ORNL
Oak Ridge
National
Laboratory
Operated by
Martin Marietta Energy Systems, Inc.
for the Department of Energy
Oak Ridge, Tennessee 37831
ORNL-6035
             United States
             Environmental Protection
             Agency
               Office of Toxic Substances
               Washington, DC 20460
                  EPA-560/6-83-005
                  May 1984
             Toxic Substances
             Nutritional  Requirements and
             Contaminant Analysis of
             Laboratory Animal  Feeds

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thereof.

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                                           ORNL-6035
                                           EPA  560/6-83-005
                                           May  1984
NUTRITIONAL REQUIREMENTS AND CONTAMINANT ANALYSIS
           OF LABORATORY ANIMAL FEEDS
                       by
                  Bimal C. Pal
                 Robert H. Ross
       Chemical Effects Information Center
               Information Division
          Oak Ridge National Laboratory
               Oak Ridge.  TN 37831
                       and
                 Harry A. Milman
    Health and Environmental Review Division
           Office of Tozic Substances
      U.S. Environmental Protection Agency
              Washington, DC 20460
       Interagency Agreement DW930141-01-1
            Date Published - May 1984
                  Prepared For
           OFFICE OF TOXIC SUBSTANCES
      U.S. ENVIRONMENTAL PROTECTION AGENCY
              WASHINGTON. DC 20460
                 Prepared by the
          OAK RIDGE NATIONAL LABORATORY
           Oak Ridge. Tennessee 37831
                   operated by
      MARTIN MARIETTA ENERGY SYSTEMS, INC.
                     for the
            U.S. DEPARTMENT OF ENERGY
      under Contract No. DE-AC05-840R21400

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This report has been reviewed by the Office of Toxic Substances, U.S.
Environmental Protection Agency, and approved for publication.  Approval
does not signify that the contents necessarily reflect the views and
policies of the U.S. Environmental Protection Agency, nor does mention
of trade names or commercial products constitute endorsement or recom-
mendation for use.
                                   ii

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                                CONTENTS

                                                                    Page

LIST OF FIGURES	  v

LIST OF TABLES	vii
ACKNOWLEDGMENTS 	 iz
EXECUTIVE SUMMARY	 zi

 1  INTRODUCTION	  1

 2  NUTRITIONAL REQUIREMENTS FOR LABORATORY ANIMALS -
    COMPARISON OF THE DATA PROPOSED IN THE EPA GOOD
    LABORATORY PRACTICE STANDARDS WITH THOSE OF COMMERCIAL
    PROCEDURES, NIH, AND AIN	  5
 3  EVALUATION OF DIFFERENT TYPES AND FORMS OF DIETS	  6

    3.1  Types of Diets - Advantages and Disadvantages 	  6

         3.1.1  Natural-Ingredient Diets 	  6
         3.1.2  Purified Diets 	  6
         3.1.3  Chemically Defined Diets 	  6
         3.1.4  Open Formula Diets	 12
         3.1.5  Closed Formula Diets	 12
         3.1.6  Quasi-Open Formula Diets 	 12

    3.2  Forms of Diets 	 12

    3.3  Autoclaving of Diets	 14

    3.4  Discussion	 15

 4  DIETARY INTAKE	 17

 5  VITAMINS AND MINERALS USED IN ANIMAL DIET FORMULATIONS	 18

    5.1  Vitamins	 18
    5.2  Minerals 	 18

 6  INGREDIENTS USED IN LABORATORY ANIMAL DIETS 	 22

 7  CONTAMINANTS AND PRESERVATIVES IN ANIMAL FEEDS	 24

    7.1  Introduction	 24
    7.2  Biological Contaminants 	 24
         7.2.1  Estrogens	 24
         7.2.2  Aflatozins	 26
         7.2.3  Tricothecene Tozins	 27
    7.3  Nitrosamines 	 27
    7.4  Preservatives 	 30
    7.5  Tolerance Limits of Contaminants and Preservatives
         in Animal Feed	 31
         7.5.1* Considerations, for Establishing Tolerances
                for Contaminants	 36
         7.5.2  Suggested Changes in the Tolerance Limits for
                the Contaminants Listed in the EPA GLP	 36
                                   iii

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         7.5.3  Inconsistencies in EPA and FDA Tolerance
                Limits for Contaminants	 44

 8  MONITORING AND ANALYSIS OF CONTAMINANTS IN FEED	 45

 9  INTERACTION OF DIETARY COMPONENTS 	 47
    9.1  Interplay Among Zn, Se, As, Vitamins, Amino Acids,
         Fatty Acids, and Phytate 	 47
    9.2  Ca:P Ratio  	 47
    9.3  K:Na Ratio	 47
    9.4  Enzyme Induction and Inhibition of Neoplasia by Minor
         Dietary Constituents, Feed Additives,
         and Contaminants	 48
         9.4.1  Enzyme Induction by Dietary Constituents 	 48
         9.4.2  Enzyme Induction by Feed Additives	48
         9.4.3  Enzyme Induction by Contaminants in Animal Feed ... 48
         9.4.4  Inhibition of Neoplasia	 49
         9.4.5  Monitoring of Induced Enzyme Activity 	 49
         9.4.6  Enzyme Induction and Genetic Differences 	 49

10  SPECIAL TOPICS	 50
   10.1  Phytates 	 50
   10.2  Arsenic	 50
   10.3  Selenium	 51
11  ANALYSIS OF PUBLIC COMMENTS ON THE PROPOSED EPA
    GUIDELINES FOR DIETARY REQUIREMENTS AND
    CONTAMINANT ANALYSIS	 52
    11.1  Criticisms of Proposed Guidelines and Related
          Discussion	 52
    11.2  Analysis of Specific Comments 	 53
          11.2.1   Shelf Life Restrictions 	 53
          11.2.2   Feed Meal  	 53
          11.2.3   Calcium, Phosphorus, Iron, and Cobalt 	 53
          11.2.4   Vitamins	54
          11.2.5   Choline and Inositol 	 54
          11.2.6   Alternative Sources of Minerals	 55
          11.2.7   Dicalcium Phosphate 	 55
          11.2.8   Fat	 55
          11.2.9   Ash	 55
          11.2.10  Air Dry	 56
          11.2.11  Units of Measurement 	 56
LITERATURE CITED 	 57

Appendix A.  National Institutes of Health Standard
  for Nutrient and Chemical Contaminant Analyses of
  Laboratory Animal  Diets	 71

Appendix B.  Conversion Factors for Selected Vitamins 	 73

Appendix C.  Letter  from Edward J. Ballitch 	 74
Appendix D.  Abbreviation List	 75

Appendix E.  Additional Literature References	 76
                                   iv

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                            LIST OF FIGURES

Figure                                                              Page


   1   Growth curve for rabbit (New Zealand White)  	   8

   2   Growth data for guinea pig
       (Ft. Detrick Dunkin Hartley) 	   9

   3   Growth curves for fifteen breeds of dog	  10

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                             LIST OF TABLES

Table                                                               Page


  1  Approximate Nutrient Composition of EPA,  NIH,  AIN
     and Commercial Laboratory Animal Diet Formulations 	  2

  2  Estimated Nutritional Requirements of Laboratory Animals 	  3

  3  Normal Growth. Rate of the Hamster, Rat,  and Mouse	  7

  4  Reproduction and Life Span Data on Selected
     Laboratory Animals	 11

  5  Concentrations of Selected Nutrient and Toxic  Components
     in Random Samples of Rodent Natural Product Diets	 13

  6  Vitamins, Minerals,  and Animal Diet Formulations 	 19

  7  Trace Minerals Included in the GRAS List	 21

  8  Ingredients Commonly Used in Laboratory Animal Diets 	 23

  9  Estrogens in Animal  Feed	 25

 10  Fusarium Toxins	 28

 11  Contaminants and Preservatives in
     Laboratory Animal Feeds	 32

 12  Pesticides and Contaminants in Laboratory Animal Feeds 	 33

 13  Pesticides in Laboratory Animal Feeds	 34

 14  Normal Screening Levels of Detection 	 37

 15  Biologically Effective Concentrations of
     Selected Organic Feed Contaminants	 38

 16  Biologically Effective Concentrations of
     Selected Heavy Metals 	 39

 17  Interaction of Dietary Factors with Toxicants  	 40

 18  Results of Analyses  of Laboratory Animal  Diets 	 43

 19  References to the Methods of Analysis of Contaminants
     in Animal Feed and Relevant Statistical  Data	 46
                                  vii

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                             ACKNOWLEDGMENTS


     We have received assistance from many people in the preparation of
this document.  Dr. Gene Bingham, veterinarian. Biology Division, Oak
Ridge National Laboratory, and Dr. Joseph J. Enapka, nutritionist.
National Institutes of Health, have generously shared their expertise  in
this area. We are indebted to Betty J. Ward and Edward J. Ballitch of  the
Food and Drug Administration for enlightening us on the latest regulatory
information. Dr. John C. Chah, Zeigler Bros., and Dr. Charles R. Adams,
Hoffmann-La Roche, provided information on the stability of fats and
vitamins. Thanks are due to Jon H. Ford, Manager, Ralston Purina Company
Plant, Richmond, Indiana, for information on the current manufacturing
practices in the laboratory animal feed industry. We have received
invaluable advice, comments, and suggestions during the preparation of
this document from Dr. Damon C. Shelton, Director, Laboratory of Special
Chows Research Department, Ralston Purina Company, St. Louis, Missouri.
Dr. Harry A. Milman of the U.S. Environmental Protection Agency provided
us with a copy of the public comments on the USEPA Dietary Requirements
under the Good Laboratory Practice Standards and general guidance during
the preparation of this document. Thanks are due to Drs. Joseph J. Enapka
(NIH), Kenneth C. Hayes (Harvard), Paul M. Newberne (MIT), and H. Leroy
Shilt (Ralston Purina) for their in-depth reviews of this document.  We
greatly appreciate the assistance of Janice Pruett and Carolyn Seaborn
for extensive literature searching and of Donna Stokes and Frances Lit-
tleton for the very demanding task of typing.

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                            EXECUTIVE SUMMARY
     The primary objectives of this report are to present  information
concerning the nutritional requirements of several commonly used  labora-
tory animal species (i.e., mouse, rat, hamster, guinea pig, rabbit,  and
dog) and to discuss various aspects of the problem of contamination  of
laboratory animal feeds.  In addition, this document discusses  the dif-
ferent types of laboratory animal diets (e.g., open vs closed formula),
the ingredients used in these diets, the  interaction of dietary com-
ponents, and the public comments received respective to the EPA proposed
guidelines for the nutrient composition of laboratory animal diets.
Much of the data are presented in tabular form as this method seemed the
most appropriate.

     The principal focus of the discussion on nutritional  requirements
of laboratory animals is a comparison of the proposed EPA  guidelines for
rodent diets with the diet compositions for rodents of selected commer-
cial laboratory animal feed manufacturers and with the recommendations
of the National Academy of Sciences (NAS) regarding the nutrient  compo-
sition of laboratory animal diets.  These comparisons revealed  the fol-
lowing: (1) commercial feed manufacturers are generally in good agree-
ment with the dietary requirements proposed by EPA for rodents; and  (2)
the levels of nutrients proposed by EPA and found in the commercial
feeds are usually higher than those recommended by the NAS.  These
higher levels result from nutrient concentrations in commercial diets
being formulated to compensate for losses during the manufacture  and
storage as well as for differences in biological availability of
nutrients.

     The different types of diets include natural-ingredient, purified,
chemically defined, open formula, closed formula, and quasi—open  for-
mula.  The merits and demerits of the open formula versus  closed  formula
diet are a highly controversial issue.

     With respect to ingredients used in laboratory animal diets„ all of
the ingredients listed in the proposed EPA guidelines are  used  in the
National Institutes of Health (NIB) and in the selected commercial diet
formulations reviewed.  However, some ingredients are included  in the
NIH and commercial diet formulations that are not included as approved
ingredients in the proposed EPA guidelines (DSEPA 1979).

     Contaminants in laboratory animal feeds arise from biological as
well as nonbiological sources.  Biological contaminants originate from
microorganisms and are mainly estrogens, aflatozins, and trichothecene
toxins.  Nonbiological contaminants are usually pesticide  residues,
nitrosamines, and heavy metals.  The EPA proposed guidelines list toler-
ances for certain contaminants and preservatives, and commercial  feed
manufactures list maximum acceptable levels for contaminants.   For some
contaminants (e.g., lindane tfnd cadmium), the maximum allowable levels
in commercially manufactured feeds exceed the EPA proposed tolerance
levels.  No preservatives are allowed according to the proposed EPA
                                   xi

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guidelines whereas, for all the commercial producers whose data were
reviewed, the preservative butylated hydroxyanisole is used in diets
containing animal fats and the preservative ethoxyquin is used to
prevent oxidation of vitamin A in diet formulations.

     Just as the presence of contaminants in the feed can affect the
outcome of a long-term toxicity study, the interaction of dietary com-
ponents can also play a determining role on the results of a chronic
toxicity study.  For example, selenium possesses anticarcinogenic pro-
perties in animals and humans, and the uptake of selenium can be dimin-
ished by zinc (Schrauzer 1977).  Knowledge of such interactions would
obviously be important for an investigator.

     Several commenters (comments regarding the proposed EPA guidelines)
disagreed with the guidelines for nutrient composition of laboratory
animal diets on the following grounds: (1) lack of feasibility; (2)
practicality; (3) scientific justification; (4) lack of harmony with the
Food and Drug Administration and the Department of Agriculture; (5) lack
of  incentive to continue research on diet development; and (6) failure
to  promote standardization of the diet.

     In conclusion, it should be noted that virtually no information
exists with respect to the nutrient requirements of laboratory animals
beyond the growth and reproductive segments of their life spans.  There-
fore, it is not known if the nutrient levels proposed by EPA and those
in  commercial diet formulations are the optimum for a lifetime bioassay
study.  Research in this area is obviously needed.  In addition, the
proposed EPA guidelines for diet composition are stated as the recommen-
dations  for rodents.  However, some confusion arises since no dietary
requirement is proposed for vitamin C which is needed in the diet of
guinea pigs.  Further clarification, or possibly diets recommended  for
individual species, would obviate this confusion.
                                   xii

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1. INTRODUCTION
     The coverage in this treatise has been restricted to six laboratory
animal species: mouse, hamster, rat, guinea pig, rabbit, and dog.  The
purpose of this document is to provide the EPA with relevant facts and
figures to assist in the revision of the Appendix B, Dietary Require-
ments and Contaminant Analysis, of the Proposed Good Laboratory Practice
Standards for Health Effects (USEPA 1979).  Discussion and literature
coverage of the nutrient requirements of different laboratory animals
has been brief since this information is already available in the excel-
lent monographs published by the National Academy of Sciences (NAS 1974,
1977, 1978).  However, Appendix D contains a list of references not
cited in this report but pertinent to the area of nutritional require-
ments of laboratory animals; many of these are cited in the NAS publica-
tions.

     The manufacture of the natural-ingredient diet, which is the most
widely used animal diet, is quite involved and requires an expensive
outlay.  This is why almost all laboratories depend on the feed manufac-
turer to provide an adequate and nutritious diet for the animals.  Also,
these commercial diets have long historical backgrounds and reliability.
Representative data on the composition of animal feed from two of the
more prominent producers have been collected and presented, along with
data on diet composition from the National Institutes of Health (NIH)
and the American Institute of Nutrition (AIN) (see Table 1), to provide
the basis for comparison with the proposed EPA guidelines (also included
in Table 1) and discussion of the state-of-the-art of dietary require-
ments.  Table 2 lists data on the nutritional requirements of laboratory
animals during growth, gestation, lactation, maintenance, and reproduc-
tion as recommended by the National Academy of Sciences (NAS 1974, 1977,
1978).  It should be noted that a data gap exists in nutrient require-
ments for animals involved in long-term studies beyond their reproduc-
tive life span (NAS 1978).

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                      Table 1.  Aftroxtaurte Nitriot Coaqiositioi of EPA, NIH, AIN ud CoBSMfdal Laboratory Aiinal Diet FuiHuliBoai
EPA"
rodent diet
Nutrients
Crude protdn, rain., %
Crude fat, rain., %
Crude fibcr,%

Ash, %

Linoleic acid, %
Total digestible
nutrients (TON), %
Amino acids, %
Aiginine,%
Cystine.%
Glydne.%
Histidine,%
Isolcucinc, %
Leucine,%
Lyiine,%
Metbionine, %
Phenylalanine, %
Threoninc,%
Tryptophan, %
Tyrosine,%
Valine.%
Minerals
Calcium, %
Chloride, %
Chromium, ppro
Cobalt, ppm
Copper, ppm
Fluoride, ppm
Iodine, ppm
Iron, ppm
Magnesium, %
Manganese, ppm
Phosphorus, %
Potassium, %
Selenium, ppm
Sodium, %
Sulfur, %
Zinc, ppm
Vitamins
Vitamin A, RJ/g
Vitamin D, IU/g
dVTocopherol
(vitamin E), ppm
Tniamine,ppm
Riboflavin, ppm
Niatin, ppm
Pantotbcnic acid, ppm
Choline, ppm
Pyndoxine, ppm
Folk acid, ppm
Bntin,ppm
Vitamin BIB ppm
Vitamin K (Menadione), ppm
Inoshol, ppm
Vitamin C, ppm
For autoclavabk diets:
Vitamin A, IU/g
Thiamin, ppm
Vitamin K (Menadione), ppm
min.
18.0
4.3
4.2

8.0

NG
NG


0.95
0.27
1.00
0.38
0.95
1.50
0.90
0.38
0.90
0.65
0.20
0.60
0.95

1.15
NG
NG
0.80
12.0
NG
1.85
345.0
0.20
140.0
0.90
0.80
0.1
0.33
NG
50.0

15.0
4.0

50.0
14.0
7.0
65.0
32.0
1900.00
10.0
2.0
0.3
0.03
3.0
NG
NG

100.0
70.0
20.0
max.
NG
NG
NG

NG

NG
NG


NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG

NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
0.6
NG
NG
NG

75.00
10.00

NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG

NG
NG
NG
Agway*
(Charles River)
RMH3000
22.0
5.0
5.0

6.0

0.9
NG


1.63
0.44
1.35
0.51
1.10
1.83
1.41
0.42
1.13
0.91
0.27
0.83
1.15

0.97
0.15
NG
0.96
23.0
35.0
I.I
289.0
0.21
61.7
0.85
0.95
0.25
0.44
NG
84.0

20.229
1.045*

55.62
11.50
10.38
72.45
21.92
1542.00
8.84
1.67
0.40
0.06
0.97
NG
NG

28.15
67.32
1.38
Purina'
Rodent Lab
Chow* 15002
20.0
4.5
5.5
(max.)
7.0
(max.)
NG
77.0


1.13
0.27
0.86
0.49
1.03
1.58
1.18
0.43
0.88
0.78
0.24
0.60
1.05

0.90
0.47
2.09
0.6
13.3
NG
1.2
180.0
0.21
63.0
0.70
0.86
NG
0.30
NG
52.4

17.6
2.2

60.0
13.3
8.0
60.0
17.0
1800.0
6.0
4.0
0.13
0.02
NG
NG
NG

37.0
70.0
8.8
Purina'
Guinea Pig
Chow* |5026
18.0
4.0
16.0
(max.)
9.0
(max.)
NG
67.6


1.08
0.28
0.87
0.43
0.96
1.46
0.95
0.40
0.89
0.71
0.27
0.59
0.95

1.1
0.30
6.01
0.38
21
NG
1.6
298.7
0.35
121
0.6
1.2
NG
0.32
NG
122

30.0 + 59.9^
3.4

44.0
5.5
6.0
50.0
19.0
1850.0
4.0
4.2
0.30
0.01
NG
NG
1000.0

NG
NG
NG
NIH open''
formula
mouse & rat
diet
23.5
5.0
4.5

NG

NG
NG


1.25
0.35
1.10
0.50
1.10
1.80
1.20
0.50
1.10
0.90
0.25
0.75
1.20

1.20
NG
NG
0.70
15
NG
1.80
250
0.15
100
0.95
0.80
NG
0.33
NG
45

15.0
4.0

35.0
14.0
7.0
80.0
20.0
2000.0
10.0
4.0
0.15
0.03
3.0
NG
NG

NG
NG
NG
Purified diet'
AIN-76*
(rodents)
17+
5
5

NG

NG
NG


NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG
NG

0.52
0.156
2.0
NG
6.0
NG
0.2
35.0
0.05
54.0
0.40
0.36
0.1
0.102
333.3
30.0

4.0
1.0

56.6
5.34
6.0
30.0
16.0*
NG
7.0*
2.0
0.2
0.1
0.05
NG
NG

NG
NG
NG
Purina'
Canine Diet
15007
25.0
9.0
4.0
(max.)
10.0
(max.)
NG
78.0


1.46
0.37
1.85
0.59
1.13
2.21
1.10
0.44
1.20
0.90
0.25
0.78
1.24

1.8
0.42
2.34
0.50
13.0
NG
1.70
241.4
0.24
85.0
1.0
0.71
NG
0.42
NG
48.1

40.0
4.4

44.0
9.8
4.5
60.0
20.0
2000.0
12.5
3.6
0.18
0.03
0.57
NG
NG

NG
NG
NG
Purina'
Rabbit Chow*
15322
16.0
2.5
18.0
(max.)
8.0
(max.)
NG
66.0


0.90
0.25
0.77
0.40
0.82
1.30
0.78
0.35
0.80
0.64
0.23
0.75
0.84

0.95
0.40
4.56
0.38
13.0
NG
0.59
252.6
0.25
44.4
0.50
1.40
NG
0.30
NG
3X5

28 + 46^
2.3

44.0
3.5
4.5
33.0
19.0
1600.00
4.5
1.2
0.12
0.01
NG
NG
NG

NG
NG
NG
 NG — Not given.
"Data taken from USEPA (1979).  Data on ViL B^and Vit. A in the autoclavable diet have been converted into ppm and IU/g, respectively.
 Data taken from Agway Inc. (n.d). Rat, mouse, hamster 3000.
"JData taken from Ralston Purina Company (1980).
"Data taken from NIH (1980).
*Data taken from AIN (1977) and NAS (1978).
' As carotene.
'Vitamin D,.
"CasalL
'Hydrochloride.

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Raf'd
Growth, gestation
Nutrient lactation Maintenance
Protein, %

Fat.%
Digestible energy, kcal/g
Fiber, %
Linoleic acid, %
Total digestable
nutrients (TON), %
L-Amino acids, %
Arginine
Asparagine
Olutamic acid
Histidine
Isoleucine
Leucine
Lyiine
Methionine
Phenylalanine + tyrosine
Praline
Threonine
Tryptophan
Nonessential
Minerals
Calcium, %
Chloride, %
Cobalt, mg/kg
Magnesium, %
Phosphorus, %
Potassium, %
Sodium, %
Sodium chloride, %
Sulfur, %
Chromium, mg/kg
Copper, mg/kg
Fluoride, mg/kg
Iodine, mg/kg
Iron, mg/kg
Manganese, mg/kg
Selenium, mg/kg
Vanadium
Zinc, mg/kg
\2.W

5.00
3.8
NO*
0.6
NO


0.60
0.40
4.00
0.30
O.SO
0.75
0.70
0.601
0.80
0.40
0.50
0.15
0.59*

0.50
0.05
/
0.04
0.40
0.36
0.05
NO
0.03
0.30
5.00
1.00
0.15
35.00
50.00
0.10
NO
12.00
4.201

5.00
3.8
NO
NO
NO


/
/
/
0.08
0.31
0.18
0.11
0.23
0.18
/
0.18
0.05
0.48"

NO
NO
/
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
Mouse"
growth
reproduction
12.5,
18.0
NO
NO
NO
0.3
NO


0.3
NO
NO
0.2
0.4
0.7
0.4
0.5
0.4
NO
0.4
0.1
NO

0.4
NO
NO
0.05
0.4
0.2
NO
NO
NO
2.0
4.5
n
0.25
25.00
45.0
o
P
f
Golden
Hamster"'
15.0

5.0
4.2
NO
NO
NO


0.76
NO
NO
0.40
0.89
1.39
1.20
0.32
0.83 + 0.57
NO
0.70
0.34
NO

0.59
NO
1.1
0.06
0.30
0.61
0.15
NO
NO
NO
1.6
0.024
1.6
140.00
3.65
0.1
NO
9.2
Guinea pig"4
growth
18.0

<1«
3.0
10.0
NO
NO


NO
NO
NO
NO
NO
NO
NO
NG
NO
NO
NO
NO
NO

0.8-1.0
NG
NO
0.1-0.3
0.4-0.7
0.5-1.4
NO
NO
NG
0.6
6.0
NO
1.0
50.0
40.0
0.1
NO
20.0
Rabbit*
Dog*-"
20.0

4.5
NG
NO
0.9
NO


NG
NO
NO
NO
NO
NO
NO
NO
NG
NO
NO
NO
NO

1.0
NO
NO
0.036
0.8
0.5
NG
1.0
NO
NG
6.5
NG
1.39
54.0
4.5
0.10
NG
45.0
Growth
16.0

2.0
2.5
10-12
NG
65


NG
NG
NG
0.3
0.6
1.1
0.65
0.6
1.1
NO
0.6
0.2
NG

0.4
0.3
NO
0.03-0.04
0.22
0.6
0.2
NO
NO
NO
3.0
NG
0.2
o
8.5
NG
NG
o
Maintenance
12.0

10
2.1
14
NG
5


NO
NG
NO
NG
NO
NO
NO
NG
NG
NG
NO
NG
NO

0
0.3
NO
0.03-0.04
0
0.6
0.2
NO
NG
NG
3.0
NO
0.2
0
2.5
NO
NG
o

-------
Rat*-"
Nutrient
Vitamins
A,IU/kg
D, lU/kg
E.IU/kg
K,. Mg/kg
Choline, mg/kg
Folio acid, mg/kg
Niacin, mg/kg
Pantothenate, mg/kg
(Calcium)
Riboflavin, mg/kg
Thiamin, mg/kg
B,, mg/kg
B,2, Mg/kg
Biotin, mg/kg
Inositol (myo-)
Vitamin C, mg/kg
Growth, gestation
lactation Maintenance

4,000.00
1,000.00
30.00
50.00
1,000.0
1.00
20.0
8.00

3.00
4.00
6.00
50.0
k
1
m

NG
NG
NG
NG
NG
*NG
M NG
NG

NG
NG
NG
NG
k
1
m
Mouse"-"
growth
reproduction

500.0
150.0
20.0
3,000.00
600.0
0.5
1010
10.0

7.0
5.0
1.0
0.01
0.2
/
m
Golden
Hamster"-'

3,634.00
2,484.00
3.00
4,000.00
2,000.0
2.00
90.0
40.0

15.0
20.0
6.0
10.0
0.6
100.0
m
Guinea pig"4
growth

20,328.00
1,000.00
50.0
5,000.00
1,000.0
4.00
10.0
20.00

3.00
2.00
3.00
10.00
0.3
NG
200.00
Rabbit'
Dog*-"

4,500.00
450.00
45.00
NG
1,100.0
0.16
10.3
9.0

2.0
0.90
0.90
20.00
0.09
NG
m
Growth

580.0
i
40.0
*
1,200.0
NG
180.0
NG

NG
NG
39.0
NG
NG
NG
m
Maintenance

o
t
o
k
NG
NG
NG
NG

NG
NG
NG
NG
NG
NG
m
"Data taken from NAS (1978).
'Data taken from NAS (1974).
'Data taken from NAS (1977)
'Based on 90% dry matter.
'Unless indicated,  requirements listed for growth are the same for reproduction.  When indicated, first value listed is for growth, second for reproduction. Values
  are estimated minimal requirements for conventional mice.
/Estimates based on minimal amounts in diets adequate for growth for 6 weeks following weaning.
'Minimal requirements.
*Nutrient levels selected to meet the requirements of the most demanding life cycle segments, i.e., rapid growth and lactation.
'Although not stated by author, presumably none required.
'NG - not given.
*Not required, produced by bacterial synthesis in intestine.
'Not required under conventional laboratory conditions.
"Dietary source not required.
"Controversial whether or not required.
"Required; no quantitative data given.
'No data; may be needed in ultraclean environments.
«Unsaturated fatty acid.
'Probably required; amount unknown.
'As ideal protein.
'Partially supplied by L-cystine.
"Mixture of glycine, L-alanine, and L-serine.

-------
2. NUTRITIONAL REQUIREMENTS FOR LABORATORY ANIMALS - COMPARISON OF THE
   DATA PROPOSED IN THE EPA GOOD LABORATORY PRACTICE STANDARDS WITH
   THOSE OF COMMERCIAL PRODUCERS. NIH. AND AIN
     Nutritional requirements vary from species to species and also with
the physiological state of the animal within the same species.  Guinea
pigs and rabbits, for instance, can utilize cellulose to some extent
(MAS 1977, 1978).  This is reflected in the commercial diets for these
animals.  Purina guinea pig chow and rabbit chow include as much as 16
and 18% crude fiber, respectively (see Table 1).  The NAS recommendation
for fiber content of the guinea pig and rabbit diets is 10 and 10-12%,
respectively (see Table 2).  Of the laboratory animals under discussion,
guinea pigs are unique in their absolute dependence on a dietary source
of vitamin C.  All commercial diets for guinea pigs are supplemented
with vitamin C (see Table 1).  Special and richer diets are often used
in commercial reproducing colonies (NAS 1978) because, contrary to gen-
eral assumption, diets that produce maximum postweaning growth are not
necessarily adequate for maximum rates of reproduction.

     It is worthwhile to point out that the Appendix B of the TTSEPA
(1979) was probably written with respect to the rat, mouse, and hamster,
although these animal species are not specified.  It apparently was not
written for rodents in general since vitamin C, which is essential in
the diet for the guinea pig, is not included in the list of dietary
requirements.  Also, Purina rodent chow #5002 (Ralston Purina Company
1980) is a misnomer, since this chow, lacking in vitamin C, is not
intended for the guinea pig.  The proper designation for these chows
should mention the names of the animals for which they are intended, as
exemplified in NIH (1980) and Agway Inc. (n.d.) (see Table 1).

     As Table 1 indicates, commercial feed manufacturers are generally
in good agreement with the dietary requirements proposed by EPA for
rodent diets (a 10% variance is permitted by EPA).   Notable exceptions
are manganese (140 ppm vs 61.7 ppm for Agway rat-mouse-hamster 3000
diet) and pantothenic acid (32 ppm vs 17 ppm for Purina rodent chow),
vitamin A [100 lU/g (30 ppm) vs 28.15 TO/g (8.44 ppm) for Agway's rat-
mouse-hamster autoclavable diet], and vitamin K (20 ppm vs 1.38 ppm for
Agway's rat-mouse-hamster autoclavable diet).

     Table 2 shows the estimated nutrient requirements for the species
of concern in this study as recommended by the National Academy of Sci-
ences (NAS 1974, 1977, 1978).  These data support the use of special
diets in production colonies.  Comparison of the nutrient requirements
listed in Table 2 with those proposed by EPA and the dietary composition
of commercially available feeds (see Table 1) indicates that for most
nutrients, the EPA and commercial levels are generally higher than the
estimated requirements recommended by the NAS.  This is because the
nutrient concentrations in commercial diets and those proposed by EPA
are formulated to compensate for losses during the manufacture and
storage as well as for differences in biological availability of
nutrients.

-------
3. EVALUATION OF DIFFRBEMT TYPES AND FORMS OF DIETS
     The two criteria most widely used for judging the adequacy of a
diet are: (1) growth curves and (2) reproduction data (i.e., litter
size, average weight at birth, average number weaned, average weaning
weight, and estrus cycle).  Normal growth data for hamsters, rats, and
mice are presented in Table 3, and growth curves for rabbits, guinea
pigs, and dogs are shown in Figures 1, 2, and 3, respectively.  Newberne
(1982) has suggested that the study of the subchronic effect of a com-
pound for 90 days should be used to establish dose levels that will
result in no more than 10% depression in body weight gain.  Reproduction
and life span data for these animal species are shown in Table 4.  Vari-
ous types of laboratory animal diets are described in the following sec-
tions.  A carefully designed long-term tozicity experiment with labora-
tory animals should take into account the possibility of induction of
enzymes by the dietary components and/or contaminants.  Such enzymes may
have the potential to alter the tozicity of the chemical under investi-
gation (Newberne 1975).  This topic is discussed in Section 9.4.

3.1 Types of Diets - Advantages and Disadvantages

     3.1.1 Natural-Ingredient Diets

     These diets are economical and are the most widely used.  They are
made from appropriately processed whole grains such as wheat, corn,
oats, or commodities that have been subjected to limited amounts of
refinement such as fish meal, soybean meal, or wheat bran.  Some of the
disadvantages are: the necessity for commercial manufacture; the inabil-
ity to completely control the nutrient concentrations; batch-to-batch
variation in nutrient concentration; difficulty in altering composition
to study the effect of the absence of a particular nutrient; and the
potential for contamination with pesticide residues, heavy metals, or
other agents that might alter the response to experimental treatment
(NAS 1978).

     3.1.2 Purified Diets

     Diets formulated with refined ingredients such as casein, sugar,
starch, vegetable oil, and cellulose are known as purified diets.  Some
of the advantages are that (1) ease of preparation in the laboratory,
(2) capability for duplication of nutrient concentrations or alteration
for induction of nutritional deficiencies or excesses, and (3) low
potential for chemical contamination.  Disadvantages include being more
expensive than natural-ingredient diets and not palatable to all species
of animals (NAS 1978).  Purified diets can be both open formula and
closed formula diets.

     3.1.3 Chemically Defined Diets

     These diets are prepared by mixing chemically pure compounds such
as amino acids, sugars, triglycerides, essential fatty acids, inorganic
salts, and vitamins.  Two advantages are ease of preparation in the

-------
                                                 Table 3. Nonul Growtfc Rate of the HuMtcr, Rat, ud Mow
Range and average body weights (g) as a function of age (days)
Animal species
Outbred Golden Hamsters
CnRHG (SYR)
Male
Female
Rats: Sprague-Dawley
Male
Female
Rats: Fischer
Male
Female
Inbred mouse:
Male
Female
21
range

29-51
30-50
50-61
45-63
24-39
22-39
7.7-15.8?
7.5-14.8*

av.

40
40
46"
44"
NG
NG
11.0
10.2
28
range

32-71
31-69
71-114
71-130
28-56
35-51
11.3-20.5*
9.9-18.6°

av.

49
44
75"
64°
53°
44°
15.7
14.2
42
range

NGC
NG
NG
NG
NG
NG
14.4-28.7?
13.1-25.8*

av.

NG
NG
NG
NG
NG
NG
21.0
18.6
58
range

86-98
85-104
206-259
188-205
155-209
105-156
16.1-30.8*
15.1-28.96
84
av.

92
95
236°
185°
160°
123°
24.1
21.5
range

99-109
103-127
317-385
231-283
183-238
112-175
NG
NG
av.

104
115
302a
210a
213°
145"
NG
NG
112
range

NG
NG
NG
NG
NG
NG
23.2-35.7?
21.1-37.6°
168
av.

NG
NG
NG
NG
NG
NG
30.2
28.1
range

128-142
150-167
436-482
275-301
312-380
203-238
NG
NG
av.

141
158
365"
230"
256°
162°
NG
NG
"Average body weights are averages of figures given by two different suppliers of the two strains.
Vr
 Range of averages for 26 inbred mouse strains.
cNot given.

Source: NAS (1978).

-------
                                                                                             ORNL-DWG 82-17970
oo
                h-
                LU
10
 9
 8
 7
 6
 5
 4
 3
 2
 1
 0
                                        I    I     I
I     I    T
              AGE: days  30  40   50   60   70
                  weeks       6      8     10
                 months  1             2
                            80   90  100  110  120  130  140  150  160  170 180  190  200
                                 12             16             21             25
                                 3456
           Figure 1.  Growth curve for rabbit (New Zealand White).  (Source:  Dutchland Laboratories, Inc. 1982.)

-------
   900
                                                        ORNL-DWG 82-17971
   800  I—
   700  I—
   600  h-
* 500  I—
o
   400  h-
   300  I—
   200 I—
   100 I—
                           6       8       10
                                   AGE (weeks)
12
14
16
      Figure 2.  Growth data for guinea pig (Ft. Detrick Dunkin Hartley)
 (Source:  Dutchland Laboratories, Inc. 1982.)

-------
                                                          ORNL-DWG 82-17972
                                                                  61.7

                                                                  59.9
                                              COCKERS
                                              BEAGLES
                                              SCOTTIES
                                                FOX TERRIERS
                                                DACHSHUND
                                                BOSTONS
                                              PEKINGESE
                 0  2
10  12  14  16  18  20  22  24 26 28 30
     MONTHS
      Figure  3.  Growth curves for  fifteen breeds of dogs.
1974, p. 1.)
                                   (Source:   NAS
                                        10

-------
                                   Table 4. Reproduction" and Life Spai* Data on Selected Laboratory Animate

Weight
Adult male

Adult female
At birth
Breeding Age
Male
Female
Breeding Data
Estrus cycle

Gestation
Weaning age
Litter size
Breeding life
- Male
Female
Rebreeding
Mating


Life span

Hamsters

85-1 10 g

95-1 20 g
2g

60 days/85-1 10 g
60 days/95-120 g

4-15 days

15-19 days
20-24 days/35 g
6-10

1 year
10-12 months/4-5 litters
4-6 days
Pair


1 yr. av.,
2 yr. max.
Mice

20-40 g

25-40 g
1-5 g

50 days/20-35 g
50-60 days/20-30g

4-5 days

17-21 days
16-21 days/10-12 g
1-23/av. 12

18 months
6-10 litters
immediately
Pair or colony;
1 male, 3 females

1.5 yr. av.,
3 yr. max.
Rats

300-400 g

250-300 g
5-6 g

100 days/300 g
100 days or 200 g

5 days

20-22 days
21 days/40-50 g
8-12

1 year
1 year
immediately
Pair or colony
1 male, 3-4 females

3 yr. av.,
4 yr. max.
Dogs

13.-18.5 kg
(beagle)
13.5-16 kg
350-450 g

10-12 months
9-12 months

bi-annually

60-65 days
6-8 weeks
4-8

6-14 years
6-10 years
next heat period
1 male, up to
40-60 females

15 yr. av.,
35 yr. max*
Guinea pigs

1000-2000 g

850-900 g
100 g

90-150 days/550 g
90-150 days/500 g

post partum
16-18 days
59-67 days
10 days/250 g
1.6/av. 4

5 years
4-5 years
immediately
Colony: 1 male,
3-10 females

3 yr. av.,
7 yr. max.
Rabbits

4.5-5 kg

4.5-6.5 kg
100 g

6-7 months/4 kg
5-6 months/4.5 kg

polyestrus

30-32 days
8 weeks/1.8 kg
1-18/av. 8

1-3 years
1-3 yean
35 days
Pair. Mate in
bucks cage;
1 male, 6-10 females
6 yr. av.
15 yr. max.
"Data taken from Ralston Purina Company (n.d.).
*Data taken from Agway Inc. (n.d.).

-------
laboratory and strict control of nutrient concentrations.  The fact that
these diets are too expensive for general use and that availability of
nutrients may be altered by oxidation or interactions among nutrients
represents the principal disadvantages  (NAS 1978).

     3.1.4 Open Formula Diets

     These are diets of known ingredient composition and are manufac-
tured from natural, purified, or chemically defined ingredients.
Specifications for open formula diets not only  state the amount of each
ingredient to be used but also define the minimum acceptable nutrient
composition of ingredients to be used.  Advantages include the fact that
the diet can be procured by competitive bidding, resulting in lover cost
compared with the brand name diets under sole source negotiated con-
tracts, and that the investigator has the option to make alterations in
nutrient composition to satisfy specific program objectives (NIH 1980).


     3.1.5 Closed Formula Diets

     Most widely used closed formula diets are  natural-ingredient diets,
but  the  ingredient  compositions are well-kept secrets of the manufactur-
ers.   In general, most  laboratory animals thrive on these diets.  Some
disadvantages are  that  these diets  introduce an unknown element (such as
nature and composition  of  ingredients)  that can be critical to the
interpretation of  the results  in a  particular investigation and that the
diets  can be procured only through  negotiated sole source contracts.  A
list of  ingredients as  well  as  the  nutrient composition of the diet is
provided by  the manufacturer  (NIH 1980).  These diets have extensive
historical background data.  Recently,  Newberae (1982) reported wide
variation  in the nutrient  composition of  closed formula diets, and toxic
component  composition of natural ingredient diets from commercial
sources  has  been reported  (Table 5).

     3.1.6 Quasi-Open Formula  Diets

     The closed  formula diet  can be procured  through  competitive bidding
by specifying  a  list of acceptable  ingredients  and thereby constitutes a
quasi-open formula diet.   However,  the  manufacturer  is not obligated to
use all  of the  listed  ingredients  (NIH  1980).

3.2 Forms of Diets

     Diets in various  physical forms  have been  used  for  laboratory
animals.   These  include (a)  meal,  (b) pelleted, (c)  crumbled,  (d)
extruded,  (e) baked,  (f)  flaked,  (g)  semimoist  or gel  forms,  and  (h)
liquid.  For a  detailed discussion of these different forms of diet, the
reader is  referred to  the  document  published by the National  Academy of
Sciences (NAS  1978).   The  pelleted,  extruded, gel, and liquid forms of
diets  are  discussed below.

     The pelleted  diet  is  the one most  widely used for feeding labora-
tory animals.  During  the  pelletization process,  meal  is heated  to 180-
190°F  for  30 seconds to form dense  compressed pellets that are  easier  to
                                    12

-------
                   Table 5. Concentrations of selected nutrient and toxic components
                           in random samples of rodent natural product diets
          Component
Requirements,
     rat"
   Diet analysis*
Minerals
  Calcium (%)
  Phosphorus (%)
  Magnesium (%)
  Copper (ppm)
  Zinc (pppm)
Amino acids
  Tryptophan (%)
  Methionine (%)
  Phenylalanine + tyrosine (%)
Vitamins
  Vitamin A (mg/kg)
  Vitamin D (lU/kg)
  Riboflavin (mg/kg)
Toxicants
  Aflatoxins (ppm)
  Nitrates (ppm)
  Nitrosamines (ppb)
    JV-dimethylnitrosamine
    JV-nitrosopyrrolidine
  Lead (ppm)
     0.56
     0.44
     0.04
     5.60
    13.3

     0.17
     0.67
     0.89

     0.67
    1108
   0.5-4.0
0.5, 0.27,  1.67
1.90, 0.68, 0.13
0.54, 0.02, 0.23
3.8, 6.9, 65
20, 17, 10, 60

0.10, 0.39, 0.08
0.13, 1.21, 0.22
2.01, 1.05, 1.82

2.10, 0.31, 3.75
987, 1360, 5100
12, 0.3, 0

0.01, 0.20, 0.12, 0.0
90, 5, 10,  18, 32

8, 0, 32, 18
0, 7, 5, 16
0.8, 1.8, 4.2, 2.5
"Requirements according to the National Research Council, 1978a.
* Each line represents different samples from the  same manufacturer. Analysis conducted at MIT over a
  period of 15 years.
Source:  Newberne 1982.
                                                13

-------
handle and store.  Wastage is minimized, and the daily dietary  intake of
the test animals is relatively easy to measure.  However,  if admin-
istered in the diet, the substance under study has to be incorporated in
the meal before the pellets are made.

     During the manufacture of the extruded diet, the meal  is subjected
to moist heat (350-400°F for 1 minute).  This treatment partially cooks
the starch and makes the diet highly palatable to some animals,  e.g.,
nonhuman primates, dogs, cats.  However, other laboratory  animal species
waste a lot of feed, and frequent feeding  is necessary because  of the
low diet density.

     Diets in semimoist or gel forms are produced by adding water, agar,
gelatin, or other jelling agents, to meal.  These diets are more palat-
able than dry rations and more convenient  for incorporating the sub-
stances to be tested.  They also allow efficient measurement of food
consumption.  However, because these diets are susceptible to microbial
growth, they must be kept frozen or refrigerated and feeding must be at
frequent intervals.  Large quantities  are  thus difficult to handle.

     Following the pioneering liquid diet  research of Lieber and DeCarli
(1966), Bio Serve Inc. has been offering isocaloric liquid diet formula-
tions for rats, mice, and dogs.  This  diet offers an excellent  delivery
option in toxicity studies of volatile test substances.

3.3  Autoclaving of Diets

     Extent of loss of heat sensitive  components of the diet, e.g.,
vitamins, is partly determined by the  procedure used during autoclaving.
It is perhaps desirable to recommend a standardized procedure in the EPA
Good Laboratory Practice  (USEPA 1979)  for  autoclaving laboratory animal
feed.  One procedure, used by Agway  (Agway Inc. n.d.),  is  outlined
below.

     PROCEDURES FOR STERILIZATION OR
     PASTEURIZATION OF R-M-H 3500

     Since  autoclaves differ,  these  procedures will be  outlined in
     three  (3) generalized phases  so that  the operator  of  any par-
     ticular  autoclave may  successfully  sterilize or pasteurize
     the  formula based on operational  procedures peculiar  to that
     autoclave.

     PHASE  I.  CREATE VACUUM AND DEVELOP  HEAT

     Adjust jacket pressure  to normal.  Place volume  of pelleted
     feed in  autoclave  according  to  its  capacity,  then  pull a
     vacuum up to 25 to 29  inches  for  approximately 15  minutes.
     Afterward,  slowly meter  in  steam  while  maintaining a  vacuum
     of 10  to 15  inches.  The  interval of  time  required should  be
     sufficient  to bring  the pellets to  a heat  of 180  to 190°F  (10
     to 15 minutes).  Meter steam  in slowly so  that  the pellets
     are brought  to the  above  temperature  and yet moisture is not
                                    14

-------
     permitted to condense on or within the pellets.  Experimenta-
     tion may be required.

     PHASE II.  PASTEURIZATION

     Tarn off vacuum pump.  Introduce full volume of steam.  This
     should elevate the temperature within the pellets to 215 to
     220°F.  This will require approximately 20 to 25 minutes from
     the time steam pressure reaches 15 Ibs.

     PHASE II.  STERILIZATION

     Turn off vacuum pump.  Introduce full volume of steam.  This
     should elevate the temperature within the pellets to 250 to
     260°F.  This will require approximately 20 to 25 minutes from
     the time steam pressure reaches 15 Ibs.

     PHASE III.  EXHAUST AND DRY

     Open chamber exhaust and vent to 2 to 5 Ib. of steam pres-
     sure.  Turn on vacuum pump pulling 20 to 25 inches to remove
     steam from the autoclave.  The drying cycle (approximately 30
     minutes depending on capacity of vacuum pump and quantity of
     feed) may be adjusted according to desired dryness.  Stop
     vacuum pump and introduce bacteriologically filtered air into
     the chamber.

3.4  Discussion

     Highly purified diets and chemically defined synthetic diets are
the diets of choice when true and reliable standard diets are required
over an indefinite period.  However, these diets have two main disadvan-
tages — they are expensive and they are not consumed well by all
species.  The use of the natural-ingredient diets of known composition
(open formula) has been advocated (AIN 1977).  Admittedly there is sea-
sonal and year-to-year variation in the composition of the natural
ingredients but by specifying the standards of the quality of the
ingredients, the variability can be kept to a minimum.  The list of
approved ingredients should be revised from time to time to allow inclu-
sion of new, improved, or more economical substitnents.  However, as
Knapka (1974) has pointed out, "the use of open formula rations  could
result in a liability without adequate control of product quality and
sanitation of manufacturing facilities.  Quality assurance at NIH is
obtained by requiring that the facilities used to manufacture the ration
be in compliance with the sanitation standards in the National Insti-
tutes of Health Standard Number 1"  (NIH 1980).  It  is  imperative  that
other animal feeds containing drugs (e.g., cattle feed, poultry feed)
should not be manufactured on the same premises where laboratory animal
feed is manufactured to avoid possible cross contamination.

     The closed formula diet on the other hand has a history of accept-
able performance although the investigator is left in the dark so far as
the composition of the natural ingredients is concerned.  These diets
                                   15

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are also generally more expensive  than  the open  formula  diets.  The
manufacturers closely guard the secrecy of the diet  formula,  and  they
are free to alter the composition  of  the ingredients  according  to their
availability and prices (AIN 1977).   It will be  very  difficult  to
unearth any interaction between dietary components and the  test sub-
stance in experiments using closed formula diets.  Although the open
formula diet need further development and improvement, compared with the
closed formula diet, the ability to control the  diet  composition  will
certainly aid in obtaining sound and  reproducible animal experiments.
The National Institutes of Health  are currently  using open  formula diets
for the rat, mouse, hamster, guinea pig, and rabbit.  The food  for dogs,
however, is purchased via an advertised contract using a specification
for a quasi-open formula diet.  Manufacturers may use any combination of
the listed ingredients to produce  a diet with the indicated nutrient
concentrations (NIH 1980).

     Recent data indicate that highly purified diets  are not infallible,
although the use of such diets for definitive studies has been  strongly
recommended (Newberne 1982).  The  AIN-76A™ diet, for example,  has been
reported to cause severe periportal lipidosis in the livers of  male  F-
344 or CD rats (Hamm et al. 1982). The AIN-76711 diet causes nephrocal-
cinosis in female Sprague-Dawley rats  (Nguyen 1982).  The presence of
traces of solvents used in the purification of some  of the  ingredients
in semisynthetic diets may also cause complications.

     Assuming that a perfect diet, free from contaminants,  preserva-
tives, etc., is used in long-term  toxicity  testing with  animals,  one
cannot help but raise the question of how relevant will  data from such
tests be for assessing the risk to man, who  is normally  fed his share of
preservatives, pesticide residues, etc.  It  appears  that the practical
solution to this problem is  to establish adequate quality control over
nutrients and contaminants and rigid  protocols  in natural ingredient
diets to ensure reproducibility of results  free  from any interference
due to dietary factors, no matter  whether closed formula or open formula
diets are used in the experiment.  Newberne  and  McConnell (1981)  have
also  strongly  recommended surveillance  over both contaminants and
nutrients  in natural product  as well  as semipurified diets.  This has
become  extremely  important  in view of the fact  that  closed  formula diets
have  been  found  to  differ considerably in the  composition of nutrients
and contaminants  (Newberne 1982,  Table  5).
                                    16

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4.  DIETARY INTAKE
     During the long-term toxicity test, it is not unusual  for  an  animal
to lose or gain weight at a lower than normal rate.  The weight loss  or
reduced rate of weight gain may be due to low dietary  intake or to the
toxic effect of the chemical or to both.  Excessive weight  in laboratory
animals should also be avoided since the response to chemical stress  of
an overweight animal is likely to be different from that of a normal
animal.  It is critical, therefore, to monitor the food intake  of  the
test animals.   Equal food intake between control and  test  animals can
be achieved by pair feeding (Newberne et al. 1978).  Most laboratory
animals are coprophagous, which introduces an unknown  element in the
diet through ingestion of soiled bedding.  This factor however,  can be
minimized by the use of screen-bottomed rather than solid-bottomed cages
(Newberne 1978).

     The effects of dietary restrictions on immunity and aging  have been
reported by Weindrnch and Makinodan (1981).  Undernutrition without mal-
nutrition has led to increased life-span and lower spontaneous  cancer
incidence in mice (Weindruch and Walford 1982).  What  is true for  mice
may be true for humans, but it may not be wise to do long-term  toxicity
studies with laboratory animals on restricted diets since this  will
introduce an additional factor in extrapolating the results of  animal
experiments to human exposure.  Besides, administration of  restricted
diets to a large number of laboratory animals is expensive  and  diffi-
cult.
                                    17

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5. VITAMINS AND MINERALS USED IN ANIMAL DIET FORMULATIONS
5.1 Vitamins

     The guinea pig is unique among the laboratory animal species under
discussion (mouse, rat* hamster, guinea pig, rabbit, and dog)  in its
dietary requirement for vitamin C (MAS 1978).  Most other animals can
synthesize sufficient amounts of vitamin C to meet their daily require-
ment so the vitamin does not need to be added to their diet.   Unfor-
tunately, the ascorbic acid in the pelleted  feed is not stable.  This
phenomenon has been investigated at Hoffmann-La Roche (n.d.) using cry-
stalline ascorbic acid and ethylcellnlose-coated ascorbic acid.  Fifty-
one percent of the ethylcellulose-coated ascorbic acid is retained after
storage for 3 months at room temperature whereas only 27% of the
uncoated crystalline ascorbic acid was retained under the same condi-
tions.  Ethylcellulose-coated ascorbic acid  is used in NIB open formula
diets (NIH 1980).  Additional ascorbic acid  supplementation of the feed
is necessary if the feed is to be used during the second 3-month period
of storage.

     The preservative ethozyquin is used as  a stabilizer for vitamin A
in both the NIH open formula diet and commercial diets (see Sect. 7.4).
Preservatives and their use for this purpose should be considered for
inclusion in the proposed EPA guidelines.  Present EPA guidelines (USEPA
1979) do not permit the use of any preservative in the animal  feed.

     Inositol is not normally required in  the diet of laboratory
animals; however, the National Academy of  Sciences recommends  a level  of
100 ppm in the diet of the golden hamster  (MAS 1978).  Inositol may also
be required under special circumstances, e.g., rodents kept on antibiot-
ics  (NAS 1978).

     Table 6 lists sources of vitamins included in the EPA GLP (USEPA
1979), NIH open formula rations for mouse/rat and germ-free mouse/rat
(NIH 1980), AIN-76™ purified mouse and rat  diet  (AIN 1977), Purina
Rodent Chow #5002 and  autoclavable Rodent  Chow #5014  (Ralston  Purina
Company 1980), and Agway R-M-H 3000 and autoclavable R-M-H 3500  (Agway
Inc. n.d.).  Choline bitartrate and thiamine hydrochloride have been
used  in the AIN-76TM purified diet in place  of choline chloride and thi-
amine mononitrate, respectively.  The  latter two  sources are  included  in
the EPA GLP  (USEPA 1979) and  are  also  constituents of commercial diets.
Consideration should be given to  the  inclusion of choline bitartrate and
thiamine hydrochloride in  the proposed guidelines  (USEPA 1979).  Purina
Rodent Chows #5002 and #5014  apparently do not include any source of
biotin and probably depend on the natural  occurrence  of biotin in feed
ingredients.

5.2  Minerals

     Table 6  lists sources of minerals  included  in  the EPA GLP (USEPA
1979), NIH open  formula rations  for mouse/rat  and germ-free mouse/rat
(NIH 1980), AIN-76TM purified mouse  and  rat  diet  (AIN 1977), Purina
                                     18

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                                       Tabte 6. Vitamins, Minerals, umi Aafanal Diet FormbtW

                                                 NIH*

A. Yitamims
Vitamin A acetate
Vitamin A palmitate
EPA
GLP*
;
Mouse/rat
diet
•j
j
mouse/rat
diet
^
AIN-76*
purified
diet''
-

Rodent Autoclavable
chow |5002 chow |5014 R-M-H 3000
j
"<*T
R-M-H 3500
(autoclavable)
'
  Vitamin D activated
     animal sterol (03             j         j            •/•/•/              J              j              j
  Menadione activity             «         j            s           s
  dl,a-Tccopherol acetate         -j         j            j           j
  Choline bitartrate                                                   J
  Choline chloride                j         j            s                       j              j              j              j
  Folic acid                      j         j            j           j           j              •/              •/              •/
  Niacin                         ^         j            j           s           j              s                       -j            •>           j           ^              
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Rodent Chow #5002 and autoclavable Rodent Chow #5014  (Ralston Purina
Company 1980), and Agway R-M-H 3000 and autoclavable R-M-H 3500 diets
(Agway Inc. n.d.).  As Table 6 indicates, the sources of these minerals
other than those specified in the USEPA (1979) include the following:
copper oxide, cnpric carbonate, ferrous carbonate, ferric citrate, zinc
sulfate, zinc carbonate, monocalcium phosphate, manganous carbonate,
potassium iodate, citrate, sulfate, sodium selenite,  and chromium potas-
sium sulfate.  In addition to the latter five sources mentioned above,
monocalcium phosphate, zinc carbonate, ferric citrate, and cupric car-
bonate are used only in the AIN-76^M purified mouse amd rat diet.  A
purified diet requires supplementation with trace elements because
essentially none are provided in the major ingredients.  Although
chromium is required in the purified AIN-76^ diet and in the NAS recom-
mended guinea pig diet (Tables 1 and 2 respectively), it is not used  in
Ralston Purina or Agway Inc. commercial diet formulations (Table 1).
Silica is used as an anticaking agent in autoclavable diets -  Purina
Rodent Chow #5014 and Agway R-M-H 3500.  Most of the  diet formulations
except the purified diet depend on the natural presence of selenium in
the feed ingredients and do not include any extraneous selenium in the
form of sodium selenite, although the addition of extraneous selenium
has been permitted by the EPA as an exception to the  Delaney clause (see
Sect. 10.3).  Copper oxide, cupric carbonate, ferrous carbonate, iron
ammonium citrate, zinc sulfate, zinc carbonate, manganese carbonate,  and
potassium  iodate are included in the 6RAS list  (USFDA 1980a) (Table 7).
Consideration should be given to expansion of the list of mineral
sources in USEPA  (1979) to  include these different mineral forms and
silica, allowing some flexibility in the diet formulation.
                                    20

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      Table 7. Trace minerals included in the GRAS List0
  Element
      Source compounds
Cobalt
Copper
Iodine
Iron
Manganese
Zinc
Cobalt acetate
Cobalt carbonate
Cobalt chloride
Cobalt oxide
Cobalt sulfate
Copper carbonate
Copper chloride
Copper gluconate
Copper hydroxide
Copper orthophosphate
Copper oxide
Copper pyrophosphate
Copper sulfate
Calcium iodate
Calcium iodobehenate
Cuprous iodide
3,5-Diiodosalicylic acid
Ethylenediamine dihydroiodide
Potassium iodate
Potassium iodide
Sodium iodate
Sodium iodide
Thymol iodide
Iron ammonium citrate
Iron carbonate
Iron chloride
Iron gluconate
Iron oxide
Iron phosphate
Iron pyrophosphate
Iron sulate
Reduced iron
Manganese acetate
Manganese carbonate
Manganese citrate (soluble)
Manganese chloride
Manganese gluconate
Manganese orthophosphate
Manganese phosphate (dibasic)
Manganese sulfate
Manganous oxide
Zinc acetate
Zinc carbonate
Zinc chloride
Zinc oxide
Zinc sulfate
"These substances added to animal feeds as nutritional dietary
 supplements are  generally recognized  as safe when added at lev-
 els consistent with good feeding practice.
 Source:  USFDA (1980a).
                             21

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6. INGREDIENTS USED IN LABORATORY ANIMAL DIETS
     All of the ingredients  listed  in Appendix B  of  the EPA Good Labora-
tory Practice Standards, July 26, 1979  (TJSEPA 1979),  are  used  in the  NIH
and commercial diet formulations  (see Table  8).   However,  some
ingredients are not included in the above-mentioned  list  but are used in
both NIH and commercial diet formulations.   These include  animal fat
protected with butylated hydroxyanisole  (BHA), cane  molasses, meat  and
bone meal, and dried  skimmed milk.   In  addition,  the commercial diets
include casein, dried whey,  ground  beet  pulp, and wheat germ meal,  which
are not used in the NIH diet (Table 8).   The NIH  dog diet  formulations
allow the use of  the  following preservatives in various ingredients:
BHA, propylene glycol, propyl gallate,  and citric acid  (NIH 1980).
Animal feeds containing animal fat  without preservative have a  shelf
life of about 12  weeks when  stored  at room temperature  (personal commun-
ication from Dr.  John C. Chah, Ziegler  Bros. 1982).   However, when  soy
oil is used as a  source of fats,  it contains enough  natural antioxidants
(tocopherols) to  obviate the necessity  of adding  any extraneous preser-
vative.

     From the available information it  seems that none  of the  feed
manufacturers have  any control over the  supply of the food ingredients,
although this is  where the most effective control on the  major  source of
contaminants in the feed can be exercised.   It would seem advisable to
include in a given  set of guidelines the specifications  (grade, etc.)
for individual ingredients.  To illustrate the point consider  the NAS
specification for wheat (NAS 1974). As  many as six  different  types of
wheat have been listed as common  dog food ingredients:  (1) wheat, durum,
triticum durum. (2) wheat, hard red spring,  triticum aestivum,  (3)
wheat, hard red winter, triticum  aestivum, (4) wheat red  spring, triti-
cum aestivum, (5) wheat, soft, triticum aestivum, and (6)  wheat, soft
red winter, triticum  aestivum.  These vary considerably in their nutri-
tional quality (e.g., protein content varies from 12 to 16.3%  on dry
basis).  The NTH  open formula diet  avoids all these  uncertainties by
specifying hard winter wheat (NIH 1980).

     The other source of contaminant control is the  guidelines  for
proper sanitation in  facilities used to manufacture  the ration (NIH
1980, Appendix A, Standard 1) .
                                    22

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                                                                  Table 8. Ingredients Commonly Used in Laboratory Animal Diets
u>
                                    .    ..
                                    ingrcaicnt
                        Agway
                     R.M-H 3000
    Purina 5002
certified rodent chow
Purina canine
 diet #5007
 Purina guinea
pig chow #5026
NIH open formula
 mouse & rat diet
Alfalfa meal
Brewers dried yeast
Corn gluten meal
Dicalcium phosphate
Fish meal
Ground whole wheat
Ground #2 yellow
  shelled corn
Ground whole oats
Ground limestone
Salt
Soy oil
Soybean meal
Wheat middlings

Ground beet pulp
Wheat germ meal
Cane molasses
Dried whey
Dried skimmed milk
Casein
Animal fat & BHA
Meat  & bone meal
                                                                      A. Ingredients listed in the EPA GLP (USEPA 1979)
                                                          •/                  /                     v                    v
                                                          
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7. CONTAMINANTS AND PRESERVATIVES IN ANIMAL FEEDS
7.1 Introduction

     Contaminants in laboratory animal  feeds  arise  from biological  as
well as nonbiological sources.  Biological contaminants originate  from
microorganisms growing on plants  in  the  field,  grain,  and  prepared  feed.
These are mainly estrogens, aflatozins,  and trichothecene  toxins.   Non-
biological contaminants are usually  pesticide residues and nitrosamines.

     When laboratory animals consume any contaminant  residue  daily in
their diet, they are in effect chronically exposed  to a considerable
amount of the contaminant over their lifetime;  for  instance,  when  a rat
is  exposed to 100 ppb of lindane  in  its  daily dietary intake  of 12  g,
the total chronic exposure over its  life-span of  3  years amounts to
about 1.3 mg.  These dietary contaminants have  the  potential  for affect-
ing the outcome of  long-term animal  experiments in  various ways.  They
may act as carcinogens, cocarcinogens,  cancer promoters, teratogens,
mutagens, or general toxicants.   They may also  induce the  production of
microsomal enzymes  that may affect the  metabolic  pattern and  inhibit
neoplasia  (see Sect. 9.4).  In either case, both  inhibitors and enhanc-
ers of toxicity are present in the natural ingredient diet.  These  diets
thus differ  from semipurified diets  in  the way  they 'permit'  an animal
to  respond to  a test substance, usually in the  animal's  favor (Newberne
and McConnell  1981).  This protective action  may  have a  good  or bad
effect on  experimental results, depending on  the  purpose of the study.
This effect  extends to spontaneous as well as chemically induced tumors.
If  the objective  is to accumulate animal data for extrapolation to
assess the toxicity to man, the presence of  these dietary  contaminants
in  the animal  feed  may not be bad since it  is practically  impossible for
humans to  consume  food completely free  from pesticide residues.

     Preservatives  are chemicals  deliberately added to animal feed to
increase  its  shelf  life  and preserve the easily oxidizable vitamins
present  in the feed.  The  following  subsections will describe in more
detail biological  contaminants,  nitrosamines, and preservatives and will
examine  the  differences  between  EPA's proposed  contaminant tolerances
for rodent diets  and the contaminant levels  found in commercial rodent
feeds.

7.2 Biological Contaminants

     7.2.1 Estrogens

     Table 9 lists  three estrogens that may occur in animal feed.   These
are formed when a  crop  is  infected with fungi in the field or during
storage.   The  three estrogens  in Table  9 show a low level  of estrogenic
activity in  the  following  order:  genistein >  coumesterol > zearalenone.
Therefore, they are usually not  of much concern in animal  feed manufac-
ture.  However,  when animals  are used for studies on reproduction, the
estrogenic activity of  the feed should be assayed.
                                    24

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                                                                              Table 9. Estrogens in Animal Feed
                        Estrogen
Chemical structure
                                                                                Estrogenic activity
                                                                               compared with DBS
                                                                                 (on oral dosing)
Occurrance
Stability
Genistein
                                                                                                          <10->
                                                              Soybeans (6 Mg DES/kg)
                                Heat stable
                    Coumestrol
ro
                                             <35 X 10-'       Alfalfa,  soybeans;   alfalfa  infested  with  fungal   Heat stable
                                                              pathogens (115 ppm)
                     Zearalenone
                                                         OH     o      CH3
                                             620 X 10~s       Possibly  produced on corn during  storage particu-
                                                              larly when infested with Fusarium graminearum
                                                                                                                                                        Heat stable
                    Diethylstilbestrol
                     Source: Compiled from Stob (1973).

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     7.2.2 Aflatoiins

     Aflatozins are a family of 10 or more brightly  fluorescing  furano-
coumarin compounds.  The most prominent of these  are Bl, B2.  Gl,  and G2-
62 and 62 are partially reduced (dihydro) forms of Bl  and Gl,  respec-
tively.
                      6  0
                             10
                            OCH3
              Aflatoxin Bi(B2)
             OCH3

Aflatoxin G!(G2)
     Aflatozins  are produced by Aspergillus  flavus,  a  common mold grow-
 ing on  a variety of food materials  including corn,  soybean,  peanuts,
 rice, and wheat.  Although  aflatozin Bl  is  fairly stable  to  heat, a
 reduction of  aflatozin Bl in peanut  meal from 7000 to  340 ug/kg  has been
 achieved by autoclaving the moist meal  (60%  moisture content) at 15 Ib
 pressure (120°C)  for  4 h.   The photodecomposition of aflatozin is known
 to occur at fairly low light levels  (Wilson  and Hayes  1973).

     Aflatozin Bl appears to be the  most potent hepatocarcinogen known
 (Miller 1973).   Moderate to high  incidences  of hepatomas  and hepatocel-
 lular carcinomas have occurred  in rats  continuously administered afla-
 tozin in the  diet at  concentrations  as  low  as IS ppb.   Experimental evi-
 dence suggests that aflatozin Bl needs  to be metabolically activated  to
 be carcinogenic  in vivo  (Miller 1973).

     The ubiquitous presence of the  mold Aspergillus flavus  indicates
 the  improbability of  complete  elimination of aflatozin contamination
 from animal  feed; however,  high humidity and a temperature of 25°C have
 been found  to be conducive  to  the growth of  this mold.  Like most fungi
 Aspergillus  flavus  is highly aerobic.   The FDA has lowered the maximum
 amount  of aflatozins  permissible  in food products as methods of detec-
 tion and control have improved.   The upper  limit has been set at 20 ppb
 (total, Bl, B2«  Gl, and G2) in  feeds [EPA proposed guidelines (USERA
 1979) specify 5  ppb]  and 0.5 ppb  aflatozin MI in milk  (USFDA 1980b).
 Aflatozin MI  is  a metabolite of aflatozin Bl (4-hydrozy derivative of
 aflatozin Bl) and has been  identified  in the milk of cows ingesting
 aflatozin Bl.
                                    26

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      7.2.3  Tricothecene  Toxins

      These  my co tor ins  comprise  a  family of  closely related sesquiter-
penoids produced by  various  species  of  fungi  such as  Fusarium,  Myrothe-
cium. Trichoderma, Trichothecium.  Cephalosporium,  Verticimonosporium and
Stachybotvs and are  collectively  called trichothecenes  after tricothe—
cin,  the  first isolate,  discovered in 1949  by Freeman and Morrison.
Fusarium  tricinctum  and  Fusarium  roseum are the  two most important fungi
as  far as animal feeds are concerned.   The  former causes moldy  corn  (or
hemorrhagic) disease and the  latter  causes  vomiting and feed-refusal in
animals.  Both can grow  on corn,  barley,  and  rye.   T-2  toxin, HT-2
toxin, and  diacetoxyscirpenol are produced  by Fusarium  tricinctum. and
deoxynivalenol, nivalenol, zearalenone  and  an unknown factor are pro-
duced by Fusarium roseum.  The  chemical structure,  LD50» natural
occurrence,  and biological effects of these toxins  are  described in
Table 10.

     It has been suggested by Schoental (1981) that some of  the incon-
sistencies  in epidemilogical and  experimental studies on the role of
various types of fats  in the etiology of  cardiovascular disorders and
certain tumors may be related to  the presence of  adventitious contam-
inants (e.g., tricothecenes) in the  fats.

     Various toxicological (e.g., vomiting  in ducklings),  cytological
(e.g., cytotoxicity to HeLa cells) and  biochemical  (e.g.,  inhibition of
protein synthesis in rabbit reticnlocytes)  assays have  been  developed
for tricothecenes.  A sensitive radioimmunoassay  capable of  detecting 1
and 2.5 ppb of T-2 toxin in wheat and corn, respectively,  has been
recently reported (Lee and Chu  1981).

7.3 Nitrosamines

     Nitrates and nitrites have been used for the preservation  of fish
and meat, often in conjunction with sugar,  spices,  polyphosphates,
a-tocopherol, and sodium ascorbate.  The use  of ascorbic  acid is  rather
fortuitous  since it greatly reduces the chance for  nitrosation  of amines
in the stomach by nitrous acid.  Besides protecting meat  from spoilage
by bacteria such as Clostridium botulinum.  nitrite  imparts red  color to
the meat.  It reacts with myoglobin to  form nitrosylmyoglobin,  which
during cooking becomes denatured; the color is retained because  of the
formation of nitrosylmyochrome.

     N-Nitroso compounds are produced in food principally from  the reac-
tion of naturally occurring secondary amines with nitrites that may  have
been added to the food or formed from bacterial reduction  of nitrate.
The most common volatile nitrosamine present  in food is  N-nitroso-
dimethylamine (NDMA).  N-Nitrosopyrrolidine and N—nitrosomorpholine  have
also been detected.   The latter, however, has been  shown to be  formed
principally from morpholine used as a corrosion inhibitor  in boilers
when food is processed by steam in a smokehouse.
                                   27

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                                                                                                 Table 10. Fnsarinm Toxins"
rO
CO
                                             Toxin
                                                                  Formula
      LDso'
       Foods Naturally
     Contaminated with
         Mycotoxin
                                                                                            Comments
                                       Fusarlum trtclnctum
                                         Diacetoxyscirpenol
                                         T-2 toxin
                                         HT-2 toxin*
                                       Fusarium roseum
                                         Nivalcnol
                                         Deoxynivalenol"
                                           (vomitoxin)
                                        Zearalenone
Structure I
RLR2.R3-H
R4,Rj,—OAc
   RS-OH
Structure I
Rl,R3-H
R2—3-methylbutyryloxy
R4,R6-OAc
RS-OH
Structure I
R,,R3=H
R2—3-methylbutyryloxy
R4-OAc
R$.R6-OH

Structure I
RI.=O
R3,R4.R5,R
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     Volatile nitrosamine contamination of  laboratory animal  diets has
been investigated by Edwards et al.  (1979).  Low  levels  of  N-nitro-
sodimethylamine  (1-4 ppb) have been  found in most  of  the commercial pel-
leted diets.  Higher levels (5-50 ppb) of N-nitrosodimethylamine  (NEWA)
have been detected in three out of seven samples  of NIH  open  formula rat
and mouse ration, and low levels of  N-nitrosopyrrolidine (0.3 ppb to 2.1
ppb) have also been detected in these samples.  Silverman and Adams
(1983) investigated the presence of  N-nitrosamines in laboratory  animal
feed and bedding used by NIH using a gas chromatograph with a thermal
analyzer.  N-Nitrosodimethylamine was detected  in  all samples of  NIH-07
meal (1.2-6.9 ppb) and 62% of NIH-07 pellets (0.6-35.2 ppb).  It  was
also detected in 66% of closed formula meal (1.9-45.1 ppb)  and  83% of
closed formula pellets (0.2-21.3 ppb).  Low concentrations  (1-4 ppb)
were found in samples of hardwood chip and corncob bedding.  It appears
that the poor quality of the fish meal is responsible for the higher
nitrosamine content of NIH-07 diets.  The elevated temperature  created
during the regrinding of food pellets to produce meal diets may be a
contributing factor to the formation of nitrosamin.es.  In addition,
atmospheric nitrogen oxides may be absorbed and subsequently react with
secondary or tertiary amines on the  greater surface area of the meal
diet.

     It has been demonstrated that as little as 10 ppb of MDMA  included
in the water supply of Strain A/J mice (tumor-prone)  during the whole
fetal, weaning, and post-weaning period (up to 22 weeks  of  age) causes a
tripling in the lung tumor incidence from 8% to 23% (Edwards and  Fox
1979).  However, it is likely that even 50 ppb of NDHA may not  cause a
significantly increased incidence of cancer in non-tumor-prone  mice.
Synergistic effects of MDMA with 3-methylcholanthrene have been demon-
strated at a high NDHA level but not at the low levels found in labora-
tory animal diets.  However, it seems advisable to keep  the level of
MDMA in laboratory animal diets as low as possible to avoid any poten-
tial problem.

     At one time it was thought that an appreciable quantity of volatile
nitrosamines present in the feed is  lost during the pelletization pro-
cess (Enapka 1979), but this view is now discounted (personal communica-
tion from Enapka 1982, NIH, and Shelton 1982, Ralston Purina).  One  com-
menter has reported (comments respective to proposed  EPA guidelines)
that antoclaving of the feed reduces the nitrosamine  content.   Although
there appears to be no documentation of this observation in the open
literature, investigating ways and means for reducing the nitrosamine
content of fish meal used in the production of laboratory animal  feed
would certainly provide valuable information.

     The detection and estimation of nitrosamines in  animal feed  at  the
ppb level is carried out using a thermal energy analyzer nitrosamine
detector, interfaced with a gas or liquid chromatograph  (Edwards  et  al.
1979).
                                    29

-------
7.4 Preservatives

     Two of the most widely used preservatives  in  laboratory animal  feed
are ethoxyquin and butylated hydrozyanisole  (BHA).  The  former  is  used
as an antiozidant in vitamin A  formulations  (She1ton  1982,  NIB  1980).
Ethoxyquin retards the oxidation of  carotene, xanthophylls,  and vitamins
A and E and prevents organic peroxide  formation in canned pet food.   It
is also added to dehydrated forage prepared  from alfalfa, barley,
clover, bermnda grass, corn, fescue, oats, orchard grass, sorghums,
wheat, etc., for this same reason.   The  tolerance  limit  for ethoxyquin
in animal feed has been  set at  150 ppm by  the FDA  (USFDA 1980a).

     Vitamin A stabilized with  ethoxyquin  is manufactured by Hoffmann-La
Roche, New Jersey.  In a micronized  form,  it contains gelatine  and other
additives, as well as ethoxyquin, 7%,  and  vitamin  A acetate, 650,000
lU/g.  This calculates to 8 ppm of ethoxyquin  in  feed containing 75  III
of vitamin A/g (EPA proposed maximum in  rodent  feed,  see Table  1), well
below the tolerance limit set by the FDA.  However, the  purified diet
described for rabbits in the Nuritional  Requirements  for Rabbits (MAS
1977) permits a rather high concentration  of ethoxyquin  (250 ppm).

     Soybean oil contains sufficient amounts of natural  antioxidants,
making further addition  of preservatives unnecessary; however,  whenever
animal fat  is used  in feed  formulation,  BHA  has been  frequently used as
a preservative.  For  instance,  Purina  Rodent Chow #5002  does not contain
animal fat  and consequently no  BHA.  The Agway RMH 3000  diet, Purina
Canine Diet #5007, Purina Guinea Pig Chow  #5026,  and  the NIH dog diet
formulation contain  animal  fat  and unspecified amounts of BHA.   There is
no  evidence of storage of BHA  in  fatty tissues  in rats ingesting BHA and
no  evidence of chronic toxicity in rats  fed  up  to  91% (1000 ppm) in  the
diet for 2 years  (Patty's Industrial Hygiene and  Toxicology 1981a).
Both ethoxyquin and BHA  have been  found, however,  to  be  potent  inducers
of  hepatic  epoxide hydratase when  administered in the food  of rats at
0.1% for 14 days  (Kahl and Klaus 1979),  potentially resulting in
enhanced metabolism of a toxicant.

     Appreciable  improvement  (20-30%)  in the stability of vitamin  C  in
pelletized  feed during storage  has been claimed for the  ethylcellulose-
coated vitamin C preparation of Hoffmann-La  Roche. The  NIH open formula
diets  specify the use of this  stabilized form  of  vitamin C.  However,
the product has yet  to gain popularity with  feed  manufacturers. Ethyl-
cellulose presumably  affords protection by acting as  a moisture barrier
(Hoffmann-La Roche n.d.).   It  is very  inert  physiologically and has  been
found  to be nontoxic  (Patty's  Industrial Hygiene  and  Toxicology 1981b).

     The NIH open  formula diet  also  permits  the use of propylene glycol,
propyl gallate, and  citric  acid as preservatives  in animal  feed (NIH
1980); however, the  allowable  concentrations of these ingredients  have
not been  specified.
                                    30

-------
7.5 Tolerance Limits of Contaminants and Preservatives  in Animal  Feed

     Table 11 lists the tolerances proposed by EPA for  certain contam-
inants and preservatives in rodent diets (USEPA 1979).  For  comparison
the maximum concentrations of feed contaminants considered acceptable
for natural ingredient rations for rodent diets of the  National Center
for Tozicological Research (NCTR) (NEC 1976), and the maximum  levels  of
contaminant permitted (guaranteed analysis) in the Agway R-M-H (rat-
mouse-hamster) 3000 diet and guinea pig diet  (Agway Inc. n.d.)  and  in
the Ralston Purina Guinea Pig Chow #5026 and Rodent Chow #5002 (Ralston
Purina Co. 1980) are also provided.  Also included in Table  11 are  the
maximum permitted contaminant levels in several nonrodent diets.  When
the data in this table are compared, the following becomes evident:
      1.  The EPA maximum tolerances exceed those of NCTR for all con-
          taminants with the exception of estrogenic activity (1 ppb vs
          2 ppb) and PCB (50 ppb vs 500 ppb).

      2.  The Agway R-M-H 3000 and guinea pig diets are identical with
          respect to maximum allowable levels of contaminants whereas
          the maximum permissible concentrations of malathion, DDT, cad-
          mium, mercury, and PCB are lower in these diets than in the
          Purina Rodent Chow #5026.

      3.  The guaranteed maximum levels of contaminants permitted in
          commercial rodent diets exceed the proposed EPA maximum toler-
          ance for lindane, heptachlor, DDT (Purina chows only), dield-
          rin, cadmium, mercury (Purina chows only), and PCB (Purina
          chows only).

      4.  No preservatives are allowed according to the proposed EPA
          guidelines, whereas all the commercial producers use bntylated
          hydroxyanisole in diets containing animal fats.

Besides the contaminants listed in Table 11, the feed industry also mon-
itors the level of heptachlor epoxide (a metabolite of heptachlor),
endrin, chlordane, benzene hexachloride, toxaphene, phorate, diazinon,
disulfoton, methyl (ethyl) parathion, endosulfan, ethion, and carbo—
phenothion.  The maximum levels of these contaminants permitted in Agway
and Purina rodent feed are indicated in Table 12 and, as shown, are
quite similar between the two producers.  (Table 11 was restricted to a
comparison of those contaminants listed in the proposed EPA guidelines -
a list which the EPA recognizes as being inconclusive.)

     In addition to the contaminants listed in Tables 11 and 12, a host
of chemicals (primarily pesticides) are identified by the FDA (USFDA
1980a) and EPA (USEPA 1981) as potential contaminants in animal feeds.
Table 13 lists some of the chemicals more likely to be found in labora-
tory animal feeds, along with their uses and tolerance levels.  Neither
the EPA nor the FDA tolerance listed is that for the finished feed but
rather for raw commodities and feed ingredients, respectively.  Pyreth-
rins in conjunction with piperonyl bntoxide have been reported to be
                                   31

-------
                                                   Table 11. Contaminants and Preservatives in Laboratory Animal Feeds
EPA proposed
tolerance for
rodent diet
Contaminants min.
Aflatoxins (total)
ppb
Estrogenic activity
(DBS eq), ppb
Lindane, ppb
Heptachlor, ppb
Malathion, ppm
DDT (total), ppb
Dieldrin, ppb
Cadmium, ppb
Arsenic, ppm
Lead, ppm
Mercury, ppb
Selenium, ppm 0.1
PCB, ppb
Nitrosamines,
ppb
Antibiotics
Preservative
max.
5*


1
20
20
2i5
100*
20
160
1.0
1.5
100
0.6
50
10

0
0
National Center'
for Toxicological
Research
rodent diet
1.00


2.00
10.00
10.00
0.50
150.00
10.0
50.0
0.25
1.00
50.0
0.5
500.00
NG

NG
NG
AgwayCl^
(Charles River)
R-M-H
3000
5.0


NG
50
30
0.3
100
30' "<•
200
1.0
1.5
100
0.2
50
NG

NG
BHA+*
Agwayc
Purina Purina (Charles River) Agway
Rodent Chow* Guinea Pig Guinea (Charles River)
#5002 Chow* #5026 Pig Diet Rabbit Diet
10.0


NG
50
30
0.5
150
50.0
500
1.0
1.5
200
NG
150
5-12>

NG
NG
10.0


NG
50
30
0.5
150
50.0
500
1.0
1.5
200
NG
150
NG

NG
BHA+*
5.0


NG
50
30
0.3
100
30'
200
1.0
1.5
100
0.2
50
NG

NG
BHA+*
5.0


NG
50
30
0.3
100
30'
200
1.0
1.5
100
0.2
50
NG

NG
NG
Agwayc Purina*' Purina
(Canine Diet Rabbit Chow* Canine Diet
respond 2000 #5322 #5007
5.0


NG
50
30
0.3
100
30'
200
1.0
3.0
100
0.2
50
NG ,

NG
BHA+*
10.0


NG
50
30
0.5
150
50.0
500
1.0
1.5
200
NG
150
NG

NG
NG
10.0


NG
50-
30
0.5
150
50.0
500
1.0
3.0
200
NG
150
NG

NG
BHA+*
NG — Not given.
"All data are maximum allowable levels unless otherwise stated.
*Data taken from USEPA (1979).
cData taken Agway Inc. (n.d.).
 Data taken from Ralston Purina Company (1980).
'Data taken from NRC (1976).
•'Rat-Mouse-Hamster diet.
* Animal exposure to aflatoxins in food is limited to the level of 20 ppb (total BI, 82, GI, 62) under the current FDA regulations (USFDA, 1981).
*The  permissible limit in animal feed is 5 ppm under the USFDA (1980).
 +Aldrin.
•'Personal communication from Purina.
 BHA, butylated hydroxyanisole.

-------
                            Table 12. Pesticides and Contaminants in Laboratory Animal Feeds

Common name
Aldrin + dieldrin



Heptachlorepoxide

Endrin

Chlordane


BHC



Toxaphene

Phorate, Thimet

Diazinon


Disulfoton

Methyl(ethyl)parathion


Endosulfan, Thiodan



Ethion

Carbophenothion,
Trithion

Chemical name
1 ,2,3,4, 1 0, 1 0-hexachloro-

4-endo-S,8-dimethanonaphthalene
(aldrin)


Hexachloroepoxyoctahydrc-endo,
endo-dimethanonaphthalene
1,2,4,5,6,7,8,8-Octachlor-
2,3,3a,4,7,7a-hexahydro-
4,7-methanoindane
Benzene hexachloride



Chlorinated camphene

O.O-Diethyl S-{(ethyIthio)-
methyl)phosphorodithioate
O.O-Diethyl O-(2-isopropyl-4-
methyl-6-pyrimidinyl)
phosphorothioate
O.O-Diethyl S-{2-(ethylthio)-
ethyl}phosphorodithioate
O,O-Dimethyl)ethyl)
o-p-nitrophenyl
phosphorothioate
6,7,8,9,10,10-Hexachloro
1 ,5,5a,6,9,9a-hexahydro-
6,9-methano- 1 ,4,3-benzo(e)-
dioxathiepin-3-oxide
O.O.O.O-Tetraethyl S.S-methylene
bisphosphorodithioate
S-{(p-chlorophenylthio)methyl|
O,O-diethyl phosphorodithioate

Use
Insecticide
(soil insects)


Metabolite of
heptachlor
Insecticide

Insecticide
(termites)

No longer produced
or sold for domestic
use in the United
States
Insectcide (soybeans,
sorghum, and peanuts)
Insecticide (alfalfa,
corn, wheat, etc.)
Insecticide and
pesticide

Insecticide and
acaricide
Insecticide


Insecticide



Insecticide

Acaricide

Tolerance, p]
Agway (Charles River)
R-M-H 3000*
0.03



0.03

0.03

0.05


0.05



0.2

0.3

0.3


0.3

0.3


0.3



0.3

0.3

?ma
Purina rodent
chow* #5002C
0.05+0.05



0.05

0.05

0.05


NG



NG

0.5

0.5


0.5

0.5+0.5


0.5



0.5

0.5

NG = Not given.
"Values are maximum allowable levels.
 Data taken from Agway (n.d.). Rat-Mouse-Hamster 3000.
cData taken from Ralston Purina Company (1980).
                                                     33

-------
                                                                                                Table 13. Pesticides IB Laboratory Animal Feeds
CO
-is
Tolerance (ppm)
Common name
Acephate
Aldicarb

Aluminum phosphide
NF


Banvel

Benomyl

Bcntazon, Basagran

Butachlor

Chlordimeform

Chlorpyrifos



2,4-D

Dalapon


Daminozide, Alar

Demeton, systox



Dialifor, Torak

NF

NF

NF

NF

Chemical name
O,S-Dimethyl acetylphosphoramidolhioare
2-Methyl-2(methylthio)proionaldehyde
O-(methyl-carbamoyl )oxime
Aluminum phosphide
4-Amino-6-(l,l-dimethylethyl)-
3-(methylthio)- 1 ,2.4-triazin-S
(4H)-one
2-Methoxy-3,6-dichlorobenzoic acid or
3,6-dichloro-o-anisic acid
Methyl 1 -(butylcarbamoyl)-2-benzimidazole
carbamate
3-( 1 -Methylethyl)- 1 H-2. 1 ,3-benzothiadiazin-
4(3H)-one 2,2-dioxide
2-Chloro-2'.61-diethyl-N- ., v
(butoxymethyl)acetanilide
N'-(4-Chloro-c-tolyl)-N,N-
dimethylformamidine
O,O-Diethy!O-(3,5,6-trichloro-2-pyridyl)
phosphorothioate


2,4-Dichloro-phenoxy acetic acid

2,2-Dichloropropionic acid


Butanedioic acid mono (2,2-dimethyl
hydrazide)
Mixture of O.O-diethyl O-|2-(ethylthio)ethyl|
phosphorothiate and O.O-diethyl
S-|2-(ethylthio)ethyl) phosphorothioate

S-(2-Chloro- 1 -phthalimidoethyl) O.O-diethyl
phosphorodithioate
N>-(2,4-Dimethylphenyl)-N-[{(2,4-dimethylphenyl)
unino)methyl]-N-methylmethanimidamie
2-Ethoxy-2,3-dihydro-3,3-dimethyl-S-benzofuranyl
methanesulfonate
S-[2-(EthylsuIfinyl)ethyl] O,O-dimethyl
phosphorothioate
O-Elhyl O-[4-(metbylthio)-phenyl] S-propyl
phosphorodithioate
Use
Insecticide
Systemic insecticides, acaricide,
nematicide for soil use
Fumigant insecticide
Herbicide


Herbicide

Fungicide

Herbicide

Herbicide

Insecticide

Insecticide



Herbicide

Growth regulation


Plant regulator

Systemic insecticide



Insecticide

Insecticide

Herbicide

Insecticide

Insecticide

Feed
Soybean
Cottonseed hulls
Soybean
Bulk grain
Barley, wheat
Sugar cane molasses
Tomato pomace
Corn, wheat, sorghum

Dehydrated citrus pulp
Citrus fruit
Soybean

Rice, bran

Cottonseed hulls
Cottonseed
Sugar beet molasses
Sugar beet pulp, dried
Sorghum milling fractions
Sorghum grain
Barley, oats, rye, wheat
Sugarcane molasses
Dehydrated citrus pulp
Citrus frut, grain crops
(excl. wheat)
Dried tomato pomace
Peanut
Sugar beet pulp
Sugar beet
Dehydrated citrus pulp
Citrus fruit
Dehydrated citrus pulp
Citrus fruit
Dehydrated citrus pulp

Sugar beet molasses
Sugar beet
Sorghum

Cottonseed hulls
Cottonseed
USFDA"
4C
0.3

0.1'
3.0
0.3
2.0
	 h

50.0

NA

0.5

10.0

3.0
11.0
1.5

2.0
5
20.0


600.Q
90.0*
5.0

5.0

15.0

3.0

0.5

2.0

1.0

USEPA*
1.0

0.02
0.01
0.75
NG
NO
	 h


10.0
0.05

NG


5.0
NG
NG

0.75
0.5


0.5


30.0

0.5

0.75

3.0



0.3
NG


0.5

-------
                                                              T«Me 13. (continued)
Tolerance (ppm)
Common name Chemical name
NF Hexakis (2-methyl-2-phenylpropyl)
distannoxane
Magnesium phosphide Magnesium phosphide

Methanearsonic acid Methanearsonic acid


Paraquat l,l'-Dimethyl-4,4'-bipyridinium dichloride

Phosalone, Zolone O,O-Diethyl S-{-(6-chloro-2-oxo-benzoxazolin-
3yl)-methyl)phosphorodithioate
Picloram, Tordon 4-Amino-3,5,6-trichloropicolinic acid
Piperonyl butoxide a-{2-(2-l-Butoxyethoxy)ethoxy)-4,5-
methylenedioxy-2-propyItoluene

Plictran Tricyclohexyl hydroxystannane

Profenofos, Curacron O-(4-Bromo-2-chlorophenyl)-O-ethyl S-propyl
phosphorothioate
Ui Propanil 3',4'-Dichloropropionanilide
«
Pyrethrins

Simazine 2-Chloro-4,6-bis(ethylamino)-s-triazine

TDE (DDD) 1 , 1 -Dichloro-2,2-bis(p-chlorophenyl)ethane

NF S.S.S-Tributyl phosphorotrithioate

Tutane Sec-butylamine

Zn ion + maneb


NA - not applicable; NF - not found; NO - not given.
"tolerances in feed ingredients, USFDA (1980).
Tolerances in raw commodities, USEPA (1981).
^Soybean meal.
Peanut meal.
'AS2C-3.
* Cation.
*No tolerance given.
Use
Insecticide

Fumigant insecticide

Herbicide


Herbicide

Insecticide

Herbicide
Synergist wih pyrethrin (insec-
ticide); treatment of bags
used for packaging food
Acaricide

Insecticide

Herbicide

Insecticide; treatment of bags
used for packaging food
Herbicide

Insecticide

Herbicide

Fungicide

Fungicide










Feed
Dehydrated citrus pulp
Citrust fruit
Not specified
Barley, corn, cottenseed
Cottonseed hulls
Cottonseed
Sugarcane mollasses
Sunflower seed hulls
Sunflower seed
Dehydrated citrus pulp
Citrus fruit
Barley, oats, wheat
Not specified
Barley, rye, wheat

Dried citrus pulp
Citrus fruit
Soybean
Cottonseed hulls
Rice milling fraction
Rice
Not specified
Barley, rye, wheat
Sugarcane molasses
Alfalfa
Dried tomato pomace
Tomato
Cottonseed hulls
Cottonseed
Dehydrated cirus pulp
Citrus fruit
Barley, oats, rye, wheat
Wheat
Corn grain








USFDA"
7.0

O.le

0.9/

3.(X
6.0*

12.0

3.0
10.0


8.0

— h
6.0
10.0

1.0

1.0

100.0

6.0

90.0

20.0










USEPA*

4.0

0.1

0.7


2.0

3.0
0.5-1.0

20.0


2.0
NO
NO

2.0

3.0

15.0

7.0

0.25

30.0

1.0
0.1








Use indicated in Farm Chemicals Handbook (1981).

-------
used for the treatment of bags used for packaging, primarily  to
discourage insect infestation of the stored food  (USFDA 1980a).  The
current manufacturing practice probably does not  make use  of  any insec-
ticide treatment of the bags used for packaging animal feed,  as exempli-
fied by the Ralston Purina Company (Jon Ford 1982).

     7.5.1 Considerations for Establishing Tolerances for  Contaminants

     Three of the most important considerations in setting tolerance
limits for contaminants in animal feed are analytical capability, bio-
logical no-effect levels, and interactions between dietary components
and contaminants.  There  is no point in setting a tolerance limit below
the detection limits of the currently available analytical techniques.
Normal screening levels of detection (not necessarily the  detection
limit) of different contaminants have been reported by Greenman et  al.
(1980) (see Table 14).  Assay of contaminants  at  such low  levels pro-
vides a challenge to the  analytical chemist.   Therefore, reproducibility
of various assays and variation from laboratory to laboratory need  to be
investigated.  The open literature contains biological effect and no-
effect data for some contaminants (see Tables  15  and 16).   Such data
need to be developed for  other contaminants of interest.   Interaction
between dietary components and toxicants  is an active area of research.
A few representative examples are given in Table  17.  Many dietary  con-
stituents such as BHA are known to affect the  metabolism of chemical
carcinogens by microsomal mixed-function  oxidases in liver, lung, intes-
tine, and other tissues  (Schrauzer 1977).  Any synergism,  antagonism or
initiator-promotor activity of the contaminant is certain  to  influence
the outcome of long-term  toxicity studies.

     7.5.2 Suggested Changes  in the Tolerance  Limits for the  Contaminants
Listed in the EPA GU
                           >
          7.5.2.1 Aflatoxins

     In harmony with the  current FDA guidelines  (USFDA 1980b), con-
sideration should be given for setting a  tolerance of 0-20 ppb.

          7.5.2.2 Estrogenic  activity

     This contaminant has not posed  any  serious problem  in the past so
far as animal  feed manufacture  is concerned  (Greenman  et al.  1980). The
estrogenic activity has been  found  to be  so  low  that  it  is no longer
monitored at NIH  (personal communication  from  J.  Enapka  1980). The NIH
bioassay procedure uses 4 ppb  of DBS  (diethylstilbestrol)  as  a positive
control, and animal  feeds are  regarded  to have positive  estrogenic
activity only  when  they  exhibit higher  activity  than  the standard con-
taining  4 ppb  of DBS.  The tolerance  level possibly  should be raised  to
4 ppb.

          7.5.2.3 Lindane

     Even  though  a  concentration  of  0-50  ppb  of  lindane  is allowed  in
animal  feeds by many producers, most of  the  commercial  feed analyzed by
                                    36

-------
                Table 14. Normal Screening Levels of Detection
      Analyte
Normal screening
level of detection
Reference
Aflatoxin
      5 ppb        Horwitz (1970c)
                   Stubblefield et al. (1967)
                   Beljaars et al. (1975)
                   Przybylski (1975)
Pesticides and PCBs
DDT
Dieldrin
Heptachlor
Lindane
PCBs
Malathion
As

Cd
Ca


Pb

Se
Hg
Cu
Zn

Vitamin A
Vitamin Bt
Fat
Protein


5 ppb
3 ppb
3 ppb
3 ppb
20 ppb
50 ppb
50 ppb

5 ppb
1000 ppb


500 ppb

40 ppb
20 ppb
20 ppb
20 ppb

10 lU/g
5 ppm
0.5%
0.5%


Bowman and Beroza (1970)
Bowman et al. (1971)
McMahon and Sawyer (1975a, 1975b)
Horwitz (1970d)
Burchfield and Johnson (1965)
Brody and Chaney (1966)
Hundley and Underwood (1970)
Horwitz (1970b)
J. Assoc. Off. Anal. Chem. (1973a)
Heckman (1968)
Horwitz (1970a)
Horwitz (1970b)
Horwitz (1970b)
J. Assoc. Off. Anal. Chem. (1973b)
Hoffman et al. (1968)
J. Assoc. Off. Anal. Chem. (1971)
Horwitz (1970a)
Horwitz (1970a)
Heckman (1968)
Bowman and King (1973)
Bowman (1973)
Horwitz (1970a)
APHA (1965)
USEPA (1969)
   Source: Adapted from Greenman et al. (1980), p. 237.
                                      37

-------
           Table 15.  Biologically Effective Concentrations of Selected Organic Feed Contaminants
Dietary
concentration
(ppm)
Compound Species
Aflatoxin Mouse

Rat

DDT Mouse




Rat


Dieldrin Mouse


Rat



Heptachlor Mouse

Rat

Lindane Mouse

Rat


Malathion Rat





End point
Liver lipids
Liver tumors
Liver hyperplasia
Liver tumors
Reproduction
Neoplasia
Liver tumors
Liver tumors
Lung tumors
Liver morphology
Microsomal enzymes
Microsomal enzymes
Reproduction
Mortality
Liver tumors
Microsomal enzymes
Microsomal enzymes
Liver weight
Brain lesions
Liver weight
Liver tumors
Microsomal enzymes
Microsomal enzymes
Tumor induction and
liver morphology
Microsomal enzymes
Microsomal enzymes
and liver weight
Liver weight
Cholinesterase
Cholinesterase and
EEG
DMBA-induced
tumors
Effect
0.114
1
0.001
0.015

3
2
250
10
5
2.5
1
2.5
10
0.1
5
5
1
0.34
1
5
5
2


50

20
100
1000

380«

250
No effect
0.057
-

-
3


20
-
1
2
0.2
-
1
-
1
2
0.1
0.02
-
1
1


50
20

2

100

-

-
Reference
Lindenfelser et al. (1976)
Newberne and Butler (1969)
Wogan et al. (1974)
Wogan and Newberne (1967)
Tarjan and Kemeny (1969)
Tarjan and Kemeny (1969)
Tomatis et al. (1972)
Terracini et al. (1973)
Shabad et al. (1973)
Laug et al. (1950)
Gillett (1968)
Kinoshita et al. (1966)
Virgo and Bellward (1975)
Walker et al. (1972)
Walker et al. (1972)
Gillett and Chan (1968)
Den Tonkelaar and Van Esch (1974)
Walker et al. (1969)
Harr et al. (1970)
Epstein (1976)
Epstein (1976)
Gillett and Chan (1968)
Den Tonkelaar and Van Esch (1974)

Weisse and Herbst (1977)
Den Tonkelaar and Van Esch (1974)

Pelissier and Albrecht (1976)
Cecil et aL (1974)
Hazelton and Holland (1953)

Desi et al. (1976)

Silinskas and Okey (1975)
"Estimated equivalent.
Source: Greenman et al. (1980), p. 242.
                                                   38

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Table 16. Biologically Effective Concentrations of Selected Heavy Metals



Element Species End point
As Mouse Reproduction
Growth and mortality
Mortality
Mammary tumors"
Rat Growth
Cd Mouse Reproduction
Mortality
Rat Renal vasculature
Hypertension
Pb Mouse Mortality
Growth
Antibody formation
Rat 5-Aminolevulinate
dehydratase
Mortality
Hg Mouse Mortality and growth
Rat Hypertension
Behavior and learning
Kidney ultrastructure
Se Mouse Reproduction
Growth and mortality
Mammary tumors'
Rat Growth, mortality,
and tumors
AAF-induced tumors'*
Hepatitis
Dietary or water
concentration
(ppm)
Effect No effect
5
5
5
10
62.5* 31.25*
10
5
0.2
1
5
5
14

10 1
5
5
5 2.5
2"
2*
3
3
2

2
0.5* 0.1*
2.5* 0.5*



Reference
Schroeder and Mitchener (197 la)
Schroeder and Mitchener (197 la)
Schroeder and Balassa (1967)
Schrauzer and Ishmael (1974)
Bryon et al. (1967)
Schroeder and Mitchener (197 la)
Schroeder et al. (1964)
Fowler et aL (1975)
Perry and Erlanger (1974)
Schroeder et al. (1964)
Schroeder and Mitchener (197 la)
Roller and Kovacic (1974)

Hubermont et aL (1976)
Schroeder et al. (1965)
Schroeder and Mitchener (197 la)
Perry and Erlanger (1974)
Olson and Boush (1975)
Fowler (1972)
Schroeder and Mitchener (197 la)
Schroeder and Mitchener (1972)
Schrauzer and Ishmael (1974)

Schroeder and Mitchener (1971b)
Harr et al. (1973)
Harretal. (1973)
"Decreased incidence, increased tumor growth rate.
•
Mixed in the diet; all others were administered
'Decreased tumor incidence.
Increased latent period.
Source: Greenman et al. (1980), p. 241.
in water.







                                  39

-------
                                             Table 17. Interaction of Dietary Factors with Toxicants
      Dietary factors
          Toxic agents
            Biological response
            Reference
Protein
 Deficiency
Fat
 Increased intake
  Addition of herring oil
   and linoteic acid
  High fat, low in choline,
   methionine, folic acid
 High fat

Lipotropes
 Low lipotropes
 Low lipotropes
  Low lipotropes, high fat
Carbon tetrachloride
 Dimethylnitrosamine
Pesticides
Mercuric chloride
Dimethylnitrosamine
Dimethylnitrosamine

Chloroform
Carcinogens

7,12-Dimethylbenzanthracene
Azaserine
Aflatoxin
7,12-Dimethylbenzanthracene
  Low lipotropes, high fat      N-2-fluorenylacetamide
Vitamins
 Vitamin A

 Vitamin A
 Ascorbic acid
  a-Tocopherol (Vit. E)
Polynuclear aromatic hydrocarbon

Benzo(a)pyrene
Secondary amines
3-Methylcholanthrene
Reduced toxicity (rats)

Increased toxicity
Reduced toxicity (rats)
Reduced carcinogenicity
Reduction in spontaneous hepatomas (rats)

Increased sensitivity
Maximum synthesis of cytochrome P-450

Enhanced liver tumor induction

More mammary tumors (rats) than in
 animals on regular diets

Increased susceptibility to liver carcinogenesis
Increased hepatotoxicity
More mammary tumors (rats) than in
 animals on regular diets
More mammary tumors (rats) than in
 animals on regular diets

Inhibits induction of squamous metaplasia
 and squamous  cell tumors
Enhanced induction of respiratory
 tract tumors

Reduces nitrosation
Reduces sarcomas in mice
McLean and Verschurn (1969)

Boyd (1969)
Swithin and Yagi (1958)
Swan and McLean (1968)
Silerstone and Tannenbaum (1951)

Goldschmidt et al (1939)
Marshall and McLean (1969)

Rogers et al. (1974),
 Rogers (1975)
Corrou and Khor (1970)
Shinozuka et al (1978)
Newberne et al (1968)
Newberne and Rogers (1976)

Newberne and Rogers (1976)
Saffiotti et al (1967)
Cone and Nettesheim, 1973
Smith et al (1975)
Smith, Rogers, and
 Newberne (1975)
Fan (1973)
Haber (1962)

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                                                             Table 17. (continued)
      Dietary factors
          Toxic agents
            Biological response
                                                                                                                        Reference
Minerals
 Arsenic

 High Zinc
 Selenium
 Selenium

 Low iron

 Low magnesium, potassium
Butylated hydroxyanisole,
 butylated  hydroxy toluene
High fiber  diet

Fiber
Butylated hydroxyanisole,
 ethoxyquin
Molybdenum (Mo)
Cadmium (Cd), Mercury (Hg)
Carbon tetrachloride (CC^)
Benzo(a)pyrene (BP)

Aflatoxin, estrogens

Carcinogen/procarcinogens
                             Benzo(a)pyrene (BP)
                             7,12-Dimethylbenzanthracene
                             Dimethylnitrosamine
Decreases cancer susceptibility; an
 essential micronutrient?
Increased toxicity to Mo (rats)
Decreased toxicity to Cd, Hg
Reduces the toxicity of CCLj which
 catalyzes lipid peroxidation.
Increased hepatic mixed function oxidase
 activity
Decreased oxidase activity
Decreases the carcinogenicity of BP

Reduces the toxicity and carcinogenicity
 of the agents
Decreases transit  time, alters the bacterial
 flora in the gut,  reduces incidence of
 colon cancer
Decreases the carcinogenicity of BP
                                                                                                             Frost (1978)

                                                                                                             Brinkman and Miller (1961)
                                                                                                             Farkas(1978)
                                                                                                             Fodor and Kemeny (1965)

                                                                                                             Becking (1976)

                                                                                                             Becking (1976)
                                                                                                             Carr (1982)

                                                                                                             Carr (1982)

                                                                                                             Burkitt(1971, 1976)
                                                                                Wallenberg (1979)
"No toxicant interaction.

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Greenman et al. (1980) during 1974-78 showed much less than 20 ppb (see
Table 18).  Feed manufacturers should be able to comply with the
currently set level of 20 ppb.  No change, therefore, seems warranted.

          7.5.2.4 Malathion

     Consideration should be given to reducing the tolerance level of
malathion from 2.5 ppm to perhaps 0.5 ppm  since it appears the feed
industry can easily comply  (see Tables 11, 18).

          7.5.2.5 Cadmium

     Commercial samples  (see Table 18) contained much less than the pro-
posed tolerance of 160 ppb  of Cd during 1974-78 (Greenman et al. 1980).
However, it should be noted that the Agway and Ralston Purina certified
diets may contain 200 ppb and 500 ppb, respectively  (see Table 10).  If
there is any problem meeting this tolerance level  (160 ppb), Cd-rich
ingredients in the feed  should be identified and replaced.  No change
seems warranted.

          7.5.2.6 Arsenic

     Until the status of As as a micronutrient is  established, the
current tolerance limit  of  1.0 ppm seems appropriate (see Sect. 10.2 for
further discussion).

          7.5.2.7 Selenium

     Consideration  should be given to reducing the upper level of Se to
0.4  ppm,  since Se at  a 0.5  ppm level has been reported to increase the
latent period  for 2—acetylaminoflnorene-induced tumors (Greenman et al.
1980)  (see Sect. 10.3 for;further discussion).

          7.5.2.8 Preservatives

     Addition  of ethozyquin, ethylcellnlose, and butylated hydrozyan-
isole  (BHA),  should perhaps be permitted  in the feed in keeping with the
current practice for  the preservation of vitamin A,  vitamin C and animal
fat, respectively.  This will  also permit  an increase  in the shelf life
of the feed  to six months  instead of three months  as currently stipu-
lated  in  the EPA GLP  (USEPA 1979).

     Hoffman-La  Roche formulations of protected vitamin A contain 7% of
ethozyquin;  at the  highest  level of vitamin A permissible in the feed
 (75  HJ/g)  in the proposed EPA  guidelines  (USEPA 1979), the concentration
of ethozyquin  is 8  ppm.  This  is well below the tolerance limit  set by
the  FDA  (150 ppm).  A tolerance  limit of  10 ppm for  ethozyquin in animal
feed would  seem  satisfactory.

     The  amount  of  crude fat used  in animal diet formulations can be
ezpected  to be as high as 9%  (see Table 1).  USFDA (1980a) allows a BHA
                                    42

-------
                                                                          Table 18. Results of Analyses of Laboratory Animal Diets
CO
Annual average*
Analyte-
Lindane (ppb)
Heptachlor (ppb)
Malathion (ppm)
DDT (ppb)
PCB (ppb)
Dieldrin (ppb)
Cd (ppb)
As (ppm)
Pb (ppm)
Hg (ppm)
Se(ppm)
Ca(%)
Cu (ppm)
Zn (ppm)
Vitamin A (lU/g)
Vitamin B, (mg/100 g)
Protein (%)
Fat (%)
1974
2.20
2.64
0.11
14.0
0.5
4.9
79.4
0.038
0.39
0.036
0.30
-
-
-
36.95
7.36
-
-
1975
5.96
4.10
0.38
151.61
0.5
12.15
84.93
0.01
0.89
0.037
0.43
-
-
-
27.68
8.91
-
-
1976
(«=54)
1.81
1.11
0.62
13.93
0.5
1.21
86.30
0.38
0.42
0.023
0.42
1.25
12.99
108.07
49.08
9.03
24.43
5.33
1977
0.84
0.32
0.10
18.10
19.85
1.43
93.15
0.32
0.34
0.019
0.22
1.16
15.20
106.66
40.31
9.46
23.80
5.72
1978
0.26
0.02
0.10
10.11
16.80
0.18
87.27
0.01
0.55
0.02
0.30
1.08
16.72
110.10
38.73
9.61
24.50
5.5
Mean
(«=148«)
1.67
1.07
0.33
27.7
8.7
2.35
87.3
0.25
0.47
0.024
0.34
1.16
15.0
108.2
41.6
9.1
24.2
5.54
Accumulated 5-yr value
SD
3.6
2.24
0.53
48.4
15.0
4.6
33.2
0.28
0.38
0.018
0.15
0.18
2.8
9.7
36.9
1.25
2.4
0.58
Maximum
value
40
12.3
2.4
309.1
55.0
26.3
168.0
0.92
1.92
0.16
0.66
1.67
22.0
140
439
13.1
44.4
6.6
Minimum
value
0.02
0.02
0.005
0.15
0.5
0.08
5.0
0.01
0.02
0.007
0.04
0.82
6.9
78
11.5
5.7
21.7
4.0
CV<
215
209
161
175
172
197
38
112
81
75
44
16
19
9
89
14
10
10
                                     •In addition to the analyses reported here, each lot was analyzed for aflatoxin and estrogenic activity, the results of these analyses were
                                       always less than the detectable concentration (5 ppb).
                                     'Five new analytes were added to the surveillance list in 1976; this accounts for the voids (indicated by dashes) in the table.
                                     'Results are reported for 148 production lots of autoclavable laboraory diet.
                                     'Coefficient of variation.
                                     Source: Greenman et al (1980), p. 240.

-------
level in the diet of 0.02% of the fat content.  Therefore, consideration
for a tolerance limit for BHA of 20 ppm in the finished diet should be
given.

     Both BHA and ethoxyquin have been shown to be good inducers of
enzymes and inhibit the carcinogenic effect of B(a)P and DMBA; however,
the level of the preservatives used in these experiments (Wattenberg
1972) is much higher (5-10 mg/g of feed) than what would be added to
animal feed to prolong its shelf life and will therefore probably not
result in any significant inhibition of carcinogenesis.

     7.5.3 Inconsistencies in EPA and FDA Tolerance Limits for
Contaminants

     A couple of inconsistencies apparently exist between the EPA and
FDA tolerance limits for aflatoxin and DDT.  The EPA Good Laboratory
Practice Standards  (USEPA 1979) specifies a maximum limitation of 5 ppb
for aflatoxin (Bi, 82, GI, and 62) in animal feed, whereas the Food and
Drug Administration Compliance Guide (USFDA 1980b) recommends legal
action if the aflatoxin level in the finished feed ingredients is above
20 ppb.  The EPA Good Laboratory Practice Standards (USEPA 1979) also
specifies a maximum limitation of 100 ppb for DDT (total) in animal
feed, whereas the FDA (USFDA 1980a) revised as of April 1, 1980, states:

          The following tolerance is established for residues
      of DDT resulting from use of DDT as a pesticide on the
      growing agricultural crop: 100 parts per million  in or on
      dried tomato pomace to be used in dog and cat food at lev-
      els up to 5 percent by weight of the prepared food.  If
      the residues of IDE (DDD) on tomatoes are also present,
      the total of both such chlorinated compounds shall not
      exceed 100 parts per million.
                          >
      This calculates to be 5 ppm of DDT (total) in the prepared feed,  a
level 50-fold higher than the limit (100 ppb) proposed in the EPA Good
Laboratory Practice Standards (USEPA 1979).  This is,  however, in con-
trast with an action level of 0.5 ppm for residues of  DDT, DDE, and TDE
individually or in  combination in processed animal feed prescribed in
the FDA Compliance  Policy Guide 7126.27, Attachment D  (USFDA 1981).
                                    44

-------
8. MONITORING AND ANALYSIS OF CONTAMINANTS IN FEED
     To insist that the industry analyze each batch of manufactured  feed
for the potential contaminants identified in Sect. 7 will put  an  almost
unbearable and expensive analytical burden on them. On the other  hand,
investigators sometimes assume that because control animals receive  the
same basic diet as experimental animals, variations in nutrients  or  con-
taminants will not have significant effect on the experimental outcome.
Such an assumption may not always be correct since dietary variables can
have significant interactions with experimental variables or parameters.
The necessity of monitoring the contaminants in animal diets has  been
addressed in an important paper by Greenman et al. (1980). These  authors
analyzed commercial rodent feed for a series of nutrients and potential
contaminants during a 5-year period. Frequently, Se was found at  concen-
trations at which it has been shown to interact with the process  of
chemical carcinogenesis. DDT, dieldrin, Cd, and Pb were occasionally
close to concentrations known to have biological effects. Besides the
seasonal and regional variation in the contaminant level of the feed
crop, there may also be variation from year to year as revealed in this
study. For instance, the DDT concentration in the commercial animal  feed
was highest in 1975 (152 ppb), whereas it was between 10-18 ppb in 1974
and in 1976-78. These considerations suggest that periodic monitoring of
the contaminants in the feed ingredients and the finished feed by the
manufacturer and the investigator are necessary to provide adequate
quality assurance as specified in USEPA (1979). Current awareness of the
farming practice and the environmental regulations should provide clues
to the manufacturer as to the nature of the contaminants for which he
should analyze. For example, after DDT was banned, its concentration in
the animal diet has gone down, and with increasing use of unleaded gaso-
line in cars, the concentration of Pb in the environment has been
reduced, with consequent reduction of the level of Pb in human blood
(Sterba 1982). Similar reduction in the Pb level in food crops can prob-
ably be expected.

     As previously mentioned, there is no point in setting tolerance
limits for contaminants at a level below the analytical capability for
detection and assay of the contaminants. In many cases the detection
limits and accuracy of analysis are unknown. The development of new
analytical methods and refinement of the existing methods for assay  of
contaminants at ppm/ppb levels should continue to be pursued by the
scientific community. The variability in the results of the assay
methods widely adopted in commercial and research laboratories should be
investigated by collaborative studies as described in AOAC (1980).
While no effort was made to include a comprehensive coverage of the
literature for different analytical methods for contaminant analysis,
the methods in use at the NIH laboratories are briefly described  in
Appendix A, and pertinent information concerning the analytical methods
currently in use at Ralston Purina Company Laboratories at St. Louis  is
given in Table 19.
                                   45

-------

Contaminant
Pb
Cd
Hg
Se
As
Aldrin, Heptachlor, Dieldrin,
Matrix
Alfalfa
Cereal
Feed
Feed
Feed
Feed
Feed
Average
recovery
86.7%
107.4%
93.2%



Mean level
of analyte
2.98 ppm
1.41 ppm
0.46S ppm
131 ppb
1 ppm
0.03%
Standard
deviation
0.29 ppm
0.14 ppm
0.032 ppm
8 ppb
0.12 ppm
0.002%
Coefficient of
variation
9.76%
9.65%
6.89%
6.4%
11%
5%
Confidence level/
sample wt
0.1 ppm/10 g
O.OS ppm/10 g,
0.02 ppm/25 g
SOppb/l.Og
O.OS ppm/ 1.0 g
0.2 ppm/ 1.0 g
0.02 ppm/10 g
References
for analytical
methodology
a
b
c
d
e
f
   DDE, DDT, Lindane, Chlordane,
   Endrin, BHC, HCB, Minx,
   Methoxychlor
 PCB
 Thimet, Diazinon, Disulfoton,
   Methyl Parathkn, Malathion,
   Parathion, Thiodan,
   Ethion, Trithion

 Aflatorin
Feed
Feed
                                   Feed
0.15 ppm/10 g


0.02 ppm/10 g


20 ppm/50 g
"AOAC (1980), 13th ed, 25.068-25.073.
*AOAC  (1980), 13th ed., 2.109-2.113, 7.096-7.098,  33.089-33.094; Perkin-Elmer, Analytical Methods for Absorption Spectrophotometry,
  3/73.
 Thorpe, Determination of Mercury in Food Products, Michigan Department of Agriculture (1970), modified.
 AOAC  (1975)  12th ed., 3.078;  Watltinson,  J.H., AnaL Chem. 38(\). Fluorometric  Determination of Se in Biological Material  with
  2,3-Diaminonaphthalene.; Haddad, P.R. and L-E-^mythe, Talanta, 24, 859,  1974.
'Monior, Williams G.W., Trace Elements in Foods, p. 213, John Wiley and  Sons, Inc., NY (1949); Bnmford, F., Poisons (1951) 3rd ed., p.
  73, The Blakeston  Co., Philadelphia, Pa.; Sandell, E.B., Colorimetric Determination of Traces of Metals, p.  142, Intersrience Publishers,
  New York, N.Y., 1974.
'Pesticide Analytical Manual, VoL I, Sec. 211.13-211.17, 212.101-212.136; AOAC (1975),  12th ed, 29.001-29.018.
f Pesticide Analytical Manual, VoL I & II; AOAC (1975), 12th ed, 29.001-29.018.
"AOAC (1975), 12th ed. Supplement Method 26.A01-26.A08.
Source: Ralston Purina Company (1982).
                                                              46

-------
9. INTERACTION OF DIETARY COMPONENTS
     Certain components in the laboratory animal diet are known  to
 interact with each other.  Awareness of this aspect of animal nutrition
 is essential for the successful formulation of animal diets.  The inter-
 play among Zn, Se, As, vitamins, amino acids, fatty acids, and phytate
 is described below, as is the importance of Ca:P and K:Na ratios in  the
 animal diet and the enzyme induction by dietary constituents and
 contaminants.

 9.1  Interplay Among Zn. Se. As. Vitamins, Amino Acids, Fatty Acids, and
     Phytate

     Zn plays a role in the metabolism of vitamin A (Smith et al. 1976),
 and Zn deficiency causes alteration in fatty acid patterns in the skin
 of rats under essential fatty acid deficiency conditions (Betteger et
 al. 1979).  Phytate present in soy protein interferes with the absorp-
 tion of Zn; therefore, when soy protein is used as the main source of
 protein in animal diets the Zn level is usually increased.  This is  the
 rationale for the higher Zn content of the AIN-76™ diet of 30 ppm (AIN
 1977) compared with the NAS-NRC recommendation of 12 ppm for the rat
 diet (NAS 1978).

     Selenium possesses anticarcinogenic properties at low levels in
 animals and humans (Schrauzer 1977).  The uptake of Se can be diminished
 by Zn, and diets rich in sulfur-containing amino acids diminish the
 physiological activity or availability of Se (Schrauzer 1977).   Arsenic
 behaves as an antagonist to Se in that it increases the urinary excre-
 tion of Se in rats and causes a deficiency of Se (Schrauzer 1977).
 There is also an interrelationship between Se and vitamin E.   Supple-
 ments of Se can prevent or cure liver necrosis in the rat and ozidative
 diathesis in the chick, which are manifestations of vitamin E defi-
 ciency.  Selenium, however,  is ineffective against other manifestations
 of vitamin E deficiency such as testicular and embryonic degeneration in
 the rat and encephalomalacia in the chick.  Sulfur-containing amino
 acids have a sparing effect on the vitamin E requirement in certain cir-
 cumstances and offer at least partial protection against liver necrosis
 and ozidative diathesis (Clark et al. 1977).

 9.2  Ca;P Ratio

     The Ca:P ratio is important in animal nutrition and should be  main-
 tained between 1.0 and 1.5 (NAS 1978).   As it has been pointed out  by
 one commenter (comments on the proposed EPA guidelines),  this ratio is
more important than the absolute amounts of Ca and P in the diet.  This
 fact should possibly be emphasized in the EPA GLP (USEPA 1979).

 9.3  K:Na Ratio

     The K:Na ratio varies from a low of 1.69 in Purina canine diet
#5007 to as high as 7.20 in the NAS-NRC recommended diet for the rat
 (Tables 1. 2,  respectively).   The protective  effect of K in rats during
high Na intake in the diet has been reported  (Heneely 1973).   The role
                                   47

-------
of the K:Na ratio in animal diets should be investigated particularly  in
view of the recent controversy of the value of a  low sodium diet  in
reducing hypertension  (Eolata 1982).

9.4  Enzyme Induction  and Inhibition of Neoplasia by Minor Dietary
     Constituents, Feed Additives, and Contaminants

     A few representative examples of interaction between dietary con-
stituents and toxicants have been given in Table 17 and discussed
briefly in Sect. 7.5.1.  In this section the  focus  is  on enzyme  induc-
tion and its role in inhibition of neoplasia.

     9.4.1  Enzyme Induction by Dietary Constituents

     Many xenobiotics  are capable of  inducing microsomal enzymes.  These
indueers are of  at least two types, exemplified by  phenobartital  (P-450)
and 3-methylcholanthrene (P-448) (Conney 1967).   The microsomal mixed-
function oxidase system is a complex biochemical  entity that  metabolizes
a wide variety of xenobiotics  including chemical  carcinogens.  Three
components of the system have been identified: cytochrome P-450,  cyto-
chrome P-450 reductase, and a  lipid.  Two distinctive  cytochromes have
been  identified  in liver microsomes: naturally occurring P-450 and a
closely related  species, P-448  (also  called Pi~450).   Considerable work
has been done on one of the components of the cytochrome P-450 system,
aryl hydrocarbon hydroxylase  (AHH) activity,  which  is  induced by  many
chemicals and dietary  factors.  A basal level of  AHH activity is  present
in  the liver but not in the small  intestine or lungs.  AHH  activity and
also  glntathione sulfur-transferase activity  was  shown to be  induced  in
these tissues by natural ingredient diets such as Purina Rat  Chow (Wat-
tenberg 1982).   Later  investigations  revealed that  most of  the inducing
activity was associated with  the vegetable component,  which consisted  of
alfalfa meal.  Naturally occurring inducers were  found in cruciferous
plants such as brussels sprouts, cabbages, and cauliflower  and identi-
fied  as indole derivatives.  Flavones naturally occurring in  citrus
fruits, safrole, iso-safrole,  and  0—ionone have also been found  to be
enzyme inducers  (Wattenberg 1975).

      9.4.2  Enzyme  Induction by Feed  Additives

     Preservatives, butylated  hydroxyanisole  and  ethoxyquin,  have been
shown to be good enzyme  inducers  and  consequently reduce  the  carcino-
genic effect of  chemicals  such as  benzo(a)pyrene,  7,12-dimethyl-
benzanthracene,  and dimethylnitrosaniline  (Wattenberg  1979)  (Table 16),
However,  in these  experiments,  much higher  levels of preservatives  (5-10
mg/g) were used  than  is normally present  in  animal  feed  (8-20 ug/g).

      9.4.31  Enzyme  Induction  by Contaminants  in Animal Feed

      Data on enzyme  induction by pesticide  residues in animal feed  are
rather scarce.   Chlordane, DDT, hexachlorocyclohexane, dieldrin,  aldrin,
heptachlorepoxide,  and pyrethrums  have been  reported  to be  inducers  of
enzyme activity  (Conney 1967)  and,  therefore, if  present  in animal
diets, have  the  potential  to  alter the  outcome of long-term toxicity
                                    48

-------
experiments by inducing enzymes that may alter the metabolism  of  the
chemical under study.

     9.4.4  Inhibition of Neoplasia

     Food contains a large number of inhibitors of carcinogenesis  such
as phenols, indoles, aromatic isothiocyanates, methylated flavones, cou-
marins, plant sterols, selenium salts, protease ihibitors, ascorbic
acid, tocophorols, retinol, and carotenes.  At present, the mechanism of
inhibition of carcinogenesis by these factors is poorly understood.  An
attempt has been made to classify these inhibitors into three  different
classes according to the time in the carcinogenic process that they are
effective.  The compounds that prevent the formation of ultimate carci-
nogenesis from precursors belong to the first group (e.g., o-tocopherol,
ascorbic acid).  In the second group are compounds that inhibit carcino-
genesis by preventing carcinogenic agents from reaching or reacting with
critical target sites in the tissues (so-called blocking agents).  The
third category of inhibitors acts subsequent to exposures to carcinogens
(so-called "suppressive agents").  Of these three categories,  the second
category or the "blocking  agents" most often act as indncers of enzymes
(Wattenberg 1983).

     9.4.5  Monitoring of Induced Enzyme Activity

     The most frequently monitored induced enzyme activities are aryl
hydrocarbon hydroxylase (Wiebel et al. 1974) and glutathione
S-transferase activity (Sparnins et al. 1982).  UDP-glucuronyl-
transferase, epoxide hydratase (Wattenberg 1980). aminopyrene demethy-
lase, p-nitroanisole demethylase, acid phosphatase, and glucose phospha-
tase (Newberne 1982) have also been monitored.

     9.4.6  Enzyme Induction and Genetic Differences

     Induction of cytochrome Pi~450 (also called P-448) by polycyclic
aromatic compounds has been manifested in the B6 mouse (the inbred
C57BL/6 strain) and in other responsive inbred mouse strains, but  induc-
tion of this form of cytochrome by polycyclic aromatic hydrocarbons is
absent in the liver and markedly decreased in all other tissues examined
in the D2 (the inbred DBA/2 mouse strain) and other nonresponsive  inbred
mouse strains.  This responsiveness to aromatic hydrocarbons has been
termed the Ah locus: the allele Ah^ denotes the B6, and Ahd the D2
inbred mouse (Nebert et al. 1977).

     It has been shown that when mice are given massive intraperitoneal
doses of benzo(a)pyrene, the survival*time of the three responsive
inbred strains - B6, C3H/HeN, and BALB/cAmN - is significantly shorter
than that of the two nonresponsive inbred strains, D2 and AHR/N.   In
contrast, when benzo(a)pyrene is administered orally in smaller daily
doses, the nonresponsive mouse survives less than 4 weeks, whereas no
significant earlier death rate is seen in genetically responsive mice,
even after ingesting benzo(a)pyrene for 6 months.  Similar differences
have been observed when benzo(a)pyrene was substituted by arochlor 1254,
lindane, or hexachlorobenzene.  Eepone has also been shown to  induce AHH
activity in B6 but not in D2 mice (Nebert et al. 1977).
                                   49

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10. SPECIAL TOPICS
     Phytates, arsenic, and selenium are treated separately  in this sec-
tion due to the special concern about them in recent years.

10.1 Phytates

     Oberleas (1973) provides a comprehensive discussion of  phytates as
a naturally occurring toxicant in food.  Of all the ingredients used in
animal feeds, probably soybean meal and wheat are the richest sources of
phytate.  The phytic acid from plant sources has been identified to be
myoinositol 1,2,3,4,5,6-hexakis (dihydrogen phosphate).  Consideration
of phytates in animal nutrition is important because they can interfere
with the absorption of metal ions from the gut.  At pH 7.4 phytates form
complexes with metals in the following decreasing order: Cu^+ > Zn2+ >
Co2* > Mn2+ > Fe3+ > Ca2+.  An important factor in the precipitation of
metal phytates is the synergistic effect produced when two or more metal
ions are present simultaneously; by acting together they increase the
quantity of metal phytate precipitated.  This phenomenon has been demon-
strated for Zn and Ca and for Cu and Ca.  Oberleas states that when
diets contain plant materials (e.g., soybean) rather than casein as a
major source of protein, it is advisable to increase the amount of Zn
intake.  For this reason the AIN-76^* purified rat and mouse diet uses
2.5 times the level of Zn recommended by NAS  (see Tables 1 and 2,
respectively).

     Calcium absorption in the gut is influenced by phytate, vitamin D,
and other dietary factors.  Diets that have enough Ca, P, and vitamin D
and calcium: inorganic phosphorus ratios between 1:1 and 2:1, respec-
tively, are not likely to be rachitogenic even though much calcium may
be bound to the phytates.

10.2 Arsenic

     The role of arsenic (As) in the animal diet is controversial (Shen-
driker 1982, Huff 1982, Frost 1982).  Although there is inadequate evi-
dence for the carcinogenicity of arsenic compounds in animals, there is
sufficient evidence that inorganic arsenic compounds are skin and lung
carcinogens in humans  (IARC 1980).  Recently Frost (1982) has focused on
the noncarcinogenicity of As and on its anticarcinogenicity. High As
intake has led to reduced spontaneous lung cancer in mice  (Kanisawa and
Schroeder 1967, 1969), and epidemiological data indicate a correlation
between low As intake and high lung cancer rate (Schrauzer 1978).  Niel-
sen et al. (1975) have shown that the offspring of Sprague-Dawley dams
placed on a purified diet containing approximately 30 ppb As, and main-
tained in a plastic isolator environment, displayed a rough  coat and a
significantly slower rate of growth than controls receiving  a supplement
of 4.5 ppm As as sodium arsenate  (4 ppm) and  arsenite  (0.5 ppm).  At 12-
15 weeks the deficient males exhibited significantly low hematocrits and
enlarged and blackened spleens containing 50% more iron on a per gram
basis.  The beneficial effects of As on the growth, health,  and feed
efficiency of pigs  and poultry have been well established  (Frost 1967).
                                   50

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4-Nitrophenylarsenic acid and 3-nitro—4-hydroxyphenylarsonic acid have
been found to be effective growth stimulants in pigs and poultry, and
phenylarsenoxides are more potent than arsenic acids as coccidiostats.
Arsenic can act as an antagonist to selenium (Se) and has been used suc-
cessfully to alleviate Se poisoning in animals (Underwood 1977).
Whether As should be treated as a micronutrient like Se in animal nutri-
tion is still an open question.  Unfortunately, no information document-
ing safe levels for long-term feeding studies is available.

10.3 Selenium

     The role of selenium (Se) as an essential micronutrient in animal
feeds has been well established.  It has been shown to be a constituent
of glutathione peroxidase, an enzyme involved in the disposal of perox-
ides in body tissues.  Selenium and vitamin E supplement each other in
most animal species studied except in rabbits where the relationship
does not hold (MAS 1977).

     Superiority of natural Se over selenite Se in increasing the Se
levels of muscle and liver has been demonstrated in laying hens (Latshaw
1975).  Biological availability of Se was shown to be only 54-58% as
great from tuna as from selenite for induction of glntathione peroxidase
in liver and in red blood cells of rats (Douglass et al. 1981).  The Se
in most of the feed stock of plant origin was highly available, ranging
from 60-90%, but was less than 25% available when the feed stock was of
animal origin.  This assay was based on the prevention of exudative
diathesis induced in chicks on a Se-deficient diet (Cantor et al. 1975).

     Although Se is an essential micronutrient, an overdose causes res-
triction in food intake in rats and dogs together with anemia and severe
pathological changes in the liver (Moxon and Rhian 1964).   Biliary Se
excretion is increased when subacute doses of As are administered.
Arsenic has been used as an antidote to Se poisoning,  and mercury,
copper, and cadmium are also known to interact with Se and offer protec-
tion against Se poisoning (Underwood 1977).  Contrary to earlier experi-
ments, Se has been demonstrated to have an anticarcinogenic effect
(Weisberger and Suhrland 1956).  Selenium (sodium selenite,  ~0.5
mg/week) is undergoing clinical trial for the treatment of endemic car-
diomyopathy in China (Sadler 1982).

     Selenium requirements in animal feeds are usually met by the
selenium naturally occurring in feed stock.  However,  when naturally
insufficient, it may be necessary to add Se to the animal  feed.  At
present selenium is recognized as a carcinogen, and its incorporation
into commercially prepared laboratory animal feed is subject to the
Delaney anticancer clause in the Federal Food,  Drug, and Cosmetic Act;
but in view of the fact that Se is an essential micronutrient in labora-
tory animal diets,  the Food and Drug Administration has decided not to
enforce this regulation in this particular case.   The legal position of
the Food and Drug Administration is explained by Ballitch (see Appendix
C).
                                   51

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11.  ANALYSIS OF PUBLIC COMMENTS ON THE PROPOSED EPA GUIDELINES FOR
     DIETARY REQUIREMENTS AND CONTAMINANT ANALYSIS
11.1 Criticisms of Proposed Guidelines and Related Discussion

     Several commenters agreed with the EPA that a standardized diet
should be required and should meet minimal requirements because dietary
constituents can influence the incidence of disease,  including neo-
plasms, and certain dietary contaminants may be linked to  synergistic,
additive or antagonistic  effects  in animal studies.   Many  commenters,
however, disagreed with the EPA approach on several grounds:
(1) feasibility, (2) practicality, (3) scientific justification,
(4) lack of harmony with  FDA, USDA, etc.,  (5) cost effectiveness,
(6) lack of incentive to  continue research on diet development, and
(7) failure to promote standardization of the diet.   The changes  sug-
gested in the EPA approach include (1) deletion of Appendix A and B  from
the proposed guidelines and (2) adoption of a different  set of criteria
for diet standards.

     The focus of EPA's concern in these proposed guidelines  is long-
term tozicity testing of  chemicals using laboratory animals.  The fact
that dietary constituents and contaminants can affect the  outcome of the
tests  is well recognized. The customary use of a set of control  animals
for the purpose of comparing with the exposed animals is not  an adequate
safeguard since dietary variables can have significant  interactions  with
experimental variables or parameters  (Greenman et al. 1980).  These  con-
siderations justify  the EPA approach  to  set the guidelines for the
dietary requirements  and  contaminant  analysis.  However, most labora-
tories procure their  animal feed  from commercial  sources.   A major  share
of  the burden of complying with the EPA  regulations will thus fall  on
the laboratory animal feed manufacturers.  As testified  by several  com-
menters, the industry has established a  good record of  adequate service
to  the needs of the  scientific community.  The commenters  feel that  the
EPA regulations should be flexible and permit the investigator and  the
feed manufacturer a  greater latitude  in  the choice of feed ingredients,
use of preservatives, and analytical  requirements.  As  an  example of the
difficulty  that feed manufacturers have  in ensuring the  use of proper
ingredients, consider alfalfa, which  used  to be oven-dried but now  is
mostly field-dried for  economic reasons  with consequent  reduction in
quality of  the resulting  feed.

     It is  customary to  analyze the vitamins and  minerals  in  the
premixes and to analyze  one or  two components  in  the  finished product  to
ensure proper distribution.   Vitamins that are partially destroyed  dur-
ing the. manufacturing process,  such as vitamin C, have to  be  assayed in
the finished product.   Some of  the analysis may be  costly, time-
consuming  and unnecessary if  carried  out routinely;  for instance  estro-
genic  activity  is usually not assayed unless  it  is  relevant to  the  par-
ticular experiment.   The  analytical burden on  the industry should be
kept at a minimum without compromising  the objectives of the  EPA  Good
Laboratory  Practice.   It  should be noted that  as  is  evident from  the
                                    52

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data presented in Table 1, the animal feed industry is already meeting
many of the standards set by the EPA.

11.2 Analysis of Specific Comments

     11.2.1 Shelf Life Restrictions

     Numerous commenters argued that the restriction on shelf life (90
days) is unwarranted.  Consideration should be given for the use of
preservatives such as ethozyquin and BHA, except where these compounds
are known to interact with the chemical under investigation.  In fact,
as shown in Table 8, NIH diet formulations do use preservatives.

     If preservatives are allowed, the shelf life of most laboratory
feeds is accepted to be about 6 months except in case of guinea pig feed
where the shelf life is usually 3 months because of rapid deterioration
of vitamin C.  However, if supplemented with vitamin C, shelf life of
guinea pig feed can also be extended to 6 months.  These shelf life data
are valid only when the feed is kept at 70°F or lower and a relative
humidity of 50% under clean storage conditions (personal communication
from D.C. SheIton of Ralston Purina 1982).

     11.2.2 Feed Meal

     Justification of the requirement that the feed in meal form should
be manufactured by regrinding pellets has been questioned.  Pelletized
feed for long-term studies has been suggested.  Joseph Knapka of NIH has
retracted his statement (Knapka 1979) that volatile nitrosamine levels
in animal feed are substantially lowered during the pelletizing process
(personal communication from J. Knapka 1982); therefore,  there
apparently is little justification for preparing the feed in meal form
by regrinding the pellets, although it may be preferable to do so to
minimize biological contaminants and to subject the feed to the same
heat treatment as the pellets.  Whether autoclaving reduces nitrosamine
concentrations in the feed, as suggested by one commenter, needs to be
documented.

     11.2.3 Calcium, Phosphorus, Iron, and Cobalt

     The EPA proposed minimum for calcium (Ca) and phosphorus (P) for
rodent diets are 1.15% and 0.9%, respectively.  Calcium and phosphorus
in some commercial rodent diets range from 0.9% to 1.1% and from 0.6% to
0.85%, respectively (see Table 1).  One commenter stated that the EPA
minimum levels for Ca and P are rather high.  According to NAS (1978)
the Ca:P ratio in the diet is more important than their absolute percen-
tage in the feed and should be greater than one.  Consideration should
be given to lowering the proposed minimum levels of Ca and P in the diet
and also for including a specified minimum for the Ca:P ratio.

     The EPA proposed minimum for iron in rodent diets is 345 ppm.  Lev-
els of iron in some commercial rodent diets range from 180 ppm to 298.7
ppm (see Table 1).  The NAS recommendation for iron in rodent diets
ranges from 25 ppm to 140 ppm (see Table 2).  As has been pointed out by
                                   53

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one commenter, the minimum level of iron in the proposed EPA guidelines
seems rather high, and consideration should be given to lowering the
level of iron.

     One commenter stated that cobalt is not a requirement under normal
animal husbandry.  This agrees with the NAS recommendation for the rat
diet.  However, cobalt is a requirement for the golden hamster; the
amount required in the diet has been estimated to be 1.1 ppm (see Table
2) (NAS 1978).  It is required for the synthesis of vitamin Bj.2, and all
commercial rodent feed formulations include cobalt, 0.38 ppm to 0.96 ppm
(Table 1), to ensure proper nutrition.

     11.2.4 Vitamins

     The minimum level of vitamin E proposed in the EPA guidelines is
3 ppm.  One commenter has pointed out that the vitamin K level of 3 ppm
is totally inadequate for normal blood clotting in certain widely used
strains of rodents.  The most satisfactory level appears to be 15 ppm
according to this commenter.  Rodents meet a large part of the dietary
need for vitamin K through intestinal synthesis and coprophagy (NAS
1978).  Purina rodent chow #5002, guinea pig chow #5026, and rabbit chow
#5322 do not include vitamin K (Table 1); however, the Agway R-M-H 3000
diet does include 0.97 ppm of vitamin K (Table 1).  These facts favor
the retention of the proposed level; however, the requirement for higher
levels in certain strains of rodents should be further investigated.
One commenter questioned the absence of vitamin C in the proposed guide-
lines.  Vitamin C is required in guinea pig diet formulations (NAS
1978).  Other animals do not require a dietary source of vitamin C, and
commercial diet formulations for the mouse, rat, dog, hamster, and rab-
bit do not include vitamin C (Table 1).  Since the guinea pig is a
rodent the EPA guidelines should include vitamin C if they are intended
for all rodents.

     As pointed out by one commenter, alternative sources of thiamine
(thiamine hydrochloride) and niacin (niacinamide) should be considered
for inclusion in  the proposed EPA guidelines to allow flexibility in
diet formulations.

     A question was raised on whether EPA should allow the use of vita-
min D—activated vegetable sterol along with vitamin D-activated animal
sterol.  Vitamin D-activated animal sterol is a source of vitamin DS,
and vitamin D-activated vegetable sterol is a source of vitamin D2
(AAFCO 1982).  Although no information was available for rodents, vita-
min DS is preferred over D2 for poultry diets (Merck Index 1976).  The
commercial diet formulations listed in Table 1 use vitamin D-activated
animal sterol.  No data are readily available to suggest that the use of
vitamin D-activated vegetable sterol be permitted.

     11.2.5 Choline and Inositol

     One commenter observed that the minimum level of choline proposed
in the EPA guidelines  (USEPA 1979) is too high (1900 ppm).  The
guaranteed minimum level of choline in rodent diets varies from 1542 ppm
                                    54

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to 2000 ppm in commercial diets  (Table 1).  The NAS  recommendation for
choline in the diet of different animals ranges from a  low  of  600  ppm
(mouse) to a high of 2000 ppm (golden hamster) (Table 2).   No  reason is
readily apparent for changing the proposed EPA value unless  it is
desired to provide values for individual species.

     One commenter questioned the absence of  inositol in the EPA guide-
lines.  Inositol is not normally required in  the diet of laboratory
animals.  None of the commercial diet formulations include  inositol  (see
Table 1).  However, the NAS recommended diet  for the golden hamster  does
require 100 ppm of inositol (NAS 1978) (see Table 2).

     11.2.6 Alternative Sources of Minerals

     One commenter pointed out that the permitted sources of minerals
include manganese oxide and cobalt carbonate but do  not include man-
ganese sulfate nor cobalt sulfate.  Since the two latter compounds  are
included in the GRAS list (see Table 7), their use in the EPA  guidelines
should be considered to allow flexibility in  the diet formulation.

     11.2.7 Dicalcium Phosphate

     One commenter expressed concern about the potential effects of
fluorine usually associated with dicalcinm phosphate, which is specified
as a source of minerals in the proposed guidelines.   Specifications  for
diealelorn phosphate include a maximum permissible level of fluorine  of
no more than 1 part to 100 parts of phosphorus (AAFCO 1982).  Most com-
mercial diet formulations do not state the amount of  fluoride present;
the Agway R-M-H 3000 diet is an exception and contains an average of 35
ppm of fluoride (see Table 1).  Consideration should be given  for speci-
fying an acceptable level of fluoride in the diet.

     11.2.8 Fat

     The minimum percentage of fat allowed in the proposed EPA guide-
lines is 4.3%.  One commenter remarked that in the case of adult,
nonbreeding rodents, the use of a lower percentage (2-3%) of fat in  the
diet avoids obesity and perhaps shortening of life span.  Commercial
rodent diets include 4-5% fat (see Table 1).  The NAS recommendation for
the rodent diet also recommends inclusion of 5% fat  (see Table 2).

     11.2.9 Ash

     One commenter stated that the minimum ash content of 8% in the  EPA
guidelines is rather excessive, particularly for adult rodents.  The
maximum ash content of some commercial rodent feeds  is guaranteed to be
6% (Agway Inc. n.d.) or 7% (Ralston Purina Company 1980).  The specified
ash content in the EPA guidelines possibly should be revised accord-
ingly.
                                   55

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     11.2.10 Air Dry

     One commenter asked fox a definition of "air dry" because the EPA
guidelines specify that the nutrient content of both ingredients and the
finished product must be expressed as a nutrient content percentage by
weight on an air-dry basis.  Since normal storage conditions of animal
feed specify a temperature of 70°F and a relative humidity of 50%,  "air
dry"  feed may be  defined  as  the  feed dried  to  a constant  weight under
these conditions.  Alternatives are  to report the results on a dry
weight basis or 90% dry matter basis as reported  in NAS (1974).

     11.2.11 Units of Measurement

     For  the sake of uniformity, consideration  should be  given to using
ppm instead of mg/kg.  Vitamins A and D are usually expressed in I.U./g.
The use of units  such as Mcg/lb should be avoided, as  indicated by  one
commenter.
                                    56

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APPENDIX A.  NATIONAL INSTITUTES OF HEALTH STANDARD FOR NUTRIENT AND
CHEMICAL CONTAMINANT ANALYSES OF LABORATORY ANIMAL DIETS
                                        NIH SID No. 5A
                                        November 1, 1980
                                        Superseding NIH STD No. 5
                                        November 1, 1978
1. Scope

1.1 This specification covers nutrient and chemical contaminant analyses
on samples of laboratory animal diets purchased under NIH contracts.

2. Requirements

2.1 Laboratory analyses to be performed

    a. Nutrient Analyses - Diet samples submitted shall be subjected to
       the following nutrient analyses in accordance with the most
       recent issue of Official Methods of Analyses of the Association
       of Official Analytical Chemists (A.O.A.C.).

       (1) Moisture
       (2) Crude Protein
       (3) Crude Fat
       (4) Ash
       (5) Crude Fiber
       (6) Nitrogen-Free-Extract
       (7) Calcium
       (8) Phosphorus

       Nutrient analyses shall be conducted on duplicate samples.

    b. Contaminant Analyses - Diet samples submitted shall be subjected
       to the following contaminant analyses in accordance with the
       indicated procedure.

              Contaminant                      Analysis Method

(1) Chlorinated hydrocarbon pesticides   Shall be conducted in
(2) Polychlorinated biphenyls (PCB's).   accordance with A.O.A.C.
(3) Organo-phosphate pesticides.         section 29.011 for sample
                                         preparations. Electron
                                         capture detection by gas
                                         liquid chromatography.

(4) Lead                                 Shall be conducted in
                                         accordance with A.O.A.C.
                                         section 25.068 for sample
                                         preparation; analysis by
                                         atomic absorption.
                                   71

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              Contaminant
(5)  Arsenic
(6) Cadmium
(7) Mercury
     Analysis Method

Shall be conducted in
accordance with Anal.
Chem. 48: Page 120, 1976
for sample preparations
(discussion on automation
may be disregarded).
Analysis by atomic
absorption.

Shall be conducted in
accordance with A.O.A.C.
section 25.105 for sample
preparation; analysis by
atomic absorption using a
double beam instrument
with simultaneous back-
ground correction.

Shall be conducted in
accordance with A.O.A.C.
section 25.105 for sample
preparation; analysis by
atomic absorption.

Shall be conducted in
accordance with A.O.A.C.
section 16.A01-26.A08
(mini column method for
combined Bl, B2, Gl, 62).

Shall be conducted in
accordance with
J.A.O.A.C., 51, P. 763,
1968.
Contaminant analyses on duplicate samples is not required. Samples to be
analyzed under this Specification will be submitted by the NIB animal
feed contractors and/or the project officer. The feed manufacturers and
the Independent Laboratory performing the analyses will be notified in
writing, at the time the contract is awarded, of the diet samples which
they are authorized to submit for analyses. The Government will be
responsible to pay the cost of analyzing only these authorized samples.

2.2 Frequency of Assays - All specified nutrient and contaminant ana-
lyses shall be completed within 28 days after the feed samples are
received by the laboratory. The laboratory shall maintain a log indicat-
ing the date each sample is received, the name of the company submitting
the sample and the complete identification. (Feed contractors are
required to identify all samples with the name of the diet, the date of
manufacture and the NIH stock number.)
(8) Aflatoxins
(9) Nitrate
                                    72

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APPENDIX B.  CONVERSION FACTORS FOR SELECTED VITAMINS
           al IU of Vitamin A = 1 USP unit
                              = 0.3 (ig all-trans retinol
                              = 0.344 fig all-trans retinyl  acetate  or
                                0.550 |ig all-trans retinyl  palmitate
                              = 0.6 jig of all-trans 0-carotene

          al mg of 0-carotene = 1667 IU of Vitamin A
                              = 833 IU of Vitamin A activity  for  the dog

           bl IU of Vitamin D = 0.025 fig of cholecalciferol

           bl IU of Vitamin E = 1 mg of dl-o-tocopheryl acetate
                              = 0.91 mg of dl-o-tocopherol

        bl mg of thiamine HC1 = 0.89 mg of thiamine

bl mg of calcium pantothenate = 0.92 mg of pantothenic acid

      bl mg of pyridozine HC1 = 0.82 mg of pyridozine

          bl mg of Vitamin ~K~ — 0.73 mg menadione sodium bisulfite
                                or 0.38 mg menadione

Source: aNAS (1974).
        bHerck Indez (1968).
                                    73

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APPENDIX C.  LETTER FROM EDWARD J. BALLITCH


                              April 8, 1982
Dr. B. C. Pal
Oak Ridge National Laboratory
Post Office Box z
Oak Ridge, Tennessee 37830

Dear Dr. Pal

This responds  further  to your  telephone  call  of March 23,  1982,  to Dr.
Gerald Guest,  Acting Bureau Director,  and  our telephone  conversation of
March 32, 1982, asking whether the Delaney anticancer clause  in  the
Federal Food,  Drug and Cosmetic Act  (Act)  is  applicable  to selenium
incorporated  into commercially prepared  laboratory animal  feed.

This clause,  in section 409(c)(3)(A)  of  the Act  (21 U.S.C. 348(c)(3)(A)),
prohibits issuance of  a food additive regulation  for a substance which
induces cancer, except that it does  not  apply with respect to an
ingredient of  feed for food producing animals under specified conditions.
Therefore, under  a literal  reading of the  law, an article  which  is a car-
cinogen may not be approved for use  in laboratory animal feed, as you
know, selenium has been demonstrated to  induce cancer in laboratory
animals.

The  agency recognizes, however, that selenium is  an essential nutritional
element for laboratory animals and  that  feed  is  the most practical method
of providing  this nutrient. Furthermore,  its use for this purpose is
very limited  and  carefully  monitored in laboratory animal  diets.  We
have, therefore,  concluded  that our  current position is  that  we  do not
intend  to take regulatory action against the  marketing and use of
appropriate supplemental  sources of  selenium  at  generally accepted nutri-
tional  levels in  laboratory animal  feeds solely  on the basis  that a regu-
lation  for this use  is prohibited under the Act.   Of course,  if  future
information raises safety concerns  regarding  this policy,  the agency will
take appropriate  measures.

Undoubtedly you are  aware of data suggesting  that trace levels of
selenium  act  to inhibit carcinomas  in laboratory animals.   We caution
that this fact be taken  into account when designing toxicity studies
involving animals fed  selenium in their feed.  Selenium levels in labora-
tory animal feed  should be  reported  in the study results.

                               Edward J.  Ballitch
                               Director
                               Division of Compliance
                               Bureau of Veterinary Medicine
                               Food  and Drug Administration
                               Rockville. MD 20857
                                    74

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APPENDIX D.  ABBREVIATIONS LIST






AIN                American Institute of Nutrition




BHA                Butylated hydroxyanisole




IU                 International units




NAS                National Academy of Sciences




NDMA               N-Nitrosodimethylamine




NIB                National Institutes of Health




NRC                National Research Council




TON                Total Digestible Nutrients




USDA               United States Department of Agriculture




USP                United States Pharmacopoeia
                            75

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APPENDIX E.  ADDITIONAL LITERATURE REFERENCES
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Afonsky D. 1954. Folic acid deficiency in  the  dog.  Science 120:803.

Agar J. 1971. Effect  of a  low zinc  diet  during gestation on  reproduction
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Anonymous. 1978. BRIEFING: Nitrosamines  found  in NIH-approved animal
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5*0272-101
 REPORT DOCUMENTATION
        PAGE -
                        1. REPORT NO.
EPA 560/6-83-005
                                                                         3. Recipient's Accession No.
 4. Title and Subtitle
  Nutritional Requirements and Contaminant Analysis of
  Laboratory Animal Feeds
                                                5. Report Date
                                                  May 1984
 7. Authors)
  -Bimal C. Pal,  Robert H.  Ross, Harry C. Milman (EPA)
                                                8. Performing Organization Rept. No.
                                                 ORNL
 9. Performing Organization Name and Address
   Information  Center Complex
   P.O.  Box X
   Oak Ridge National Laboratory
   Oak Ridge, TN 37831
                                                10. Project/Task/Work Unit No.
                                                11. Contract(C) or Grant(G) No.

                                                (C)

                                                (G) DW930141-01-1
 12. Sponsoring Organization Name and Address
  Office of Toxic  Substances
  U.S.  Environmental Protection Agency
   401 M Street  SW
  Washington, DC 20460
                                                13. Type of Report & Period Covered

                                                  Final
                                                14.
 15. Supplementary Notes
  This report  supersedes  PB&4111541.
 16. Abstract (Limit 200 words)
        The primary objectives of this report  are to present information concerning the
   nutritional  requirements  of several commonly  used laboratory animal species (i.e., mouse,
   rat,  hamster,  guinea pig, rabbit,  and dog)  and to discuss various aspects  of the problem
   of  contamination of laboratory animal feeds.   In addition, this  document discusses the
   different  types of laboratory animal diets  (e.g., open vs closed formula),  the ingredi-
   ents  used  in these diets, the interaction of  dietary components,  and the public comments
   received respective to  the EPA proposed guidelines for the nutrient composition of
   laboratory animal diets.   Much of  the data  are presented in tabular form.
 17. Document Analysis  •. Descriptors
  Laboratory animals
  Diets
  Nutrition
  Vitamins
   b. Identifiers/Open-Ended Terms
  Preservatives
  Contamination
  Impurities
  Pesticides
Nitroso compounds
Estrogens
Fungi
Molds
Aspergillus
Fusarium
   c. COSATI Field/Group  Biology
 18. Availability Statement
  Release unlimited
                                19. Security Class (This Report)
                                  Unclassified
                                                          20. Security Class (This Page)
                                                           Unclassified
                                     21. No. of Pages
                                          118
                                                           22. Price
(SeeANSI-Z39.18)
                                         See Instructions on Reverie

                                                  101
                                                          OPTIONAL FORM 272 (4-77)
                                                          (Formerly NT1S-35)
                                                          Department of Commerce

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