigated to determine whether 4,4'-MDA was used,  as  such,  in



the preparation of. the fiber, or if urethane linkages (known to



be labile at high temperatures) might  have been  broken  (after



having been formed from the possible use of MDI  in  the  fiber)  to



release 4,4'-MDA.   The results of this investigation  could have



implications regarding potential exposures to  4,4'-MDA  in a



workplace setting  not previously identified.



        5.  Releases from Disposal of  Wastes (Versar, 1983b)



     No information could be found concerning  the disposal



practices for 4,4'-MDA-containing wastes from  the manufacture  of



the amine or MDI.

-------
                                92
     CMA  (1984) reports  that  of  the  312  users  and  processors it



surveyed, 38 reported  some  information on  environmental  releases,



though mostly  in a qualitative fashion.



     Twenty respondents  reported on  air  emissions.   Four reported



using scrubbers or baghouses  to  limit releases.  Six firms



reported  air emission  values  (other  than "trace").   One  reported



1315 pounds/year released based on mass  balance, but there  was



some question  whether  this  included  material removed by  their



scrubber.  Another reported 193 pounds/year released.  Two



reported  about 10 pounds/year.  Another  firm reported  emission



levels at 1.3 parts per  billion.



     Eight companies (CMA,  1984) reported  that their aqueous



effluent  contain 4,4'-MDA;  seven of  these  send their effluent to



a publicly owned treatment  works.  Of these seven,  five  said the



effluents contained "trace" amounts  of the amine and the  others



release 50 pounds/year by this route.



     Of the 38 respondents  (CMA, 1984),  33 reported  sending  solid



wastes, including spillage, clean-up materials, containers,



reactor rinse solvents and other 4,4'-MDA-containing solutions,



to landfills.  Sixteen of these reported that all 4,4'-MDA  was



"fully reacted" before being sent to the landfill.   Eleven



companies reported disposing of 5 to 100 pounds/year to



landfills.  Another firm reported landfilling 270,000  pounds/



year.  Three firms reported incineration of waste 4,4'-MDA  and



empty bags.



     Other disposal methods reported included "RCRA" or  "EPA"



disposal and use of waste chemical reclaimer companies.

-------
                                93
         6.   Potential  Releases from Degradation of Polyurethane



     Since  about  98  to 99%  of  4,4'-MDA production is converted to



MDI and  PMDI and  thence  to  various  polyurethane products,  and



since degradation of such polyurethanes could generate 4,4'-MDA,



there is concern  over  the fate of polyurethanes disposed  of  in



landfills.



     An  example of the behavior of  monomers  used as starting



materials in the  manufacture of such  plastics was submitted  to



EPA by the  International Isocyanate Institute (III,  1979).   Ill



submitted the results  of a  research effort to determine whether



polyether diol-based polyurethane flexible foams made  from



toluene diisocyanate,  an analogue of  MDI, would biodegrade under



the conditions of  sanitary  landfills,  and whether corresponding



amine analogs, 2,4- and 2,6-toluene diamines  (TDA),  would be



released.   Polyurethane foam made with   C-labelled  toluene



diisocyanates was subjected to  three  experimental  media---sanitary



land fill medium, refuse compost medium, and  parabrown earth



medium—of  different bacterial  activity  for  three  months.  The



sanitary fill medium and the refuse compost medium were subjected



to temperatures of 22°C and 50°C.   After three  months, at 50°C,



0.04% of the   C-tagged starting activity in  foam  extracts was



identified  as 2,4- and 2,6-TDA.  At 22°C no TDA could be



detected, and no  releaso of    C02 was  identified  from any



experiments done  with  sanitary  fill medium.   In  refuse compost



medium and  parabrown earth medium,  no detectable  TDA was



formed.   However, at 22°C and  at 50°C,  0.01%  and  0.1% of the



starting activity of the labelled foam  was detectable as   CC.

-------
                                94
The  III  paper  concludes  that  polyurethane is very resistant to



microbial  degradation.   EPA believes that 4,4'-MDA in



polyurethane could  be expected  to  behave  in a manner similar to



TDA.   Therefore,  very little  4,4'-MDA release would be expected



in landfill situations;  and the 4,4'-MDA  released is expected to



be degraded chemically or  microbially fairly rapidly.  Since 50°C



is an  extreme  (though sometimes attainable)  environmental



temperature, release of  4,4'-MDA during normal environmental



conditions would  not be  expected.  However,  even  at the higher



temperatures,  any 4,4'-MDA release would  probably be very slow



and at very low levels.  There  are no monitoring  data available



for 4,4°-MDA in the terrestrial environment.



        7.  Environmental  Pate  and Transport of 4,4'-MDA



               Releases



            a.  Environmental Transport of  4,4'-MDA



     Most 4,4'-MDA  is converted at the site  of  its  manufacture to



MDI,  which is  then used  to  produce polyurethanes.   4,4'-MDA can



be expected to be released  as a waste  during  the  conversion to



MDI.   It was estimated above that most of the  releases  will be to



aquatic systems.  Typical  treatment processes  used  by 4,4'-MDA



production plants involve  the discharging of  aqueous  waste  to  a



holding lagoon from which  the wastewater  is  ultimately  diverted



to a  municipal sewage treatment  plant  (Young  and  Parker,  1978)  or



surface waters.



     In general, no significant  quantities of  gaseous or  solid



wastes contaminated with 4,4'-MDA have been  reported  (JRB,  1980;



ESE,  1981), although one processor reportes  landfilling  270,000

-------
                                95
Ibs. of waste  that  contains  some  4,4'-MDA (CMA,  1984).   It is not


expected  that  4,4'-MDA  will  be  transported from  aquatic systems


to the atmosphere since its  aqueous  solubility (1,000 mg/1)  and


low vapor pressure  (10~7  torr at  25°C)  make volatilization from


water unlikely (Callahan  et  al.,  1979).   Deposition in  sediment


or sorption  to soils  also is unlikely  for 4,4'-MDA dissolved in


water, because of its solubility  and its  partitioning


preference.  Values calculated  for the  log octanol/water


partition coefficient are 1.76  (Kenaga  and Goring,  1980),  1.84


(Banerjee jet_ _al_. , 1980),  1.88 (Leo and  Hansch, 1979),  and  2.52


(Chiou et_ _al_. ,  1977).   Values calculated  for  the  log  organic


carbon distribution coefficient are 1.79  (Karickhoff  et al.,


1979), 1.90  (Briggs,  1973),  1.99  to 2.47  (Kenaga  and  Goring,


1980), and 2.62  (Karickhoff _et_ _al_. , 1979).


             b.   Photodegradation


     Although  no data have been found regarding photolysis of


4,4'-MDA in  the  aquatic environment, indirect  evidence  indicates


that photo-oxidation may  be  the major fate of  the  compound


released in  aqueous waste.   4,4'-MDA crystals  darken  when  they


are exposed  to  air  (Moore, 1978).'  Similar behavior of  phenols


and other aromatic amines has been attributed  to  the  formation


and photolysis  of charge-transfer complexes with  oxygen (Joschek


and Miller,  1966).  Free  radical  intermediates and  hydroxylated


products are reported.


     Landrum and Crosby (1981) report that dilute  aqueous


solutions of p-toluidine  are oxidized rapidly  enough  to make its
                                         ••

aquatic fate difficult  to study.  The structure of  4,4'-MDA  is

-------
                                96
sufficiently  similar  to  p-toluidine  (both bear benzylic




hydrogens)  to expect  similar  photochemical reactivity.   Moreover,




free radical  intermediates  of 4,4'-MDA,  analogous to those which




can be postulated  for p-toluidine,  should be more readily formed




(Laity ^t_ _al_. ,  1973)  from structures  such as 4,4'-MDA.   Zabik and




Kawaguchi  (1982) have shown that  structurally analogous 4,4'-




methylenebis-2-chloraniline pnotodecomposes  in water with a half-



•life of 3.69  hours.




            c.  Oxidation




     Aromatic  amines  are susceptible  to  oxidation by a  variety of



chemical oxidizing agents (Cason,  1948).   The resultant products



are usually quinones.  Aromatic amines,  such as  aniline and p-



chloroaniline,  become  more  easily oxidized after being  adsorbed



to the aquatic  clay,  montmorillonite  (Cloos  ^t_ ^1_. ,  1979).



Similar enhanced reactivity toward oxygen  also should be  expected



with 4,4'-MDA.



            d.  Hydrolysis



     There are  no data to suggest that aromatic  amines  undergo



hydrolysis under environmentally relevant  conditions.   The



covalent bond of a substituent attached  to an aromatic  ring is



resistant to hydrolyis because of the high negative  charge-



density of aromatic structures (Morrison  and Boyd, 1973).



            e.  Volatilization



     4,4'-MDA's solubility  in water (1,000 mg/1)  coupled  with its



low vapor pressure (10~7 torr at 25°C) diminish  the  importance of



volatilization  as an  environmental transport process  (Callahan et




al., 1979).

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                                97
            f.  Sorption



     The adsorption by soil of  two similar  aromatic  amines,



aniline and p-chloroaniline, has been  found  to  depend  both on



organic matter and clay content of the  soil  (Moreale and  Van



Blade, 1976; Cloos £t_ ajL_. , 1979).  The  extent of partitioning,



however, between soil and water depends on  the  solute's  relative



affinity for the soil and water phases.  The values  which have



been calculated for 4,4'-MDA's  log organic  carbon  distribution



coefficient (1.79 to 2.62) and  log octanol/water partition



coefficient (1.76 to 2.52) indicate that the compound  will not  be



strongly sorbed to soils, and that if  it were sorbed,  it  would



probably be subject to leaching (BSE,  1981).



            g.  Bioaccumulation



     Although no direct evidence has been found in the literature



regarding bioconcentration of 4,4'-MDA, bioconcentration  factors



have been estimated which range from 1.83 to 46 (ESE,  1981).



Metcalf and Sanborn (1975) point out that compounds  with



solubilities of 50 mg/1 or more generally have  little  potential



for aquatic bioaccumulation.  Lu j5t_ ^1_. (1977)  reported  that



although benzidine was taken up by the  organisms of  their aquatic



ecosystem,  it was not bioaccumulated, and it remained  in



equilibrium with the benzidine dissolved in  the water.   The



structure of benzidine differs  from the structure  of 4,4'-MDA



only by the absence of the central methylene group.



            h.  Biodegradation



     No information regarding the microbial  degradation  of 4,4'-



MDA was found.  Subba-Rao and Alexander (1977), however,  have

-------
                                98
reported that Pseudomonas putida,  isolated  from  soil,  was  capable



of degrading structurally similar  bis(p-nitrophenyl)-methane



slowly.  Bis(p-hydroxyphenyl)methane  was  not  degraded.   Inasmuch



as activated sludge can be acclimated to  degrade benzidine (Baird



et_ al_. , 1977), 4,4'-MDA could probably  be treated  in a  similar



manner.



                 i.  Summary



     Photoxidation may be the major fate  of 4,4'-MDA released  in



aquatic waste.   Volatilization, sorption, and bioaccumulation are



probably not important, leaving dilution  as the  principal  pathway



for dissipating  MDA which remains  undegraded.  Biodegradation



probably would become a viable process  only in acclimated  sludge.



        8.  Estimated Surface Water Concentrations of 4,4'-MDA



     Concentrations of 4,4'-MDA in surface waters  that  could be



used as drinking water supplies were  estimated using the release



estimates given  above, information in EPA's Exposure Analysis



Modeling System  (EXAMS), and confidential production data  for



4,4'-MDA (and MDI) manufacturing plants derived  from the TSCA



section 8(a) Information System.  This material  is discussed at



the beginning of Section - IV C above and summarized in Table  11.



        9.  Populations Potentially Exposed to Contaminated



              Surface Waters



     This section identifies and estimates the sizes of



populations potentially exposed to 4,4'-MDA through ingestion of



drinking water and through dermal contact with contaminated



surface waters.  Populations exposed  through other pathways, such



as ingestion of  potentially contaminated groundwater, could  not

-------
                                99
be  identified  and  were  not  considered  within the scope of this


report.


             a.   Potential Drinking  Water Exposures


     Drinking  water  may  be  contaminated  by  4,4'-MDA released from


4,4'-MDA, MDI  and/or polyurethane manufacturing  plants.   The


Vvater Supply Data  Base  (WSBD) was checked to determine whether


any drinking water intakes  were  located  downstream of 4,4'-


MDA/MDI manufacturing plants.  The  WSDB  is  a computerized data


base, maintained by  the  Monitoring  and Data Support Division


(MDSD) of EPA, that  contains  information on the  location  of


surface water  utilities; the  locations of the  utilities'


treatment plants,  intakes,  and sources of raw  water;  the


populations served;  and  the average and  maximum  daily


production.  Table 12 enumerates the populations  served by


drinking water facilities at  various points  downstream from each


plant.  4,4'-MDA manufacturing plants not listed  in the table  do


not discharge upstream of any drinking water  intakes  (i.e.,  no


drinking water intakes are  located between  the plant  discharge


point and the confluence of the receiving water  with  a salt water


body).  As stated  above, there is at present no  indication that


any drinking water supply is  contaminated with 4,4'-MDA.   Ongoing


work will resolve  the question of whether such contamination


occurs.


            b.  Potential Ambient Environmental  Exposures


     Populations may be  exposed to 4,4'-MDA in the  ambient


environment through  inhalation or through dermal  contact  with
                                         V

surface waters.  Only the later will be  considered  here,  since

-------
                                       101
                                     TABLE 12
                      POPULATIONS POTENTIALLY EXPOSED TO 4,4'-MD&
                           IN ERINKING fcftTER DCHJSTREAM OP
                            4,4'-MEft. MANUFACTURING PLANTS
Plant Location
Olin Chemicals Moundsville, WV


Receiving
Stream
Ohio River

*
Location of Drinking
Water Intake (Miles
Downstream frcm Plant) (b'c'd^
0.5
35.3
62.7
Exposed
•Population
900
2,500
25
Mobay(a)

BASF(a) and
 ICI Americas
 lnc.(a'e)
     New Martinsville,  Ohio River
       W
     Geismar, LA
Mississippi
  River
Dupont
     Belle, wv
Kanawha River
15.4

27.9
38.2
44.9
46.2
71.6
78.9
80.3
83.8
85.4
87.5
88.7
11.3
  2,500

  4,000
  2,000
 12,500
  5,850
 54,800
232,000
550,000
 12,000
 60,000
 25,000
 62,700
  1,950
      (a)
      (b)
      (c)
      (d)

      (e)
Also produces MDI.
All drinking water  intakes between  the  Olin and Mobay plants
and the  confluence  of  the Hocking River with the Ohio River
(a distance of about  100  miles from  the Olin plant  and about
60 miles  from the Mobay plant) are  listed.
All drinking water  intakes located  within 90 miles  downstream
of the BASF and ICI Americas plants  are listed.
All drinking water  intakes between  the  Dupont plant and thex
confluence  of the Kanawha River with the Ohio River (a
distance  of about 70 miles)  are listed.
ICI Americas owns Rubicon, which is  the name used by CMA's
4,4-MDA  Project Panel  member that operates  this plant.
     Source:   EPA's Water Supply Data  Base,

-------
                                      102
                                    TABLE 13
                      POPULATIONS SWIMMING IN SURFACE WXER
                        NEAR 4,4'-MDA MANUFACTURING PLANTS
Plant
                Location
                     Receiving stream .
                       Exposed population
Olin Chemical


Mobay


Mobay

BASF

ICI Anericas,
Inc. (Rubicon)

DuPont
Jniroyal

UpJohn
Moundsville,
  WV

New Martinsville,
  WV

Baytown, TX

Geismar, IA

Geismar, LA


Belle, WV

Deepwater, NJ

Naugatuck, CT

LaPorte, TX
                                    Ohio R.  (Marshall Co.)     insignificant^3'
Ohio R.  (Wetzel Co.)


Cedar Bayou

Mississippi R.

Mississippi R.


Kanawha  R. (Kanawha Co.)

Delaware R. (Salem Co.)

Naugatuck R.

San Jacinto Bay
                                                             insignificant^3'


                                                                  0
-------
                                103
 V.   QUANTITATIVE RISK ESTIMATION (COOK AND GRINDSTAFF, 1983;



       Grindstaff,  1984)



      In  this seccion the method and results of the quantitative



 estimation  of cancer risks posed by 4,4'-MDA are presented.



      The model used to extrapolate from the dose-response region



 of  the NTP  bioassays down into the estimated human exposure range



 was  the  one-stage  version of the Crump (1980)  multistage model.



 Estimated human  response to these exposures (a.k.a.  the risk



 level) were  calculated based on tumor incidences at  individual



 sites  for each sex  and species as well as  on pooling tumor



 incidences  in various sexes and species.



     The human exposures,  or LADDs,  that were  used in the risk



 estimation are explained.   They are  based  on monitoring data and



 hypothetical  constructions  of  a variety of workplace and  drinking



 water  exposure situations.



    A.   Introduction



     In National Toxicology Program  bioassays  (NTP,  1983a)  for



 the carcinogenicity  of 4,4'-MDA,  F344/N rats and B6C3F1/N mice of



 both sexes were administered  the  dihydrochloride salt ad  libitum



 in 'drinking water at  concentrations  of  150 parts per-million



 (ppm)  and 300  ppm for  104 weeks.   Controls of  each species  were



given  no 4,4'-MDA.   Results  from  these  bioassays were used  in
                                *


high-to-low dose extrapolations  to derive  human  carcinogenic risk



 following inhalation,  dermal,  and  oral  exposure  to 4,4'-MDA.



     While the bioassays  were  conducted using  the dihydrochloride



of 4,4'-MDA,  for the  reasons set  forth  i.n  Section III,  this



assessment assumes  that  the  results  can be used  to estimate



cancer risks associated  with the parent amine.   Likewise,  while

-------
                                104
the bioassays  involved drinking  water  exposures,  because of the



demonstrated capability  of  4,4'-MDA to penetrate  human skin,  to



be absorbed through  the  human  gastro-intestinal  tract, and to be



rapidly distributed  in mammals,  this  assessment  uses the



bioassays to estimate cancer risks  for humans  exposed  dermally,



via inhalation or  ingestion.



     Certain tumor types displaying a  consistent  dose-related



increase in incidence in the bioassays were  judged  appropriate


for use in calculating human carcinogenic  risk at that site



(Milman, 1984).  These sites are listed  in Table  14, along with



incidence rates of tumors in the test  animals  for different dose



levels.  Also listed in Table  14 are data  on four tumor  types


whose  incidence, while statistically signficant,  do not  permit



their use in quantitative risk estimations;  this  information  is


discussed further  in subsection B.3, below.



     Also given in Table 14 are  the incidences of those



statistically significant tumors useful  in assessing risk


aggregated by species/sex, and a similar aggregation of  such



tumor  incidences in which the malignant  tumors alone were


statistically significant.  These aggregations have been proposed
               4                1

for use in estimating total cancer  risk  that a substance might


pose (EPA, 1984).


     The true mathematical relationship  between dose and response



to 4,4'-MDA for animals or humans is not known.   To provide an


indicator of risk, data  from the NTP bioassays were  fitted to the


Global 83 high-to-low dose extrapolation model (Crump, 1980),


modified to reflect the  fact that only 2 positive dose-levels

-------
                                105
were suitable  for use  in  the extrapolation.   This  method  provided



carcinogenic risk estimates for  human  exposure  to  low  levels  of



4,4'-MDA by extrapolating  from the higher  levels of  4,4'-MDA



given to the test animals.



     For the purpose of this assessment, several different  sets



of exposure situations representing occupational and



environmental  exposures to 4,4'-MDA, described  above in Section



IV, were used  to estimate carcinogenic risk.  These  exposures



include environmental exposure through drinking water  and



workplace exposure situations.   Lifetime average daily doses



(LADDs) for humans were calculated for each situation, and  these



LADDs are given in Tables 19 and 20, along with estimated extra



lifetime cancer risks.  These situations are  described in detail



below,  and the calculations are given  in Appendix  B.



     Data were handled using two significant  figures in this



section, except where it was obvious that more were  appropriate.



Risk estimations are given with one significant figure.



    B.   Methods and Results



        1.  High-Dose to Low-Dose Extrapolation Model



   .  The NTP bioassay data were fitted to the Crump multistage



model (Crump, 1980).  The multistage model has been  in wide use



in the  EPA since the summer of 1980, and is used by  EPA's



Carcinogen Assessment Group to set air and water quality criteria



and standards.   This model was expected to provide a good fit to



the dose-response data.  Other models, such as the logit, probit,



Weibull and the gamma multi-hit were not appropriate for this



analysis, because the number of dose levels in the NTP bioassay

-------
                                106
was  equal  to  the  number  of  parameters being estimated using these



models.  The  maximum likelihood estimate of carcinogenic risk and



the  upper  95% confidence limit of this risk were calculated for



the  human  exposure  situations (LADDs) at eight sex- and species-



specific tumor sites in  the test animals.   Risk estimates were



also calculated based  on incidences  of all the statistically



significant tumors  in  male  and female rats and in female mice,



and  another set of  risk  estimates was derived from incidences of



all  the statistically  significant tumors in male rats and female



mice for which the  incidences of malignant tumors alone were



statistically significant.   The  "pooling"  of tumor incidences was



done only  on  the  sexes/species indicated because it was those



sex/species which responded in the bioassay in a manner amenable



to mathematical analysis.   No pooling of male mouse data was done



because only  one  tumor type showed monotonic dose-response,  and



in the female  rat there  were no  statistically significant



malignancies.   Liver neoplastic  nodules  were not taken  into



account in any  of these  calculations,  even though the incidence



of this lesion  was  statistically significant,  because the proper



use  of such lesions  in quantitative  risk estimation has not  yet



been  satisfactorily  resolved.



      Upon  examination  of  the risk levels presented in Tables 19



and  20, one notes that there is  little or  no differences between



the  levels calculated  for the two different kinds of tumor data



pooling.  This means that most of  the  calculated risk is due to



malignancies.   If the  risk  level from pooling tumor data in  which



the  malignancies alone are  statistically significant had been

-------
                                107
much  lower  than  that  derived  from pooling all tumors,  then one

would conclude that the  contribution of malignancies to risk was

relatively  low.   This was  not the case.

      Goodness-of-fit  tests were  performed to evaluate  how well

the experimental  data fit  the model.   P-values are presented for

each  site,  and these  are given in Table 15.

        2.  Animal to Human Extrapolation

      In order to  extrapolate  the expected response in  humans to

various lifetime  average daily doses  of 4,4'-MDA,  one  must first

determine what the dose-response relationship is  in the test

animals from the  bioassay  data.   Then  one must take the expected

human LADDs and convert them  to  animal LADDs  using a species

conversion  factor, and, using  the  model  described  above,

calculate the response that the  animals  would  have shown  at  those

lower doses.  This response is then represented as the  "risk to

humans" —  in reality, of  course,  it  is  the response one  would

have expected in  the  test  animals  at doses equivalent  to  those

that humans receive.

            a.  Dose-Response  in the Bioassay

     The animal exposures,  in  ppm  in drinking  water, were

converted to mg/kg/day LADD by the following  relation:

    LADD (mg/kg/day)  = d (ppm) F  (kg/day)
                            W  (kg)

where LADD  is lifetime average daily dose, d  is the concentration

of the test chemical  in the animals'  drinking  water, F  is  the

amount of water a test animal  consumes  per day, and W  is  the

weight of the test animal.  For  this analysis  it is assumed  that

rats weigh 350 grams,  mice weigh  20 grams, rats consume 20 grams

-------
                                108
of water per day,  and  mice  consume  5.5  grams  of  water per day.
                                                      
-------
                                109
      Since  human weight is assumed to be 70 kg and the rat and



mouse weight,  0.35  and 0.020  kg,  respectively, the ratio of



animal  dose  to human  dose  is  0.17 for rats and 0.066 for mice.



Hence,  for  rats,



        Human  LADD  =  0.17  x Animal LADD



and  for mice,



        Human  LADD  =  0.066 x  Animal LADD



        3.   Tumors  Observed in the Bioassay



      Table 14  presents the incidence  of  tumors from the NTP  •



bioassays.   Thirteen  different species-,  sex-  and/or site-



specific tumors/lesions were  observed  in the bioassays at



statistically  significant  incidences,  and  12 were  judged



biologically appropriate for  use  in estimating risks to humans



(Milman, 1984).  As stated above,  there  is  at  present  no



consensus on the proper use of liver  neoplastic nodules in  this



sort of assessment, so that particular statistically significant



lesion in male rats was not used  here.   Further, since the



goodness-of-fit to  the one-stage  model displayed (Table 15) by



the data on male mice  liver hepatocellular  carcinoma,  male  mice



liver hepatocellular carcinoma  and  adenoma, female  mice malignant



lymphoma,  and  female mice  thyroid  follicular cell  carcinoma and



adenoma was either  inadequate  or  marginal,  no  risk  calculations



were made using these  individual  tumor data.



     In order  to obtain insight into the total risk for each  sex



and species, the incidences of  all  statistically significant



tumors that each species and  sex  experienced in the  bioassay  were



tabulated.   That is, for instance,  in  the case of  female  mice,

-------
                                110
all controls  and  test  animals  that  had  at  least 1 tumor of the

statistically significant  classes:   all malignant lymphomas,

liver hepatocellular carcinoma or adenoma,  thyroid follicular-

cell carcinoma or adenoma,  or  lung  alveolar/bronchiolar carcinoma

or adenoma; were  counted.   Each animal  bearing  such a tumor was

counted only  once,  even  if  it  had more  than one of these tumor

types.  Further,  in order  to obtain insight into the

contributions of  benign  tumors to the overall risk, a "pooling"

similar to that described above was done,  but only for those

tumor types in which the observed malignancies,  alone,  were

statistically significant.  In this assessment,  rather than

present risk  calculations in the text for  all these sets of data,

estimates based on the individual and pooled tumor types showing

highest risk  are  given in the  text,  in  Tables 19  and 20.   Risk

estimates made using the remaining  bioassay data  are given in

Appendix C in Tables 19A and 20A.

     In addition  to the tumors  in Table  14, other  rarer  tumors

were observed in  the bioassay.   These are  listed  below  along with

their incidence in a large group of  control animals  and  the

probability (p-value by Fisher1s Exact Test) of  observing  this

tumor by chance alone,  given the incidence  in the  historical NTP

program control population.  A bile  duct adenoma  was found in  one

(p-value = 0.0136) 150 ppm dose  male rat.  This  tumor  had  not

been previously diagnosed in 3,633  control male  rats in  the NTP

bioassay program.   Transitional  cell papillomas  of  the  urinary

bladder were  found in 2/50  (p-value = 0.0017) low-dose  and 1/50
                                       •»
(p-value = 0.0531) high-dose female  rats compared  with  3/3644

-------
                                      Ill
                                   TABIE 14
              TUMOR INdDHO B3f SPECIES, SEX AM) SHE OF TUMOR.
                                      r 1983a)
                                  Control
                 150 ppn
                300 ppn
        Male Rats
Liver-Neoplastic Nodule (d)
1/50
P_<0.001 *
12/50           25/50
Pf=0.001(c)     Pf<0.001
Thyroid-Follicular Cell
  Carcinoma
Thyroid-Follicular Cell
  Adenoma or Carcinoma
     Female Rats
Thyroid-Follicular Cell
  Adenoma or Carcinoma
Thyroid-C-cell Adenoma or
  Carcinoma
        Male Mice

Liver-Hepatocellular
  Carcinoma
Liver-Hepatocellular Adenoma
  or Carcinoma
Adrenal-Pheochromocytoma
     Female Mice
Lung- Aveolar/Bronch iolar-

  Adenoma or Carcinoma
0/49
Ps<0.001
PjfO.428
0/47
                                 7/48
                                 P£=0.006
1/49
Ps= 0.001
PL=0.590
0/47
Pg<0.001
PjfO.086
1/47
Pg= 0.055
PL=0.153
10/49
P =0.047
PL<0.001
17/49
Ps<0.001
PL<0.001
2/48
P,,=0.116
4/47
Pf=0.175
4/47
?£=0.058
5/47
Pf=0.102
33/50
P^O.OOl
43/50
Pf<0.001
12/49
p£=0.004
10/48
P£=0.005
19/48
7/48
Pf=0.032
29/50
Pf=0.001
37/50
Pf<0.001
14/49
                                  PL<0.002
2/50
TJ =0.010
                 3/50
                8/49
                Pf=0.043

-------
                                    112
                           TABLE 14 - GQNEINDED

All Malignant Lymphonas
Liver-Hepatocellular
Carcinoma
Liver-Hepatocellular
Adenona or Carcinoma
Thyroid- Poll icular cell
adenoma or carcinoma
Control
13/50
P^O.OOl
PL=O.IOS
1/50
Ps<0.001
Pjf 1.000
4/50
Ps<0.001
PL=0.700
0/50
Pg<0.001
150 ppm
28/50
P£=0.002
6/50
P£=0.056
15/50
Pf=0.005
1/47
Pf=0.485
300 pan
29/50
Pf=0.001
11/50
Pf=0.002
23/50
Pf<0.001
13/50
P<.001
             POOLED DATA:  ALL STATISTICALLY SIGNIFICANT TOMQRS
                                                                (e)

Male rats with thyroid
follicular cell
carcinoma or adenoma
Female rats with thyroid
follicular cell.
carcinoma or adenoma
or thyroid C-cell
carcinoma or adenoma
Female mice with liver
hepatocellular
carcinoma or adenoma,
Control
1/49
Ps=0.001
PjfO.590
1/47
Ps<0l001
P£=0.301
16/50
Ps<0.001
PjjO.052
150 ppn
4/47
P£=0.175
9/47
Pf=0.005
38/50
P£=0.002
300 ppn
10/48
Pf=0.005
25/48
Pf<0.001
44/50
Pf<0.001
carcinoma or adenoma,
lung alveolar/bronchiolar
carcinoma or adenoma or
any malignant lymphoma

-------
                                      113
                                TABIE 14 -  QGNTINDED
                 POOLED DKEA:  ALL SEKT3STICAI12lf SIGNIFICANT TOMQRS
                 FOR miCH MUJGNMCIES AICNE ARE SIGNIFICANT
                                  Control	150  ppn	300 ppm
Male rats with thyroid            1/49             4/47             10/48
  follicular cell                 Ps=0.001         P £=0.175         p£=0.005
  carcinoma or adenoma            Pj==0.590

Female mice with                  16/50(9>         36/50            43/50
  liver hepatocellular            Ps<0.001         P£=0.004         Pf<0.001
  carcinoma or adenoma            PL0.119
  or any malignant
  lymphoma
(a^ PS= two-sided p-value for positive slope.  Small values  indicate  that  the  slope
    is significantly different from zero, meaning that there  is  a  tendency for
    increasing dose to be associated with increasing response.

^  '  r two-sided p-value for departure from linear trend.   Small values indicate
 rf
th
      at the association between dose and response is not linear.

    P£= Fisher Exact Test p-value.  Small values indicate response  in  the control
    animals is statistically significantly different from the response  in the
    control animals.

    At this time there is no consensus on the proper use of this tumor  type  in
    quantitative risk estimations, so it is not used in this assessment.

    Male mouse data were not used because response did not increase monotonically
    with dose.

    Female rats did not display a response in which malignancies alone  were
    statistically significant.

    NIP report did not identify the animal (could it have been Minnie?) bearing a
    liver hepatocellular carcinoma, so this numerator could change by one.

-------
                                114
control female rats  in  the  bioassay  program.   Finally,  granulosa



cell tumors were  found  in the  ovaries  of  2/50  (p-value  =  0.0140)



high dose female  rats and 3/50  (p-value =  0.0009)  low-dose  female



rats and 1 (p-value = 0.0283)  of  the latter  tumors was  a



granulosa-cell carcinoma.   Granulosa-cell  tumors  were  identified



in 11/3462 controls, and granulosa-cell carcinomas have been



observed in only  1/3462 control animals.



   •  fables 16 and 17 give  the historical  tumor  incidence for  a



large group of control animals from  the NTP  bioassay program



(1983b) for mice  and rats,  respectively.   Included are  all  tumors



with a spontaneous frequency of at least 0.5%.  They are



presented to put  the tumor  incidence in the  controls of this NTP



bioassay into perspective with the incidence of tumors  in a  large



historical control population.  The  incidence  of  specific tumors



in the control group of this bioassay appears  to  be consistent



with historical groups.  For example, the  incidence of  tumors  in



control animals appears to  be high in three  sites  in this



bioassay, yet it  is consistent with  the historical group.   In



control male mice 20% (10/49) developed hepatocellular  carcinomas



and 35% (17/49) developed hepatocellular carcinomas or



adenomas.   In the historical control population 21.3% (498/2334)



of the male mice developed  hepatocellular  carcinomas and  31.1%



(725/2334)  developed either hepatocellular nodules, adenomas or



carcinomas.   In this bioassay, 26% (13/50) of  the  control female



mice had a malignant lymphoma of the hematopoietic system



compared to 27.2% in the large control population.

-------
                                      115
                                    TRBIE 15
                      GOODNESS -OP-PIT TEST p-VAIDES FOR EMB
                             TOMDR TYPE IN TAB££ 14
 Species
 And Sex
           Tumor Type
     p-Value*
Male Rats.

Male Rats

Male Rats


Female Rats


Female Rats


Male Mice

Male Mice


Male Mice

Female Mice


Female Mice

Female Mice

Female Mice


Female Mice
   Liver Neoplastic Nodules

   Thyroid Follicular Cell Carcinomas

   Thyoid Follicular  Cell Adenomas
    or  Carcinomas

   Thyroid Follicular Cell Adenomas  .
    or  Carcinomas

   Thyroid C-Cell Adenomas
    or  Carcinomas

Liver Hepatocellular Carcinomas

Liver Hepatocellular Adenomas
    or  Carcinomas

Adrenal Pheochromocytomas

Lung Alveolar/Bronchiolar
    Adenomas or Carcinomas

All Malignant Lymphomas

Liver Hepatocellular Carcinomas

Liver Hepatocellular Adenomas
   or Carcinomas

Thyrid  Follicular Cell
  Adenomas or Carcinomas
    p> 0.995
0.750 < p < 0.900


0.900 < p < 0.950


0.025 < p < 0.050

    p < 0.005


0.500 < p < 0.750

0.950 < p < 0.975


0.250 < p < 0.500



    p >  0.995


0.250 < p < 0.500
* This p-value is from the X* goodness-of-fit test.  The higher the p-value
  the better the fit of the model to the data.  Inadequate fits commonly show
  p_< 0.05, marginal fits show 0.05 < p < 0.10, and adequate fits show p^.
  0.10.  A dash indicates that the test was not appropriate, as the number of
  experimental dose levels was equal to the number of free parameters in the
  model.

-------
                                116
                             TABLE 16

 HISTORICAL  INCIDENCES  OF PRIMARY TUMORS(a)  IN UNTREATED CONTROL
                   B6C3F1/N MICE.  (NTP, 1983b)
Tumor Site
Lung
Alveolar/Bronchiolar
Adenoma
Alveolar/Bronchiolar
Carcinoma
Liver
Neoplastic Nodule or
Adenoma
Carcinoma
Nodule or Adenoma or
Carcinoma
Adrenal
Pheochromocytoma
Pheochromocytoma, Malignant
Thyroid
C-cell Adenoma
C-cell Carcinoma
Follicular Cell
Adenoma
Carcinoma
Reproductive System
Mammary Gland
Fibroadenoma
Adenocarcinoma
Hematopoietic System
Leukemia
Lymphoma
Le ukem i a/ Lymphoma ^ d '
Male
2343(b)

282(1?. l)(c)

119(5.1)
2334

240(10.3)
498(21.3)

725(31.1)
1903
28(1.2)
2(0.1)
2178
0(0.0)
0(0.0)

22(1.1)
5(0.2)
2343

0(0.0)
0(0.0)
2343
17(0.7)
230(12.0)
297U2.7)
Female
2468

131(5.5)

47(2,0)
2469

98(4.0)
101(4.1)

196(7.9)
2051
16(0.7)
0(0.0)
2203
2(0.0)
0(0.0)

40(1.8)
6(0.3)
2486

8(0.3)
40(1.6)
2468
52(2.1)
625(25.1)
677(27.2)
 a'  Includes all tumors occurring with a frequency of 0.5% or
    greater.
(  '  Number of animals examined histopathologically (or, for
    certain lesions, the number of animals necropsied).
|<~!  Numbers in parentheses are percentages.
(d)  This combination is included because certain early studies in
    the data base tended to use these terms interchangeable.

-------
                                117
                             TABLE 17
  HISTORICAL INCIDENCE OP PRIMARY TUMORS    IN UNTREATED CONTROL
                      F344 RATS (NTP, 1983b)
Tumor Site
Lung
Alveolar/Bronchiolar
Adenoma
Alveolar/Bronchiolar
Carcinoma
Liver
Neoplastic Nodule or
Adenoma
Carcinoma
Nodule or Adenoma or
Carcinoma
Adrenal
Pheochromocytoma
Pheochromocytoma, Malignant
Thyroid
C-cell Adenoma
C-cell Carcinoma
Follicular Cell
Adenoma
Carcinoma
Reproductive System
Mammary Gland
Fibroadenoma
Adenocarc inoma
Hematopoietic System
Leukemia
Lymphoma
Le ukemi a/ Lymphoma ' ° '
Male
2305(b)

35(1. 5}

20(0.9)
2306

78(3.4)
18(0.8)

96(4.2)
2280
388(17.0)
23(1.0)
2230
114(5.1)
84(3.8)

22(1.0)
17(0.8)
2320

51(2.2)
6(0.3)
2320
648(27.9)
51(2.2)
699(30.1)
Female
2345

18(0.8)

9(0.4)
2356

71(3.0)
4(0.2)

74(3.1)
2262
81(3.5)
11(0.5)
2265
111(4.9)
81(3.6)

10(0.4)
10(0.4)
2370

527(24.1)
48(2.0)
2370
414(17.5)
36(1.5)
448(18.9)
(d)
Includes all tumors occurring with a frequency of 0.5%  or
greater.
Number of animals examined histopathologically (or,  for
certain lesions, the number of animals necropsied).
Numbers in parentheses are percentages.
This combination is included because certain early studies  in
the data base tended to use these terms  interchangeably.

-------
                                118
                             TABLE 18

            INCIDENCE OF ANY MALIGNANCY IN F344/N RATS
           AND B6C3F1/N MICE  BY SEX  FOR DIFFERENT DOSE
              LEVELS FROM NTP BIOASSAYS ON 4,4'-MDA.
F344/N Rats
Male
Total animals with'3'
tumors uncertain
Female
Control
19/50
1/50
16/50
150 ppm
15/50
13/50
20/50
300 ppm
17/50
25/50
14/50
B6C3F1/N Mice(b)

Male

Total animals witlv3'
  tumor uncertain
25/49


1/49
38/50
40/50
    Tumor diagnosis is uncertain, may be benign  or  malignant.
    May include the same animals as above  in  each case.
(b)
    Data for female B6C3F1/N mice not available.

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                               119
     Table 18 shows the incidence of any malignancy  observed  in

the test animals in the 4,4'-MDA bioassays  by dose level.

        4.  Exposure Situations

     Several situations of human exposure were  used  to  estimate

LADDs and human carcinogenic risk.  The LADDs were calculated  for

each situation1s combination of exposure concentration,  exposure

duration, frequency and extent.  The LADDs  were  then applied  to

calculate carcinogenic risk using the one-stage  model and  tumor

incidence data given in Table 14.  This section  will describe  the

various exposure situations which include both workplace and

drinking water situations.

            a.  Workplace Situations

     Mathematical details of the calculation of  LADDs from the

situations described here can be found in Appendix B, as can  the

assumptions used in the calculations.

     There are several important caveats regarding the

assumptions used to calculate workplace LADDs.   First,  while  a

skin absorption rate of 1% per hour of deposited material  was

used based on data for MBOCA, the actual penetration rate  of

4,4'-MDA remains to measured.  Second, while a uniform

permeability of skin to 4,4'-MDA was assumed (to give a  uniform

absorption rate of 1% over all surfaces), it is  well known that

different skin surfaces display different permeabilities,  and

this element of uncertainty does not appear to be amenable to

resolution in this type of assessment.  Third,  in certain  of  the

hypothetical exposure cases studied the assumption is made that
                                       -.
all 4,4'-MDA is removed by washing, and-preliminary  data from  the

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                                120
skin penetration  study  now  underway indicate  that soap and water
may not  remove  all  the  compound  in a simple wash.   Fourth, the
data used  from  NIOSH  (1984a)  were  collected over six hour
periods.   At  the  end  of that  time  the hand pads  were removed and
analyzed for  4,4'-MDA.   The total  amount  collected over six hours
was divided by  six  to derive  an  hourly deposition rate.   It is
not known  whether,  in fact, deposition occurred  linearly with
time.
                i.  Case 1;   4r4*-MDA/MDI Manufacturing
     Information  supplied by  CMA (1983c)  indicates that workers
are potentially exposed  to 4,4'-MDA  for varying  periods  during
the work week.  LADDs were calculated for workers  in the three
exposure-duration classes that were  reported  by  CMA,  viz.,  8
hours or less-, 9 to  20  hours-,  and  more  than 20  hours-per-
week.   For the  first  class, exposure  for  8 hours  per week  was
assumed; for  the  second, 20 hours  per week; and  for  the  third,  40
hours per week.
     Inhalational exposure levels  were  assumed to  be  to  the
highest average 8-hour Time Weighted  Average  (TWA) values  for the
three exposure duration  classes .reported  by the  five  4,4'-MDA
manufacturers who are members of CMA1s  4,4'-MDA Project  Panel.
It is believed  that use  of the highest  average TWA was  a
realistically conservative assumption.  The highest  of  the  TWA
ranges reported, viz. 7.2 mg/nr, was  judged unrealistically high
because it was based  on  area monitoring in the vicinity  of
fugitive emissions  to which workers  are not exposed  throughout
their work time in  the unit.  Furthermore, the 7.2 mg/m3 value

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                                121
was obtained  using  the  Marcali method,  and  analytical

interference  from aniline  is  likely  to  have been significant.

Aniline would be more likely  to  be a chief  constituent of

fugitive  emissions  from this  sort of equipment  than would

4,4'-MDA, because of physico-chemical properties and process

conditions.

     Dermal exposures were  also  considered  in this  situation,  and

the dermal information  from NIOSH (1984a) was used  to calculate

the dermal component of the LADDs.   The data were obtained  as

described in Section IV above.

                ii. Case 2;   4,4'MDA Using/Processing

     In this situation,  the impact of washing off 4,4'-MDA  from

exposed skin, either immediately after exposure  or  with delays of

2, 4 or 6 hours, is assessed.  Workers are  considered who may

handle the chemical for  varying periods during the  work day, viz.

0.5 hours-, 1.6 hours-,  4 hours-, or  8 hours per day as they mix

4,4'-MDA with other materials, charge reactors,  or  conduct

similar operations, and  who then wash-up after some  delay.

     The inhalational component of the LADDs calculated for  these

workers is based on measured  air levels (personnel  monitoring) of

4,4'-MDA reported by Ameron (1983),  a firm  that  manufactures

epoxy surface coatings  for  concrete  and steel structures  and

corrosion resistant piping, among other products.   The analytical

method employed by Ameron was to collect 4,4'-MDA on silica  gel

tubes and then to measure the amount  collected colorimetrically,

a modification of the Marcali method.  The  employees that were
                                        •.
monitored were engaged  in pulverizing, mixing, blending and

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                                122
packaging of dry  4,4'-MDA  containing  coatings  products.   Ameron

presented no dermal  exposure  data.

     The dermal component  of  LADDs  derived  from this situation is

based on dermal monitoring reported in  NIOSH  (1984b).   This

monitoring was conducted in the  epoxy resin mixing  room  of a

facility than produces  filament-wound piping and pipe  fittings.

     The worker was  fitted with  a "golf-glove-like"  device which

covered glycerine-wetted cotton  gauze pads  on  the palm and back

of the hand.  The worker wore no protective gloves.  The gauze

pads were collected  and analyzed after  the  worker1s  exposure,  as

described in NIOSH (1984b).  The worker was engaged  for  less.than

10 minutes in weighing  about 150 Ibs. of granular*,  99%  assay

4,4'-MDA into a resin mixing vat.

     In the situations  analyzed  in  this case,  the hypothetical

worker is assumed to handle 4,4'-MDA  for only  about  as long  as

the worker studied in NIOSH (1984b)  and to  receive the same

dermal exposure as that worker,  but the worker  remains in  a  work

station where air levels are as  indicated for  the indicated

durations.

     The hypothetical worker wears  no gloves,  and is exposed via

the palms at the level recorded  on  the palm of  the worker  who  was

monitored.   He or she is exposed through the rest of the hand,

forearms, face and neck at the level  recorded  on  the back  of the

hand of the worker who was monitored.
*  Use of granular material had recently been instituted  in hope
   of diminishing the amount of dust formation and distribution
   that apparently had been experienced'with the previously used
   flake form of 99% assay 4,4'-MDA.

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                                123
      LADDs  are  calculated for situations in which the



 hypothetical  worker washes thoroughly all exposed skin 0.25, 2, 4



 or  6  hours  after  being  exposed,  completely removing all deposted



 4,4'-MDA.   These  situations were analyzed in order to assess the



 impact of washing after a limited-duration dermal exposure.



                 iii.  Case 3:   4,4*-MDA Using/Processing



      In  this  case the impact of  shift-long exposure without  the



 protection  of gloves  is assessed.



      Inhalational exposures are  assumed to be  at  the level



 reported by Ameron (1983),  and  to  be  for 8 hours  per day.



 Assumptions regarding worker weight,  breathing rate,  etc., used



 in  calculating doses are  the same  as  in Case 1 and  are  given in



 Appendix B.



     Dermal exposure is assumed  to occur at the rate experienced



 by  the worker who  was monitored  in NIOSH (1984b),  namely 43



 ug/cm2/10 minutes  (250  ug/cm2/hr)  for  the  palms and 4.6  ug/cm2/10



minutes (27 ug/cm2/hr)  for  the rest of  the hands,  forearm, face



 and neck.  Exposure is  assumed to  occur for four  hours  on  these



 body areas twice  during  the  shift, with  a  mid-shift wash-up  for



 lun'ch, but presumably the face and neck are not cleansed until  an



after-work shower, when all  deposited 4,4'-MDA  is  removed.



Deposition is assumed not to continue during the  mid-shift break,



 though absorption  of already deposited  material does  continue



during this time.



                iv.  Case 4;  4,4'-MDA  Using/Processing



     In this case,  the  impact of wearing protective gloves is



assessed.                               •

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                                124
      Inhalation  exposures  and  workplace  routines  considered here



 are  identical  to those  described  in  Case 3,  above.



      The dermal  exposure,  however, is  continuous  for  0.25,  2,  4



 or 6  hours  per day,  and 4,4'-MDA  is  deposited  on  the  skin  at a'



 linear rate derived  from data  in  NIOSH (1984a)  for  the  4,4'-MDA



 flakker-bagger.   This worker wore mid-forearm  length  latex



 gloves, inside of which was mounted  a  hand-pad  device as



 described above.



                 v.   Case 5;  4,4*-MDA  Using/Processing



      In this case the inhalational exposures and  work routines



 considered are the same  as in  Cases  3  and 4 above.



     The impact  of wearing protective  gloves during a single 0.5



hour per day dermal  exposure,  followed by immediate, thorough



washing to remove deposited 4,4'-MDA from hands and forearms is



assessed.   4,4'-MDA  deposited  on  the rest of the  upper  body  is



assumed to remain there  until  a shower at shift's end (6 hours



exposure).



                vi.  Case 6;   4r4'-MDA Using/Processing



     This case assesses  the impact of  the level of worker



protection used by DOE contractors (DOE, 1983c) who use 4,4'-MDA



to fabricate nuclear weapons.



                vii.  Case 7;  4,4'-MDA Using/Processing



     The impact of very  protective industrial hygiene practices



is assessed in this case.



     Inhalational exposures and work routines are similar to



those described in Cases 3, 4 and 5,  except that exposure is for



either 4 or 8 hours per day, which relatively long exposures

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                                125
 prompt  the  use  of  very protective industrial hygiene practices.

 Also, another  inhalational exposure level is used in addition to

 the  one  reported by Ameron (1983).   The additional level is the

 one  reported for a resin mixing operation at a filament winding

 factory  (CMA, 1983a).   Thus,  this case  is divided into two

 sections, reflecting the two  different  inhalational exposure

 levels.

     The  industrial hygiene practices assumed in this case

 include wearing gloves,  as described above,  during two 0.5 hour

 exposure  periods per shift*,  during which dermal exposure could

 occur, followed by immediate  and  thorough washing to remove

 deposited material from  hands and forearms.   Use of a full face

 shield and  impervious  outer garments during  periods when dermal

 depositon could occur  is  also assumed,  thus  restricting dermal

 deposition of 4,4'-MDA to  that  which the  worker  in NIOSH (1984a)

 experienced under  the  gloves.

                viii.  Case 8;  MDA Using/Processing 	

                         Hypothetical Workplace  Standard

     This case presents  a  hypothetical  situation in which a

workplace standard  is  in effect that mandates  a  0.001 ppm (0.0081

mg/nr)  8-hr TWA airborne exposure level and  use  of protective

clothing described  in Case 7  above.  The  worker  is assumed  to

handle 4,4'-MDA for one hour,  to  wash the  exposed areas of  the

hands following exposure to completely  remove  deposited amine,  to

handle 4,4',-MDA for and additional  hour in the second half  of the

shift,  and then to wash up, removing any  deposited amine.
  The 0.5 hour exposures occur at the beginning of each half-
  shift.

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                                126
            b.  Drinking Water Case



     In this case  it  is assumed that  an  individual consumes 2



liters of water daily over  a 70-year  lifespan,  and that the



person weighs 70 kg during  the lifespan  and  that  50%  of the



ingested dose is absorbed.



        5.  Estimation of Risks for Exposed  Populations



            a.  Workers



     Table 19 summarizes the lifetime extra  cancer risks  for



workers in 4,4'-MDA/MDI manufacturing plants and  in 4,4'-MDA



using and processing plants under conditions outlined  above and



detailed in Appendix B.  These  estimates are based on  data  from



the bioassay (NTP, 1983a) results with female rats that developed



thyroid follicular cell carcinomas and adenomas,  female mice,



pooling all statistically significant tumors, and  female  mice,



pooling all tumors in which malignancies alone were statistically



significant, using the one-stage extrapolation model.   Tumors



were observed in both sexes of  mice and rats  at multiple  sites.



Risk estimations based on data  for other tumor types and  other



tumor poolings are given in Appendix C, Table 19A.



            b.  People Drinking Contaminated Water



     Confidence in the risk estimations for  the drinking  water



case is low because of the lack of data at this time on actual



releases of 4,4'-MDA into waters that could  serve  as drinking



water supplies and the parallel lack of information on  the  fate



of any such releases.



     The LADDs shown in Table  20 were derived using the



assumptions stated above and the Best Estimate water

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                                127
concentrations  for  the  locales A  through  D in Table 11.



Absorption of 50% of  the  ingested dose  is assumed (Thies,  1983).



     Risk estimates in  Table  20 were  based on the same



species/sex  tumor data  cited  in the previous  subsection  for



worker risks, and additional  estimates  based  on  other tumor types



and other tumor poolings  are  given in Appendix C, Table  20A.



    C.  RJSK Characterization



     Since we do not  have  sufficient  quantitative data detailing



the carcinogenic effects of 4,4'-MDA  in humans,  this  risk



assessment relies on  the available data showing  animal



carcinogenicity as the  source of  estimates  of human risk  from



exposure to the substance.  Moreover, when, as here,  animal



effects data are available only for exposures at  a higher  level



than the level of estimated human  exposure, we rely on



statistical models to extrapolate  the risk  to animals  from high



to low exposure, then derive  human risk estimates from the low



exposure animal risk estimates.  The  confidence  we have  in the



estimates of human risk derived in this way is dependant on,



among other things, our degree of  confidence  that £he  animal  data



demonstrate a carcinogenic response,  and  that the character of



the human response will be comparable to  the  animal  response.



Confidence also depends on how accurately  we  can  quantitatively



estimate and compare the doses of  the chemical received  by the



animals with those received by humans, and  on how well the



statistical model portrays the relationship between  dose and



response.  These matters are  discussed  in  depth  separately in



this risk assessment.   The purpose of this  section is  to give a

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                                128
more brief, overall perspective  on  the  results,  highlighting some



of the more important  observations.



     There is evidence demonstrating  4,4-MDA's  carcinogenic!ty in



animals.  This evidence  is  chiefly' found  in  the  NTP bioassays on



rats and mice.  These  studies were  well designed and well



conducted, and they showed  strong dose-response  in both sexes of



both species.  In addition  to tumors  of the  liver and thyroid,



which were seen in both  species, lymphomas,  adrenal, and lung



tumors were observed at  statistically significantly elevated



incidences in the mice.  Tumors  of  the  urinary bladder occurred



in rats.



     Close structural  analogues  of  4,4-MDA have  also been found



to be carcinogenic in  the liver  and/or  thyroid of these two



rodent species.



     A number of studies in addition  to the  NTP  bioassays showed



carcinogenic activity  in animals, and several others failed  to



show such activity.  All of these studies, however,  were flawed



in terms of duration,  number of  animals exposed,  pathology



reporting or overall design.



     Several additional  lines of evidence are consistent with a



conclusion that 4,4'-MDA will also be carcinogenic  in  humans.



     The chemical is genotoxic,  and it binds to  DNA in vivo.



Thus, carcinogenic activity may  occur, at least  in  part,  by  a



direct genotoxic mechanism  involving  attack  on DNA.   If this  is



the mechanism, it should operate in humans as well  as  animals.



     Additionally, the chemical  is a  close structural  analogue of



chemicals that are carcinogenic  in both a'nimals  and  humans.

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                                129
Moveover,  while  the  one  available  epidemiology study is limited


by  the  presence  of confounding  exposure to epoxy compounds, the


fact  that  an elevated  incidence of bladder tumors was observed—a


tumor type produced  in humans by benzidine,  a close structural


analogue of 4,4'-MDA—may  be significant,  especially in light of

the occurrence of urinary  bladder  tumors  in  rats in the NTP


bioassay.   Furthermore,  4,4'-MDA is  absorbed by humans.

      All of these factors,  combined  with  sufficient evidence of

carcinogenicity  in animals  give a  high  degree of confidence that


the character of the response in humans will be comparable to

that  in animals.  An EPA classification of this chemical as a

probable carcinogen  in humans [B2] has  therefore been assigned.

      The chief sources of  uncertainty in  this assessment relate

to the different exposure  routes that humans and the test animals

of the bioassays experience, and to  the inherent uncertainties in

extrapolating human  risks  resulting  from  low level  exposure based

on experiments with  animals who  experienced  relatively  high


exposures.

      In the workplace, humans are  exposed  to 4,4'-MDA

intermittently, chiefly  via dermal and  inhalational  routes,  while

the test animals were exposed to the dihydrochloride continuously

via drinking water.   As  discussed  earlier, in performing the risk

assessment, the assumption  has  been made  that the dihydrochloride

dissociated to the free  amine in the intestine.   The differences


between the animals  and  human routes of exposure, and our lack of

certainty  in estimating  the absorption  rate,  and thus exact dose
                                        V
received,  affect the quantitative  estimation of  human risk.

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                                130
 These  uncertainties are explained throughout this assessment and



 are  highlighted below.



     Confidence is high that humans absorb the chemical.



 Evidence  from  several  industrial hygiene reports shows that



 dermal  exposure to humans results in absorption of significant



 amounts of  4,4'-MDA.   The structure of the chemical indicates



 that inhalational  exposure will also result in absorption, and



 gastro-intestinal  absorption also occurs,  as evidence by the



 "Epping Jaundice"  case  described earlier.



     The  state-of-the-art of quantitatively assessing dermal



 exposures under industrial chemical processing conditions is



 relatively  primitive, but is rapidly developing.   Thus,  while it



 is clear  that  4,4'-MDA  is absorbed through human skin, and that



 this phenomenon  occurs  in the  chemical processing workplace,  the



 rate of deposition  of 4,4'-MDA on the skin and the irate  of



 absorption  of  deposited material  are not precisely known.   The



 estimates of each  of these rates  used in this  assessment are



 reasonable, based on existing  experimental  data.   These  estimates



 will be refined  using data from studies  now ongoing  to measure



 the in vivo absorption rate  of  4,4'-MDA  through  the  skin of



 animals,  including  rhesus monkeys.



     There  is  some  question  regarding  the  coupled use  of the



 estimated deposition and  absorption  rates  in an  integral form to



 assess dermal  exposure in  this  assessment.   It  is the  author's



view that such  coupling is defensible,  in  that  it uses all the



available experimental data, and  the  uncertainties are duly



noted.   It  should be noted that  an  alternate approach  that has

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                                131
been used by  EPA  in  the  past,  namely  assuming  100%  absorption,



would yield much  higher  risk  estimates.



     There are also  uncertainties  related  to high-to-low-dose



extrapolation modeling and  animal-to-human extrapolations.   In



this case the quantitative  risk estimates  were  made using  only



tumor incidence that  showed monotonic dose-response behavior



using the one-stage  version of the  linearized multi-stage  model.



The fact that the maximum likelihood  estimates  of risk  differ



from the upper 95% confidence  limits generally  by less  than  a



factor of 2 indicates a  good  fit of these  experimental  dose-



response data to  the model  used, and  the linear shape of the



dose-response curve  at the  low doses expected from  human



exposures is consistent  with the apparent  genotoxic  mechanism of



4,4'-MDA carcinogenic action.



     The reader is cautioned against an assumption  that the



quantitative risk estimates made in this assessment  represent the



true,  known risk  to humans.  The risk estimates given here are  an



upper  bound estimate, not a declaration of actual risk  levels.

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                                       132
                                                     TABLE 19
                                ESTIMATED EXTRA LIFETIME RISK OP CANCER FOR WORKERS
                                                    (EPA, 1984)
ADDED RISK BASED ON
Exposure Setting
4,4'-MDA/MDI Mfg.
Appendix B, Sec. 1
8 hr/wk
20 hr/wk
40 hr/wk
4,4'-MDA Use/Proc.
Appendix B, Sec. 2
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
,• t
4,4'-MDA Use/Proc.
Appendix B, Sec. 3
Appendix B, Sec. 4
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
Appendix B, Sec. 5
Total LADD
(mg/kg/day)
0.0051
0.020
0.040
o.ooii
0.0053
0.012
0.020

0.17
0.00068
0.0031
0.0094
0.020
0.0018
FRFC/A(a) FMPA^
MLE
2 X 10~3
7 X 10~3
1 X 10~2
4 X 10~4
2 X 10~3
4 X 10~3
7 X 10~J

6 X 10~2
2 X 10~4
1 X 10~3
3 X 10~3
7 X 10~3
6 X 10~4
U95CL(e)
3 X 10"3
1 X 10~2
2 X 10 2
5 X 10~4
3 X 10 3
6 X 10 3
1 X 10~2

8 X 10~2
3 X 10~4
1 X 10~3
4 X 10~3
1 X 10~2
9 X 10~4
MLE
5 X 10~3
2 X 10~2
4 X 10~2
1 X 10~3
5 X 10 *
1 X 10 2
2 X 10

1 X 10"1
6 X l6~4
3 X 10~3
7 X 10"3
2 X 10~2
2 X 10~3
U95CL
7 X 10~3
2 X 10~2
5 X 10~2
1 X 10~3
7 X 10~3
1 X 10 2
2 X 10 2

2 X 10"1
8 X 10~4
4 X 10~3
9 X 10~3
2 X 10~2
2 X 10~3
FMPM
MLE
4 X 10~3
2 X 10~2
3 X 10 2
9 X 10~4
4 X 10~3
1 X 10 2
2 X 10

1 X 10"1
6 X 10~4
3 X 10~3
6 X 10~3
2 X 10~2
2 X 10~3
(c)
U95CL
6 X 10~3
2 X 10~2
4 X 10 2
1 X 10~3
6 X 10~3
1 X 10~2
2 X 10~2

2 X 10"1
7 X 10~4
3 X 10~3
8 X 10~3
2 X 10~2
2 X 10~3
Appendix B, Sec. 6
  8 hr/wk
0.000013
5 X 10
                   ,-6
6 X 10
                  ,-6
1 X 10
                    ,-5
2 X 10'
                  r5
1 X 10
r5     i x io~5

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                                         133
                                                        TABLE 19
                                                       CONTINUED
                                                                   ADDED RISK BASED ON
Exposure Setting
Total LAPP

(rng/kg/day)
                                               FRFC/A(a)
                               FMPA
                                                 (b)
                               FMPM
                                                              (O
MLE
             U95CL
                                                         (e)
  MLB
U95CL
MLE
  Appendix B, Sec. 8
    40 hr/wk
 0.00033
1 X 10 4    2 X 10 4
3 X 10 4    4 X 10~4
U95CL
Appendix B, Sec. 7A
20 hr/wk
40 hr/wk
Appendix B, Sec. 7B
20 hr/wk
40 hr/wk
0.0052
0.010
0.0013
0.0026
2 X 10 3
4 X 10~3
5 X 10~4
9 X 10 4
3 X 10 3
5 X 10~3
6 X 10~4
1 X 10~3
5 X 10 3
9 X 10~3
1 X 10~3
2 X 10~3
6 X 10~3
1 X 10~2
2 X 10~3
3 X 10~3
4 X 10~3
8 X 10~3
1 X 10~3
2 X 10"J
6 X 10 3
1 X 10~2
1 X 10~3
3 X 10"3
              3 X 10"4  -   4 X 10 4
    Female rat, thyroid follicular cell carcinoma and adenoma.   See Appendix C for additional risk data.
   'Female mouse, pooled, all significant tumors.
    Female mouse, pooled, all tumors in which malignancies alone are significant.

  ,  MLE = maximum likelihood estimate of risk, multi-stage model.
    U95CL = upper 95% confidence limit on estimate of risk, multi-stage model.

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                                               134
                                            TABLE 20

                             ESTIMATED EXTRA LIFETIME RISK OF CANCER
                                  FRCM DRINKING WATER EXPOSURES
ADDED RISK BASED ON
4,4'-MDA cone. LADD
Locale . (mg/1 )
A 0.00018
B 0.00015
C 0.00015
B + C 0.00030
D 0.0012
FRFC/A(a) FMPA(b)
(mgAg/day) MLE
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                                135
VI.  DISCUSSION



     While  this  assessment  focusses  on  quantitatively estimating



cancer risks,  it should  be  noted  that other health effects have



been linked with 4,4'-methylenedianiline  (4,4'-MDA).   The last



Federal health authority action on 4,4'-MDA,  the 1976 Current



Intelligence Bulletin  issued  by NIOSH,  (1976a),  addressed the



chemical's acute toxicity to  the  liver.   Retinopathy  has  also



been cited as  a  toxic  effect  (Schilling Von Canstatt  et al.,



1966; NIOSH, 1981; Leong et_ al_. ,  1984), as  has acute



myocardiopathy (Brooks _et^ jal_. ,  1979) and  allergic dermatitis



(Emmett, 1976).  Retinopathy  has  been observed in two animal



species, the cat and the guinea pig, and  may  have occurred in



humans, while  liver toxicity  and  myocardiopathy  have  been



observed in humans.



     These adverse health effects, coupled  with  the results of



the NTP bioassays on the chemical, evidence  from mutagenicity



studies, evidence of the carcinogenicity  of  close structural



analogues in animals and humans,  epidemiologic evidence and



evidence of present inhalational  and dermal  exposures to  the



chemical in workplaces that lead  to estimated extra lifetime



risks as high as from about one in one hundred to about one in



ten (B2) in certain situations, combine to make  4,4'-MDA  a prime



candidate for exposure controls and hazard  warnings to those



exposed.



     Of special concern  is  the dermal route of exposure.   This



route is insidious.  Many workers and managers appear to  be



unaware of its significance.  For instance,  in Vaudaine et al.

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                                136
 (1982)  it  is reported that knowledge of the hazards of 4,4'-MDA



 prompted the use of "divers'  suits," an extreme measure, to



 protect against exposure.   Yet 15% of urine samples taken during



 that  time  contained measurable levels of 4,4'-MDA which



 subsequent events have shown  to have resulted from unsuspected



 dermal  exposure..



      Likewise-in Dunn and  Guirguis (1979),  even after workers had



 been  supplied with positive-pressure,  supplied air breathing



 apparatus  to protect against  inhalational exposure, cases of



 jaundice were still observed  among workers  who were being exposed



 dermally.



      The liver toxicity reported in McGill  and Motto (1974)



 occurred only in workers who  were  dermally  exposed, while co-



 workers in the same work station who breathed the same air as



 affected workers,  but  who  did not  touch the 4,4'-MDA-containing



 resin system,  were not affected.



     While no cases of acute  toxicity  were  reported,  the exposure



 of the  resin  mixer reported in NIOSH (1984b)  is  a concern in the



 same  regard.   Apparently,  attempting to lower the potential  for



 exposure,  the  company  involved had recently switched  from the



 flake, form of  the  chemical to the  granular  form.   Even with  the



 material of  "lower dusting potential,"  (NIOSH,  1984b)  the worker



 involved received  a substantial  exposure.   This  might have



 resulted,  at  least in  part, because  the worker assumed that



 "dusting"  had  been eliminated,  or  at least  reduced to a



 sufficient  degree  to dispense  with the  use  of  protective



 clothing.   How many  other  examples of  such  inadvertant exposure



may there  be  in  such workplaces?

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                                137
      Clearly,  as  shown in Vaudaine et_ al_. (1982), once workers



and managers  are  made  aware of the dermal exposure route and the



hazards  it  can pose, exposures can be reduced.   Such an



educational program for those who manufacture,  use or process



4,4'-MDA  in the United States is  clearly indicated by the



evidence  of exposure and the carcinogenicity of the chemical.



      While  the dermal  exposure route  is  particularly worrisome,



irihalational  exposures are also of concern.   The LADD



calculations  in Appendix B,  Cases 4 and  7 and the corresponding



risk  estimations  in Table 19 illustrate  this.  When dermal



exposures are  sharply  limited,  inhalational  exposures at levels



that  have been reported by industry sources  still result in



significant risks.  It  is  obvious that attention to both routes



of exposure is called  for in order to bring  risks down.   It is



also obvious from reports  of airborne levels  of 4,4'^MDA



submitted by CMA  (1983a)  that control of airborne levels is



feasible.   Thus, control  of  airborne  levels  by  use of engineering



methods and control of  dermal  exposures  by use  of protective



clothing and good industrial  hygiene  practices  is feasible, and



these controls  result  in  risk  estimations in  the range of  about



one in ten  thousand extra  lifetime  risk  of cancer (Cases 7  and



8).



     Aside  from the overriding  issue  of  acting  expeditiously  to



protect workers' health,  there  are  scientific questions  the



answers to  which could  help  to  reduce the uncertainties  in  our



understanding  of the risks associated with 4,4'-MDA.

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                                138
     A metabolism  study  in  Fischer 344 rats coupled with worker



urine monitoring would help to relate the external dose that rats



received  in  the NTP  bioassay to the internal dose that resulted



in the observed tumor  incidence in the animals and to the



internal  dose  that exposed  workers are receiving.



     Follow-up of  workers who were exposed and who were studied



by Vaudaine  et_ al_. (1982),  Dunn and Guirguis (1979) and McGill



and Motto (1974) could prove useful.   Some of these exposures



occurred  as  long ago as  17  years and  may  have lasted for as long



as 9 years.



     The  skin  penetration rate of 4,4'-MDA will be a valuable



tool in reducing uncertainty in this  case,  as will data on



effluent  levels of 4,4'-MDA and on the fate of the chemical in



natural surface waters.



     Development and use of an analytical  method for measuring



airborne  levels of 4,4'-MDA that does  not  suffer from



interference from aniline will be of  value  in reducing



uncertainty about exposures in the 4,4'-MDA manufacturing



workplace.  Likewise, a kinetic study  on  the rate of deposition



of 4,4'-MDA on various parts  of  the body would be useful in this



regard.   Such  studies should  not,  however,  impede exposure



control and hazard warning  programs for this probable human



carcinogen.

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                                139








                            APPENDIX A





ANALYTICAL METHODS



     A key issue  in  assessing workplace  exposures  to and



associated risks  from 4,4'-MDA  is the  analytical methodology  used



for measuring airborne concentrations  of the  chemical.  A  related



issue is the-determination of 4,4'-MDA levels  in workers'  urine



as a possible assessment  tool for relating workplace exposures



with actual received doses.  The latter  issue  is under  study  by



NIOSH, which is developing a protocol  for measuring  4,4'-MDA  in



urine.  Dr. Mark  Boeniger, of the Cincinnati office  of  NIOSH,  is



the leader on this project.



     Regarding analytical techniques for measuring airborne



levels of 4,4'-MDA, a summary of methods used  in the past  and



those undergoing  development will be given here.



     1.   Marcali  Method



     This method, of which there are several permutations,



involves drawing  air through a liquid  collecting medium of acetic



and hydrochloric  acids.   The resulting amine salt  is then



converted to the  diazonium compound and  thence to an azo dye  by



coupling with 1-N-naphthylethylenediamine.  The concentration of



the azo compound  is then colorimetrically determined.



     The major limitation of this method is its inability  to



discriminate among 4,4'-MDA, MDI (which  is hydrolyzed to the



amine in the collection medium), aniline (which is often present



at 4,4'-MDA manufacturing plants) or other aromatic  amines.   This

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                                140
 limitation  results  in  reports of  4,4'-MDA  levels  which  may be


 erroneously high  when  interfering compounds  are present (CMA,


 1983a).

     2.   Liquid Chromatoqraphic Methods


     The  most promising methods for measuring  4,4'-MDA  levels in


 air in the  presence of MDI, aniline, and other aromatic amines


 involve high-pressure  liquid chromatographic  (HPLC)  separation of


 analyte desorbed  from  a variety of collection  media  and converted

 to elutable  derivatives.

          a.  Acid-Treated Glass Fiber Filter Method


     This technique, used by DOE  contractors (DOE, 1983c),

 involves  uniformly coating a 37 mm glass fiber filter with  dilute

 sulfuric  acid, followed by driving off the water  in  an  oven.   Air

 containing 4,4'-MDA is drawn through the filter,  which  captures

 the amine and stabilizes it toward re-volatilization and  against


 oxidative loss by converting the  amine to the  hydrogen  sulfate

 salt.   The analyte is  then desorbed using 0.26_N NaOH that  is  5%

 (v/v)acetonitrile and  converted to the diacetyl derivative  with

 acetic anhydride.  The resulting  solution is then analyzed  on a

 high pressure liquid chromatograph using a solvent gradient

 (water/ acetonitrile)   and a UV detector.

     DOE reports  (DOE, 1983c) that the method  is  still  under
          t
 study,  but filter collection efficiency and recovery of 4,4'-MDA

 from spiked  samples are greater than 90%.

     EPA and NIOSH are working to further validate this general

method.

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                               141
         b.  Glass-Fiber Filter/Silica Gel Method
     NIOSH (1984a, b) conducted the referenced  surveys  using  an
untreated glass-fiber filter in series with a silica gel  tube for
the area monitoring portion of the work.  The filter was  designed
to trap particulate matter and the silica to collect vapor-phase
material.  However, it has been discovered that severe  loss of
4,4'-MDA particles from non-acid-treated filters occurs,
rendering the results of those studies suspect  insofar  as  the
reported results of area monitoring are probably lower  than
actual levels.  Duplicate area and personnel samples were
analyzed by NIOSH and the company using this method (and  the
Marcali method for area samples).  Agreement among the  samples
was not good, and air monitoring data from these NIOSH  visits
were not used in this assessment.
         c.  Silica Gel Collection Method
     This method (several permutations) involves collection of
4,4'-MDA from the vapor phase on treated or untreated silica
gel.   Silica treated with diethylamine has been used to sample
atmospheres containing 4,4'-MDA,  MDI,  and dimethyl formamide.
The diethylamine converts MDI to a stable urea,  rendering
chromatographically separable the MDI and 4,4'-MDA components
(Lipski, 1982).
     Desorption has been accomplished with methanol or  diethyl
ether, and the 4,4'-MDA has been analyzed using HPLC, with UV
detection, either per se or as a benzoyl derivative (CMA, 1983a).

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                                142
     There is concern that use of a  standard,  untreated  silica
gel collection system might not efficiently  remove  particles  of
4,4'-MDA.
     The assumption ha's been made in this assessment  that results
obtained with the Marcali method can give an upper bound on
actual exposure levels (and is probably quite reliable  in the
absence of interferences), while results obtained with  the
untreated glass fiber filter/HPLC method would give a lower bound
on actual exposure levels.

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                               143
                            APPENDIX B

LIFETIME AVERAGE DAILY DOSE (LAPP) CALCULATIONS
1.   4,4'-MDA/MDI Manufacturing Workplace
     Inhalational Component
     Assumptions:
     o   1.2 m3/hr breathing rate
     o   2.50 day/year exposure
     o   50% absorption of airborne 4,4'-MDA through the lung
     o   40 year working career
     o   70 year lifetime
     o   70 kg worker weight
     o   exposure levels for different exposure durations are
         highest values from average TWA columns in Table 5.
     8 hrs/week   =    1.6 hrs/day
     AVE.  TWA   =   0.07 ppm   =    0.57 mg/m3
     0.57  mg/m3 X 1.2 m3/hr X 1.6 hr/day X 250 X 40 X 0..5 •* 70 kg
                                           365   70
         LADD   =   0.0031 mg/kg/day

     20  hrs/week  =    4 hrs/day
     AVE.  TWA   =   0.059 ppm  =   0.48 mg/m3
     0.48  mg/m3 X 1.2 m3/hr X 4 hr/day X 250 X_40_x °-5 * 70 k<3 =
                                         365   70
         LADD   =   0.0064

     40  hrs/week  =    8 hrs/day
     AVE.  TWA   =   0.07 ppm   =    0.57 mg/m3
     0.57  mg/m3 X 1.2 m3/hr X 8 hr/day X 250 X 40 X 0.5 * 70 kg =
                                        365  "70"
         LADD   =   0.015 mg/kg/day

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                           144
Dermal Component

Assumptions:

o   Deposition  rate  of  4,4'-MDA is  uniform over time.

o   Absorption  through  all  skin areas  is  at a uniform  rate
    of 1%/hr  of deposited material.

o   Body  surface areas  (male  and female averages,  Snyder et
    _al. ,  1975) .

    Face = 650  cm2

    Back  of neck = 110  cm2
                                          2
    Front of  neck and V of  chest =  150 cm

    Chest and stomach =  3550  cm2

    Back = 3500  cm2

    Upper arms =  1320 cm2
                      2
    Forearms =  1210  cm

    Hands = 820  cm2

o   Exposure of  the  back of the  hand under a cotton  glove
    mimics exposure  to  the entire upper body (face,  neck,
    arms, back  of hands, chest,  stomach and  back), which
    area totals  10,900  cm2.   Area of two  palms  is  410  cm2.

o   Worker showers at the end of the shift,  completely
    removing all  4,4'-MDA remaining on skin.
                                                         f\
o   Deposition occurs on both palms at a  rate of 9 ug  cm""'
    hr~| and on  the  rest of the  upper body at 2.5  ug cm
    hr"1 (NIOSH,  1984a, Table IV).  There  is  zero  deposition
    on other body surfaces.

o   For 40 hr/wk  workers, two 3.5 hour half  shifts under the
    above conditions is assumed, along with  a 1 hour lunch
    period during which no deposition occurs.   It  is assumed
    that the hands and  forearms  are washed free of 4,4'-MDA
    at lunch,  and that  absorption of material already
    deposited on  the rest of  the upper body  continues  during
    lunch.

Dose through the Palms  (40 hr/wk)

Daily Dose =

    2 X 0.01 hr"1 X  9 ug cm~2 hr'1 X 410 cm2 fjj*5  tdt

      =  74 xi/2 X  t2 ] ^'5 =  450 ug .

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                           145
Dose  through  back  of  hand  and  forearms (40  hr/wk)

Daily Dose =

    2 X  .01 hr"1 X 2.5  ug  cm"2 hr"1  X 2830  cm2 f3)'5 tdt

      =  140 X ^ X  t2  ] J'5 =  860 ug

Dose  through  rest  of  upper  body (40  hr/wk)

Daily Dose =

    2 X  .01 hr"1 X 2.5  ug cm"2 hr"1  X 9280  cm2 J^*5 tdt

    + 0.01 hr"1 X  2.5 ug cm"2  hr"1 X 3.5  hr X  1  hr X 9280  cm2 =

    460  X ^ X t2 ]jj-5 + 810 =  3600 ug

Dose  through  the palms  (8 hr/wk and  20  hr/wk)

Daily Dose =

    0.01 hr"1  X 9  ug  cm"2 hr"1 X 410 cm2]"?  tdt  where X =  4.0
                                                           1.6

    10 X Vfc X  t2 ] J =  80 ug


    10 X ^ X  t2 ] 1<6 = 13 ug

Dose through  rest  of  upper body (8 hr/wk  and 20  hr/wk

Daily Dose =

0.01 hr"1 X 2.5 ug  cm"2 hr"1 X 10,900 cm2f£ tdt  where x =  4.0
                                         J                 1.6
    270 X ^ X  t2 ]  £   = 2200 ug
    270 X^X t2 ] J'6 = 350 ug

Total daily dermal doses at:

    40 hrs/wk = 4900 ug = 4.9 mg
    20 hrs/wk = 2300 ug = 2.3 mg
     8 hrs/wk =  360 ug = 0.36 mg

     LADD = daily dose X 250 X _4£ 4 70 kg
                         365   70

Dermal LADDs for:

    40 hrs/wk = 0.027 mg/kg/day
    20 hrs/wk = 0.014 mg/kg/day
     8 hrs/wk = 0.0020 mg/kg/day

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                               146
     Total LADDs for Durations of

                    8 hr/wk       20 hr/wk        40 hr/wk
                   	.	in mg/kg/day	

     Dermal          0.0020        0.014            0.027
     Inhalational    0.0031        0.0064           0.015
       TOTAL         0.0051        0.020            0.042

2.   4,4'-MDA Dsing/Processing Workplace with Minimal Dermal Exposure
     Duration and Delayed Wash-up Following Exposure

     Inhalational Component

     Assumptions:

     o   Same as above inhalational assumptions,  and

     o   Respirable 4,4'-MDA concentration in air is 0.38 mg/m3
         (Ameron, 1983;  mean of range limits, Page 4,  Section 5.3).

     o   Worker spends 0.5, 1.6,  4 or 8  hrs/day in a work station with
         the above 4,4'-MDA air concentration.

     2.5  hrs/wk  =   0.5  hr/day

     0.38 mg/m3 X 1.2 m3/hr.  X 0.5 hr/day X 0.5 X 250  X 40  *  70 kg =
                                                  365    70
         LADD  =   0.00066 mg/kg/day


     8  hrs/wk  =   1.6 hrs/day

     0.38 mg/m3 X 1.2 m3/hr X 1.6  hr/day X 0.5  X  250 X 40  * 70 kg =
                                                 365   70
         LADD  =   0.0021 mg/kg/day


     20 hrs/wk  =   4  hrs/day

         LADD  =   0.0052 mg/kg/day


     40 hrs/wk  =   8  hrs/day

         LADD  =   0.0iO  mg/kg/day


     Dermal Component

     Assumptions:

     o    Same as  above dermal assumptions,  and

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                           147
o   Physical  form of 4,4'-MDA  used  is  capable  of  producing
    the  same  "dusting"  experienced  by  the  worker  in NIOSH
    (1984b).

o   Worker wears no gloves  or  other protective gear,

o   Worker actually handles 4,4'-MDA only  long enough (about
    10 minutes) to receive  the dermal  exposure cited in
    NIOSH (1984b), Table  IV, and  no longer,  though  he/she
    may  remain  in the same  general  work  area longer.

o   Worker thoroughly washes   forearms,  face,  and neck 0.25,
    2, 4, or  6  hours after  handling 4,4'-MDA.

o   Worker is exposed through  the palms  (410 cm2) at 43 ug
    cm"2 and  through the  rest  of  the hands,  forearm,  face
    and  neck-V  (2400 cm2) at 4.6  ug cm"2 (NIOSH,  1984b,
    Table IV).            .          .

Dose through palms

Daily dose  =

For 0.25 hr exposure:

    .01  hr"1 X  43 ug cm"2 X 0.25  hr X  410  cm2  = 44  ug

For 2 hr exposure:

    .01  hr"1 X  43 ug cm"2 X 2  hr X  410 cm2  =  360 ug

For 4 hr exposure:

    .01  hr"1 X  43 ug cm"2 X 4  hr X  410 cm2  =   720  ug

For 6 hr exposure:

    .01  hr"1 X  43 ug cm"2 X 6  hr X  410 cm2  =   1100  ug

Dose through rest of hands, forearms,  face,  and neck-V

Daily dose  =

    .01  hr"1 X  4.6 ug cm"2  X 0.25 hr X 2400  cm2 = 28  ug

For 2 hr exposure:

    .01  hr"1 X  4.6 ug cm"2  X 2 hr X 2400 cm2   =   220  ug

For 4 hr exposure:

    .01  hr"1 X  4.6 ug cm"2 X 4 hr X 2400 cm2   =   440  ug

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                               148
     For 6 hr exposure:

         .01 hr'1 X 4.6 ug cm~2 X 6 hr X 2400 cm:
     TotaJ daily dose @:
           0.25 hrs/day  =  72 ug
            2 hrs/day  -   580 ug
            4 hrs/day  =  1200 ug
            6 hrs/day  =  1800 ug
         LADD  =  daily dose X 250 X 40  -f  70 kg
                               365   70
                      660 ug

                      0.072 mg
                      0.58 rag
                      1.2 mg
                      1.8 mg
         LADDs @:   0.25 hrs/day  =
                      2 hrs/day  =
                      4 hrs/day  =
                      -6 hrs/day  =

     Total LADDs for Duration of
                     0.00040 mg/kg/day
                     0.0032 mg/kg/day
                     0.0067 mg/kg/day
                     0.010 mg/kg/day
               2.5 hr/wk       8 hr/wk       20 hr/wk
               	    in mg/kg/day
     Dermal
     Inhal.
     Total
0.00040
0.00066
0.0011
0.0032
0.0021
0.0053
0.0067
0.0052
0.012
                                           40 hr/wk
0.010
0.010
0.020
3.   4r4'-MDA Using/Processing Workplace Without Use of Gloves.
       Exposure Duration for Entire 8-Hour Shift

     Inhalational Component

         The same inhalational component of exposure for the 40-
     hours per week situation as given in Case 2, above, is
     assumed, namely:  LADD = 0.010 mg/kg/day.
     Dermal Component

     o   Same,general assumptipns as in Case 2, except that the
         worker is exposed to 4,4'-MDA deposition for the entire
         shift (two 4-hour periods, broken by the mid-shift 0.5
         hr break) at the rate given in NIOSH, 1984b, Table IV.C,
         namely 43 ug cm~2/10 minutes (250 ug cm"2 hr"1), palms
         (410 cm2); and 4.6 ug cm~2/10 minutes (27 ug cm"2 hr"1),
         rest of hands, forearms, face and entire neck (2500
         cm2).

     o   Worker washes off all deposited 4,4'-MDA from hands and
         forearms at mid-shift break, leaving face and neck (910
         cm2) un-washed, and removes all 4,4'-MDA with a shift-
         end shower.

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                           149
    Deposition does not  continue  during  0.5  hr mid-shift
    break,  though  absorption  of already  deposited material
    continues through  this period.
2 X  .01 hr"1 X 250  ug  cm"2  hr"1 X  410  cm2 j*Q  tdt
Dose through palms

                                           *Q

  2100 X l/2 x fc2 10= 17'000 U9

Dose through rest of exposed skin

2 X .01 hr"1 X 27- ug cm"2 hr"1 X 2500 cm2 j'o tdt

  + .01 hr"1 X 0.5 hr X 4 hr X 27 ug cm"2 hr"1 X 910 cm2
          l     9 4
  = 1400 X 1/2 X t2]   + 490
                  0       ug

  = 11,000 + 490 ug = 11,000 ug

Total daily dermal dose = 28,000 ug = 28 mg

LADD = daily dose X 250 X 40 * 70 kg
                    365   70

Dermal LADD = 0.16 mg/kg/day

Inhalational LADD = 0.010 mg/kg day

Total LADD = 0.17 mg/kg/day

4,4'-MDA as ing/Process ing Workplace with Better  than Minimal
  Industrial Hygiene and Variable Durations of Exposure

Inhalational Component

    The same inhalational component of exposure, for the
same time periods, is assumed for this workplace setting as
in Case 2, above.

Dermal Component

Assumptions:

o   Same general assumptions as in Case 2, above.

o   Worker wears fresh mid- forearm- length neoprene/latex
    gloves while handling 4,4'-MDA.

o   No further dermal exposure occurs after handling 4,4'-
    MDA and removing gloves.

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                                150
     o   Worker handles 4,4'-MDA for 0.25, 2, 4 or 6 hr/day,
         using  both  hands freely so that there is no difference
         between right- and left-hand exposure.
     o   Deposition  of  4,4'-MDA occurs linearly with time, as in
         NIOSH,  1984a  (Table IV, Samples DM2A, DMB), at 4.2 ug
         cm"2 hr"1 on  the palms (410 cm2)  and 0.7 ug cm""2 hr"1 on
         the rest of the upper body (10,900 cm2).  No other
         dermal  exposure.
     o   4,4'-MDA penetrates upper body clothing and deposits on
         the skin at the same  rate as it penetrates  the
         neoprene/latex gloves,  viz.  0.7 ug cm"2 hr"1.
     o   Mid-shift handwashing is  not accounted for  in  these
         calculations.
     (O   Workers shower at  shift's end,  completely removing
         remaining 4,4'-MDA.
     Dose through the palms
     Daily Dose  =
         .01 hr"1 X  4.2  ug  cm"2  hr"1  X  4'10  cm2f0tdt  x =  0.25  hrs
                     .  .  __                                 2  hrs
         17 X 1/2 X  t2]§'25 =  0.53  ug                      4  hrs
                     o  •?                                    6  hrs
         17 X 1/2 X  t2!  g    =  34 ug
         17 X 1/1 X  t2]  §  =  140 ug
         17 X 1/2 X  t2]  §  =  310 ug
Dose through rest of upper body
Daily Dose   =
       .01 hr"1 X 0.7 ug cm"2  hr"1 X  10,900 cm2 fgtdt  x =  0.25  hrs
                     -)  n ->*   '                                 2  hrs
         76 X 1/2 X  t2]2-25 =  2.4 ug                          4  hrs
                                                               6  hrs
         76 X 1/2 X  t2!  3   =   15°  u*
         76 X 1/2 X  t2]  $   =   610  ug
         76 X 1/2 X  t2]     =   1400 ug

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                           151
Total daily dose @:  0.25 hr/day = 2.9  ug =  0.0029  mg
                     2 hr/day = 180  ug  = 0.18 mg
                     4 hr/day = 750  ug  = 0.75 mg
                     6 hr/day = 1700  ug = 1.7 mg

LADD = daily dose X 250 X 40  *  70  kg
                    365   70

LADDs @ 0.25 hr/day = 0.000016 mg/kg/day
           2 hr/day = 0.0010 mg/kg/day
           4 hr/day = 0.0042 mg/kg/day
           6 hr/day = 0.0095 mg/kg/day

Total LADDs for Duration of

              2.5 hr/wk     8 hr/wk     20 hr/wk     40 hr/wk
              	in mg/kg/day	

    Dermal    0.000016      0.0010       0.0042       0.0095
    Inhal.    0.00066       0.0021       0.0052       ,0.010
    Total     0.00068       0.0031       0.0094       0.020

4,4*-BOA Using/Processing Workplace with Better than Minimal
  Industrial Hygiene and Short-Term Exposures

Inhalational Component

Assumptions:

o   Same general inhalational assumptions as in Case 1,
    above, and

o   Respirable 4,4'-MDA air concentration is 0.38 mg/m3
    (Ameron, 1983)

o   Worker is exposed only in this work station and only for
    0.5 hr/day.

0.38 mg/m3 X 1.2 m3/hr X 0.5 hr X 0.5 X 250 X 40  *  70 kg =
                                        365   70

    LADD  =  0.00066 mg/kg/day

Dermal Component

Assumptions:

o   Same general dermal assumptions as  in Case 4, above, and

o   Worker has but one 0.5 hr exposure/day and thoroughly
    washes hands and forearms immediately following the
    exposure.

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                                152
     o   Area of forearms  is  1210 cm  .

     o   Remainder of  the  upper  body  (9280  cm2)  is  exposed  for 6
         hours before  shower.

     Dose through the  palms

     Daily dose  =

         .01 hr'1 X 4.2 ug cm"2  hr"1  X 410  cm2 J"Q  tdt

         17 X 1/2 X t2]g-5 =  2.1 ug

     Dose through the  forearms

     Daily dose  =

         .01 hr'1 X 0.7 ug cm'2  hr'1  X 1210 cm2 J*0  tdt

         8.5 X 1/2 X t2]0)'5 = 1.1 ug

     Dose through rest of upper  body

     Daily dose  =

     .01 hr'1 X 0.7 ug cm"2 hr'1 X 0.5 hr X 9280 cm2 X 6 hr =  195 ug

     Total daily dermal dose  = 200 ug = 0.200 mg

         LADD  =  0.20 mg/day X 250 X 40 -fr 70 kg
                                365   70

              =   0.0011 mg/kg/day

     Total LADD (Inhal. and Dermal)   =  0.0018 mg/kg/day

6.   DOE Contractor Workplace (DOE, 1983c)

     Assumptions:

     o   As described in the text,  only inhalational exposures
         occur

     o   Other inhalational assumptions in Case 1, above, apply

     0.02 mg/m3  X  1.2 m3/hr X 0.2 hr/day X 0.5 X 250 X 40 * 70 kg
                                                 365   70

         LADD =   0.000013 mg/kg/day

-------
                               153
7.   A.  4,4*-MDA Using/Processing Workplace;  Intermittent Daily
           Exposure;  Best Industrial Hygiene Practices

     Inhalational Component

         Same as Case 2 above, but with 4 or 8  hours total
     exposure per day, delivering 0.0052 and 0.010 mg/kg/day
     LADD, respectively.

     Dermal Component

     Assumptions:

     o   Worker handles 4,4'-MDA for 0.5 hrs in first half and
         0.5 hrs in second half of shift.

     o   Worker wears neoprene/latex,  mid-forearm gloves, a
         suitable over garment arid full face shield while
         handling the chemical, which limit exposure to

         —palms (410 cm2) at a deposition rate of 4.2 ug cm~2
         hr"1 (NIOSH 1984a,  Table IV,  Sample DM2A).

         —back of hands (410 cm2)  at  a deposition rate of 0.7 ug
         cm~2 hr"1 (NIOSH 1984a,  Table IV, Sample DM2B).

     o   Worker receives no  other dermal exposure

     o   Worker washes hands immediately after exposure,
         completely removing any 4,4'-MDA.

     Dose to palms

     Daily dose  =

         2 X .01 hr"1 X 4.2  ug cm"2 hr"1 X 410  cm2 f'Q tdt
                     9  '5
         34  X  1/2  X  t2]  Q =  4.3  ug

     Dose to back  of hand

     Daily dose  =

         2 X .01 hr"1 X 0.7  ug  cm"2  hr"1  X  410  cm2 j""Q  tdt
                     *> .5
         5.7 X 1/2 X t2] Q   =   0.71  ug

     Total daily dermal dose =   5.0 ug   =  0.0050 mg

         LADD  =   daily dose X  250 X 40   -»   70  kg
                               365    70

              =   0.000028 mg/kg/day

-------
                           154
Total LADD  =  Dermal and  Inhalational  LADDs

For 4 hr/day  inhalational  exposure:

    (0.000028 + 0.0052) mg/'kg/day

         0.0052 mg/kg/day

For 8 hr/day  inhalational  exposure:

    (0.000028 + 0.010) mg/kg/day
         0.010 mg/kg/day

B.  4,4'-MDA  Using/Processing Workplace;   Intermittent Daily
      Exposure;  Best Industrial Hygiene Practices

Inhalational  Component

    Same general assumptions as in Case 2  above, except that
the airborne  concentration of 4f4'-MDA  is  the same as that
reported by CMA (1983a) for the resin mixing operation in a
filament winding plant, namely 0.1 mg/nr (See p. 64), and
exposure to this level is  for 4 or 8 hours per day.

    4 hr/day

    0.1 mg/m3 X 1.2 m3/hr X 4 hr/day X 0.5 X 250 X 40  4  70 kg
                                             365   70

    LADD =  0.0013 mg/kg/day

    8 hr/day

    LADD =  0.0026 mg/kg/day

Dermal Component

Same as in Case 7.  A above.

Total LADD = Dermal + Inhalational LADDs

4 hr/day inhalational exposure;

(0.000028 + 0.0013) mg/kg/day

     0.0013 mg/kg/day

8 hr/day inhalational exposure;

(0.000028 + 0.0026) mg/kg/day

     0.0026 mg/kg/day

-------
                               155
8.   4,4'-MDA Using/Processing Workplace;  Workplace Standard in
       Effect
     Inhalational Component
     Same general assumptions, except that exposure is at 0.001 ppm
(0.0081 mg/m3) for 8-hours.
     0.0081 mg/m3 X 1.2 m3/hr X 8 hr/day
     X 250 X 40 X 0.5 4 70kg = 0.00022 mg/kg/day LADD
       365   70
Dermal Component
Assumptions:
     o   Worker handles 4,4'-MDA for two 1-hour periods at the
         beginning of each half-shift, following which deposited
         material is immediately washed off.
     o   Deposition occurs on the palms (410 cm2) at 4.2 ug cm"2
         hr"1 (NIOSH, 1984a, Table IV, Sample DM2A); on the back
         of the hands (410 cm2) at 0.7 ug cm"2 hr"1 (NIOSH,
         1984a, Table IV, Sample DM2B).
     o   All other dermal exposure is prevented.
     Dose to palms
     Daily dose =
         2 X .01 hr"1 X 4.2 ug cm"2 hr"1 X 410 cm2 fQ tdt
                     •?  1
         34 X 1/2 X t2]  0 = 17 ug
     Dose to back of hand
     Daily dose =
         2 X .01 hr"1 X 0.7 ug cm"2 hr"1 X 410 cm2^  tdt
                      -> 1
         5.7 X 1/2 X t^] Q = 2.8 ug
     Total daily dermal dose = 20 ug = 0.020 mg

-------
                               156
     LADD = daily dose X 250 X _40 * 70 kg
                         365   70"

     =  0.00011 mg/kg/day

Total LADD » (0.00022 + 0.00011) mg/kg/day

     =  0.00033 mg/kg/day.

-------
                                              157




                                            APPENDIX C

                                            TABLE 19A
ESTIMATED EXTRA
LIFETIME RISK
OP CANCER FOR WXKERS
Extra Risk Based on Tumor Types
Exposure Setting
4,4'-MDA/MDI mfg. '
Appendix B, Sec. 1
8 hr/wk
20 hr/wk
40 hr/wk
4,4'-MDA Use/Proc'e'
Appendix B, Sec. 2
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
Appendix B, Sec. 3
Appendix B, Sec. 4
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
Appendix B, Sec. 5
Appendix B, Sec. 6
Appendix B, Sec. 7A
20 hr/wk
40 hr/wk
Appendix B, Sec. 7B
20 hr/wk
40 hr/wk
Appendix B, Sec. 8
Total IADD
nig/kg/day
0.0051
0.020
0.042
0.0011
0.0053
0.012
0.020
0.17
0.00068
0.0031
0.0094
0.020
0.0018
0.000013
0.0052
0.010
0.0013
0.0026
0.00033
MRFC(a)
MLE(C>
5 X 10"4
2 X 10~3
4 X 10"3
1 X 10~4
5 X 10"4
1 X 10"3
2 X 10"3
2 X 10~2
7 X 10~5
3 X 10~4
7 X 10~4
2 X 10"3
2 X 10~4
1 X 10~6
5 X 10~4
1 X 10~3
1 X 10~4
2 X 10~4
3 X 10~5
U95CL(d)
9 X 10~4
3 X 10~3
7 X 10"3
2 X 10"4
9 X 10"4
2 X 10"3
3 X 10~3
3 X 10~2
1 X 10'4
5 X 10~4
1 X 10"3
3 X 10~3
3 X 10~4
2 X 10~6
9 X 10~4
2 X 10~3
2 X 10~4
4 X 10~4
6 X 10"5
MRFC/A(b)
MIE
1 X 10"3
4 X 10"3
7 X 10"3
2 X 10~4
1 X 10~3
2 X 10"3
4 X 10~3
3 X 10~2
1 X 10~4
5 X 10~4
1 X 10"f
4 X 10"3
3 X 10~4
2 X 10~6
9 X 10~4
2 X 10"3
2 X 10~4
5 X 10~4
6 X 10~5
U95CL
1 X 10' 3
6 X 10"3
1 X 10~2
3 X 10"^
1 X 1C"3
3 X 10~^
6 X 10~3
5 X 10~2
2 X 10~4
9 X 10~4
2 X 10"3
6 X 10'3
5 X 10~4
4 X 10~6
1 X 10~3
3 X 10"3
4 X 10"4
7 X 10~4
9 X 10~5
•\fj Male rat, thyroid follicular-cell carcinoma
 °- Male rat, thyroid follicular-cell carcinoma and adenoma
 c' Maximum likelihood estimate
(d) upper 95% confidence limit
^e* Remaining exposures are all in use/processing category

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                                              158
                                      TABLE 19A -CONTINUED
Extra Risk Based on Tumor Types
Exposure Setting
4,4'-MDA/MDI mfg.
Appendix B, Sec. 1
8 hr/wk
20 hr/wk
40 hr/wk
4,4'-MDA Use/Proc
Appendix B, Sec. 2
2.5 hr'/wk
8 hr/wk
20 hr/wk
40 hr/wk '
Appendix B, Sec. 3
Appendix B, Sec. 4
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
Appendix B, Sec. 5
Appendix B, Sec. 6
Appendix B, Sec. 7A
20 hr/wk
40 hr/wk
' Appendix B, Sec. 7B
20 hr/wk
40 hr/wk
Appendix B, Sec. 8
Total IADD
mgAg/day
0.0051
0.020
0.042
0.0011
0.0053
0.012
0.020
0.17
0.00068
0.0031
0.0094
0.020
0.0018
0.000013
0.0052
0.010
0.0013
0.0026
0.00033
FRCC/A(f) MMAP(9)
MTE
7 X 10"4
3 X 10"3
5 X 10"3
1 X 10~4
7 X 10"4
2 X 10"3
3 X 10~3
2 X 10~2
9 X 10~J
4 X 10~4
1 X 10~3
3 X 10~3
2 X 10"4
2 X 10"6
7 X 10"4
1 X 10~3
2 X 10"4
4 X 10~4
5 X 10~5
U95CL
1 X 10~3
5 X 10"3
9 X 10~3
3 X 10~4
1 X 10~3
3 X 10~3
5 X 10"3
4 X 10"2
2 X 10~4
7 X 10~4
2 X 10"3
5 X 10~3
4 X 10~4
3 X 10~6
1 X 10~3
2 X 10"3
3 X 10"4
6 X 10~4
8 X 10~5 '
MIE
9 X 10~4
3 X 10~3
7 X 10~3
2 X 10~4
9 X 10~4
2 X 10~3
3 X 10~3
3 X 10"2
1 X 10~4
5 X 10~4
1 X 10~3
3 X 10~3
3 X 10~3
2 X 10~6
9 X 10~4
2 X 10"3
2 X 10"3
5 X 10~3
6 X 10~5
U95CL
1 X 10"3
5 X 10" 3
1 X ICT2
3 X 10~4
1 X 10~3
3 X 10~3
5 X 10"3
4 X 10"2
2 X 10"4
8 X 10"4
2 X 10~3
5 X 10"3
5 X 10"3
3 X 10~6
1 X 10~3
3 X 10"3
3 X 10~3
7 X 10~3
8 X 10~5
•  |  Female rat,  thyroid C-cell carcinoma and  adenoma
(9)  Male mouse,  adrenal pheochromocytoma

-------
                                              159
                                      TABIE 19A -OONFINDH)
Extra Risk Based on Tumor Types
Exposure Setting
4,4'-MDA/MDA Mfg.
Appendix B, Sec. 1
8 hr/wk
20 hr/wk
40 hr/wk
4f4'-MDA Use/£roc.
Appendix B, Sec. 2
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
Appendix B, Sec. 3
Appendix B, Sec. 4
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
Appendix B, Sec. 5
Appendix B, Sec. 6
Appendix B, Sec. 7A
20 hr/wk
40 hr/wk
Appendix B, Sec. 7B
20 hr/wk
40 hr/wk
Appendix B, Sec. 8
Total IADD
mgAg/day

0.0051
. 0.020
0.042 .

0.0011
0.0053
0.012
0.020
0.17

0.00068
0.0031
0.0094
0.020
0.0018
0.000013
0.0052
0.010
0.0013
0.0026
0.00033
FMABC/A^ FMIHC^
MIE

3 X 10~4
2 X 10~3
2 X 10"3

6 X 10~f
3 X 10~4
7 X 10~4
1 X 10~3
1 X 10~2

4 X 10~5
2 X 10"4
4 X 10~4
1 X 10~3
1 X 10"4
8 X 10"7
3 X 10'4
6 X 10"4
8 X 10~;>
1 X 10~4
2 X 10~5
U95CL

6 X 10'4
2 X 10"3
4 X 10"3

1 X 10"4
6 X 10~4
1 X 10~3
2 X 10~3
2 X 10~2

7 X 10~5
3 X 10~4
8 X 10~4
2 X 10~3
2 X 10"4
1 X 10"6
6 X 10~4
1 X 10~3
1 X 10~4
3 X 10"4
4 X 10~5
MIE

6 X 10"4
2 X 10"3
5 X 10~3

1 X 10~4
6 X 10"4
1 X 10"3
2 X 10"3
2 X 10~2

8 X 10~5
4 X 10"4
8 X 10~4
2 X 10"3
2 X 10~4
1 X 10"6
6 X 10"4
1 X 10~3
1 X 10"4
3 X 10"4
4 X 10"5
U95CL

9 X 1CT4
3 X 10"3
7 X 10~3

2 X 10"4
9 X 10"4
2 X 10"3
3 X 10" 3
3 X 10~2

1 X 10"4
5 X 10"4
1 X 10"3
3 X 10"3
3 X 10"4
2 X 10"6
9 X 10~4
2 X 10~3
2 X 10"4
. 5 X 10~4
6 X 10~5
•.'  Female mouse,  alveolar-bronchiolar carcinoma and adenoma
'^  Female mouse,  liver hepatocellular carcinoma

-------
                                          160
                                   TABIE 19A -OUNL'INUED
Extra Risk Based on Tumor Types
Exposure Setting
4,4'-MDA/MDA Mfg.
Appendix B, Sec. 1
8 hr/wk
20 hr/wk
40 hr/wk
4,4'-MDA Use/E>roc.
Appendix B, Sec. 2
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
Appendix B, Sec. 3
Appendix B, Sec. 4
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
Appendix B, Sec. 5
Appendix B, Sec. 6
Appendix B, Sec. 7A
20 hr/wk
40 hr/wk
Appendix B, Sec. 7B
20 hr/wk
40 hr/wk
Appendix 3, Sec. 8
Total IADD
nig/kg/day
0.0051
0.020
0.042
0.0011
0.0053
0.012
0.020
0.17
0.00068
0.0031
0.0094
0.020
0.0018
0.000013
0.0052
0.010
0.0013
0.0026
0.00033
FMIHC/A^ J ^ MRPA^ k)
MI£
1 X 10"3
5 X 10"3
1 X 10"2
3 X 10"4
1 X 10~3
3 X 10"3
5 X 10"3
5 X 10~2
2 X 10"4
8 X 10~*
2 X 10~3
5 X 10~3
5 X 10~4
4 X 10"6
1 X 10"3
3 X 10~3
4 X 10"4
7 X 10~4
9 X 10~5
095CL
2 X 10"3
8 X 10~3
1 X 10~2
4 X 10"4
2 X 10~3
5 X 10~3
8 X 10~3
6 X 10~2
3 X 10"4
1 X 10^
3 X 10 3
8 X 10"3
7 X 10~4
5 X 10~6
2 X 10~3
4 X 10~3
5 X 10~4
1 X 10"3
1 X 10~4
MCE
9 X 10~4
4 X 10~3
7 X 10~3
2 X 10"4
9 X 10~4
2 X 10"3
4 X 10~3
3 X 10~2
1 X 10~4
6 X ID-*
1 X 10 3
4 X 10"3
3 X 10"4
2 X 10~6
9 X 10"4
2 X 10~3
2 X 10"4
5 X 10~4
6 X 10~5
U95CL
1 X 10"3
6 X 10"3
1 X 10~2
3 X 10"4
1 X 10"3
3 X 10~3
6 X 10"J
5 X 10°2
2 X 10~4
9 X 10~4
2 X 10"3
6 X 10"3
5 X 10"4
4 X 10'4
1 X 10"3
3 X 10~3
4 X 10~4
7 X 10"4
9 X 10~5
Female mouse, liver hepatocellular carcinoma and adenoma
Male rat, pooled all statistically significant tumors

-------
                                              161
                                      TABIE ISA -CDNTINDBD
Extra Risk Based on Tumor Types
Exposure Setting
4,4'-MDA/MDA Mfg.
Appendix B, Sec. 1
8 hr/wk
20 hr/wk
40 hr/wk
4,4'-MDA Use/t>roc.
Appendix B, Sec. 2
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
Appendix B, Sec. 3
Appendix B, Sec. 4
2.5 hr/wk
8 hr/wk
20 hr/wk
40 hr/wk
Appendix B, Sec. 5
Appendix B, Sec. 6
Appendix B, Sec. 7A
20 hr/wk
40 hr/wk
Appendix B, Sec. 7B
20 hr/wk
40 hr/wk
Appendix B, Sec. 8
Total LADD
mg/kg/day
0.0051
0.020
0.042
0.0011
0.0053
0.012
0.020
0.17
0.00068
0.0031
0.0094
0.020
0.0018
0.000013
0.0052
0.010
0.0013
0.0026
0.00033
FRPA(1)
MLE
3 X 10~3
1 X 10~2
2 X 10"2
6 X 10"4
3 X 10~3
7 X 10~3
1 X 10~2
9 X 10"2
4 X 10"4
2 X 10"3
4 X 10~3
1 X 10"2
1 X 10~3
7 X 10~6
3 X 10~3
5 X 10~3
7 X 10"4
1 X 10~3
2 X 10~4
U95CL
4 X 10~3
1 X 10~2
3 X 10~2
8 X 10"4
4 X 10~3
9 X 10~3
1 X 10"2
1 X 10'1
5 X 10"4
2 X 10~3
5 X 10"3
1 X 10~2
2 X 10~3
9 X 10"6
4 X IQ-f
7 X10"3
9 X 10"4
2 X 10"3
2 X 10~4
MRPM(ra)
MLE
9 X 10"4
4 X 10~3
7 X 10~3
2 X 10"4
9 X 10~4
2 X 10"3
4 X 10"3
3 X 10~2
1 X 10~4
5 X 10~4
1 X 10"3
4 X 10"3
3 X 10"4
2 X 10"6
9 X 10~4
2 X 10"3
2 X 10~4
5 X 10~4
6 X 10"5
U95CL
1 X 10"3
6 X 10"3
1 X 10~2
3 X 10"4
1 X 10"3
3 X 10~3
6 X 10"3
5 X 10"2
2 X 10~4
9 X 10~4
2 X 10"3
6 X 10"3
5 X 10"4
4 X 10~6
1 X 10"3
3 X 10"J
4 X 10~4
7 X 10"4
9 X 10"5
(1)
(m)
Female rat, pooled all statistically significant tumors
Male rat, pooled all tumors for which malignancies, alone, are statistically significant

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                                          162
                                        TABLE 20A

                         Estimated Extra Lifetime Risk of Cancer
Fran Drinking Water
Locale
A
B
C
B + C
D
4,4'-MDA Cone. LAED
mg/1 mgAg/day
0.00018
0.00015
O.OOC15
0.00030
0.0012
0.0000026
0.0000021
0.0000021
0.0000042
0.000017

Extra Risk
MRFC(a)
MI£(c)
2 X 10"7
2 X 10~7
2 X 10"7
4 X 10"7
2 X 10"6
U95CL(d)
4 X 10'7
4 X 10~7
4 X 10~7
7 X 10~7
3 X 10~6
Based on Tumors
MRFC/A(b)
MIE
5 X 10"7
4 X 10~7
4 X 10"7
7 X 10~7
3 X 10"6
U95CL
7 X 10"7
6 X 10~7
6 X 10~7
1 X 10~6
5 X 10~6
Male rat, thyroid follicular-cell carcinoma
Male rat, thyroid follicular-cell carcinoma and adenoma
Maximum likelihood estimate
Upper 95% confidence limit

-------
                                          163
                                  TABIE 20A - QONTINDED
Extra Risk Based an Tumors
Locale
A
B
C
B + C
D
4,4'-MDA Cone. IADD
mg/1 mg/kg/day
0.00018
0.00015
0.00015
0.00030
0.0012
0.0000026
0.0000021
0.0000021
0.0000042
0.000017
FRCC/A(e)
MIE
4 X 10~7
3 X 10~7
3 X 10~7
6 X 10~7
2 X 10~6
U95CL
6 X 10"7
5 X 10~7
5 X 10~7
1 X 10"6
4 X 10~6
I1MAP(f)
MLE
5 X 10~7
4 X 10"7
4 X 10~7
7 X 10"7
3 X 10~6
U95CL
7 X 10"7
5 X 10~7
5 X 10~7
1 X 10~6
4 X 10~6
Female rat, thyroid C-cell carcinoma and adenoma
Male mouse, adrenal pheochromocytoma

-------
                                           164
                                  TABIE 20A - ODNl'lNUtl)
Extra Risk Based on Tumors
locale
A
B
C
B + C
D
4,4'-MDA Cone. LACD
mg/1 mgA9/day
0.00018
0.00015
0.00015
0.00030
0.0012
0.0000026
0.0000021
0.0000021
0.0000042
0.000017
FMABC/A(9)
MIE
1 X 10"7
1 X 10~7
1 X 10"7
2 X 10~7
1 X 10~6
U95CL
3 X 10~7
2 X 10~7
2 X 10"7
4 X 10"7
2 X 10~6
FMIflC(h)
MIE
3 X 10~7
2 X 10"7
2 X 10~7
5 X 10~7
2 X 10~6
U95CL
5 X 10"7
4 X 10"7
4 X 10~7
7 X 10"7
3 X 10~6
Female mouse, alveolar-bronchiolar carcinonia and adenoma
Female mouse, liver hepatocellular carcinoma

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                                              165
                                      TABIE 20A - ODKTINDED
Extra Risk Based on Tumors
Locale
A
B
C
B + C
D
4,4'-MDA Cone. IADD
mg/1 mgAg/day
0.00018
0.00015
0.00015
0.00030
0.0012
0.0000026
0.0000021
0.0000021 •
0.0000042
0.000017
FMLHC/A(i) MPPA^
MZ£
7 X 10~7
6 X 10~7
6 X 10"7
1 X 10"6
5 X 10~6
U95CL
1 X 10~6
8 X 10"7
8 X 10~7
2 X 10"6
6 X 10"6
MLE
5 X 10~7
4 X 10"7
4 X 10~7
7 X 10'7
3 X 10~6
U95CL
7 X 10"7
6 X 10~7
6 X 10~7
1 X 10~6
5 X 10"6
(i)
 .•  Female nojjse,  liver hepatocellular carcinona and adenoma
    Male rat,  pooled all statistically significant tumors

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                                          166
                                  TABIE 20A - OJNT1NUU)
Extra Risk. Based on Tumors
Locale
A
B
C
B + C
D
4,4'-MDA Cone.
- rag/l
0.00018
0.00015
0.00015
0.00030
0.0012
LADD
mgAg/day
0.0000026
0.0000021
0.0000021 '
0.0000042
0.000017
FEPA
MIE
1 X 10"6
1 X 10"6
1 X 10"6
2 X 10~6
9 X 10~6
(k)
U95CL
2 X 10"6
1 X 10~6
1 X 10~6
3 X 10~6
1 X 10"5
MEE
MLE
5 X 10~7
.4 X 10"7
4 X 10""7
7 X 10~7
3 X 10"6
,M(D
U95CL
7 X 10"7
6 X 10"7
6 X 10"7
1 X 10~6
5 X 10~6
Female rat, pooled all statistically significant tumors
Male rat, pooled all tumors for which malignancies, alone, are
significant

-------
                               167
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