645R72002
         Health Intelligence
                 for
 Fuel  and Fuel Additive Registrations
      An EPA Task Force Report
  Division of Health Effects Research
National Environmental Research  Center
  Research Triangle Park, N.C. 27711

           March 15, 1972

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I.  INTRODUCTION


     This task force report resulted from meetings initiated by the
Division of Health Effects Research and held at Research Triangle Park
on February 29, March 1  & 2, 1972.  The purpose of the task force was
to develop a systematic plan to provide health intelligence required
under Section 211 ("Regulation of Fuels") of the Clean Air Act of 1970,
as amended.  Section 211 gives EPA authority to require the conduct of
tests "to determine potential public health effects" of fuels or fuel
additives designated for registration and to control or prohibit use
of fuels or additives when emission products "will endanger the public
health or welfare".  Through this report, the task force has suggested
a program to carry out the above responsibilities.

     The members of the task force were as follows:
              Office of Fuel and Fuel
                Additive Registrations

              Division of Chemistry and
                Physics

              Division of Health Effects
                Research
Henry Miller


John Moran
John Finklea (Chairman)
Ferris Benson
Kenneth Bridbord
Kirby Campbell
David Coffin
Anthony Colucci
Marvin Hertz
Wellington Moore
Carl Shy
Wayne Sovocool

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II.  RECOMMENDATIONS

     1.  The Task Force concerned with providing health intelligence for the
     Office of Fuels and Fuel  Additive Registrations (OFFAR)  recommends  that
     a multidisciplinary committee be formed, composed of personnel  from the
     Office of Fuel and Fuel Registration, a combustion chemist, an  analytical
     chemist, a biochemist, a toxicologist, an ecologist, a physician and
     others as deemed appropriate.  The committee will be concerned  with the
     systematic assessment of possible hazards to public health and  welfare
     from fuels and fuel additives submitted for registration.

     2.  Industry should be responsible for conducting all tests required tp_
     characterize exhaust emissions resulting from use of registered fuels or
     additives.

     3.  Standard protocols to assess biological effects of exhaust  emissions
     resulting from use of registered fuels and fuel additives  should be
     developed and tested during FY 73.

     4.  An additive causing significant changes in vehicular emission patterns
     or having toxic potential in its emission products should  be subjected to
     an initial toxicologic (including phytotoxic) screen.  Development of the
     toxicologic screen should receive high priority early in FY 73.

     5.  A full toxicological  evaluation should be selectively  required for
     those additives whose initial screening suggests further investigation.

     6.  Results of toxicological screening and more definitive animal toxico-
     logical studies should be selectively evaluated through clinical and epide-
     mic! ogical human studies.

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7.  New legislative authority should be sought authorizing OFFAR to
obtain quantitative fuel and fuel  additive production information and
usage data from manufacturers.

8.  Disclosure of information acquired by industry from toxicologic
testing or occupational exposures  during the course of manufacture and
distribution of fuels and fuel additives should be required.   This dis-
closure could be required through  a change in existing regulations
authorized under Section 211 of the Clean Air Act.

9.  A tax of 1/100 cents per gallon on retail sales of fuels  is recom-
mended to cover the cost of all toxicological testing.  This  tax would
generate $13,000,000 per year and  would provide support to the entire
fuel and fuel additive registrations program.  All toxicological testing
should be carried out under EPA, rather than industry, supervision.

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III.  NATIONAL SIGNIFICANCE

     The 107 million motor vehicles presently registered in the United States
will consume about 130 billion gallons of fuel  per year.  Gross retail sales
of this volume of motor vehicle fuel amounts to $48 billion annually.   Currently,
300 gasoline fuel additives have been registered with the Office of Fuel  and
Fuel Additive Registration.  In 1969, 870 million pounds of additives  were con-
sumed at a gross value of $280 million.  Under proposed new regulations requiring
registration of gasoline, diesel fuel, fuel and heating oils, aviation fuels,
crank case lubricants, liquified petroleum gas and additives, a total  of 1000
to 1500 additives are likely to be registered.   Seventy-seven million  tons of
motor vehicle pollutants are emitted annually in the United States. This pol-
lutant mix can be generally characterized as follows:
                                                 Emission Rate
                   Chemical Class                 (tons/year)
              Combustible particulates*              380,000
              Carbon monoxide                     55,000,000
              Hydrocarbons                        13,600,000
              Polynuclear aromatics                      480
              Nitrogen oxides                      7,600,000
              Lead                                   230,000
              Sulfur oxides                          280,000
                                        Total     77,090,480
             *Includes trace elements
     The Environmental Protection Agency has received a mandate from Congress,
expressed in Section 211 of the Clean Air Act of 1970 as amended, to control or
prohibit the manufacture or sale of any fuel or fuel additive when emission pro-
ducts will endanger the public health or welfare or will impair the performance
of any emission control device (Section 211, c.l.).  Under this Section of the
Act, EPA may by regulation require registration of any fuel or fuel additive

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prior to sale or introduction into commerce.  Registration requires information
on the chemical composition and range of concentration of any additive in fuel.
EPA may also require from manufacturers information "as is reasonable and
necessary to determine the emissions resulting from use of fuels and additives"
and "the extent to which such emissions affect the public health or welfare"
(Section 211, b.2.B.).
     The authority and mandate delegated under Section 211 require EPA to evalu-
ate the potential public health effects of registered fuels and fuel additives.
The following problems were identified and considered by the Task Force in
planning to meet this challenge:
     1.  At present, no EPA person or committee systematically scrutinizes
     each registered fuel additive for potential  public health effects.
     2.  EPA lacks a systematic program to evaluate the toxicologic
     potential of registered fuels and additives.
     3.  Prime concern -should not be focused on toxicity of parent com-
     pounds registered by the Office of Fuel and Fuel Additive Regis-
     tration.  The chemical composition of these compounds will undergo
     drastic changes in the course of combustion and passage through
     advanced emission control systems.  The public will be primarily
     exposed to these combustion products rather than to parent compounds.
     At present, the manufacturer supplies no information on exhaust
     products.
     4.  However, occupational exposures to parent compounds do occur
     as a result of evaporative losses during manufacture and handling
     of fuels and additives.  In many cases, manufacturers have large,
     excellent occupational health and safety programs, through which

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human exposure data are acquired.  This information is  often  pro-
prietary and is not made available to the Government.   Protection
of the health of fuel and additive handlers, including  service  station
operators and to a lesser extent the general public, could  be con-
siderably furthered by requiring transmission of existing occupational
health data to the Government.  This effort could be coordinated
through the National Institute of Occupational  Safety and Health, DHEW.
5.  The following compounds have been identified in motor vehicle
exhausts:

TABLE.  Compounds Identified in Motor Vehicle Exhausts
 I.  Particulate Emissions
     A.  Lead and Organics             B.  Other Trace  Elements Emitted
                                           in Exhaust Particulates*~
         Pb (Cl, Br)2                                          ~
         Pb (NH3)2 & Pb NH3 Cl                  Fe         Mg
         PbO-Pb (Cl, Br)2                       Ni         Mn
         PbO-Pb $04                             Cu         Cr
         Pb Cl2                                 Al         Sn
         Pb Br2                                 Ca         Zn
         Organics (PNA's, etc.)                 Si         Ti
         HC1                                    Sb         Mo
         Fe2 03
         Fe3 04
         NH4 Cl
II.  Gaseous Emissions (based on 23 minute test cycle)
         PNA (polynuclear aromatics)
         NO
         N02
         CO
         CO 2
         200 Hydrocarbons
         Aldehydes and Oxygenates

*List is not exhaustive; other trace elements are being identified.

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Emission controls on 1975 and 1976 vehicles should reduce hydro-
carbon and polynuclear aromatic emissions by a factor of 100 from
1966 levels.  These hydrocarbons are likely to be broken down almost
completely to C02 and h^O.  Advanced catalytic control  systems employing
reducing catalytic reactors are likely to achieve substantial  re-
duction of nitrogenous compounds but may result in emissions of
ammonia and organic nitrogen compounds.  In addition, trace metals
in fuels and additives and in deterioration products of catalytic
controls will be emitted.  The Task Force agreed that the following
pollutants, likely to occur in emission of fuels combusted through
catalytic reactors, have significant toxic potential:
             a.  Trace metals
             b.  Ammonia and other nitrogenous compounds
             c.  Organic particulates and gases
                 (at 1/100 of 1966 levels)
Of most immediate concern are trace metals in blended or raw motor
vehicle fuels, and known to be present in exhaust particulates. The
Task Force agreed that these trace metals could be ranked from highest
to lowest in terms of potential public health hazard and exposure
levels as follows:
                                       Relative Concentration
         Element                     (% of particulate  fraction)
       1.  Manganese                            0.10
       2.  Nickel                               0.02
       3.  Cobalt                               0.02
       4.  Chromium                             0.05
       5.  Tin                                  0.02
       6.  Antimony                             trace
       7.  Molybdenum                           0.01
       8.  Titanium                             0.02

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These elements possess the potential for accumulating in human
tissues and producing definite systemic toxicity at elevated
tissue levels.  Other trace elements of low toxic potential  in
fuels and exhaust particulates include iron, calcium, zinc,
silicon, copper and aluminum.  Cadmium is reported at trace
amounts in some fuels, but this finding is disputed.  Barium,
lithium and boron are fuel additives which are not known to  be
in raw fuels.  Of these three elements, barium has the highest
toxic potential.  In general, systematic studies of these trace
elements have not been conducted, and EPA is not in a position
to take regulatory action based on health intelligence.
6.  The Task Force recognized the need to acquire emission pro-
files, chemically characterized, of particulates and gases re-
sulting from combustion of fuels and their passage through
advanced emission control systems.  Profiles must be acquired
for reference gasolines to serve as a comparison for changes
caused by use of registered fuel additives.  The Task Force
further recognized that these emission profiles would demon-
strate a complex array of chemical constituents.  The array
could change markedly with irradiation or with blending  of
each new fuel additive.  Evaluation of the toxicity of indi-
vidual constituents would be a costly and tedious task,  whereas
the toxicity of the complex whole is the single important con-
sideration.  Therefore, as a first step, a system is needed  to
evaluate comparative toxicologies of reference fuels against
fuels with specific additives at concentrations approximating
anticipated ambient exposures.
                                 8

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7.  An inexpensive rapid toxicologic screening system is needed
to obtain information on potential toxicity of exhaust particulate
profiles for which little or no biological effects data exists.
This screening system must employ standardized protocols using
proven toxicologic methods.  Methods to provide exhaust particu-
lates for these tests are also required.
8.  Depending on the results of toxicologic screening, more
definite toxicological studies of exhaust particulates resulting
from use of fuel additives should be selectively applied.  Protocols
for these evaluations are required and must be standardized as soon
as possible in fiscal year 1973.
9.  Trace elements of significant toxic potential  in fuels and
additives should be evaluated in elemental or simple form by
inhalation exposures of whole animals.  These substances will  pass
through advanced emission control systems; hence,  their presence
in fuel additives requires assessment both in isolated form and
within the particulate exhaust complex.
10.  The Task Force recognized that fuel additive  composition may
affect emission rates of carbon monoxide, nitrogen oxides and
precursors of photochemical oxidants.  The health  effects of these
compounds are presently under intensive study within the Division
of Health Effects Research.

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iv.  MEETING: THE CHALLENGE

     Registration and testing procedures must minimize the risk of adverse
human health effects that can reasonably be attributed to differences  in  fuels
or fuel additives.  Such effects may be linked to individual  additive  components,
complete additives, blended fuels or gaseous and particulate  emissions .from
mobile and stationary sources.  Effects of concern include, but are not limited
to an increased risk of cancer and mutations, impaired reproductive performance,
increased susceptibility to respiratory infection, increased  human pollutant
burdens and subtle changes in cellular morphology and enzymatic function.  A
schematic overview of the public health impact of fuels and fuel  additives  may
be visualized in Figure 1.  The effect of individual  additive components  may
be evaluated by reviewing industrial toxicologic screening data compiled  during
research and development for new products.  Routine occupational  health studies
and specialized surveillance of industrial exposures  can be utilized to evaluate
the hazards associated with the direct exposure to complete additives  and to
blended fuels.  Such exposures occur during additive and fuel manufacturing,
during distribution and, to a lesser extent, during consumption.   However,  the
primary concern of the Task Force was the impact of differences in fuel and fuel
additives upon gaseous and particulate emissions which can affect the  general
population, segments of which may be especially susceptible.   As previously
discussed, necessary research on the direct effects of carbon monoxide, oxides
of nitrogen and particulates per se have been considered by the Health Planning
Task Force and in other program elements.  On the other hand, our Agency  has
devoted limited resources to research on the health effects of gaseous and  parti-
culate organic compounds, trace elements, ammonia, and other  nitrogenous  compounds,
These are the pollutants that may be qualitatively and quantitatively  altered by
differences in fuels or fuel additives.
                                      10

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                                                 Figure 1
                       Overview of Public Health Impact of Fuels and Fuel  Additives
Factor Considered
                      Production and Consumption Stages
Fuel or Fuel Additive
Component
Emissions of
Concern
Research
and
Development
Additive
Components

	 »
Manufacturing
Additive or
Blended Fuel

1
Distribution
and
Vending

	 : 	 ^
Evaporative Losses
of Blended Fuel
Consumption
Gaseous and
Parti cul ate
                                                                                                 Emissions
                                                                                                 from Mobile
                                                                                                 and Stationary
                                                                                                 Sources
Human Exposures
Workers
Workers
Workers
General
 Population
Health Intelligence
 Research Approaches
Industrial
 Toxicology

Occupational
 Health
Occupational
 Health
Occupational
 Health

Special
 Toxicology
Toxicology


Epidemiology

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     A systematic effort is required to evaluate the public health risks
which may result from emission changes and to assure human safety through the
registration mechanism.  Such a system is schematically presented in Figure 2.
Registration applications containing relevant industrial  toxicology and occu-
pational health summaries would be received by the Office of Fuels and Fuel
Additive Registration (OFFAR).  These would then be screened by a Review  Com-
mittee composed of a representative from OFFAR, an ecologist, a toxicologist,
a biochemist, a representative of the Office of Research and Monitoring,  a
representative of the Office of Air Programs, and others as deemed appropriate.
The OFFAR Review Committee would consider each fuel and fuel additive registration
and registration application.  Some fuel additives or specific,fuels would be
selected for testing on the basis of widespread usage, predicted survival of a
potentially toxic substance, predicted effects upon gaseous and particulate
emissions, impact on pollution control devices, alteration of atmospheric
reactivity and visibility, and postulated public health and welfare hazards
including damage to plants and wildlife.
     In general, the Committee would first require characterization of emissions
according to standard protocols now being developed by the Division of Chemistry
and Physics of the Research Triangle Park National Environmental Research Center.
The results of this testing would be evaluated by the Review Committee and toxi-
cologic screening would be requested when indicated by significant qualitative  or
quantitative changes in emissions of gaseous hydrocarbons, trace elements, organic
particulates, ammonia or other nitrogenous compounds.  Should toxicologic screening
tests be positive, more definitive investigations could be instituted including
further toxicologic testing, special studies of occupational groups, appropriate
exposure of human volunteers and epidemiologic studies of populations representing
an exposure gradient for the pollutants in question.  The results of these tests
                                     12

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                        Figure 2
             Assessment of Public Health Impact
                 of Fuels and Fuel Additives
Registration /
Application /
                                          Environmental
                                          Information
                                          System
                        Registration
       Register
       without
       Testing
                            OFFAR
                           Review
                     -~s\  Commi ttee
                     / i	.—
                                   Review
                                   Report
        Use
     Restricted
          or
                                    Emissions
                                    Characterization

                                         T
Register
  with
Testing
     , Prohibited.-
                                                    Toxicology
                                                    Screening
                                 Definitive
                                 Toxicology
                                      Clinical
                                      Studies
                                    I , :Epidemiclogic
                                    I    Studies

                                   J	F	
 *0fftce of Fuel and Fuel Additive Registrations
**Phytotoxtc screening could most easily be performed concurrent with
  emissions characterization
                                 13

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would be reported to the Review Committee which would make recommendations  on
the use of a particular fuel additive or fuel.  On occasion the Review Committee
might simultaneously initiate tests involving emissions characterization,  toxi-
cologic screening and even more definitive toxicologic and human studies.   The
Review Committee would utilize inputs from an environmental information system
and submit reports to such a system.
     A more detailed overview of the proposed toxicologic screening system, shown
in Figure 3, reveals four levels of complexity.  A rough index of toxicity  will
first be established by comparing the response of tissue culture cell  lines ex-
posed to suspended particulate matter collected from reference fuels and similar
fractions collected during emissions characterization testing.  Both morphologic
and biochemical endpoints would be utilized.  When such screens indicate signi-
ficant increase in toxicity, or when the Review Committee deems appropriate,
more specific screening at two levels of complexity may be initiated with endpoints
involving susceptibility to infection, carcinogenesis, mutagenesis, and reproductive
                                                          \
efficiency.  In vitro enzymology profiles would then be obtained on those materials
which had caused significant adverse effects.  Enzymology profiles will help
elucidate mechanisms of action and will provide crosswalks to relate more definitive
toxicologic testing and human studies to the toxicologic screening tests.
     Toxicologic testing of appropriate compounds of trace elements would involve
the steps shown in Figure 4.  Trace element aerosols of interest would be generated
by the same propane-combustion system that is currently utilized in human exposure
studies of lead.  One or more species of animals would be exposed.  Routine tests
would involve metabolism and tissue burdens, biochemical and pathological  changes,
and assessment of physiologic function.  Special toxicologic testing would  also
be instituted where appropriate.  Definitive toxicologic testing of the carcinogenic,
                                     14

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                              Figure 3.

             Toxicologic Screening of Fuels and Fuel Additives
      Emissions
/  Characterization /
                       Request from    •
                       OFFAR  Review   f
                       Commi ttee      /
                                              7
                                                     /  Environmental
                                                        Information
                              Toxicology
                              Screening
                              Report
                              Toxicologic
                              Screening
       Toxicity to
       Pulmonary
       Alveolar
       Macrophages
                                                               Carcinogenesis
                                                               in Newborn
                                                               Mice
                                Mutagenesis  i
                                         Screen
                                        Positive
 Screen
Positiv
                                                                         Intratracheal
                                                                         Test in
                              Dominant
                              Lethal  Test
                              in Mice
Animal
Infectivity
Studies
 Negative
\Screen
Negative
 Screen
                                                          Negative
                                                           Screen,
         Screen
        os i ti ve
                                                                  Screen
                                                                 crsitive
                                      \Positive
                       In Vitro Enzymology Screen
                          Toxicology Screening
                                 Report
                                    15

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      FIGURE 4.  Definitive Toxlcologic Testing of Trace Elements Found
                 in Fuels and Fuel Additives
                  OFFAR
             Review Committee
         I  Definitive

         >\  Toxicology

         i   Testing
    ;  Toxicology

  ----j  Screening

    j   Report
       Chemical  and  Physical

         Characterization
          of  Emissions
       :   Generation and   j
     	.'  Animal Exposures  j
         of Trace Element  |
             Aerosols      !
   Metabolism
      and
I Tissue Burdens
]    Studies
i
j
!     Uptake
  Distribution
i   Excretion
iBiotransformation
   Routine
 Biochemical
     and
Pathological
    Tests
 Assessment
Physiological
  Function

  Cardiac,
Respiratory,
   Renal,
 Neurologic
Reproductive
Hematopoietic
    Special
     Tests


 Dependent on
Compounds under
     Study

                                       Toxicology

                                          Test

                                         Report
                                        16

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mutagenic and teratogenic hazards associated with specific organic fractions or
compounds could be requested from the National Center for Toxicologic Research
or performed by other EPA toxicology groups utilizing protocols recommended by
the National Academy of Sciences.
     Epidemiologic studies, investigations involving accidental or occupational
exposures and controlled exposures of human volunteers would be most appropriate
when evaluating the potential hazards attributable to toxic trace metals and
hazards associated with evaporative losses or occupational exposures.
     Task statements found in the Appendix detail the necessary steps and
resources for the described OFFAR activities to meet the scientific challenge
of fuel and fuel additives.
                                      17

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V.  BUDGET IMPACT

     At present only $225,000 is budgeted from the Fuel  and Fuel  Additive
Registration program element for health effects research.   Two  other component
tasks of the proposed system, Effect on Emission Products (Task 2) and Determi-
nation of Fuel and Fuel Additive Usage Patterns, (Task 3), are scheduled to re-
ceive $885,000 from the same program element.   Another system component,
Toxicologic Testing of Trace Elements (Task 7} will receive limited support
from the Biomedical Research program element.
     The present budget will allow design and  testing of one fuel  additive  in
part of the proposed toxicologic screen.   The  present budget will  not support
establishment of a biochemical  effects screen  or any human studies.   A minimally
adequate budget for health effects studies of  fuels and fuel additives would
total $1,115,000 and an optimal  budget would amount to $2,925,000.  At the
minimally adequate level, the toxicologic and  biochemical  screening  systems
would be established in FY 73 and 10 fuel additives would be screened.  At  the
optimal level, 20 fuel  additives would be screened and needed human  studies of
trace elements completed.
     The man-years of effort and dollar resources required to support the
health intelligence program at three levels of funding are given in  the
following Table.  Specific objectives, milestone dates and number of additives
tested are listed in the tast statements of the Appendix.
                                     18

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                               Table
      Task Description


1.  Review Committee
2.  Effect on Emissions
3.  Usage Patterns
4.  Collect Exhaust Participates
5.  Toxicologic Screening System
6.  Biochemical Screening System
7.  Trace Element Toxicology
8.  Controlled Human Exposures
9.  Epidemiclogic Studies
                           Total
                    (Intramural)
                    (Extramural)
  Dollars  ($1000)/Man-Years of Effort  (MY)

 Present    Minimally Adequate     Optimal
  25/1               60/3            240/7
   —Non-health,  considered elsewhere—
   —Non-health,  considered elsewhere—
  None               45/2.0           45/2
 200/4.1            610/6.5         1260/11
  None              250/5            750/10
  —Biomedical  Research Program  Element—
  None              100/1.7          430/6.7
  None               50/0.2       .   200/0.4
 225/5.1
(135/5.1)
(110/0)
1115/18.4
(394/18.4)
(721/0)
2925/37.1
(863/37.1)
(2062/0)
                                     19

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VI.  POTENTIAL PROBLEMS

     The proposed system for evaluating the health risks of specific fuels
and fuel additives represents the most practical, presently feasible approach,
but it is still beset by a number of perplexing problems.  These belong  to  three
broad groupings:  scope of the system, relevancy of the biological  test  pro-
cedures and economics of testing.
     The scope of the proposed system will not initially include lubricating
oils, aviation fuels, diesel oil, kerosene and fuel oils or their additives
even though these products are also subject to the registration procedure.
Separate but analogous emissions characterization systems must be established
to evaluate these products.  The biological testing systems proposed by  the
Task Force would, however, be applicable to such products.  An unanswered,  but
important problem, is the relative health risk resulting from trace element and
organic particulate emissions from fuels and fuel additives when compared to
coal-fueled stationary sources not subject to registration.  Will expensive
motor vehicle fuel controls be acceptable if quantitatively more important  sta-
tionary sources are not controlled?  Another problem with the proposed system
is the use of test methods, based upon a single additive and a standard  reference
fuel.  In practice, more than one additive might be present in any single
marketed fuel blend and any single additive could be utilized with a number of
different fuels.  The picture is even further complicated by seasonal shifts  in
fuel composition, by seasonal shifts in additive use and by frequent variations
in the crude oil precursors of a single market fuel.  A third problem with  the
proposed emissions test system relates to the use of standard, carefully maintained
combustion and exhaust control systems coupled to artifical irradiation  chambers.
                                      20

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Significant variations from this system would certainly be found if studies
focused upon operating vehicles.  The Task Force recognized the need to
quantitate these sources of variation, but held firm in its conviction  that
the proposed emissions and biological test systems should be developed  as
soon as possible and modified as needed later.
     Many questions can be raised about the relevancy of the proposed biological
test systems.  First, there are questions regarding pollutant exposure.   Should
test systems not be exposed simultaneously to gaseous and particulate emissions?
The Task Force felt that such interaction studies might be desirable, but were
not feasible for toxicologic screening.  We could not justify at this time the
substantial additional investment in facilities and personnel or the increase
in logistical complexity that would result.  Should test systems not utilize
single compound exposures instead of the complex particulate mixture or trace
element exposures now planned?  Again the Task Force felt that the very large
number of organic compounds precluded the single compound approach in the
screening process.  Should potential exposures from partially combusted fuel
additives and evaporative losses receive greater emphasis?  The Task Force
thought not in view of rapid changes in evaporative and exhaust controls and
the elapsed time which will occur before testing systems can become functional.
     The relevance of the toxicologic screening tests can also be questioned.
Effects on cell cultures, increased susceptibility to respiratory infection,
mutagenesis, carcinogenesis, impaired enzymatic function and trace element
toxicity are the most significant, but not the only adverse health effects of
fuels and fuel additives.  Other health indicators could be added if experience
indicates additional significant health risks or if additional resources become
available.  Tfie proposed screening tests provide feasible indices of suspicion,
                                      21

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but are neither perfectly sensitive nor perfectly specific.   As new knowledge
develops, other screening procedures can be substituted.   The lack of perfect
screening test is not a legitimate excuse to delay biologic testing.
     The proposed testing system is not inexpensive.  Industry should pay for
emissions characterization and the collection of exhaust particulates before
and after irradiation for use in biological testing.  If possible, it would
be best for the Federal Government to sponsor the necessary biological  testing
utilizing an extremely small portion of the Federal tax on fuels.  This dual
strategy would result in the least economic dislocation to industry, which
already utilizes test procedures closely akin to those now visualized for
emissions characterization.  Industry has little or no experience with the
proposed toxicologic screening system and this system will likely further
evolve during the next few years.  Industry might, however, be required to
support and perform additional standard toxicologic testing of additive com-
ponents and surveillance of occupational groups exposed during manufacturing
and distribution.
     The Federal Government should support the infrequent, but necessary, tests
involving human volunteers and any epidemiologic investigations.  The proposed
tax of .01<£ per gallon of gas would amply support the establishment and improve-
ment of the biologic testing system.  When compared to the economic importance
of fuels and fuel additives, the proposed testing costs are more than reasonable.
Remember, the health insurance purchased by the recommended program benefits the
entire population of our nation.
                                      22

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            APPENDIX

   Task Statements Relating to
Health Intelligence for Fuel and
   Fuel Additive Registration

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Task 1.  Establish Fuel and Fuel Additive Review and Recommendation
         Committee.
A.  Task Objective Statements:

    1.  To identify fuels and fuel  additives which require further
        health and impact evaluation before registration is permitted.
    2.  To identify relevant health and environmental  impact testing
        systems for fuels and fuel  additives.
    3.  To constantly re-evaluate currently registered additives.

B.  Approach:

    Representatives from the following EPA groups should participate
    in this committee:

                       Office of Fuel and Additive Registration
                       Division of Health Effects Research
                       Division of Chemistry and Physics
                       Division of Ecology
                       Office of Research and Monitoring
                       Office of Air Programs

     Consider each registered fuel  or additive and select some for further
     testing,  based on predicted effects on emissions  or control  devices,
     extent of use, and postulated public health and welfare hazards.

C.  Required Resources- for Each Objective:

                                     FY 73 Resource Estimate:   $1000/MY

                                Present       Minimally Adequate      Optimal

    1.  Review of fuels and
        additives submitted
        for registration         9/0.4             30/1.5              60/3.0

    2.  Identify testing
        systems                  8/0.3             10/0.5            120/1.0

    3.  Re-evaluate registered
        additives                8/0.3             20/1.0              60/3.0
                                25/1.0             60/3.0             240/7.0
        Allocation of
          Resources
In-House
Contracts
$25,000
0
$60,000
0
$140,000
$100,000
                                    A 1

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D.  Milestone Events/Target Dates  for each Objective:

                                      Target Dates  at  3  Funding  Levels

                                 Present      Minimally  Adequate    Optimal

1.  Review present registered
    additives                      1/73             10/72            10/72

2.  Develop and approve
    testing systems:

        - existing protocols       2/73             10/72            10/72

        - new protocols             -                  -               1/73

3.  Begin evaluating new
    additives                      6/73               4/73              1/73
                                    A  2

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TASK 2.  "identify Effects of Additives on Emission Products
A.  Objective:

    The Division of Chemistry and Physics has program responsibility
    to determine the effects of fuels and fuel additives on emission
    products.  Specific task objectives which will result in test
    protocols are:

    1.  Determine the effect of fuel and fuel additives on
        exhaust particulate emissions.

    2.  Determine the effect of fuel and fuel additives on exhaust
        gas emissions.

    3.  Determine the effect of fuel and fuel additives on the
        performance of emissions control devices.

    4.  Determine the effect of fuel and fuel additives on
       ratmospheric visibility.

    5.  Develop a predictive emissions model which allows an
        assessment of fuel and fuel additive effects on exhaust
        products by analysis of intermediary combustion products.


B.  Approach:

    Effects research" efforts by DCP are aimed at developing protocols
    utilizing specified base fuels and additives, automotive engines,
    engine operation procedures, and gaseous and particulate collection
    procedures to allow the assessment of the effects of fuels and fuel
    additives on gaseous and particulate emissions, performance of
    control devices, and atmospheric visibility (secondary particulates),
    An additional approach is aimed toward the development of a
    relatively fast screening method to determine potential exhaust
    species and the effect of fuels and additives thereon by analysis
    of combustion intermediate species thus allowing rapid and
    economical assessment of potential toxic emission products.

    The approach would involve collection and analysis of gaseous
    emission products.  Additionally, it would involve collection
    and analysis for total mass emitted,  trace metals, and organic
    fractions of both fresh and irradiated exhaust particulate.
    Collected particulate materials would be available for subsequent
    toxicological screening.

C.  Resources:  (Outside of Funds for Health Intelligence)

    FY '73      In-house manpower    $200,000
                Equipment             225,000
                Contract program      350,000

                            Total    $775,000

                                   A 3

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D.  Milestone Events/Target Dates:

    FY 73   A functioning emissions characterization system which will
    allow collection of fresh and irradiated exhaust particulates.
                                   A 4

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Task 3.  Fuel  and Additive Usage Data


A.  Task Objective Statement:

    To obtain information on the use of individual  fuels and fuel
    additives, in order to determine magnitude of impact of harmful
    emissions on the environment.

B.  Approach:

    The direct approach, recommended by this Task Force, is to request
    legislation to provide the authority to obtain from fuel additive
    manufacturers their production of each additive and from fuel  manu-
    facturers their use of each additive in, and their production  of,
    each designated fuel.

    Lacking such legislative authority, preliminary contact has been
    made with the Air Quality Management Branch, OAP, to develop fuel
    usage by manufacturer for combination with fuel and additive
    registration data to provide total usage of a fuel, an additive,
    or a chemical compound.

C.  Required Resources:  (outside of funds for Health Intelligence)

                                       In House    Contract     Total
          FY 1973     1/2 man-year      10,000      90,000      100,000

D.  Milestone Events/Target Dates:

          9/1/72    Contract awarded.
          3/1/73    Arrangements for receipt of State data completed.

          7/1/73    Usable data on fuel usage available.
                                   A 5

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TASK 4.  Extracts of Emissions Resulting from Use of Selected
         Fuel Additives for Toxicologic Screening
A.  Task Objective Statement:

        Collect and provide for use in toxicologic screen
        test systems exhaust particulars associated with
        the use of selected fuel additives.


B.  Approach:

        Using a standard fuel engine atmosphere generation
        system, produce successive test atmospheres (irradiated
        and non-irradiated) by combustion of reference fuel
        with and without single selected fuel additive products
        (NCT, etc.), followed by extracting particulate
        material and forwarding for testing in a rapid
        toxicologic screening system (Task  5 ).


C.  Required Resources:
                                   FY 73 Resource Estimate ($1000/MY)
                              Present     Minimally Adequate     Optimal

        Allocation: In-house    0/0             $45/2             45/2
                    Contract     -
D.  Milestone Events/Target Dates:
                                           Present    Adequate    Optimal

        Initial extracts for reference
         fuel alone and with MCT              -         7/72        7/72

        Remaining extracts corresponding
         to 4 or 5 additional selected
         additives      .                      -         9/72        9/72

(Note:  On line toxicologic testing in laboratory animals of emission
        atmospheres from above generation system is proposed under
        Biomedical program element support for FY 73.)
                               A 6

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TASK 5.  Toxicologic Evaluation of the Contribution of Fuel  Additives
         to Vehicular Exhaust
Objective:

    To detect biological effects of exhaust particulates by a
sequential application of a variety of biological models.  The source
of particulates for biological exposure is to consist of an engine
dyanometer reaction chamber, designed and built, or adapted to collect
particulate emissions and operated according to a standard protocol.
SUBTASK 1.

    A.  Task Objective Statement:

        Screen particulates derived from the above source in tissue culture.

    B.  Approach:

        Determine comparative toxicity by means of selected biological
        and biochemical parameters on material collected from combustion
        of a referenced gasoline, alone and after addition of the fuel
        additive, and before and after reaction in the irradiation chamber.


    C.  Required Resources for Each Objective:

                                           Resource Estimate:  $1000/MY
                                   Present (FY '73)   Minimally Adequate   Optimal

                                     $ 50/1.0           $ 100/1.0         $ 350/2.0

        Allocation of  - In-House       $25                 $25              $ 50
          Resources    - Contract        25                  75               300


    D.  Milestone Events/Target Dates for Each Objective:
                                             Target Dates at 3 Funding  Levels
Objective             Milestone           Present   Minimally Adequate    Optimal

Screen in        Exploratory work          10/72           10/72          10/72
 tissue culture  Design protocol            1/73            1/73           1/73
                 Negotiate contract         3/73            3/73           3/73
                 Data collection & report
                   1 additive              12/73           10/73           8/73
                   5 additives               -              8/74           6/74
                  15 additives       .        -               -            12/74
                                    A 7

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Subtask 2.  Determination of the Effect of Fuel  Additives,  Selected on  Basis
            of Reaction in Subtask 1  Above, Stepwise in a  Number  of Definitive
            Systems to Further Delineated the Toxicology and Validate Results
            in Subtask 1.

A.  TASK OBJECTIVE STATEMENTS:
    1.  Test the effect of fuel  additives on pulmonary alveolar macrophages.
    2.  Test the effect of additives  on a in vitro mutagenic model.
    3.  Test the effect of fuel  additives on a carcinogenesis model in
        newborn mice.
    4.  Test, etc, on enhancement of  pulmonary infection.
    5.  Test, etc, on production of dominant lethal  mutations in  mice.
    6.  Test, etc, on production of pulmonary tumors by intratracheal
        instillation in hamsters.

B.  APPROACH:
    Y.Material would be placed in surviving cultures of  pulmonary alveolar
        macrophage and effect would be noted on selected biological and
        biochemical parameters.
       {             •                                       ''.
    2.  Material would be studied for its property to induce mutagenesis  in
        yeast or mold cultures.

    3.  Material would be injected subcutaneously in newborn mice which
        would be sacrificed and  studied pathologically after an appropriate
        latency period.

    4.  Material would be introduced  into the lungs of mice to be proceeded
        or followed by infectious organism.  Parameters of clearance, bacterial
        growth and mortality would be observed.

    5.  Material would be injected into male mice which would then be bred,
        and females examined by  standard procedure to detect presence of
        dominant lethal genes in mice.

    6.  Material would be injected into tracheal of hamsters lone, with inert  .
        particles and with known carcinogens.  Animals would be sacrificed
        and examined for tumors  after period of latency.

C.  REQUIRED RESOURCES FOR EACH  OBJECTIVE:

                                 Resource Estimate:  $1000/MY
    Objectives                  Present    Minimally Adequate     Optimal
    T.Toxicology in P.A.M.    $20/1.0         $80/1.0$150/2.0

        Allocation of - In-House   $20            $20               $40
        Resources     - Contract                  $60              $110

    2.  Mutagenesis in vitro     $20/0.2        $40/0.5          $100/1.0

        Allocation of - In-House    $5            $10               $20
        Resources     -            $15            $30

                                   A 8

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Objectives Present
3. Carcinogenesis in $50/0.5
newborn mice
Allocation of - In-House $10
Resources - Contract $40
4. Infectivity studies $20/1.0
Allocation of - In-House $20
Resources - Contract 0
5. Dominant lethal $20/0.2
in mice
Allocation of - In-House $5
Resources - Contract $15
6. Intratracheal $20/0.2
Allocation of - In-House $5
Resources - Contract $15
D. MILESTONE EVENTS/TARGET DATES FOR
Minimally Adequate Optimal
$120/1.0
$30
$90
$80/1.0
$20
$60
$120/1.0
$20
$100
$70/1.0
$20
$50
EACH OBJECTIVE:
$150/1.0
$30
$120
$160/2.0
$40
$120
$230/2.0
$40
$190
. $120/1.0
$20
$100









Target Dates at 3 Funding Levels
Objective Milestone Present Minimal
1. Toxicity Design protocol
in PAM Negotiate contract
Data collection
& report:
1 additive
10 additives
20 additives
2. Mutagensis Design protocol
in vitro Negotiate contract
Data collection
& report:
2 additives
10 additives
20 additives
12/72
3/73
12/73
12/72
3/73
12/73
ly Adequate
12/72
3/73
12/73
12/74
12/72
3/73
12/73
12/74
Optimal
12/72
3/73
12/73
6/74
12/74
12/72
3/73
12/73
6/74
12/74
A  9

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Objective
Milestone
       Target Dates at 3 Funding Levels
Preseirt    Minimally Adequate    Optimal
3. Carcinogenesis
   in newborn
   mice
4.  Infectivity
    studies
    Dominant
    lethal test
    in mice
     Intratracheal
     innoculation
     of  hamsters
    Feasibility
    studies         12/72          12/72
    Design protocol   2/73           2/73
    Negotiate contract 3/73         3/73
    Data collection
      & report:
      1 additive     6/74           6/74
     10 additives     —           10/74
     20 additives

    Design protocol 10/72          10/72
    Negotiated contract  3/73       3/73
    Data collection
      & report:
      1 additive    12/73          12/73
      5 additives     --            6/74
     15 additives     —

    Design protocol  12/72         12/72
    Negotiated contract  3/73       3/73
    Data collection
      & report:
      1 additive     12/73         10/73
      6 additives      —           8/74
     12 additives

    Design protocol   6/73          6/73
    Negotiate  contract   12/73      12/73
    Data collection
       & report:
       1 additive     12/75         12/74
       5 additives      —          12/75
     12 additives
                                  12/72
                                   2/73
                                   3/73
                                   6/74
                                  10/74
                                   6/75

                                  10/72
                                   3/73
                                  12/73
                                   6/74
                                  12/74

                                  12/72
                                   3/73
                                   8/73
                                   6/74
                                  12/74

                                   6/73
                                  12/73
                                                                  12/74
                                                                   6/75
                                                                  12/75
                               A  10

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TASK 6..,  Use of Selected In Vitro Enzyme Assays as Indicators of Auto
         Exhaust Toxicity.


A.  TASK OBJECTIVE STATEMENTS:

    The object of this task is to develop a series of twenty-five in vitro
    enzyme assays which can be used to study auto exhaust' component toxicity.
    The enzymes chosen will constitute a spectrum that focuses on many
    aspects of general metaboltsm or serve as points of metabolic control
    In critical pathways.  Thts assay protocol will be used as a back-up
    to the whole cell system task and wtlI  serve to evaluate selected
    examples prior to their study in whole animal specific models.  Findings
    in these enzyme systems wfll serve as more specific indicators and
    quantifiers of component toxicfty and thus, will provide a more com-
    prehensive definition of component toxicity  in all test systems.

B.  APPROACH:

    The approach will Involve the development of a series of in vitro
    enzyme assays to serve as test systems in the specific evaluation
    of auto exhaust component toxicity.

    These assays  will  serve as a furtner refinement of the systems out-
    Tfnecf in Task S^and wilj^ be applied only to samples shown to have
    toxicity in the£e~preTimi7)ary ToxfcdTdgicaTllssay systems.   It may
    not be necessary" in every case  to use the entire spectrum of enzyme"
    assays, "but IT heeded "they can  be applied,

    Components wiN be added  in graded doses to the suFtable enzyme
    preparation and the  IC50 and IC90  (50$ and 90% inhibition concentration)
    will be determined.  If a component  is shown to have significant
    toxicity for a specific enzyme or class of enzymes studies of its
    inhibitory kinetic profile will be made.   In this case components will
    be classed as competitive or non-competitive and attempts will be made
    to define the molecular basis of competition.

    The enzymes selected for  use in this system appear below:

    Enzyme                            Class            MetaIs        Cofactors

    Acetyl Choline Esterase         Hydrolase

    Pancreatic Lipase               Hydrolase            Ca

    Ribonuclease                 Nucleotfdyl Transferase

    Phosphorylase b              Hexosyl Transferase                    PLP

    Amylase                      Glucoside Hydrolase     Ca

    Leucine Aminopeptidase      Aminopeptide aminoacid   Zn
                                  hydrolase
    Carboxvpeptidase.A  ..  ,.     Carboxypeptide Aminoacid Zn
                                  hydrolase

                                 A 11

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     Alcohol  Dehydrogenase

     Lactic Dehydrogenase

     Gl ucose-6-Phos.'  Dehydrogenase

     Cytochrome Oxidase

     Xanthlne Oxidase

     Tyrosfnase

     Carbonic anhydrase

     Glucose Phosphate Isomerase

     PhosphogIucomutase

     Superoxide Dismutase

     Alkaline Phosphatase

     Hexoki nase

     Creattne phophokFnase

     Phosphofructoklnase

     Aspartate Aminotransferase

     Alanine Aminotransferase

     Phosphor IbosyI  Transferase

     Dihydrofolate Dehydrogenase
         Oxldoreductase

         Oxtdoreductase

         Dehydrogenase

         Oxfdase

         Oxidase

         Oxidoreductase

         Hydro-lyase

         Isomerase

         Phosphotransferase

         Dismutase

         PhosphohydroIase

         Phosphotransferase

         PhospKotransferase

         Phosphotransferase

         Ami.no Transf erase

         Amino Transferase

         Transferase

         Oxtdoreductase
Zn
Zn

Fe, Cu
Mo, Fe
Cu
Zn
NAD
NAD
NADP




Mg
Zn, Cu
Zn
Mg
Mg
Mg .


HDP


ATP
ATP
ATP
PLP
PLP
 C.   REQUIRED RESOURCES FOR EACH OBJECTIVE:
              NADP
Resource Estimate: $IOOO/MY
Objectives
Al 1 Enzyme
Assays
Tota 1 s
Present
0/0

0/0
Minimally Adequate*
250/5.0

250/5.0
Optimal*
750/10.0

750/10.0
     AI location of
     Resources
In-House   100/5.0
Contract   150/0
300/10.0
450/0
 *This resource figure includes only the funds needed to set-up  and  refine
  all  assay systems		 _   _


**The cost per unit sample carried through the entire assay protocol
  is calculated to be $2000/sample.

                                 A 12

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D.  MILESTONE EVENTS/TARGET DATES FOR EACH OBJECTIVE:

    Milestone Events                 Target Dates at 2 Resource Levels
                                     Minimally Adequate      Optima I

    Negotiate contract                    12/72               12/72

    Develop Assays In-House                3/73                3/73
                                 A 13

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 TASK 7.   Trace  Element  Inhalation  Toxicology  of  Combustion
          Products  from  Fuel  Additives
 A.   Task  Objective  Statements
     1.   Modify  existing  aerosol  generation  system for  the
         combustion  of fuel  additives.

     2.   Characterize  and define  exposure chamber atmospheres.

     3.   Quantitate  in laboratory animals the  imoact of trace
         elements  (initially Mn)  present in  the additives upon
         normal  body burdens.   Determine the uptake, excretion
         and tissue  levels of the trace metals.

     4.   Evaluate  specific physiologic functions as indicated
         based on  anticipated biological effects of the
         combustion  products.   For example,  behavioral
         changes and neurological should be  evaluated
         following exposure  to  additives containing Mn.

B.   Approach:

     1.   A simple  combustion system such as  a jet flame will
         be incorporated  into our existing inhalation exposure
         system.

     2.   The atmospheres will be  characterized as to the gaseous
         components  such as CO  and hydrocarbons, particulate
         mass and  size; and quantisation of  the trace metal  of
         concern.

     3.   Following exposure of  the animals,  trace metal
         determinations will  be made on a selected group
        of tissues  along with determination of the amounts  in
         the diet, feces and urine.   The tissue values will  be
         compared with those obtained from control  animals
        exposed to  ambient levels.

    4.  As indicated by the compound under study,  certain
        other physiological  parameters will  be evaluated
        so as to determine the effects of increased levels
        of exposure.


C.  Required Resources for each Objective:

    Funded under the Biomedical Research Program Element.
                               A 14

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D.   Milestone Events/Target Dates of Each Objective:
    1.  Modification of Equipment            9/72
    2.  Testing and Atmospheric Characterization of the System       11/72
    3.  Exposures and data collection       12/72-3/73
    4.  Analysis and report                  4/73
                                  A 15

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TASK 8.  Controlled Human Exposures to Components of Auto Exhausts


A.  TASK OBJECTIVE STATEMENTS:
    T!Test the eye irritation potential of auto exhaust components
        resulting from use of new fuels or additives registered with
        the Office of Fuels and Fuel Additive Registrations.
    2.  Quantitate in humans uptake, excretion and tissue levels of
        trace elements present in fuels and additives and emitted
        from advanced control systems.
    3.  Test in humans adverse effects of controlled exposure to auto
        exhaust components upon resistance to infectious challenge,
        after demonstration of such effects in animal model  systems.

B.  APPROACH:
    1.  Eye irritation studies:  graded doses of exhaust components
        will be tested against tear lysozyme levels and subjective
        sensation of eye irritation at exposures bracketing ambient
        levels resulting from projected use of new fuels or additives.
    2.  Trace element studies:  careful measurement of trace  element
        in food will be coupled to controlled inhalation after vaporization
        of the element in jet flame.  Amounts taken in, excreted in feces
        and urine, and concentrations in blood and hair will  be quantified.
        Potential for increased body burdens from ambient levels produced
        by exhaust emissions will be defined.  Effects on activity of
        selected enzymes in blood will be determined.
    3.  Infectivtty studies:  respiratory challenge with common benign
        respiratory viruses and bacteria will follow carefully dosimetered
        exposure to auto exhaust components found to adversely affect
        animal resistance to infectious challenge.

C.  REQUIRED RESOURCES FOR EACH OBJECTIVE:

                               FY 73  Resource Estimate:  $1000/MY

    Objectives

    1.  Eye i rri tati on

    2.  Trace elements    0/0

    3.  Infectivity

               Totals

        Allocation of
        Resources
Present
0/0
0/0
0/0
0/0
-
Minimally Adequate
$20/0.4
80/1.3
0/0
$100/1.7
In-House $40
Contract $60
Optimal
$50/1 .0
250/4.0
100/1.7
$400/6.7
$100
$300
                                    A 16

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D.  MILESTONE EVENTS/TARGET DATES FOR EACH OBJECTIVE:

    1.   Eye irritation
                                   Target Dates at 2 Resource Levels
          Milestone Events          Minimally Adequate      Optimal

          Negotiate contract                 12/72           12/72
          Data collection - one additive      3/73            3/73
                          -second additive     —             4/73
                          -third additive      —             5/73
          Analysis and report                 5/73       5 to 7/73

    2.   Trace element studies
                                   Target Dates at 2 Resource Levels
          Milestone Events          Minimally Adequate"      Optimal

          Negotiate contract                 10/72           10/72
          Data collection - one element       2/73            2/73
                          -second element     4/73            2/73
                          -third element       —            . 4/73
                          -fourth element      ~             4/73
                          -fifth element       —             6/73
                          -sixth element       —             6/73
          Analysis and report                 6/73       6 to 9/73

    3.   Infectivity studies
                                   Target Dates at 2 Resource Levels
          Milestone Events          Minimally Adequate"      Optimal

          Negotiate contract                   ~             1/73
          Data collection - one element        —             3/73
                          -second element      ~             5/73
          Analysis and report                  ~             7/73
                                    A 17

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TASK 9.  Epidemiologic Studies Necessary to Predict the Health Impact
         of Fuels and Fuel Additives


A.  TASK OBJECTIVE STATEMENTS:
    TiTo elucidate changes in human pollutant burdens which might
        result from use of specific fuels and fuel  additives.
    2.   To link changes in human pollutant burdens  to alterations  in
        physiology and increased risk of acute or chronic diseases.

B.  APPROACH:
    T!Changes in human pollutant burdens might be predicted by special
        study of populations already representing an exposure gradient
        for the pollutants in question--  This approach would be most
        appropriate for trace element exposures,! the most important of
        which are manganese, nickel and chromium.  Tissues and body
        fluids would be collected from volunteers and at necropsy.
        The levels of selected trace metals would then be assayed  by
        appropriate techniques.  Information from these studies would
        be interfaced.
    2.   -Human pollutant burden levels in selected cases  could be
        linked to changes in metalloenzyme activity, to appropriate
        indices of erythrocyte metabolism, to changes in neurophysiology,
        alterations in performance testing, and to  cytogenetic abnor-
        malities in circulating lymphocytes and respiratory epithelium.

C.  REQUIRED RESOURCES FOR EACH OBJECTIVE:

                                      FY73 Resource Estimate:  $1000/MY

    Objectives                   Present      Minimally Adequate      Optimal

    1.   Human pollutant burden    0/0            $50/0.2               $100/0.2

    2.   Pathophysiologic studies  0/0              0/0                 100/0.2

                       Total      0/0            $50/0.2               $200/0.4

        Allocation of    -      In-House           -4-                  -8-
        Resources        -      Contract           $46                 $192

D.  MILESTONE EVENTS/TARGET DATES FOR EACH OBJECTIVE:

    1.   Human pollutant burden
                                          Target Dates at 2 Resource Levels
        Milestone Events                  Minimally Adequate       Optimal

        Negotiate contract                       12/72              12/72
        Data collection: one trace element       6/73               6/73
                         two trace elements        --                6/73
        Analysis and report                      12/73              12/73
                                    A 18

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Pathophysiologic studies
                               Target Dates at 2 Resource Levels
Milestone Events               Minimally Adequate        Optimal

Negotiate contract                      ~                12/72
Data collection: one trace element      --                12/73
                 two trace elements
Analysis and report                     ~                 3/74
                            A 19

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