ORD Carpet Study
                         Toxicology Report:
        Evaluation of Off-Gassed Carpet Sample Atmospheres
                        Submitted:  August 6, 1993
Documents Included                                                  Pages



1.    Executive Summary  	i-vi



2.    EPA Toxicology Study	EPA-1 - EPA-115



3.    Anderson Labs Toxicology Study	AL-1 - AL-84



4.    Peer Review Comments on EPA Study and Anderson Study	 PR-1 - PR-27

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                       EXECUTIVE SUMMARY

                            Toxicology Report:
    Evaluation of Off-Gassed Carpet Sample Atmospheres
                                   August 6, 1993
Background
During the summer of 1992, through news releases, and in October, 1992 at a Senate hearing,
Anderson Laboratories, Inc. released information describing neurotoxicity, pulmonary irritation
and  death in mice exposed to emissions from certain carpets.    The information released
described tests which had four primary features.  First, an exposure feature, which involved
placing carpet into an aquarium, heating the aquarium, and withdrawing air from the aquarium
into a chamber from which four mice received their breathing air.  The second feature involved
modification of a standard test of sensory irritation (ASTM E 981). The standard test measures
the rate at which the mice breathe during exposures. Research has shown mat chemicals which
humans find irritating (sensory  irritation), when present in sufficient concentration, decrease the
rate at which mice breathe. Further, certain chemicals, when present in sufficient concentration,
change the pattern of breathing in a way that can be interpreted to indicate pulmonary irritation.
Pulmonary irritation is considered to  be more serious than sensory irritation.   The standard
ASTM method was modified to include multiple exposure periods rather than a single exposure.
The third feature of the Anderson tests involves observation of the behavior of the animals after
completion of the ASTM test   This  behavior is scored by an observer and interpreted as an
indicator  of potential neurotoxicity. The fourth feature of the Anderson tests is the observation
that death occurred in some mice.  These descriptions of neurotoxic effects and death were
particularly striking because effects  of this magnitude are not consistent  with  our current
knowledge of the emissions from carpets, and have not been described in the peer reviewed
scientific  literature.

The potential public health significance of these findings prompted a vigorous effort by EPA,
with assistance from  the Consumer Product Safety Commission, to evaluate their scientific
reliability, by determining whether the findings could be replicated independently.  Aside from
being one of the cornerstones of science, independent replication in EPA laboratories is necessary
before subsequent studies can be done to determine the causative agent(s) and the relevance of
the observations for public health. This report describes the EPA effort to replicate independently
the Anderson Laboratories' findings.  The report also includes Anderson Labs' report of their
data from the concurrently collaborative effort  Comments on these two efforts provided by four

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 independent peer reviewers are included with this document as well.

 STUDIES bv EPA's Office of Research and Development (ORD)

 EPA is aware that carpet, along with other indoor products and some indoor environments in
 general has been associated with a variety of complaints, symptoms and signs. Based upon  our
 knowledge to date, we have no reason to believe that the nature of complaints associated with
 carpet is different from the nature of complaints associated with other indoor sources. In order
 to establish a firm relationship between indoor sources and complaints, EPA must have available
 methods which are objective, sensitive, reliable and valid for this purpose. Methodologies which
 fit these criteria are not yet available.  For this reason, the EPA's indoor air research program
 is identifying, developing, improving, and validating methodologies which can be used for this
 purpose.  It is in the context of this research program that EPA began evaluating the ASTM E
 981 method some time ago. Although we concluded, in a peer-reviewed paper published in the
 journal Indoor Environment last  summer, that  the value of ASTM E 981 for purposes of
 evaluating indoor air quality is currently limited, we nevertheless had planned to further evaluate
 the methodology as used by Anderson Laboratories prior to the reports of toxic effects of carpet
 We were  also in the  process of working with other tests when the Anderson  Laboratories'
 information came to our attention.  Given the  potential significance of Anderson's reports, we
 dedicated  ourselves to investigating the four  features of the  Anderson Laboratories'  testing
 described above.

 ORD's goal was to understand the toxic effects reported by Anderson Laboratories.    Before
 beginning to understand those effects, it was  necessary to be able to reproduce them in our
 laboratory.  The process by which this is  done is called independent replication. Independent
 replication is also necessary to establish that a scientific finding is reliable.  A scientific finding
 is reliable when it can  be reproduced repeatedly by scientists who are given the protocol and the
 necessary equipment

 From the beginning, ORD took these studies very seriously.  In addition, we remained highly
 confident throughout, and had every reason to believe that we would be successful in our effort
 to independently replicate the Anderson Laboratories'  findings.   Anderson Laboratories had
 indicated that their findings were reliable in their own laboratory, in that their testing of many
 different carpets revealed toxic effects.  ORD assembled a large team of highly skilled  scientists
 working on mis project, and we maintained a collegial relationship with Dr. Anderson throughout
 Even more to the point, part of the study team visited Anderson Laboratories in January, 1993,
 and not only witnessed a toxic exposure, but were able, using part of our apparatus and part of
 theirs, to produce lethality as well  There neither was, nor is, any doubt in the minds of the ORD
 team of scientists that these studies in Anderson Laboratories resulted in death to some mice.

The  bottom line from our studies, however, is that despite our best efforts, which were
considerable and which will be described below, we have not been able to independently replicate
the severe toxicitv described bv Anderson  Laboratories.  In fact we were not able to produce
any convincing signs of even mild toxicitv attributable to carpet in our tests.  Our present

                                           • •
                                           11

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conclusion is that there must be an essential difference between the conditions of our experiments
and those of Anderson Laboratories, which, despite our efforts, we have not been able to identify.

Following is a more detailed description of our efforts.  First,  the steps we took in our attempt
to  perform an independent replication of the  Anderson  Laboratories'  observations  will be
outlined.  Second, the scientific practices ORD followed during the course of these studies will
be  identified.  Third, the results  of our studies will be summarized and contrasted with  the
Anderson Laboratories' results.  Finally, the results of an independent peer review of the ORD
replication study will be presented.

The steps ORD took in an attempt to perform an independent replication  of the Anderson
Laboratories' observations included assembling a highly skilled scientific team,  assembling  the
test apparatus, performing exploratory/pilot/shakedown studies, drafting  a  formal protocol,
reciprocal visits with Anderson Laboratories' personnel, peer review of our study protocol,
performing the formal replication study, analysis and peer review of the study results, performing
additional exploratory studies, and initiation of  a dialogue with industry scientists performing
similar work.

The scientific practices ORD kept in focus during these studies were those of replication, blind
testing when subjective measurements are involved, peer review, quality assurance, and inclusion
of  measurements which should help develop testable hypotheses to account for the observed
findings.  The importance of replication has already been mentioned.  Scientists only accept
cause-effect relationships when  they can be demonstrated reliably by independent scientists.

High caliber science maintains high quality several different ways. Many scientific observations
require subjective judgment or subjective scoring, particularly in the realm of biology. Because
scientists  recognize  that  whenever subjective evaluations  are made, there is an unconscious
tendency  for expectations to color observations, good  scientific practice requires that critical
subjective observations be made by an individual who is not aware of the specific conditions of
the test  This practice is called blinding, and hi the case of these studies refers to the fact that
the individual performing scoring should not know whether the data collected were from carpet-
exposed mice or control mice.  In ORD's formal replication, effort was made to ensure blinding
of the testing laboratories by asking the Consumer Product Safety Commission to collect carpet
and randomize shipment of carpet and no carpet to the test laboratories. At EPA we  established
elaborate procedures to ensure maintenance of this blinding.

Peer review refers to the process by which outside experts provide independent comment on the
quality of a research design, the data collected and the interpretation placed upon the  data.  Most
scientific  journals send  articles to peer reviewers before  they  will consider publication.
Scientific  progress is usually measured in terms  of peer-reviewed publications, and EPA judges
the  performance of its scientific staff in large measure by  the peer-reviewed publications they
write. The process of publishing peer-reviewed papers is a lengthy one, and when EPA must act
before important data can be published in the peer-reviewed literature, independent peer reviews
are  held.  In the case of our carpet study, we believed that public concern was sufficient that we


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 could not wait for our studies to appear in the peer reviewed literature before they became
 known.  Therefore we held independent peer reviews of both our research protocol, to ensure that
 the scientific design was of high quality, and of our research findings, to ensure that our data
 were appropriately collected and interpreted. In addition to planning for a peer review at the end
 of our study, we also arranged to have independent quality assurance audits of our procedures
 and our apparatus during the study. The purpose of these audits was to ensure that all systems
 were properly  calibrated and operating as expected.

 Finally, since ORD's expectation was that efforts would be successful in replicating the Anderson
 Laboratories' findings, some measurements were included which were designed to help develop
 testable hypotheses that would account for the findings. Since it was presumed that emissions
 from the tested carpets would account for the findings, evaluation of the emissions from the
 tested carpets  was included  In addition,  pieces from the carpets were analyzed directly, to
 determine the presence of pesticides and microbiological contaminants.

 A major feature of the ORD study was collaboration with Anderson Laboratories in its design
 and execution. The protocol for performing the study was agreed to by both ORD and Anderson
 Laboratories. Each Lab received pieces from the same carpet to test, and the toxicology testing
 done routinely by Anderson Laboratories was included. Scoring procedures were discussed and
 modified to accommodate the desires of both sets of investigators. In addition, ORD performed
 a large number of other lexicological and analytical measurements. The analytical measurements
 characterizing  carpet emissions and contaminants will be detailed in a separate document

 In this collaborative study, there were three treatments. Two treatments were different carpets,
 and one treatment was a control.  Each of these three treatments was tested twice, so there was
 a total of 6 experiments performed.  CPSC collected the  carpets from sources which had
 previously supplied carpets to Anderson Laboratories, and which had been associated with severe
 toxicity  and death when tested at Anderson Laboratories.  CPSC randomized the 6 different
 sample sets, and sent a set simultaneously to EPA and to Anderson Labs for blind testing.  After
 each laboratory had completed all 6 experiments, the code was broken for data analysis purposes.
 On May 26,  1993,  a  peer review was  held of the two  data sets (EPA's and Anderson
 Laboratories*). The peer reviewers had received draft reports from EPA and from Anderson
 Laboratories several days previously.  At the peer review, each laboratory described their  study
 and results, and the peer reviewers asked questions and discussed findings with study participants.
 The two reports, one from EPA and one from Anderson Laboratories, make clear that mere was
 virtually nothing in common between the two sets of findings. EPA found no deaths in 24 tested
 animals, no severe or moderate sensory irritation, no severe or moderate pulmonary irritation, and
 no clear evidence of neurotoxicity. By contrast, Anderson Laboratories' findings included a total
 of 8 deaths in 24 tested animals, severe pulmonary irritation, and neurotoxicity.

During the course of preparing for and trying to understand these studies, EPA performed many
exploratory studies (over 30) in which ORD examined a large number of variables and tested
carpet samples  supplied to us by Anderson Laboratories. Some of these studies were performed
with as much as 10 square feet of carpet in a specially designed source chamber. Some studies


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 were done with very dry air, some with normal laboratory air, and some with partially humidified
 air. Some of the studies allowed for observation of animals for many days after exposure, and
 some of studies involved extensive heating of the carpet samples. In all, over 140 mice have
 been tested by ORD. With all of these studies, the only evidence of carpet-related neurotoxicity
 which we were able to produce occurred during our visit to Anderson Labs.

 The science performed  by EPA  was characterized independently by each peer reviewers as of
 very high quality, yet we were not able to replicate the Anderson Laboratories' findings. The
 conclusion with which we are left is that very subtle but very important differences exist between
 the studies done bv Anderson Laboratories and those done bv us.

 NEXT STEPS

 We do not believe that  the failure to replicate the Anderson Laboratories' findings proves that
 carpet emissions do not  pose adverse health effects. At the same time, however, we do not have
 a sound basis for concluding that exposure to carpet emissions presents a health risk.  Rather,
 we see two important issues.  One is the meaning of the Anderson Laboratories' findings, and
 the other is the potential health  effects of exposure to  carpet emissions.   These  may be
 independent issues.

 EPA will continue to follow up on the Anderson Laboratories' findings.  The next step we will
 take is to  hold a workshop at which data and  hypotheses from all of the laboratories working on
 this problem will be presented and discussed. Based upon the outcome of this workshop, EPA
 will determine its next steps.

 In addition to following up the Anderson Laboratories findings, EPA/ORD intends to continue
 its efforts to develop better methodologies for detecting and studying potential health effects of
 indoor sources.  While many toxicology tests are available, most of them were designed to
 detect health effects which  are very different  from die type associated with most indoor air
 complaints.   Our general strategy is to develop methods which can be used in humans, to be
 sure that they correlate with the symptoms and signs reported following exposure to some indoor
 environments.  Once we have good methods for use in humans, we will develop animal models
 of those methods.  Such models might be useful for screening purposes.  Methodologies we are
 currently working on include tear  film breakup for eye irritation, and trigcminal evoked potentials
 for sensory irritation.  As we develop appropriate animal models, we can apply mem to answer
questions  about the neurobehavioral effects that have  been suggested by various scientists as
related to  indoor air complaints.

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                                        Table 1.
                          Summary of lexicological Findings
        Endpoint
                      EPA
Deaths
 Severe Neurotoxicity

 Neurotoxicity   (extreme
 change from control)
 Pulmonary
 Irritation

 Sensory Irritation
General Appearance
           none


           none

           none
           none
           carpet- 3/16 slight;
           control: 1/8 slight

           carpet:  facial   swelling,
           lacnmation, hemorrhaging of
           pinna vessels, red tears;
           control: similar effects
         Anderson

8   of  24   (5   carpet,  3
accidental)

none

carpet:    many    variables
affected;
control:  only vocalization

carpef 4/16 severe;
control:  none

carpet 13/16 slight;
control:  none

carpet:    facial    swelling,
lacnmation and bleeding, ear
petechiae;
control:  ear petechiae
VOCs

4-PC

Pesticides


MicrobioL
                   Table 2.
Summary of Analytical Chemistry/Microbiology

- Unremarkable; most compounds in ppb range

- Detected, but too little there to quantitate

• One carpet had high levels of chlorpyrifos,  but not high enough to
produce acute toxicity

- Unremarkable
                                          VI

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 lexicological Evaluation of Off-Gassed Carpet Sample Atmospheres

                             Submitted:  Augusts, 1993

Disclaimer
The research described in this article has been funded wholly by the U.S. Environmental
Protection Agency (U.S. EPA) under contract 68-D2-0056 to ManTech Environmental
Technology, Inc.  It has been reviewed by the Health Effects Research Laboratory, U.S. EPA
and approved for publication. Approval does not signify that the contents necessarily reflect
the views and policies of the Agency nor does mention of trade names or commercial
products constitute endorsement or recommendation for use.
Acknowledgements
The authors wish to thank the following participants in the study for their effort and dedication
to completing this task: Mette Jackson for exposure and pulmonary function testing; Pam
Phillips for behavioral testing; Sean Dowd for computer/bioengineering support; Mary Daniels
for heart puncture and blood preparation; Denise Sailstad for performing the orbital bleeds and
blood preparation; Judy Richards and Rick Jaskot for clinical chemistries on serum and
lavage; James  Lehmann for peripheral smear, lavage, lung fixation, and cell differentials;
Terisita Gabriel for hemoglobin and carboxy/methemoglobin measurements; Joel Norwood for
nasal lavage and fixation; Elias Gaillard (EPL) for necropsy and histopathology evaluations;
Lynne Gates (EPL)  for performing the necropsy dissections; and Donald Doerfler for
biostatistical analysis.
                                      EPA-1

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Contributors listed in alphabetical order.

Daniel L. Costa
Pulmonary Toxicology Branch, Environmental Toxicology Division,  Hearth Effects Research
Laboratory, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina
27711

Robert S. Dyer
Office of the Associate Laboratory Director, Health Effects Research Laboratory, U.S.
Environmental Protection Agency, Research Triangle Park, North Carolina 27711

 Mark A. Mason
Indoor Air Branch, Pollution Control Division, Air and Energy Engineering Laboratory, U.S.
Environmental Protection Agency, Research Triangle Park, North Carolina 27711

Virginia C.  Moser
ManTech Environmental Technology, Inc., P.O. Box 12313, Research Triangle Park, North
Carolina 27709

Jeffrey S. Tepper
ManTech Environmental Technology, Inc., P.O. Box 12313, Research Triangle Park, North
Carolina 27709
                                       EPA-2

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Table of Contents

Tables Titles	   4

Figure Titles	   5

Abstract	   6

Introduction  	   8
       Background	   8
       Goals   	 12
       Caveats	 12

Methods	 14
       Definitions	 14
       Study Design	 16
       Experimental Test Procedure 	 17
       Exposure System	 19
       Animals	 24
       Functional Observational Battery	 25
       Frequency of Breathing Measurements	 27
       Postmortem Evaluation	 30
       General Data Analysis Strategy  	 32
       Quality  Assurance  	 38

Results  	 42
       Exposure System	 42
       Body Weight 	 46
       Irritancy Measurements  	 46
       Functional Observational Battery	 51
       Postmortem Evaluation	 56

Discussion	 65
       Interpretation of the Results 	 65
       Potential Confounds	 74
       Conclusion  	 77

References	 80

Figure Legends  	 84

Figures  	 87

Appendix A:  Summary of FOB Data for EPA Formal Replication Study	  104
                                      EPA-3

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Tables Titles
Table 1  Test Matrix Using Aquarium Source Chamber
Table 2 Mouse Pulmonary Function Checklist
Table 3 Temperature (°C) - Bottom of Aquarium (S2)
Table 4 Temperature (°C) - Inside of Aquarium (A,)
Table 5 Temperature (°C) - Inside of Mouse Chamber (Ag)
Table 6 Percent Relative Humidify of Air Entering the Source Chamber
Table 7 Percent Decrease in Frequency of Breathing for the Mean of Four Mice
Table 8 Summary of Statistical Outcomes for Functional Observational Battery Data
Table 9 Organ Weight Data by Treatment Group
Table 10.  Peripheral Blood White Cell Differential Counts
Table 11.  Serum Clinical Chemistry Values
Table 12  Lung Lavage Chemistry
Table 13  Lung Lavage White Blood Cell Count Differentials (xlO4) /ml of Bronchoarvedar
Lavage
Table 14.  Incidence of Selected Histopathological Lesions
Table 15.  Potential Causes of Clinical Chemistry and Differential Values
Table 16. Summary of Toxicological  Findings
                                      EPA-4

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Figure Titles
Figure 1 Design of the Exposure System for Evaluating the Emissions
Figure 2 Change in Body Weight with Four Sequential Exposures
Figure 3  Control Period Frequency of Breathing
Figure 4 Exposure Period (a) Individual Animal Data, (b) Exposure effect
Figure 5. Recovery Period (a) Treatment Effect, (b) Exposure Effect
Figure 6.  Sensory Irritation, Exposure Period
Figure 7.  Pulmonary Irritation, Exposure Period
Figure 8.  Disruption Index, Periods Collapsed
Figure 9. Lacrimation
Figure 10.  Dilated Pinna
Figure 11.  Jar Task
Figure 12. Tail Pinch
Figure 13. Click Response
Figure 14. Alertness
Figure 15.  Hemoglobin
Figure 16. Clinical Chemistries: (a) protein, (b) albumin, (c) cholesterol
Figure 17.  Glutathione from Nasal Lavage and Lavage Fluid Protein
                                       EPA-5

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Abstract
                    Anderson Laboratories, Inc. of Dedham, Mass, reported that the
off-gassing of certain "complaint" carpets caused sensory and pulmonary irritation, changes in
a checklist of neurobehavioral signs and, in the most extreme cases, death in exposed mice.
This study was performed in an attempt to replicate and further investigate these findings
primarily using two in vivo biological tests.  One of these tests examines the reflex change in
the breathing pattern of mice exposed to irritant airborne chemicals (American Standard Test
Method for estimating sensory irritancy of airborne chemical [ASTM E-981-84]), and the other
is an adaptation of a standard test method for evaluating the neurotoxic potential of chemicals
(functional observational battery, Subdivision F Pesticide Assessment Guidelines-FIFRA).
These two primary measures were coupled with several ancillary measures and a postmortem
assessment in an attempt to ascertain the mechanism of toxicity, if observed.   The
postmortem evaluation included measurements of hemoglobin, serum clinical chemistries
(liver, kidney and cardiac enzymes), blood  and lung lavage white cell counts and differential,
organ weights, and a gross necropsy with a microscopic evaluation of all major organs. The
study evaluated three treatment groups comprised of two carpet exposures and one zero-
grade air exposure. The investigators were blinded to the treatment group. Matched carpet
samples were sent to the EPA laboratory and  to Anderson Laboratories by the Consumer
Product Safety Commission (CPSC).  Eight mice  were tested with  each of the three treatment
groups. There appeared to be no severe toxic effects associated with exposure to the off-
gassing of the two tested carpets.  Incidental findings of statistical  significance, but unlikely to
be of biological significance, were observed. Of all the effects that were observed, only the
number of falls in the functional observational  battery would be suggestive of an "adverse"
effect  Several "possibly adverse" effects in each of the three categories of measurements

                                        EPA-6

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(irritancy, postexposure neurobehavior, and postmortem general toxictty screen) seemed to be
randomly distributed across the three treatment groups. Most likely, these effects are false
positives because of the numerous uncorrected comparisons performed.  In conclusion,
based on this assessment of irritation, neurobehavioral effects, and measures from a general
toxitity screen, there is no indication that exposure to off-gassing from these two carpets
poses a serious lexicological threat.
                                       EPA-7

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Introduction

Background        Recently, Anderson Laboratories of Dedham, Mass, distributed data
indicating irritancy and toxicrty to mice exposed to emissions from carpets collected from sites
with a history of carpet-related complaints.  An in vivo test (ASTM E-981-84) was used to
estimate irritancy in mice during exposure to air passed over warmed carpet samples in a test
chamber.  Briefly, carpet pieces were sealed in an aquarium that was then heated  until the air
temperature reached 37 °C. This air temperature was maintained for about an hour, after
which room air was pulled through the aquarium and then through the mouse exposure
chamber for one hour.

       Measurements of changes in breathing rates and patterns were used to determine
irritancy of emissions. Postexposure observations of the behavior and general condition of the
mice using a list of clinical signs were used to assess correlated neurotoxicological effects.
Death was observed in some exposed mice after multiple (up to four) one-hour exposures.
No chemical or microbiological characterizations of the emissions from the exposure system
were conducted during the tests.

       These observations raise concern that some carpet emissions may adversely affect the
health of exposed humans.  Therefore, the EPA considered it important to (1) systematically
replicate Anderson Laboratories' experiments to  provide independent corroboration of test
results; (2) apply the resources of the Health Effects Research Laboratory to perform a
comprehensive toxitity screen to leam, if possible, what factors were responsible for the
irritancy, neurobehavioral changes, and  mortality observed in the test animals; and (3)

                                       EPA-8

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conduct a thorough chemical and microbial characterization of emissions from carpets.

       This report deals only with the toxicology portion of the EPA evaluation. The EPA and
Anderson Laboratories have completed a study in which the protocol required each laboratory
to test three treatment conditions: subsamples of the same two carpets and an air control
exposure.  For these experiments, both the EPA and Anderson Laboratories were blind to the
contents of the source chamber (carpet or air control).  Upon completion of the study the EPA
and Anderson Laboratories will exchange reports and compare results (the comparison will be
the subject of a separate report). The two carpets were independently collected from their
source by a third party (Consumer Product Safety Commission [CPSC]) for distribution to the
test laboratories. Both carpets have previously been tested by Anderson Laboratories and
were shown to produce severe toxicity in some test animals and death in others.  The EPA
tested subsamples of these same carpets and a zero-grade air control using methods
specified by Anderson Laboratories. Additionally,  postmortem evidence of toxicity in mice
was evaluated. The EPA also attempted to characterize the carpet chemical and
microbiological contaminants and emissions under test conditions (see companion
chemistry/analytical report).

Test Method (ASTM E 981-84)    Initial reports  from Anderson Laboratories indicated that
exposure to carpets could produce  either sensory or pulmonary irritation, or a combination of
both.  This determination was made using an adaptation of the American Standard Test
Method for Estimating the Sensory  Irritancy of Airborne Chemical (ASTM E-981-84). This test
method provides a quantitative estimate of the sensory irritant potential of an inhaled
chemical and has been  recently reviewed (Boz et al., 1992; Tepper and Costa, 1992). Irritancy

                                       EPA-9

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 is detected by a characteristic change in the breathing pattern of mice, which results in a
 reduction in the breathing rate, during exposure to a test atmosphere.  This characteristic
 response in mice has been demonstrated to qualitatively predict nose,  throat, and eye irritation
 in humans for 51 chemicals (Alarie, 1973). A quantitative relationship has been established
 between published Threshold Limit Values and Time Weighted Averages (TLVs-TWAs) for 26
 irritant chemicals and the concentrations at which the same chemicals  reduce respiratory rate
 by 50% (RDeo) in mice.   This statistical relationship indicates that 3% of the RDM can be
 used to establish interim TLVs-TWAs, if toxicity is primarily based on sensory irritation (Alarie,
 1981).

        Although several types of irritant responses have been identified using ASTM E 981-
 84, they are broadly classified as two types, sensory and pulmonary (Alarie,  1973).
 "Sensory* (upper airway) irritation is usually produced by highly water-soluble chemicals such
 as ammonia, acrolein, and formaldehyde.  Sensory irritation is caused  by stimulation of the
 trigeminal nerve, which  innervates the areas of the nose, throat, and eyes. In humans,
 exposures to sensory irritants readily produce a burning sensation to the eyes, often
 precipitating lacrimation. If the exposure is sufficient, the larynx also can be stimulated by
 these chemicals, producing cough. Analogous sensory stimulation can be readily identified in
 small laboratory mammals by a decrease in breathing rate (Alarie, 1973).

       Pulmonary irritation, a second type of irritant response,  is caused by stimulation of
vagal nerve endings and usually occurs with less water-soluble chemicals. Prototypic
examples are ozone (Oj), phosgene (COCy, and nitrogen dioxide (NO2), chemicals that have
greater  peripheral lung deposition and thus, cause more damage in the deep lung.

                                        EPA -10

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Subjectively in humans, these chemicals may produce cough and substemal soreness without
the burning sensation of the upper airways and eyes produced by the sensory irritants.  In
mice exposed to these irritants, breathing rate again decreases, but the breathing pattern is
qualitatively different from the pattern of response seen with sensory irritation (Alarie, 1973).

Functional Observational Battery   The  initial results from Anderson Laboratories also
included many signs of toxicity that implicated involvement of the nervous system (e.g.,
tremors, hindlimb weakness or paralysis, or changes in activity level). It was therefore
appropriate to include neurological testing in this study. The test chosen was a functional
observational battery that has been validated and is used by many organizations to screen
chemicals for their neurotoxic potential.  This first-tier evaluation has been recommended by
several expert panels and is now required by the U.S. EPA for testing many chemicals (U.S.
EPA, 1991; for review, see Tilson and Moser, 1992).  The purpose of this test battery is to
identify potential neurotoxicants, which can then be studied in more depth to characterize any
neurotoxic effects detected. The functional  observational battery includes many functional
indicators of the autonomic, sensory, motor, and behavioral status of the test subject. Much
research has been conducted on the sensitivity, validity, and predictability of the functional
observational battery using rats (for example see, Moser, 1989,1990a, 1990b, 1991; Tilson
and Moser, 1992).  To a lesser extent, these specific tests have also been used in mice;
however, the functional observational battery, used in rats, is based on the original screen for
neurological signs in mice described by Irwin (1968).  More recently, others have used the
functional observational battery for mice with little or no modification (Tegeris,  1991;  Beaton et
al., 1990). Thus, this test procedure is well-suited to assess the possible neurotoxic effects of
carpet vapors.

                                       EPA-11

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 Postmortem Measurements        There is no information currently available suggesting a
 mechanism for the toxicity observed by Anderson Laboratories.  In an effort to obtain
 preliminary information pertaining to mechanism of toxic effect, a comprehensive toxicity
 screen was performed on each mouse in the study.  The screen consisted of measurements
 on the blood, lung and nasal lavage, organ weights,  gross necropsy and microscopic
 evaluation of several tissues.  Analysis of the blood included determination of normal and
 abnormal hemoglobins,  evaluation of the relative percent of different types of white blood
 cells (differential) and clinical chemistries to examine liver, kidney, heart,  muscle and stress
 responses.  Lung lavage was examined for evidence of inflammation (lavage differential), cell
 death  and changes in lung permeability.

 Goals       The were two primary goals for this initial study: (1) Can we obtain comparable
 results from testing the same carpets using essentially the same equipment and procedures
 as those used at Anderson Laboratories? (2) If toxicity is observed in test animals, can the
 EPA gather information about the biological responses of the test animals and source
 emissions to determine the cause or develop plausible hypotheses to account for the findings?

 Caveats     This study must be considered exploratory. Due to time constraints, key
 variables associated with the test apparatus, preexposure sample conditioning, environmental
 conditions during testing and  variability  among samples have not been systematically
 examined. The effects observed on test animals at Anderson Labs reportedly have ranged
from no observable effect to death within a single test that consists of four sequential one-
hour exposures of four mice over a two-day period.  Abnormal behavior, defined using
Anderson's list of clinical observations, has ranged from transient to persistent and has not

                                       EPA -12

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 occurred at predictable times after an exposure or exposures. Variability between emissions
 from subsamples of the same carpet is unknown. Quantitative and qualitative variability of
 emissions over the sequence of repeated heating/exposure cycles that constitute a single test
 is not known.  Air temperature in the test chamber has been monitored during exposures at
 Anderson Labs; however, chamber surface and carpet temperatures have not been routinely
 monitored. These temperatures may or may not be critical to producing the reported effects.

       Finally many biological end points, with the exception of death, used in these test
 procedures rely on subjective judgments by a trained observer. The functional observational
 battery, generally regarded as a screening tool that can be used to identify exposures that
 warrant further study, has been modified and adapted for these experiments. The battery
 requires a trained observer to make subjective evaluations of specific pre- and postexposure
 behaviors and appearance of the test animals. These judgments form the basis from which a
 determination is made as to severity of the effect of exposure.  Furthermore, interpretation of
 pulmonary irritancy requires subjective evaluations of pulmonary waveform.  Criteria were
 established, based on the ASTM E-981-84 for a  numerical rating system to evaluate
 pulmonary waveforms. However,  despite attempts at objectivity, these measurements are
 based on some subjective assumptions, and  thus,  interpretation between investigators may
vary.
                                      EPA -13

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 Methods

       Definitions   To aid the reader in understanding this document, we have attempted to
 use certain words in a specific and consistent manner. The following definitions will be used
 throughout this text

 Study The collection of six experiments using three treatment groups as defined below.

 Treatment The study evaluated three treatment groups (A-C).  Two of these treatment groups
 were exposed to carpet samples, whereas the third treatment group was exposed to
 humidified, zero-grade air.

 Experiment The study included six experiments; each experiment used four mice. A single
 treatment group consisted of two replicate experiments.

 Exposure Within each experiment, four one-hour exposures were performed over two days.

 Period Within each exposure there were three periods: (1) a 15-minute period during which
 the mice were exposed in the plethysmographs to zero-grade, humidified air; (2) a 60-minute
 period during which mice were exposed to the airborne contents of the source chamber; and
 (3) and a 15-minute recovery period in zero-grade, humidified air.

 Control Group Two types of controls were used in this study; each group having a unique
designation. One control is the treatment group of mice exposed to only zero-grade

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humidified air from the source chamber.  This group, however, is always referred to as
Treatment B. The second control used in the study refers to the non-exposed, unrestrained
cage-control group that is used for comparison purposes in all of the postmortem evaluations.
This group is referred to as the 'control" group or variant of this term (e.g., cage control,
unrestrained control, non-exposed control)

Source Chamber The source chamber was constructed from an aquarium and contained the
carpet samples.  In the zero-grade air treatment group, the source chamber was empty.

Animal Exposure Chamber The heads of the mice protruded into a glass animal exposure
chamber that was connected to the source chamber during the 60-minute exposure period.

Plethysmograph Attached to the animal exposure chamber were four plethysmographs. A
plethysmograph is a device for the measurement of changes in volume.  Expansion of the
chest (proportional to the volume inhaled) was sensed as a pressure change in the sealed
plethysmograph tube because the mouse inspired from air external to the plethysmograph
(i.e., from the animal exposure chamber). Frequency of breathing was instantaneously
computed by calculating the time between pressure swings.

Sensory and Pulmonary Irritation  A characteristic change in the pattern and frequency of
breathing that occurs in mice exposed to irritant chemicals that stimulate the trigeminal nerve
endings of the upper respiratory tract (Sensory Irritation) or stimulate the vagal nerve endings
in the lower respiratory tract (Pulmonary  Irritation).
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Functional Observational Battery The functional observational battery is a test battery that has
been primarily used to identify potential neurotoxicants that may require further, more in-depth
evaluation. The battery includes many functional indicators of the autonomic, sensory, motor,
and behavioral status of the test subject.
Study Design       A total of six separate experiments were conducted, consisting of two
experiments with no carpet in the source chamber (Treatment B), and four experiments using
two different subsamples of carpets previously tested at Anderson Labs (Treatments A and C).
Because some lexicological indicators used in this experiment rely on subjective judgments or
interpretations of test animal behavior and appearance, and subjective interpretation of
pulmonary waveform data, a blinding procedure was used to minimize the potential impact of
negative or positive expectations of the experimenters on subjective observations.  To ensure
experimental blind, CPSC decided the order of testing by randomizing shipments one through
six.  Randomly selected subsamples of the same carpet were tested simultaneously at each
laboratory. The actual test order is listed in Table 1.
                                       EPA -16

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 Table 1. Test Matrix Using Aquarium Source Chamber
Treatment
A-1
B-1
B-2
C-1
C-2
A-2
Experiment #
1
2
3
4
5
6
Test Dates
3/8-3/10.
3/10-3/12
3/22-3/24
3/24-3/26
3/29-3/31
3/31 -4/2
Shipment
Carpet 1
Empty
Empty
Carpet 2
Carpet 2
Carpet 1
       The CPSC shipped the appropriate subsamples (sealed in Tedlar bags) to the sample
custodian at each laboratory, who received and logged the samples, loaded the source
chamber, covered the sides and top with duct tape and placed the chamber in position for
testing.  At the completion of the four, one-hour exposures, the custodian removed the source
chamber from the exposure system, removed the subsamples, and packaged and returned
them to CPSC.  For control tests, CPSC shipped a package containing an empty Tedlar bag.
It was the responsibility of the experimenters to maintain the integrity of the blinding
procedure.

Experimental Test Procedure     The following summary briefly describes how the series
of four, one-hour exposure tests were conducted. Details for the functional observational
                                     EPA -17

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battery, the method of assessing irritation (ASTM E-981-84), and the postmortem evaluations
are described below. On the day before testing, three 1-ff subsamples of a carpet were
rolled and stapled together and then placed fiber-side down on the bottom of the source
chamber. The source chamber was sealed and moved to the biology testing laboratory and
the vinyl insulating blanket was placed on top of the source chamber. Meanwhile, six mice
meeting the selection criteria were moved to the biology laboratory and the preexperiment
functional observational battery was performed.

       On the first exposure test day, the heating blankets were turned on high to achieve the
inside air target temperature of 37±3 °C and outside bottom temperature 70±5 °C.  Once these
target temperatures were achieved, the carpet was allowed to bake under these static air flow
conditions for one hour.   During this time, all nylon bulkhead fittings were checked: the O2and
CO2 monitors were adjusted to 20.9 and 0.03%, respectively; the  flow controllers, humidify
sensor, and bottled air were turned on; and the vacuum rotameter was checked (Gilibrator
Digital Flowmeter, NIST traceable) to ensure that the flow rate was 7 ± 0.2 LPM. The vacuum
was then connected to the exhaust end of the animal exposure chamber.

       Four test animals were placed in the animal exposure chamber per ASTM  E-981-84
and provided with humidified clean air at 7 LPM for 15 minutes to establish baseline frequency
of breathing rates and control waveform morphology  (period 1). The source chamber was
then connected to the exposure chamber and clean,  zero-grade, humidified air was pulled
through the source chamber across the carpets and into the animal exposure chamber for one
hour (period 2).  After one hour of exposure to effluent from the source chamber, the source
chamber was again sealed and test animals were again exposed to humidified, zero-grade air

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for a 15-minute period to evaluate if the animals recovered from the exposure (period 3).
During these three evaluation periods (control, exposure, and recovery), magnehelic pressure,
temperature from four thermocouples, humidity, and O2 and CO2 were monitored.

       After the recovery period, the mice were immediately removed from their
plethysmographs and were returned to their home cage, where their behavior and appearance
was observed for 15 minutes. Two exposures were completed in one day with two hours
separating the exposure periods. During this two-hour period, the heating blankets were left on
and the temperature was monitored and adjusted to maintain, if possible, the temperature
inside the source chamber. Following the second and fourth exposures (days 1 and 2), the
mice were observed for 15 minutes, after which, each mouse was removed from the home
cage and was examined and scored using the functional observational battery. This pattern
was repeated on the following day such that one experiment included four, one-hour
exposures conducted over a two-day period.  Between the second and third exposures, carpet
samples remain sealed in the source chamber overnight without additional heating.

       Upon completion of the last (fourth) exposure and functional observational battery, all
mice were sacrificed for the postmortem evaluation.  Additionally, the flow through the entire
exposure system was checked.  This procedure was initiated to evaluate leaks into the
exposure system from sources other than the supply cylinder air (e.g., loose fittings, holes in
the duct tape front seal, etc.). The system leak check could only be performed after the fourth
exposure, otherwise carpet emissions would be potentially lost

Exposure System   The design of the exposure system for evaluating the emissions of

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carpets is shown in Figure 1.  Basically, the system consists of a humidified clean air system,
a modified aquarium as the source exposure chamber, carpet samples, a heating and
insulation system for the source chamber (not shown), an animal exposure chamber, and
several physical and biological monitoring systems.

 Air and humidity system During the carpet exposure period (see protocol), the emissions
from the source chamber were pulled through the animal exposure chamber at 7 LPM under
approximately -0.06" of water pressure.  Certified zero-grade air (National Welders) from a
compressed gas cylinder was used to supply excess air flow (approximately 14 LPM) to the
source chamber.  The airflow from the cylinder was divided into two streams, with the flow
rate of each stream controlled by a mass flow controller (one 10 SLPM and one 20 SLPM
mass flow controller electronically controlled by a Tylan RO-28  Flow controller). The mass
flow controllers were calibrated just before the first experiment (Gilibrator Digital Flowmeter,
NIST traceable). One air stream passed across room-temperature distilled water held in a
one liter glass impinger, the other air stream remained dry.  The two flows were recombined
and monitored for relative humidify (Omega RH411, Digital Thermo-Hygrometer) just before
entering the source chamber. Alteration of the ratio of the wet  and dry flows was used to
adjust the humidity of the inlet stream.  A relative humidity of 50 ± 10% was set as the target
concentration.  Excess airflow (approximately 7 LPM = 14 LPM cylinder • 7 LPM vacuum)
was allowed to escape into the laboratory before entering the source chamber.

Source Chamber     A commercially purchased 10 gallon (38 L) fish tank (Fish Pros, Raleigh
NC) was used as the carpet source chamber.  All aquariums were first prepared by removing
the plastic rim using a hot air gun and a knife. Excess silicone adhesive was then removed

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 with razor blades and precision knives (X-acto).  The aquarium was turned on its side so that
 the opening was facing outward (toward the animal exposure chamber) and the long side
 panels (10"x 20") became the top and the bottom. The top and sides were covered in duct
 tape to conceal the contents. A front cover was constructed from a 10" x 20" double thick
 (0.1875") plate glass.  In diagonal comers of the front cover, 3" from each side, two 0.5"ID
 holes were fitted with nylon bulkhead fittings.  This front cover was attached to the aquarium
 with duct tape and covered with duct tape to conceal the contents of the source chamber.  A
 28/12 ground glass female socket was placed on the upper 0.5"! D nylon fitting, and a 28/12
 ground glass male ball joint was connected to the lower fitting.  Supply air entered through
 this  upper hole and the source chamber atmosphere exited through the lower hole into the
 animal exposure chamber. An additional hole was cut in the front plate to accommodate a
 teflon coated 6" thermocouple probe placed in a 0.25"ID nylon fitting located 2" below the inlet
 fitting.  A  heating pad (Sunbeam model E12107) was used to heat the bottom of the
 chamber, while the top of the chamber was heated with a wool heating throw blanket
 (Sunbeam  model HT-1).  The top, bottom, and sides of the chamber were insulated with a
 vinyl coated fiberglass blanket that was adjusted (opened or sealed) as necessary to achieve
 the desired target temperatures.

       Prior to use, the aquariums were baked overnight at test temperature conditions using
 laboratory air at 7 LPM to flush the excess adhesive vapors.  The aquariums were then
 washed with an Liqui-noxR detergent solution and rinsed with deionized water. The aquariums
 were air dried or dried with a clean tissue and considered suitable for use. Just prior to the
toxicology experiments, the dean dry tank was heated for one hour under test conditions and
 duplicate 3L ST032 sorbents were collected from the heated aquarium to establish a system

                                       EPA - 21

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background before the carpet was installed.  The carpet was installed in three 1-ft2 sections,
rolled fiber-side out and stacked in pyramid fashion diagonally on the aquarium bottom
surface. During control experiments, the aquarium was sealed empty (i.e., Treatment B).

Carpet source and sample collection      Two carpets were selected for evaluation from
sites that have been tested at Anderson Labs and were shown to produce severe tbxicity or
death in mice under test conditions.  Carpets were collected by the CPSC, according to
protocols described briefly below.  The collection, transportation, and storage processes were
standardized to minimize potential differences among subsamples.   Carpet samples were
collected by CPSC personnel as soon as was practical after source sites were selected and
access had been obtained.

Sample Collection Protocol        Site data were collected using CPSC's Investigation
Guideline (appendix  G, Carpet Test Plan). Approximately 50-100 ft2 of carpet was collected
by CPSC from the site and stored.  Each sample or portion collected was tagged with an
identification number and wrapped in Tedlar.  Labels with the official sample collection number
were attached to the bag. A collection report was included with the sample describing the
collection procedures, location, date of collection, and signature of the collecting agent.
Packaged samples were placed in an appropriate shipping container and shipped to CPSC
within 48 hours of collection.  Samples were logged on receipt by the CPSC, inspected for
shipping damage, subdivided  into 1-ft2 pieces that were labeled, randomized, and then
packaged in groups of three in sealed Tedlar bags. Bags were stored at room temperature in
a sample storage room.  The  CPSC maintained a bound log of all samples and subsamples.
Subsamples were shipped via air express to EPA and Anderson labs approximately 48 hours

                                       EPA  22

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before testing.

Animal exposure chamber   A 2.3-L glass chamber with four attached plethysmographs was
purchased (Crown Glass, Somerville, NJ) to conform to ASTM  E-981-84 standards.  Prior to
use of the chamber and between experiments, it was washed with analytical grade glass
deaner (Uqui-nox") and thoroughly dried in a drying oven at 180° F. During exposure, mice
were restrained in head-out plethysmograph tubes, according to ASTM E 981-84.  Mice were
loaded into the plethysmographs using a rubber stopper with a plunger that sealed the back
end of the plethysmograph and pushed the hind quarter of the  animal forward forcing the head
through a latex collar.  The neck was sealed around a 5/16" hole in a latex dam (thin gauge
green #02146, Hygienic,  Inc.). The latex dam was attached to the animal exposure chamber
using duct tape.  A 1/2" hole in the duct tape aligned with the 5/16' hole in the latex to
accommodate the animal's neck. A cotton-tipped applicator was placed in front of the collar
during loading to prevent the animal from biting the collars.  Between exposures, collars were
checked for potential leaks and changed as necessary.  Plethysmographs were wiped dean
with tissue and distilled water after each exposure.  Latex collars were  always replaced
between experiments.

Exposure measurement system      Three additional systems were used to monitor
conditions before and during carpet emissions.  Four thermocouple probes and an electronic
thermometer (Omega HH21 Thermocouple Thermometer) were used to monitor and regulate
the source and animal exposure chambers. The probes were located in the following
positions (Figure 1):  (1) 82 (chamber bottom, outside surface,  target temperature =
70 ± 5 °C); (2) S, (chamber top, outside surface, expected temperature = 40 ± 3 °C); (3) A,

                                      EPA-23

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(source chamber air, target temperature = 37 ± 3 °C); and (4) A, (animal exposure chamber,
expected temperature = 24 ± 2 °C).  All thermocouples were calibrated before the initiation of
the experiment against a NIST thermometer.

       Percent oxygen (O2) (Beckman Labman Oxygen analyzer) and carbon dioxide (CO2)
(SensorMedics Medical Gas analyzer LB-2) were monitored and recorded every 15 minutes
during the experiment. A single point calibration was performed daily and multipoint
calibrations using certified gas sources were performed just prior to and midway through the
study. Additionally, static pressure was measured inside the animal exposure chamber using
both positive and negative magnehelics (Dwyer Instrument Co.) that were capable of reading
between 0 and 0.5" water pressure.

Animals     Weekly, 20 male Swiss-Webster mice (viral antibody free), weighing 18 to 22
grams were delivered from laconic Farms,  NY.  From each shipment of mice, sentinel
animals (four to five mice per experiment, total number of sentinel animals = 27) were sent for
serology, microbiology, and parasitology. The sentinel mice were found free of all common
infections, including murine virus antibody, respiratory tract pathogens,  endoparasites,
ectoparasites, and fecal Pseudomonas.   Mice were group housed (10 per cage) on com cob
bedding in a climate- and light- (12 hours light/12 hours dark) controlled AAALAC-accredited
vivarium for at least seven days before testing. Mouse chow (Tech Lab Agway) and tap water
were available ad libitum.  Mice were considered acceptable for use after this waiting period if
they appeared healthy and their weight was between 25.5 and 28.0 grams.  Prior to weighing
mice, the mouse scale accuracy was assessed using a 100 gram transfer standard weight
Particulate filter tops were used when transporting the animals between the vivarium and the

                                      EPA - 24

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laboratory for exposure.

       Initially, six animals that met the weight criteria were tail-marked and evaluated using
the functional observational battery (see description below). Those that were acceptable
(general appearance normal and could perform the tests in the neurobehavioral screen) were
candidates for use in the exposure on the following day. On the day of exposure, four mice
were loaded  into the plethysmographs. The two remaining mice were not exposed and served
as nonrestrained cage controls for postmortem evaluations. During the entire study, three
mice that were initially loaded into the plethysmograph on the first exposure day were
eliminated, according to ASTM E-981-84 guidelines, because  of abnormally low baseline rates
or misshaped respiratory waveform patterns.   When this occurred, the mouse was swapped
with one of the cage controls. Between exposures, the four mice in an experiment were
returned to an acrylic cage with com cob bedding located in the laboratory.  This cage was
covered with  a filter top through which charcoal-purified, HEPA-filtered air was forced so as to
maintain a chemical-free environment during the two days in which exposures were
performed. While the mice lived in the laboratory, they received food and water ad libitum,
except during exposure. The two non-exposed (unrestrained  controls) mice from the original
six were  housed similarly, but separately from the exposed group. Besides the screening
body weight measurements, body weights were also measured before each of the four
exposures. For the first 15 minutes after each exposure, general appearance and activity in
their home cage were also noted.

Functional Observational Battery
Test procedure       The functional observational battery was conducted according to the

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protocol (Appendix B, U.S. EPA Carpet Test Plan), which describes the progression of tests
and standardized scoring criteria for each measure. This protocol was originally based on that
used in this laboratory for rats; modifications and additions were made to stress the possible
neuromuscular component of this toxicity syndrome, and to include measures which Dr.
Anderson, in her experience, felt were particularly sensitive.

       The tests began with the trained observer hanging the mouse by one hind leg onto the
lip of a 1-gallon glass jar. The mouse had to pull up and stand upright on the jar rim, and this
was repeated three times. Next, the mouse was placed horizontally across a screen, held at
a 45* angle, and was given 20 seconds to either rotate and walk up the screen, walk straight
across, or rotate and move down the screen; this was also repeated three times. While on
the screen, the observer scored how often the mouse slipped a paw down between the wire
mesh. The screen was then placed on a table edge, and the mouse, held by the tail, was
lowered towards it.  A positive forelimb placing response was noted when the mouse reached
toward the screen.  The mouse was then allowed to grab the screen and was raised up until
the screen was perpendicular.  The number of times the mouse dropped the screen was
counted.  The mouse was then held in the observer's hand, during which time its reactivity to
being handled, lacrimation, palpebral closure, and salivation were ranked. In addition, the
presence  of piloerection; exophthalmus; cyanosis; gasping; facial swelling; or blood around the
eyes, ears, or nose  were  noted. Body tone was scored by assessing the resistance of the
abdominal muscle to light finger pressure. Holding the mouse between the palms of the
hands, the observer flipped it over and scored the ease with which the mouse regained
normal posture.
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       Open-field observations took place on the top of a laboratory cart (60 x 90 cm) with a
3" rim around the perimeter and covered with plastic-backed paper (which was changed
before each test). The mouse was observed for exactly two minutes.  During this time, the
number of rears were counted,  and gait characteristics, ataxia, degree of body tilt, alertness,
and overall level of activity were scored. Descriptions were recorded for body posture and
any donic or tonic motor movements.  The observer also recorded any diarrhea, excessive
vocalizations, stereotypic movements,  or any other atypical behaviors. The mouse's reactions
to a puff of air delivered to the face, the sound of a metal clicker, or a tail pinch using forceps
were then scored.  Finally, the mouse  was placed on the screen, which was then inverted.
The time required for the mouse to climb over the edge, back to the top, was recorded, with a
60-second cut-off.  During the preexposure test only, mice were given up to three tries, along
with some prodding in some cases, to leam this task.

       Observational testing required 5 to 10 minutes per mouse. All data were recorded on
preprinted sheets and were later entered into a computer for further analysis.  The observers
(one performed the manipulations, the other recorded the data) were unaware of the treatment
conditions.  Testing was conducted in  the same laboratory where exposures took place.  Entry
to the room was restricted during  testing, and extraneous noises were held to a minimum.

 Frequency of breathing measurements
 Data acquisition system     Four pressure transducers (Validyne  DP-45) were connected
to each plethysmograph via a 7" segment of thick-walled Tygon tubing.  The transducers were
connected to a chart recorder (Astro-Med, Dash-4) via preamplifiers (Hewlett-Packard, Model
8805B). A signal from the preamplifiers was also fed to a custom built frequency-to-voltage

                                       EPA - 27

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converter that reported the instantaneous frequency between two peaks meeting its threshold
requirements. The frequency data were then converted to a voltage and digitized by a
personal computer every five seconds. A computer program converted the voltage back to
frequency and stored and displayed the median value for the 12 samples as the
representative frequency for each mouse during the one-minute sample. Data files for each
experiment were named by date (e.g., MT921101.EXT) and stored on the hard disk.

       Before each experiment, the data acquisition system was calibrated using several
independent methods.  The chart recorder and frequency-to-voltage converter were first tested
using internal calibration circuits residing within the instruments. The preamplifiers were
balanced without, and then with, the electrical load contributed by the transducer. A closed
vial was loaded into the plethysmograph to simulate the displacement volume of a 25-gram
mouse.  A fixed volume syringe pump (approximately 0.25 ml) was oscillated at a fixed
frequency (approximately 250 CDS) into the constant volume plethysmograph and the
amplitude of each of the four chambers was adjusted to 6 volts of the full 10-volt scale.  The
frequency was then noted on the frequency-to-voltage converter and hand checked on the
chart recorder.  Previous experiments had verified that the transducer/plethysmograph system
was linear between 100 and 300 breaths per minute, and that the frequency-to-voltage
converter was accurately digitized by the computer between rates of 0 and 600 cycles per
second.

       Once the mice were loaded into the plethysmographs, the chart recorder was run at 10
mm/second and tidal breathing of the animals was examined to see that the signal was at
least 50%, but not more than 90%, of the width of that channel's chart and that the rates were

                                       EPA -  28

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between 200 and 275 breaths per minute. The chart recorder was then set to run in dual
speed mode (10 seconds at 10 mm/second, 50 seconds at 5 mm/second) and marked with
the experiment and exposure information. Similar information (investigator name, animal
species, strain, sex, date of birth, date of arrival, experiment number,  exposure number and
exposure information [up to 1 line of text], animal numbers, animal weights, and exposure
protocol information [control, exposure, and recovery times]) was then entered in the
computer. The chart recorder and computer program were started simultaneously so that
samples would be time stamped and matched. At the conclusion of the exposure, the data
files were backed up to floppy disk and stored.

Subjective evaluation of waveforms        During exposure, the chart recorder was run at
two speeds so that waveform morphology could be subjectively scored according to criteria
established in the ASTM  E-981-84 and subsequently refined in discussions between our
laboratory and Anderson Laboratories. For each minute, for each mouse, a subjective score
between 0 and 3 (0=none,  1=slight, 2=moderate, and 3=severe) was entered onto a
preprinted data sheet in three different categories. Subjective scores were entered for
sensory irritation, pulmonary irritation, and a disruption index based on the extent and severity
of irregular waveforms not fitting into the above categories (e.g., movement artifacts).  The
disruption index primarily identified sighs (large tidal excursions) and movement artifacts. Two
to three sighs or disruptions were scored as slight (1), while more frequent and prolonged
disruptions were scored moderate (approximately 2 to 10 disruptions) or severe (>10
disruptions). For sensory and pulmonary irritation, if several breaths were of the  characteristic
shape, and  those breaths did not precede or come immediately after a disruption, the entire
minute period was scored by those breaths. This technique would tend to overestimate the

                                      EPA - 29

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amount and severity of irritation compared to the decrease in frequency of breathing.  All
respiratory waveforms were scored by the same person, usually during each exposure.

       The minute-by-minute data (90 minutes) for each animal (N=24) for each exposure (4)
for the three different measures (sensory irritation, pulmonary irritation, and the disruption
index) (total =25,920 hand measurements) were reduced to a single score for each period
(control, exposure, and recovery) for each animal for each exposure for each measurement
type.  Previous analyses indicated that the highest (1 to 3) severity score that appeared four
or more times would be significantly different from all lower scores.  Thus, the highest severity
score that occurred four times was used as the score for the entire period for that animal.
The criteria for scoring a period as not zero were purposely set low (4 observations during the
60-minute exposure) to increase the sensitivity of detecting positive effects.

Postmortem Evaluation   Immediately after the functional observational battery testing,
mice were deeply anesthetized with halothane and the orbital plexus was tapped to obtain
blood for analysis of %methemoglobin, %carboxyhemoglobin, and hemoglobin content
(Operator's Manual IL282 CO-Oximeter, Instrumentation; Brown, 1980). The mouse was then
exsanguinated via heart puncture, a peripheral smear was obtained, the remaining blood was
centrifuged, and serum was collected and immediately frozen at -70 °C for analysis within the
week.  Peripheral blood cell differential counts were enumerated after applying Wright Giemsa
stain.
Clinical Chemistries  Clinical chemistries were performed on all available serum.  For most

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mice, 350 uL was obtained so that the full battery could be examined, which included
bilirubin, lactate dehydrogenase (LDH), alanine aminotransferase (ALT), aspartate
aminotransferase (AST), creatinine, blood urea nitrogen (BUN), 5' nucleotidase (5'-ND),
glucose, alkaline phosphatase (ALP), total protein, isocitrate dehydrogenase (ICD), albumin,
triglycerides, cholesterol, sorbitol dehydrogenase (SDH), and bile acids. However, for several
mice with insufficient serum, clinical chemistries were not performed on SDH and bile acids.
All clinical chemistries were performed using a centrifugal analyzer (Cobas Fara II clinical
chemistry analyzer) using kits (Sigma) adapted for use with this analyzer.

Nasal and Lung Lavage     After the mice were bled, a nasal lavage apparatus was inserted
into the posterior pharynx and 0.5 mL of warmed 0.85% saline was injected through the nose
and collected at the end of the nares. The mouse was then tracheostomized (20 gauge Luer
adaptor) and lavaged (BAL) three times using the same aliquot of saline (0.8 mL). The nasal
lavage and BAL were held on ice until centrifugation and the cell pellet and supernatant were
prepared for further biochemical analyses or for evaluation of cell count and differential (Ghio
et al., 1991). Cell count was obtained using a Coulter counter (Coulter Electronics, Inc.) and
cell differential was enumerated after Wright Giemsa staining.  The supernatant of the lavage
was immediately analyzed for indicators of lung injury, protein, and LDH (Ghio et al., 1991;
Smialowicz et al., 1991) using a centrifugal analyzer.  Protein was measured using the Bio-
Rad method for measurement of total protein using bovine serum albumin as  a standard.
Lactate dehydrogenase was measured using a purchased kit (Sigma).  Perchloric acid (17.5
uL) was added to the supernatant from the nasal lavage prior to high speed centrifugation.
The high speed supernatant was stored at -70 °C until it was analyzed for ascorbic and uric
acids, and glutathione.  The high speed pellet was analyzed for total protein using the

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 centrifugal analyzer as described above.

 Necropsy and Histopathology       Major organs (kidney, liver, brain, lung, nose, heart,
 thymus, spleen, adrenal, diaphragm, thigh muscle, stomach, duodenum, and colon ) were
 grossly observed and removed under the supervision of a certified veterinary pathologist
 (Experimental Pathology Laboratories, Inc.)- Organ weights for brain, heart, thymus, spleen,
 liver, and kidney were obtained prior to fixation.  Lungs were infused with a syringe containing
 a volume of 10% neutral buffered formalin equivalent to the volume removed after BAL The
 removed organs and remaining carcass were appropriately fixed in 10% neutral buffered
 formalin for histopathology and stored (Feldman and Seely, 1988). The following tissues were
 paraffin embedded, stained with hematoxylin and eosin, and microscopically examined for
 histopathological damage: kidney, liver, brain, lung, nose, heart, thymus and spleen, adrenal,
 diaphragm, thigh muscle, stomach, duodenum,  colon, and any other tissue with gross
 abnormalities.

       The relative degree of severity of inflammatory, degenerative, and proliferative changes
 were graded using the following scale:  minimal (1), slight/mild (2), moderate (3),  moderately
 severe (4), and severe/high (5). Congenital lesions were not graded, but instead were
 designated as present when observed.

General Data Analysis Strategy         Due to the small number of carpet samples and
test animals used in these exploratory experiments, detailed statistical analyses correlating
variables of the test system with measures of toxicity were not feasible. However, the general
data analysis strategy was designed to  answer  if the EPA could replicate Anderson's results

                                       EPA-32

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with carpets shown to produce toxicity to mice in her system.  Positive answers to any of the
four questions posed below would constitute a successful replication of toxicity observed at
Anderson Laboratories.

1. Are deaths observed at both laboratories in test animals exposed to emissions from either
carpet, but not observed from exposure to air?

2. In the absence of death, is unquestionable evidence of toxicity observed at both
laboratories using the functional observational battery criteria (e.g., paralysis or seizure-like
behaviors) from either carpet, but not air?

3. Do the detailed clinical chemistry, lung lavage analyses, and histopathologic evaluations
suggest abnormalities in mice exposed to carpet, but not air?

4. Are severe alterations in breathing pattern and rate as defined in ASTM E-981-84
observed for carpets, but not air exposures at both laboratories?

       For all biological end points, descriptive statistics (means, standard deviations, and
plots) were obtained.  No attempt was made to evaluate the equivalence of the replicate
exposure groups because the number of animals was too small (N=4). Treatment group A
was  a carpet exposure, B was an exposure to zero-grade air, and C was an exposure to a
different carpet sample than Treatment A.  For most end points, one-way analysis of variance
(ANOVA) was used as a first step to examine overall treatment effects on any single
parameter. In the event of a significant treatment effect, statistical comparisons to Treatment

                                       EPA -33

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 B (zero-grade air group) as well as the nonrestrained control group were made using
 appropriate parametric or nonparametric tests.  The significance level for accepting false
 positives (Type I errors) was set at 5%.  Because this study was exploratory in nature,
 corrections for multiple pairwise comparisons were not made, thus increasing the likelihood of
 calling a finding significant when it was not. This strategy was developed so that the results
 could be used to help define potentially important parameters for testing in later studies.
 Unless otherwise stated, data are presented as mean ± standard deviation for all tables and
 figures.

        For some end points, the analysis examined the three treatment groups, A, B, and C,
 during or after four exposures.  This type of data required a two-way ANOVA using treatment
 and exposure as the two factors.  Treatment refers to the contents of the source chamber
 only, whereas exposure refers to the four consecutive exposures in any experiment regardless
 of the contents of the source chamber. Thus, a significant treatment group effect would
 indicate that a significant difference between treatment groups (A, B, or C) occurred, but it
 was unrelated to the number of exposures or exposure procedure (i.e., the same effect was
 seen after each exposure).  A significant exposure effect would indicate that there were
 significant difference between exposures, but that it was unrelated to the treatment group (i.e.,
 all treatment groups behaved the same way).  If a significant treatment-by-exposure
 interaction occurred, then the effect at different exposures was different for different treatment
 groups.  For example, if only on the last exposure day, Treatments A and C had significant
decreases in the frequency of breathing, then a significant treatment-by-exposure interaction
would occur. If Treatments A and C showed decreases in frequency compared to Treatment
B after every exposure, there would be a significant treatment effect If all treatment groups

                                       EPA-34

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increased the frequency of breathing with each exposure, then a significant exposure effect
would be found.

Physical exposure data     Mean values from serial measurements (temperature and
humidity) and maximal deviation (magnehelic pressure, %O2, and %CO2) were reported on the
data summary sheet No formal analyses of these data were undertaken, except to note
when excursions beyond the target conditions existed.

Subjective Appearance     The incidence of occurrence (yes/no) for puffy faces,
hemorrhaged ears, dilated ear vessels, and lacrimation were analyzed using a categorical
modeling procedure for the linear analysis for nonparametric data (CATMOD; SAS 1990).
Two factors, treatment and exposure, were evaluated.  If no significant treatment-by-exposure
effects were observed, the data were collapsed across exposure and reanalyzed to determine
if any treatment effects could be detected.

 Frequency of breathing     One-minute measurements of breathing frequency data were
collected for each mouse for the three periods during each  exposure. The one-minute
measurement consisted of the median of 12 instantaneous  samples from the frequency-to-
voltage converter that were sampled by the computer every five seconds. The median was
used rather than the mean to filter outliers in the measurement sample.  A  spreadsheet
program (Excel, Microsoft Inc.) transformed the data into percent difference by dividing the
mean of the last five minutes in the control period by each  minute during the exposure and
recovery period,  subtracting one from the ratio and multiplying by 100.  The program then
highlighted the highest percent increase and decrease from control during the exposure

                                      EPA-35

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period.  Thus, for each animal at each exposure, four values were reported, the mean of the
last five minutes of the control period, the greatest percent increase and decrease during the
exposure period, and the mean of the recovery period.  All statistical analyses were done on
these data. The mean frequency of breathing for the group of four mice and the mean
percent difference from the control period were also calculated for three-minute periods as per
ASTM E-981-84.

       Because of the repeated nature of these data (i.e., the same animal was measured
four times), two-way repeated measures ANOVAs were used for the analyses.  The analyses
modeled treatment with three levels (A,  B, and C) as one factor, and exposure was the
repeated measure with four levels (1 to  4).  Four analyses were performed.  The first analysis
examined the mean control period value for each animal for each exposure, to evaluate if the
animals from different treatment groups  were initially the same. Additionally, the analysis
examined if the control period from subsequent exposures was the same as the initial data or
whether there was a carry-over effect  Carry-over effects could result either from the
treatment or the exposure procedure, and could result in differences in subsequent control
periods.  The second and third analyses evaluated effects during the exposure period. These
analyses examined whether the greatest increase or decrease percent difference from control
was affected by either the treatment or the  exposure procedure. The fourth analysis evaluated
whether the recovery period was different from the control period and whether carry-over
effects occurred  due to treatment or the exposure procedure.

Subjective scores of pulmonary waveforms         The incidence of severity score data were
analyzed using a categorical modeling procedure for the linear analysis for nonparametric data

                                       EPA-36

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(CATMOD; SAS 1990). Two factors, treatment and exposure, were evaluated.  If no
significant treatment-by-exposure effects were observed, the data were collapsed across
exposure and reanalyzed to determine if any treatment effects could be detected.  If the
treatment-by-exposure interaction was significant, one-way ANOVAs were conducted on the
treatment effects after each individual exposure.

Functional Observational Battery         The two test groups for each treatment (sample)
were combined for all analyses, thus n=8 per group. Statistical analysis procedures for the
data derived from these tests have been described (Creason, 1989).  Descriptive and rank
data were analyzed using a categorical  modeling procedure for the linear analysis for
nonparametric data (CATMOD; SAS 1990).  Initially, preexposure data were examined using a
one-way ANOVA to determine if  significant differences existed between treatment groups. For
those measures that showed a significant or equivocal difference in the preexposure test, the
analyses were applied to the change from baseline (delta) values rather than actual values.
Overall, ANOVAs  were conducted using treatment as the grouping factor, and repeated-
measures across time (days 1 and 2, corresponding to the tests after the second and fourth
exposures).  If there was a significant treatment-by-time interaction factor, one-way ANOVAs
for each day of testing were conducted.  If only the treatment effect was significant, treatment
groups were collapsed across the days  and subjected to ANOVA. Treatment groups were
compared using mean contrasts  (SAS 1990).

      The number of rears, being the only continuous variable, was similarly analyzed except
that the GLM procedure was used (SAS, 1990).  Square-root transformation was included to
more closely approach a normal distribution of the data.

                                      EPA - 37

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       In all cases, probability values <0.05 were considered significant However, p-values
that approached significance (p<0.10) were taken into account, along with time-course or
severity of effect, when evaluating the data from each measure.

Postmortem variables         The analysis of most of the postmortem variables was
simplified because only one value for each measured parameter existed for each animal.
One-way ANOVA was used to evaluate the pooled (N=8) three treatment groups (Treatments
A, B, and C).  If a significant treatment effect was observed (psO.05), two post-hoc Students t-
tests were performed comparing the mean of Treatment B with that of Treatment A and C. If
non-exposed control animal measurements were available for the parameter, a separate
ANOVA was performed, using the non-exposed control as a fourth  treatment group in the
ANOVA. In the event of a significant effect using this analysis, the nonrestrained control group
was compared to the restrained control group (Treatment B) to see if there was a significant
effect of the exposure regimen.

Quality Assurance        Because of the high visibility of this study and the importance of
this study to the EPA, an internal and external quality assurance program was instituted that
was specifically tailored to this study. For the biology studies conducted at the Health Effects
Research Laboratory, an interim Quality Assurance Project Plan, written protocols, and
operating procedures for all techniques and end points were developed. Additionally, several
internal quality control checklists were developed to ensure that all  steps in all procedures
were carefully defined and followed. Table 2 is an  example of the  exposure checklist form.
                                       EPA-38

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Experiment Name:
Date:
              Table 2. Mouse Pulmonary Function Checklist
                                       Exposure Number
                                       Name:
        Glass chamber is clean and all ports are connected or closed.
        Dams are not jagged or punctured and completely sealed against chamber.
        Create page in logbook with animal number/weights and comments as needed.
        Mark beginning of chart with experiment name, exposure and animal numbers.
        Check O2 setting at 20.9% and CO2 analyzer at 0.03%	
        Calibrate Frequency to Voltage converter (1st exposure only)
        Tidal signals should be triangular and of similar bandwidth (-2/3).
        Make sure corks are tight, but stoppers are pulled back behind pressure port.
        Before exposure, turn Tylan and humidity sensor on
        Turn air cylinder on
        Humidity should read between 40 and 50%
        Water vessel is appropriately filled
        Set Vacuum rotameter and check flow with Gilabrator
        Connect supply air and vacuum, tighten fittings
        Mark beginning of exposure period.
        Record pressure on report sheet and temperature and humidity every 15 minutes
        Mark end of exposure period.
        At end of experiment, copy data onto backup floppy.
        Write O2 and CO2 peak values on report sheet
        Each day analyze data and put analysis and this form in a notebook
  Tm
 15
 —
 —
 —
 —
 90
Humidity
Inside Temp
    CC)
Top Temp
   fC)
BottomTemp
    fC)
Mouse Temp
    fC)
                                         EPA-39

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       Besides internal quality control procedures, the EPA requested an external audit by the
 Research Triangle Institute, to review all procedures, ensure that all critical instruments were
 operating correctly, verify that procedures were being followed, and recommend improvements
 in existing procedures. Two types of quality assurance audits were performed.  A technical
 systems audit and a performance evaluation audit of relative humidity and temperature
 sensors, positive and  negative magnehelics, O2 and CO2 monitors, and indicated flow-rate
 measurement instruments were performed.

       The objectives of the audits were (1) to assess this study for compliance with
 requirements documented in the study protocol, Quality Assurance Project Plan, and operating
 procedures for the EPA carpet emissions project; and (2) to evaluate the study record-keeping
 procedures for data completeness, accuracy, traceability, and  defensibility.

       Due to concern that the audit personnel and activities could influence the test animals,
 and thereby compromise  the experiment, the technical system audit was not conducted while
 exposures and postexposure functional observational batteries were being performed.
 Consequently, the audit was based on interviews with project  personnel and review of project
 records, and not on direct observation of experimental procedures. Interviews were
 conducted using a checklist, and review of project records included a data tracking exercise
 conducted for two animals

       The objective of the  performance audit was to assess the performance of instruments
to provide an independent evaluation of the quality of the data generated by them.
Performance evaluations of the carbon dioxide and oxygen analyzer, five temperature
sensors, one relative humidity sensor, two pressure sensors, and two flowrate sensors were

                                       EPA - 40

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conducted. The oxygen analyzer was evaluated at one concentration using direct sampling of
a National Institute of Standards and Technology-Standard Reference Material (NIST-SRM).
Because this was a primary standard, no verification was necessary. The flow rates were
measured using a soap film flow meter, and the magnehelic gauges were audited using an
inclined manometer.  Both of these devices are primary standards and verifications were not
necessary. Temperature and relative humidity sensors were conducted according to SOP
comparing NIST traceable sensors with test system probes.
                                      EPA - 41

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Results
Exposure system
Temperature  Two temperatures were considered critical to replicate the temperature
conditions used at Anderson Laboratories.  The first critical measurement was the air
temperature in the source chamber. Although it was dear that there was a nonuniform
distribution of temperatures in the source chamber, the A, probe site was used to estimate
average source chamber air temperature. Attempts to keep this temperature stable (37±2 °C),
despite the crude method of heating, were successful for all 24 exposures (Table 3).
Similarly, attempts to keep the outside bottom temperature (S2) at 70±5 °C were successful;
however, there were specific days when we could never achieve the target temperature of 70
°C (Table 4). Despite our best attempts, the temperature in the plethysmograph hovered at
the outer limits of acceptability (24±2 °C) for 16 of the 24 exposures (Table 5). This was
primarily due to changes in the laboratory ambient temperature. With the discovery and
subsequent repair of a leaky room air conditioning unit, the final experiment  more closely
approached the target temperature.
                                      EPA-42

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Table 3.  Temperature (°C) - inside of Aquarium (A,)
.TREATMENT
EXPERIMENT #




EXP1
EXP2
EXP3
EXP4
A
9317
37.7
37.0
37.3
37.7
9322
36.0
36.1
37.6
36.3
B
9318
37.4
36.9
39.3
36.9
9319
37.3
37.6
37.6
37.7
C
9320
36.9
37.3
37.6
36.9
9321
38.3
36.3
36.4
36.1
Table 4. Temperature (°C) • Bottom of Aquarium (S2)
TREATMENT
EXPERIMENT #




EXP1
EXP2
EXP3
EXP4
A
9317
69.9
71.4
71.3
71.6
9322
71.9
72.7
73.7
72.6
B
9318
64.0
64.7
64.4
64.4
9319
65.4
66.1
65.9
66.6
C
9320
71.7
67.6
70.7
70.3
9321
72.6
72.9
73.6
73.0
                   EPA-43

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           Table 5. Temperature (°C) - Inside of Mouse Exposure Chamber
TREATMENT
EXPERIMENT #




EXP1
EXP2
EXP3
EXP4
A
9317
25.6
25.7
25.3
25.4
9322
22.1
23.1
23.1
22.7
B
9318
25.4
25.4
25.4
25.0
9319
25.6
26.4
25.9
26.0
C
9320
26.1
30.0
26.1
26.3
9321
24.7
23.6
23.4
22.7
sold numoer exceeaea study limit
Humidity The target relative humidity of 50±10% was not achieved.  Although the humidity
probe was audited just prior to the study, and typically, such probes maintain their calibration
for months, unbeknownst to us, at some time just before the study the sensor stopped
working correctly.  This error was discovered during the quality assurance audit after the
study was complete. Using a recently calibrated sensor, we were able to reconstruct the ratio
of dry and wet flows and calculate the actual relative humidity of air entering the source
chamber. These values are listed in Table 6. The actual humidity range was between 18.7%
and 29.2%.  If experiments are examined in date order, the progressive failure of the relative
humidity sensor can be observed.
                                       EPA-44

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          Table 6.  Percent Relative Humidity of Air Entering the Source Chamber
TREATMENT
EXPERIMENT #
EXPOSURE DATE




EXP1
EXP2
EXP3
EXP4
A
9317
3/9-10
29.2%
29.2%
27.6%
27.6%
9322
4/1-2
18.7%
19.9%
19.4%
18.7%
B
9318
3/11-12
27.6%
27.6%
27.2%
27.2%
9319
3/23-24
21.2%
24.2%
20.3%
20.3%
C
9320
3/25-26
19.9%
19.9%
20.8%
20.8%
9321
3/30-31
19.4%
21.0%
19.4%
20.3%
Bold numoers are outside study target range
System Flow, Static Pressure,  Oxygen and Carbon Dioxide       These four measures were
made to support the critical measurements described above.  System flow, when measured at
the vacuum source, was always within 3% of the target flow (7 LPM) and within the limitations
of the normal house vacuum fluctuations.  At the end of each experiment, flow through the
entire system was checked to evaluate possible leaks in the system. Flow through the entire
system indicated that no more than 4% leakage occurred, which is well within measurement
error, indicating that there were no leaks. Static pressure was monitored to make sure that
the animals were not exposed for prolonged periods to excessive negative or positive
pressure (±0.3" water pressure).  During all conditions, static pressure was negative (vacuum
driven system) and ranged  between -0.05 and -0.075" water pressure, except for very brief
excursions (<10 seconds) when the source chamber was connected to the animal exposure
                                      EPA-45

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chamber. Larger excursions in pressure were tolerated at this time period to ensure that none
of the contents of the source chamber escaped into the laboratory. Oxygen and carbon
dioxide were monitored with no unusual findings, given the limits of accuracy and reliability of
these instalments.  The poststudy audit of the flow meter, the magnehelics and the oxygen
and carbon dioxide monitors indicated that all instruments were functioning properly and were
accurate within the limitations of the instrument.

Body Weight   All mice used in the exposure studies met the weight requirement for
inclusion in the study one day prior to testing (25.0 to 28.0  grams). Mice gained weight
between the pretest day and the first exposure day. Body weight on the first day of exposure
for all 24 animals ranged from 25.8 to 28.9 grams. Treatment (A, B, or C) had no significant
effect on body weight. On the other hand, the experimental procedure caused a reduction in
body weight (p<0.001), with each succeeding exposure, causing a further decrement in body
weight (Figure 2).  On average, animals lost 82% of their body weight between the beginning
of the first and the end of the last exposure.

Irritancy Measurements
Rate changes  Frequency of breathing was one of the primary measurements evaluated in
this study.  As described in the methods section, the data were analyzed in two ways. First,
the data were analyzed according to the ASTM E-981-84 procedure using the group mean
(N=4). To increase sensitivity, a second analysis was performed using individual animal data.

ASTM E-981-84  Analysis  The ASTM method specifies that the greatest percent reduction in
frequency for the mean of all four animals is to be used as "the" response for the test Thus,
statistics could not  be performed because the raw data (Table 7) consisted of only  six data

                                      EPA-46

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points per exposure (i.e., two per treatment group per exposure).
Table 7.  Percent Decrease in Frequency of Breathing for the Mean of Four Mice
Treatment
A-1
A-2
B-1
B-2
C-1
C-2
Sample #
1
6
2
3
4
5
Exposure 1
6.8
4.3
12.3
6.6
5.3
4.1
Exposure 2
6.0
3.2
6.3
42
2.0
5.7
Exposure 3
10.2
9.1
6.7
8.5
6.7
11.6
Exposure 4
13.3
13.3
5.8
9.1
6.4
14.2
 Bold numbers indicate those groups in which the percent decrease in frequency or breathing
would be classified as slight (12-20% decrease) sensory irritation by ASTM E-981-84.
       The data from Table 7 suggest that with an increased number of exposures, a
decrease in frequency of breathing is observed. When the two replicate experiments were
combined, there is some suggestion of a greater decrease in frequency of breathing during
the fourth exposure for Treatments A (13.3%) and C (10.3%), compared to Treatment group B
(7.5%).
 •
Individual Animal Analyses         Because there was some suggestion of an effect using
the ASTM E-981-84 criteria, a more in-depth analysis of the individual animal's response to
                                      EPA - 47

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treatment was examined. The analysis attempted to answer three questions related to the
treatment response of individual animals with four successive exposures during the three
measurement periods.

 1. Was there a treatment-related difference in frequency of breathing during the clean zero-
grade air control period? The ANOVA indicated that there was a treatment-related difference
(p=0.0129) in the control periods, with the Treatment B group having a slightly lower
frequency of breathing than Treatment A or C (Figure 3a).  Additionally, there was a significant
exposure-related effect (p<0.001) without an exposure-by-treatment related interaction
(p=0.759).  The lack of a significant interaction term  would indicate that the treatment-related
differences that occurred were maintained across the four exposures.  Thus, when the data
were collapsed across all treatment groups,  frequency of breathing elevated with increasing
numbers of exposures (Figure 3b).   This result would suggest that there was a carry-over
effect from the previous exposures, but it was unrelated to source chamber contents.
                                     r

2. Were differences in treatment groups observed during the exposure period?  Because
Treatment group B had a significantly lower frequency of breathing initially, and because that
difference  was maintained across the four exposures, all subsequent analyses were
performed on data adjusted for this difference. Percent difference from each animal's control
response was used as the adjustment Analysis of each animal's greatest one-minute percent
decline in frequency (Figure 4a) indicated that there were significant exposure-related effects
(p<0.001),  but no significant treatment (p=0.972) effects or treatment-by-exposure interactions
(p=0.639).  The significant exposure effect occurred because the decrease in frequency was
less after the second exposure and greater after the fourth exposure than the decrease
observed during the first and third exposure (Figure 4b).  This effect was significant only when

                                        EPA-48

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the data were collapsed across all treatment groups. A similar analysis of each animal's
greatest one-minute percent increase in frequency indicated that there were no significant
treatment or exposure-related effects.  With all treatments and exposures combined, the mean
greatest one-minute increase in frequency was 15.1%. Thus, overall, no treatment group
related increases or decreases in frequency of breathing could  be detected.

3. Were differences in treatment groups observed during the recovery period?  Although no
treatment-related differences were observed during the exposure period, it is possible that
treatment-related differences may become manifest  during the recovery period.  Another two-
way ANOVA was performed evaluating the percent difference from the control period.  The
analysis indicated that both significant exposure (p=0.013) and  significant treatment (p=0.044)
effects occurred; however, a significant treatment-by-exposure interaction was not observed
(p=0.529). The significant treatment-related effect occurred because, when collapsed across
all exposures, the Treatment A or B groups did not fully recover, whereas the Treatment C
group did (Figure 5a). The exposure effect occurred because the second exposure recovery
period was significantly (p=0.029) different than the  percent recovery for exposures 1, 3, and 4
(Figure 5b).

Subjective Evaluations of Pulmonary Waveforms    Alterations of the normal sinusoidal
respiratory waveforms were classified as either looking like sensory or pulmonary irritation, or
abnormal, but not either of the above (disruption index). The existence and severity of altered
respiratory waveforms were evaluated for each of the three exposure periods.   In general,
between 70 and 90% of all periods in an exposure had less than four one-minute scores
greater than zero (i.e., no evidence of sensory-like or pulmonary irritation).  Analysis indicated
that significantly more respiratory waveforms that looked like slight sensory irritation occurred

                                        EPA - 49

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during the control period (p= 0.012) and during the second and fourth exposure periods
(p=0.005) for the Treatment B group. Figure 6 shows the incidence of sensory irritation during
the exposure period when the data are collapsed across the four exposures.

       Although a significant treatment-by-exposure interaction was observed for pulmonary
irritation during the exposure period, the interaction occurred because of differences between
Treatment A and C during the fourth exposure. When collapsed across exposure periods, no
significant differences between Treatment B (zero-grade air group) versus A or C were noted
(Figure 7).

       There was also a significant (p=0.001) treatment-by-exposure interaction for the control
period when the disruption index was analyzed. This interaction occurred because Treatment
A showed more disruptions than Treatment B during the third exposure.  Although no
differences in the disruption index were observed during the exposure period, a marginally
significant (p=0.051) treatment effect was revealed during the recovery period because
Treatment A had more disruptions than Treatment B (p=0.039) when the data were collapsed
across all four exposures.  The disruption index for all periods combined (control, exposure
and recovery) and collapsed across all exposures (1 through 4) is shown in Figure 8.

Postexposure appearance     Although not part of the formal functional observational battery,
mice were observed for at least 15 minutes after each exposure.  During this time, any
unusual behavior or abnormal appearance was noted.  During most of these postexposure
observation periods, mice would initially be still and then after 2-3 minutes they would begin to
groom and drink water.  No abnormal behavioral observations were noted for any of the
animals.  However, their appearance was abnormal.  These effects, which included

                                       EPA-50

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lacrimation (tearing), dilated or hemontiaged blood vessels of the pinna (outer ear), and facial
swelling, were observed in all experimental groups after most exposures.  Analysis of the
incidence of occurrence indicated that there were no differences in incidence among treatment
groups for the facial swelling and hemonrhaged pinna.  For lacrimation (Figure 9) and dilated
pinna vessels (Figure 10), significant treatment differences were observed. Treatment C was
found to have significantly (p<0.001) less lacrimation, but more dilated pinna vessels
(p<0.001) than Treatment groups A or B.  No treatment-by-exposure interactions were
significant on these observations.

Functional Observational Battery        A summary of the data for all of the measures of
the functional observational battery is included in Appendix A. All tests were conducted at the
prescheduled times.  For ease of interpretation, the functional observational battery tests have
been sorted into groups representing the neurological functions they most closely represent
(1) neuromuscular function, (2) sensorimotor function, (3) general activity and  excitability, and
(4) general appearance and other measures.

      Some tests were not affected at any time; they showed no variability across groups
and therefore were not subjected to statistical analysis. These were: Body Tilt, Forelimb
Placing, Tonic Movements, Excessive Vocalizations, Diarrhea, Gasping, Cyanosis,
Exophthalmus, and Salivation. The results of statistical analysis for the remaining behavioral
measures are  shown in Table 8.  Significant or equivocal differences between groups were
detected in 8 of 18 analyses.
                                       EPA - 51

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Table 8.  Summary of Statistical Outcomes for Functional Observational Battery Data*
FOB Measure Treatment
II (TRTMT)
Neuromuscular
Jar Task
Grip Strength
Body Tone
Righting Reflex
Body Posture
Ataxia Score
Gait Score
Inverted Screen
Test
Missteps
Sig.
NS
NS
NS
NS
Equiv.
NS
NS
NS
TRTMT-by-Time Day 1

Sig.
NS
NS
NS
NS
NS
NS
NS
NS
Sig.
A*B








Day 2

Sig.
A*B
C*B








TRTMT






NS



Sensorimotor
Air Putt
Response*
Click Response
Tail Pinch
Response*
NS
Sig.
Equiv.
NS
NS
NS







Sig.
A*B
Sig.
A*B
OB
Activity and Excitability
Activity
Alertness
Handling
Reactivity
Rearing
Clone
Movements
NS
NS
NS
NS
NS
Sig.
Sig.
NS
Equiv.
NS
NS
NS

NS

Other
Tilted Screen | Sig.
NS |
Equiv.
C*B

NS








Sig.
A*B
  •DDaDUIiy Ol BiyniiiwciiH UIIIOIWIMO WBIWV
 Sig.«p<0.05
 NS « p>.10
 Equiv. = 0.05
-------
Neuromuscular function     Performance on the jar task was affected by treatment (Figure
11), showing a significant treatment-by-time interaction (p=0.042). Following the second
exposure (day 1), mice in the treatment A group had more falls than did Treatment B (air-
exposed group, p=0.002).  This difference was apparent again after the fourth exposure, but
the contrast was not quite significant (p<0.052). Group C was significantly different from
Treatment B, but this was because the Treatment C mice had less falls than the air-exposed
group (p=0.017).  Thus, more falls occurred after exposure to Treatment A than with
Treatment B, and better performance was observed with Treatment C after the last exposure.

       The overall analysis of ataxia score produced a marginal treatment effect (p=0.084).
However, when the treatment data were collapsed across days, the significant effect (p=0.051)
was between Treatment A and C. Thus, exposure to carpets did not produce effects on this
measure that could be differentiated from the air-exposed mice.

       One mouse in the Treatment B group dropped the screen twice, after both the second
and fourth exposures. There were some mice with slightly decreased body tone in all
treatment groups.  In addition, there was one instance of slightly slow righting in each of
Treatments B and C, and one hunched posture in Treatment B. Four, five, and six mice
displayed somewhat abnormal  gaits (score of 3) in the Treatment A, B, and C groups,
respectively; one mouse in Treatment B and one in Treatment C also showed marked gait
abnormalities (score=4). For all these measures, however, there were no statistically
significant differences in the distributions of these scores across treatment groups. Thus,
although there were some measures that showed deviations from preexposure values in these
mice, these differences were equally distributed across all treatment groups. When there
were only one or very few mice affected, most commonly it occurred in the Treatment B

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 group.
 Sensorimotor measures     There was a dear preexposure difference between treatment
 groups (p=0.01) in the response to the tail pinch, and responses to the air-puff stimulus
 showed a marginal (p=0.061) differences on the day before testing.  Therefore the data for
 these measures were analyzed using the change from preexposure values. A marginally
 significant overall treatment effect (p=0.066), but no treatment-by-time interaction, was
 detected  in the tail pinch response; there were no changes in the air-puff response. Mice
 exposed  to either carpet showed less increases in response to the tail-pinch than controls;
 that is, mice in Treatment B showed more increased responses than  did mice in either
 Treatment A or C (see Figure 12).  However, the data for mice in Treatments A and C were
 most like their pre-exposure values, and therefore the significance of this difference is
 questionable.

       There was a significant overall treatment effect with the dick response (p=0.004), but
 no treatment-by-time interaction. Further analysis revealed that mice in Treatment A showed
 less reactivity to the dick stimulus than did mice in Treatment B.  Figure 13 shows that
 following  Treatment A, there were more responses rated as "slight" (rank=2), whereas with
 Treatment B, more mice showed "dear" (rank=3) responses.  However, as with the tail pinch
 response, the scores in group A mice were more like their own preexposure data than were
 the Treatment B group's data.

Activity and Excitability      Changes in the ranking of handling reactivity and the number of
rears were the same in all treatment groups. One mouse in Treatment A and one in
Treatment B showed slight quivers after the fourth exposure.  None of these measures were

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statistically significant

       The overall treatment-by-time interaction for activity level was significant, but there
were no significant differences in rank distribution on any one day.  A trend was detected after
the fourth exposure (rx.0772), at which time the mice in Treatment A showed lower activity
levels than did those in Treatment B.

       The treatment-by-time interaction was also significant for the scoring of alertness
(p=0.024).  Univariate ANOVAs showed that on day 2, the mice in both Treatments A
(p=0.007) and C (p=0.029) showed lower scores than did those in Treatment B. Review of
the data (Figure 14) showed that this difference was due to more Treatment B mice appearing
hyper-alert, which was only observed in one mouse before exposures began.  Treatment C
mice, in fact, showed no changes in level of arousal across days, whereas two Treatment A
mice showed slightly lower values on day 2.

Other Measures    There was a significant overall difference between treatment groups on
the direction taken on the  tilted screen (p=0.03), but no treatment-by-time interaction.
Collapsing the data across days, it appeared that more mice went down the screen (2 or 3
times out of 3 trials) following exposure to Treatment A than did after exposure to Treatment
B.

General Appearance        After exposures, almost all mice showed facial swelling,
lacrimation, dilation and hemorrhaging of pinna vessels, and some  chromodacryorrhea
(reddish tears). Although  these signs were recorded during the behavioral tests as well as
upon removal from the animal exposure chamber, the analysis of the data was conducted on

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the observations made immediately after removal from all four exposures (see above).

Postmortem Evaluation    Two separate one-way ANOVAs were used to analyze the
postmortem data.  The first analysis examined differences between the three treatment groups
(A, B, and C), whereas the second analysis examined the three treatment groups and also
included the non-exposed cage-control mice.

Gravimetric data  Gravimetric data were obtained during the necropsy for six tissues: brain,
heart, liver, kidneys, thymus, and spleen (Table 9).

Table 9.  Organ Weight Data by Treatment Group
Treatment
Control
A
B
C
Brain
0.43±0.02
0.42±0.03
0.440.02
0.4310.02
Heart
0.14±0.01
0.13±0.01
0.13±0.01
0.1310.01
Liver
1.4610.13
1.2510.08
1.29±0.ir
1.18*0.07
Kidney
0.4310.04
0.3810.03
0.4010.05
0.4110.04
Thymus
0.0810.02
0.0610.02
0.0610.02*
0.0610.01
Spleen
0.1010.02
0.0810.02
0.0910.03
0.0910.01
(old number indicates significant difference from I reatment B.
* Indicates significant difference from non-exposed unrestrained cage control group.

       Significant treatment differences in organ weight were found only for liver weight
(p=0.033).  This difference occurred because Treatment C livers weighed less (p=0.021) than
Treatment B (air-control group). When liver weights were corrected for individual differences
in body weight, the difference was only marginally significant (p=0.055); however, there were
no significant differences in body weight between treatment groups.
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       Analysis of treatment effects compared to the non-exposed control indicated that there
were significant treatment effects for liver (p< 0.001) and thymus (p=0.027).  Both liver and
thymus weights of the non-exposed controls were larger than any of the treatment groups and
were significantly different from Treatment B.

Hemoglobin Measurements        Three parameters were analyzed to evaluate potential
differences in the oxygen-carrying ability of blood from carpet-exposed mice. Comparison of
the three treatment groups indicated a marginally significant (p=0.059) effect of treatment on
hemoglobin concentration. When the non-exposed control group was included into the
analysis as an additional treatment group, significant differences in hemoglobin concentration
were observed (p=0.026). The analysis indicated that the non-exposed and Treatment B
groups had significantly more hemoglobin than the Treatment A or C groups (Figure 15), but
Treatment B was not different from the cage control. The other two parameters that were
evaluated, %methemoglobin and %carboxyhemoglobin, were found not to be significantly
different by treatment with or without the non-exposed controls added into the analysis.

White cell differential        Analysis of the differential white cell percentages in peripheral
blood indicated that there was an overall treatment effect for neutrophils (p<0.001) when
examining the three treatment groups and the non-exposed controls (Table 10).  Significantly
more neutrophils were in the peripheral blood of the Treatment B mice (p<0.001) than for the
non-exposed controls.  There were no significant differences between Treatment B and
Treatments A or C.
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Table 10.  Peripheral Blood White Cell Differential

%Monocyte
%Neutrophil
%Lymphocyte
%Eosinophil
%Unknown
Control
9.0 ± 12.0
15.0 ±5.1
55.9 ±15.1
1.7 ±2.3
18.5 ±8.6
Treatment A
10.7 ±7.8
49.7 ± 22.1
31.0 ±16.4
0±0
8.3 ±1.5
Treatment B
5.9 ± 3.0
40.2 ± 9.0"
42.7 ± 12.2
0.4 ± 0.7
10.7 ±4.7
Treatment C
4.3 ± 2.4
46.7 ± 8.9
41 .7 ± 7.2
0.1 ± 0.4
7.1 ± 4.9
  maicates significant amerence tram non-exposea unres ramea cage control group,
 Serum Clinical Chemistry     Sixteen measurements indicative of liver, kidney, heart, and
 stress-related responses were evaluated in the serum of treatment mice and non-exposed
 controls (Table 11). Of these 16 measurements, three were found to be significantly different
 in the three group treatment comparison.  Total serum proteins (p=0.003), albumin (p=0.002)
 and cholesterol (p=0.023) were found to be lower in Treatment C compared to Treatment B
 (Figure 16).  Treatment A was not different from Treatment B for any of these measurements.
 When the non-exposed control group was included into the analysis as an additional treatment
 group, eight of the sixteen measurements showed significant treatment differences. Of the
three measurements that were significant in the three treatment group comparison, Treatment
C was most similar to the non-exposed control group for all three measurements.
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Table 11.  Serum Clinical Chemistry Values
Parameter
N
TBIL
LOH
ALT
AST
CREA
BUN
5-ND
GLUC
ALP
PRO
ICD
ALB
TRIG
CHOL
SDH
BILE
Control
12
0.429 ± 0.130
541 .7 ±187.8
37.1 ± 19.9
75.9 ± 24.6
0.583 ± 0.083
19.7 ±6.2
22.3 ±5.4
236.8 ±235
138.6 ± 27.4
4.90 ±0.38
20.7 ±11.1
2.93 ±0.21
89.1 ± 26.6
1115 ±16.9
15.0 ±3.1
45.4 ± 9.6*
Treatment A
8
0.526 ± 0.359
6335 ± 127.3
60.5 ± 24.3
123.0 ±32.7
0.614 ±0.1 77
29.0 ± 7.0
24.0 ± 4.5
207.9 ±18.0
138.6 ±29.2
5.44 ± 0.46
33.0 ± 6.9
3.35 ± 0.40
60.4 ± 12.3
136.3 ±24.0
17.1 ±6.7
103.0 ±103.8"
Treatment B
8
0.446 ± 0283
773.3 ± 356.0
475 ±21 .3
108.6 ±37.4*
0.603 ± 0.074
30.8 ± 72*
31 .4 ±17.3
21 4.8 ±22.9*
157.8 ±11. 6
5.48 ±0.36*
38.0 ± 9.0*
3.45 ± o.ir
56.7 ± 10.9*
146.1 ± 13.6*
18.3 ± 2.01
222.0 ±222.0"
Treatment C
8
0.436 ±0.1 07
806.1 ± 332.6
49.0 ± 152
157.8 ±61 5
0.546 ± 0.153
33.7 ± 12.3
26.4 ± 9.0
198.0 ±18.8
143.8 ± 29.3
4.83 ± 027
37.6 ± 13.7
2.93 ± 020
45.7 ± 132
115.7 * 22.7
16.9 ± 3.1'
2282 ± 295.8"
     numbers indicate a signiricant difference irom i reaimern a.
* Indicates significant difference from non-exposed unrestrained cage control group.
**** Insufficent serum was available, N= 7,5,2, and 6, respectively
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Nasal and Bronchoatveolar Lavage Chemistry       Four parameters were measured from the nasal lavage
- ascorbic acid, uric acid, glutathione, and total protein. Of these measurements, uric acid was not
detectable in the nasal lavage and no significant treatment effects occurred for ascorbic acid or total protein.
 Glutathione obtained from the nasal lavage was significantly (p=0.021) greater in Treatment B than in
Treatment A, but not different than Treatment C or the non-exposed control group (Figure 17). Only two
parameters were examined in the bronchoalveolar lavage of mice - total lavageable protein and lactate
dehydrogenase. A significant (p<0.001) treatment effect for total protein was observed, indicating that
Treatment B had less protein in the  lavage than Treatments A or C. However, the lavageable protein in
Treatment B was also significantly (p=0.027) less than the non-exposed controls (Table 12).  No differences
in  lactate dehydrogenase were noted.

Table 12. Lung Lavage Chemistry

Controls
Treatment A
Treatment B
Treatment C
Total Protein
136 ±36
144*17
108 ±15*
157 ±26
Lactate Dehydrogenase
33.5 ±8
46 ±15
41 ±15
43 ±10
Bold numoers indicate a significant oirrerence rrom i reatment b.
 Indicates significant difference from non-exposed unrestrained cage control group.
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Lung Lavage White Cell Differential       Between 60,00 and 100,000 cells were removed from the lungs
of both non-exposed and exposed mice, with the alveolar macrophages being the most prevalent
(approximately 80% of cells, Table 13).  Analysis of variance indicated a significant treatment effect for the
number of lymphocytes when either the three treatment groups were analyzed (p=0.012) or when the non-
exposed control was an additional group in the analysis (p=0.003).  No significant difference was detected
in a comparison of the number of lymphocytes in Treatment B versus the non-exposed control group.
Treatment A, but not C, had significantly (p=0.027) more lymphocytes than Treatment B.
Table 13.  Lung Lavage White Cell Count and Differential (xlO4) / ml of Bronchoalveolar Lavage

White Count
Macrophage
Neutrophil
Lymphocyte
Epithelial
Unknown
Control
69.6 ± 33.8
49.1 ± 18.8
0.51 ± 0.41
0.7 ±0.1
3.1 ± 2.4
8.7 ±7.3
Treatment A
102.8 ±67.7
81 .9 ±562
0.42 ± 0.51
2.8*1.8
22 ±1.9
14.6 ±17.7
Treatment B
61 .6 ±20.4
52.7 ±18.6
021 ± 0.26
0.7 ±0.5
1.3 ±1.6
7.1 ±3.7
Treatment C
100.0 ±57.9
78.2156.5
0.15 ± 0.36
1.0 ±1.0
1.9 ±2.6
14.7 ± 155
Bora number indicates significant airrerence rrom i reatment B.
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Histopathology      Several microscopic lesions were observed in treatment groups that either were not
diagnosed or occurred with a lower incidence or severity in the non-exposed, unrestrained control mice.
The incidences of these histopathological lesions are reported in Table 14.  Minimal to mild
necrosis/inflammation of the heart and its arteries, focal liver necrosis, pituitary hemorrhage, thymic cortical
necrosis, and hemorrhage/inflammation of the pinnae were common findings in all treatment groups.
Table 14. Incidence of Selected Histopathological Lesions in Treated and Non-Exposed Mice
Treatment

Total Number of Tissues Examined
Heart, Necrosis
Heart Artery Inflammation (minimal)
Heart Artery Medial Necrosis/Hemorrhage
(minimal)
Heart Artery Medial Necrosis/Hemorrhage
(slight/mild)
Heart Artery Medial Necrosis/Hemorrhage
(moderate)
Liver, Focal Necrosis
Pituitary, Pars Distalis, Hemorrhage
Thymus, Cortical Necrosis (slight)
A

8
1
3
2

0

0

3
2
6
B

8
4
5
2

2

1

2
4
7
C

8
2
5
0

1

2

1
4
4
Non-
Exposed
12
0
3
1

0

0

0
0
0
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      Minimal myocardial necrosis was observed in mice from all of the treatment groups, but was not
observed in the non-exposed, unrestrained controls. The incidence of necrosis was greatest with Treatment
B. This lesion was characterized by relatively small focal accumulations of cellular debris with an
associated minimal infiltration of mononudear cells and neutrophils replacing myocardial fibers.

      Inflammation and medial necrosis/hemorrhage in the arteries of the heart were also observed in
some mice from all groups.  The incidence of inflammation, and to a lesser degree, the medial
necrosis/hemorrhage was greatest in Treatments B and C. The severity of the medial necrosis/hemorrhage,
which ranged from minimal to moderate, was also greatest in the affected mice in Treatments B and C.
The inflammation and medial necrosis/hemorrhage involved the coronary arteries and their branches and
rarely the large elastic arteries (aorta). The inflammatory changes were characterized by a minimal
infiltration of mononudear cells and lesser numbers of neutrophils in the perivascular area and occasionally,
the walls of the arteries.  Medial necrosis/hemorrhage consisted of the replacement of smooth musde fibers
in the tunica media with an eosinophilic fibrinoid material and occasionally erythrocytes.  In most instances,
the changes were accompanied by a small amount of a pale basophilic, somewhat granular substance in
the perivascular area.

      Focal hepatic necrosis was diagnosed in one to three mice of each treatment group, but in none of
the non-exposed control mice.  The incidence of this lesion was greatest in Treatment A. The focal
necrosis was typically just beneath the hepatic capsule and was occasionally accompanied by a minimal
infiltration of inflammatory cells.

      Hemorrhage of the pars distalis of the pituitary  gland was also diagnosed in some mice in each of
the treatment groups, but in none of the non-exposed control mice.  The incidence of pars distalis
hemorrhage was greatest in Treatments B and C.  This lesion was frequently bilaterally symmetrical in
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distribution and was characterized by the focal accumulation of extravasated erythrocytes with secondary
coagulative necrosis.

       Thymic cortical necrosis was diagnosed in all mice.  Most of the mice in the treatment groups (A, B,
and C) had mild cortical necrosis compared to the minimal necrosis observed in the non-exposed mice.
Minimal cortical necrosis was characterized by occasional pyknotic or karyorrhectic nuclei and occasional
small foci of nuclear debris.  This degree of cortical  necrosis was considered to be due to normal cell
turnover (necrobiosis).  In contrast, mild cortical necrosis, as seen in the treatment groups, was
characterized by more frequent small foci of nuclear debris.

       The pinna of several mice in each of the treatment groups had either hemorrhage and/or subacute
inflammation. Both lesions frequently occurred together in the pinna and consisted of extravasated
erythrocytes, with or without an infiltration of neutrophils and mononuclear cells. The incidences of these
lesions were greatest in Treatment groups  B and C. Subacute inflammation was not diagnosed in any of
the non-exposed control mice; however, minimal hemorrhage was present in the pinna of one non-exposed
control mouse.
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Discussion
Interpretation of the Results      Overall, more than 70 different measurements were evaluated for each
mouse and statistically significant differences were detected among the three treatment groups. However,
many of these differences, although statistically significant, were not consistently observed in any carpet-
exposed treatment group and those differences from Treatment B may be of little or no biological
significance.  For some parameters, it is not dear that the significant statistical or biological difference
represents an adverse effect. Furthermore, significant differences were also observed between Treatment B
(zero-air exposed group) and the non-exposed, unrestrained cage controls, indicating that the exposure
procedure itself had significant consequences associated with it.  A discussion of the two primary
evaluations (measurements of irritancy and the neurobehavioraJ screen) and the postmortem assessment
follows.

       Sensory and Pulmonary Irritation      Irritation was evaluated (1) by an adaptation  of the ASTM
method, (2) by examining the reflex changes in breathing frequency for individual animals,  and (3) by
subjectively inspecting and scoring the respiratory waveform morphology. The ASTM method of combining
the four animal responses seemed to indicate that there was a greater decrease in frequency of breathing
(a sign of irritation) with increased numbers of exposure that was somewhat more prominent in Treatments
A and C than for Treatment B (the air-exposed group). This finding would provide minimal support that
irritation was associated with carpet exposure. However, the rate decreases observed would only be scored
slight, at best, according to the ASTM criteria (Table 7).  To gain a further, more in-depth  understanding of
the rate decrease, individual animal data were used as input to a statistical model that allowed us to
examine and separate treatment-related effects from exposure procedure effects. Visual inspection  of
Figure 4a emphasizes what the conclusions from the statistical analysis indicated, which was that there
were no differences in response among the three groups to any of the four exposures.  The most
conspicuous difference between groups (Figure 4a) was observed during the first exposure when more mice
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from Treatment B (air-exposed group) had greater decreases in frequency of breathing than carpet-exposed
mice (Treatments A or C); however, this difference was not significant.  Statistical differences in breathing
frequency during the recovery period, which could be interpreted as a manifestation of toxicity,  were also
observed.  However, the percent difference in frequency from the control period ranged from 0 to 3% for the
three treatment groups (Figure 5a), a difference that would not be considered biologically significant

         Although the rate determinations discussed above were the primary determinants of irritancy,
subjective analyses of respiratory waveforms were also evaluated to distinguish the type of irritant effect
(i.e., sensory, pulmonary, or mixed).  Using a very aggressive method to detect altered waveforms,
evidence of sensory and pulmonary effects was observed for all treatment groups. During the exposure
period, a greater incidence of sensory irritation was found for Treatment B (air-exposed) as compared to
Treatments A or C (carpet-exposed), during exposures two and four.  The rate analysis described  above,
however, indicated that the largest rate decrease for Treatment B occurred during the first exposure period.
Thus,  in contrast to the evidence of sensory irritation based on waveform morphology, the altered
waveforms did not translate into a decrement in breathing frequency. This would indicate that biologically
significant sensory irritation did not occur according to the ASTM procedure for which rate is the ultimate
determinant of effect. Although this may seem discordant it can be explained by the waveform analysis
technique. For example, during the scoring of the waveforms, if a pattern indicative of sensory irritation
appeared for several breaths (3 to 5), the entire minute rating period was scored as showing evidence of
sensory irritation.  However, if only five breaths had prolonged early expiratory pauses characteristic of
sensory irritation, there would be minimal or no impact on the median rate calculated for the approximately
220 breaths. Additionally, it was observed that for many of the one-minute segments in which altered
waveform morphology was observed, these periods were also accompanied by periods of rapid breathing.
Juxtaposition of breaths with decreased rates and increased rates during the same minute would further
dilute the impact of the expiratory pause to cause a decline in frequency of breathing.
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       Evidence of possible "pulmonary* irritation was also detected in all three treatment groups, ranging
from a slight rounding at the end of expiration (score=1, slight) to a pause between breaths (score=2,
moderate). Although there was one significant effect noted during the four exposure periods, it was
attributed to a difference between Treatments A and C and not Treatment B.   Visual inspection of the data
collapsed across all exposure periods (Figure 7) would suggest that Treatment A had more pulmonary
irritation than  Treatment B, and that Treatment C had the least among the three groups; however, these
differences were not significant. Again, evidence of pulmonary irritation based on waveform morphology did
not correspond with observed decrements in frequency of breathing. However, in contrast to sensory
irritation, pulmonary irritation is not solely diagnosed by a decrease in breathing frequency.  Therefore, it is
possible that Treatment A showed a slight pulmonary irritant effect

      Finally, in an attempt to quantify other abnormal breath shapes that would not be defined as sensory
or pulmonary irritant-like, a disruption index was formulated.  Most of these abnormal waveforms were
movement artifacts related to the animals struggling in the plethysmograph, but it was of interest if such
struggling would increase or decrease in association with an inhaled toxic exposure.  The statistical
analyses indicated mice in Treatment A were somewhat more disrupted than Treatment B during the control
and recovery  periods, but not during the exposure periods, whereas no differences in the  index were
observed between Treatment C compared to B. The interpretation of the relative adversity of this finding is
uncertain.
      Subjective Appearance and Functional Observational Battery     After each exposure, both the
behavior and the general appearance of the animals were observed. Formal testing using the functional
observational  battery was applied only after the second and fourth exposure.   In general,  many of the
differences from the preexposure baseline performance were  either similar across treatment groups or else
were more prominent in the air-exposed group (Treatment B).  There were also several significant
differences between Treatments A and C, with Treatment C appearing more benign. Indeed, as these data
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were being analyzed and before the code was broken, It appeared that Treatment C was the control.

       Four prominent findings related to the animal's appearance were observed after each exposure.
Virtually all of the animals had some lacrimation and dilated vessels of the pinna (outer ear), whereas many
had facial swelling and evidence of hemorrhaged vessels within the pinna. There were statistical
differences between treatment groups indicating that more mice In Treatment C (carpet-exposed) had
dilated vessels of the pinna and more mice in Treatment B (air-exposed) had lacrimation. The occurrence
of these four effects and the treatment group differences may, in part, be attributed to the high temperatures
and low humidity in the animal exposure chamber (Tables 5 and 6).  Higher temperatures occurred during
both of the experiments involving Treatment B (range, 25.0 to 26.4 °C) and were the worst for the first
experiment using Treatment C (range, 26.1 to 30.0 °C).  Vessel dilation is one mechanism that rodents use
to dissipate heat.

       The significant treatment effects detected using the functional observational battery were not
clustered In any one neurological domain. The only significant neuromuscular effect was the altered jar task
performance observed in Treatments A and C. The increased number of falls observed in Treatment A
could be interpreted as a clear, though not severe, effect  On the other hand, the Improvement of
performance in Treatment C, while also significant, would be difficult to Interpret as an adverse effect.  The
other neuromuscular measures, which should also detect vestibular changes, weakness, or IncoordlnatJon
that might compromise the ability to climb on the jar, were not altered by carpet  exposure. This lack of
correlative findings reduce the certainty of a significant neuromuscular/vestlbular effect of Treatment A.

       The sensorimotor changes observed in Treatments A and C, although statistically significant, could
not be considered clear evidence of carpet toxldty. Although It appeared that mice exposed to carpet
(particularly Treatment A) had lower reactions to both the click and tall-pinch responses than those exposed
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to zero-grade air,  in reality the Treatment B mice responded more vigorously than they did before
exposure. Moreover, In all groups, most of the responses were scored as "slight" or "clear", which are the
responses expected for "normal" mice.  Therefore, It is difficult to conclude that the differences in response
between treatment groups was an adverse consequence of carpet exposure.

       On the open field test, the only clearly significant effect was an apparent decrease  In level of
alertness In mice exposed to carpets. The same situation applies, however, as with the sensorimotor
responses in that the effect was due not to lower scores in carpet-exposed mice,  but an increase In the
score of Treatment B mice, when compared to their preexposure data as well  as what has historically been
expected as "normal" behavior.

       Postmortem Evaluation       Although a crude indicator of toxlclty, a treatment-related change In
body weight Is often a sensitive Indicator of effect  In this study, body weights declined with exposure, but
there were no treatment-related differences (Figure 2).  Uver and thymus weights were found to be less
than those of the non-exposed cage control group with a somewhat larger reduction in liver weight in the
Treatment C group. Typically, liver damage produces an increase in liver weight, whereas the factors
responsible for loss of body weight (physical, humidity, and temperature stress; food and water deprivation)
may account for the reduction between treatment groups and the non-exposed animals. However, even
after corrections for the differences in body weight, Treatment C mice were still significantly affected (10%
decrease), suggesting a small, treatment-related  effect.

       Because the lung Is the portal of entry for the carpet vapor exposure, It might be a primary target for
toxidty. Thus, several screening measurements were conducted to evaluate the Impact of exposure.
Lactate dehydrogenase (LOH) In the BAL was unaffected, Indicating that there was no direct cytotoxlctty to
pulmonary cells. Lavage fluid protein was increased in Treatments A and C compared to Treatment B.

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However, the BAL protein from the non-exposed cage control group was higher than that observed with
Treatment B. Thus, although an increase in BAL protein might be considered evidence of increased lung
permeability (leakage of plasma protein from the blood to the lung surface), the BAL protein values of the
cage control group would suggest that the effect was not biologically significant. The only other significant
effect observed in the BAL was a small, but significant, increase in the number of lymphocytes for
Treatment A, which might suggest an increased immune system activation from an antigenic protein or viral
infection. However, no other physical (particle concentration), microbiological, or histopathological evidence
would support these findings.

       Histopathological examination revealed several differences between the cage control group and the
three treatment groups (Table 14). Myocardial necrosis and necrosis of the small heart vessels were more
frequently observed in Treatments B and C. Liver necrosis was seen in 3 of 8 mice exposed to Treatment
A, with Treatments B and C showing less of an effect, respectively. Similarly, thymic cortical necrosis was
observed in all mice, including the cage controls; however, the severity was much greater in the treated
mice, especially in Treatments A and B.  Hemorrhage of the pars distalis of the pituitary gland was
observed predominately in Treatments B and C (50% incidence), but was also observed in Treatment A
(25% incidence). The origin of these effects is uncertain, but is possibly related to the food and water
deprivation during exposure, and physical restraint stress associated with the exposure procedure employed
in this study. Overall, the histopathological effects were minimal such that the pathologist could not dearly
distinguish which group was the air-exposed treatment group (i.e., Treatment A was incorrectly identified as
the air-exposed control group).

      Several measurements were obtained from the blood that focused on alterations of hemoglobin,
white blood cell population profiles (differential), and serum chemistries.  A marginally significant decrease in
hemoglobin was observed for Treatments A and C compared to both Treatment B and the non-exposed
                                             EPA - 70

-------
caged controls. A decrease in hemoglobin content could signify a decrease in oxygen-carrying capacity;
however, only a 6% decrease was observed, a change that would not be considered clinically significant.
No significant differences were seen in the peripheral blood white cell differential among treatment groups.
When compared to the cage controls, all of the treatment groups had significantly elevated percentages of
neutrophils (approximately threefold increases). Although this may be a stress-induced demargination of
neutrophils, it could also signal an acute infection, chemical intoxication, acute hemorrhage or hemolysis, or
acute tissue necrosis. However, correlative pathology (described  above) and serum enzyme chemistries
(described below) do not support these alternate interpretations. The fact that this condition was observed
equally in all treatment groups, including the air-exposed group  (Treatment B), suggests strongly that it is
related to the exposure procedure (Table 10).

       Significant alterations  in serum chemistries were also observed (Table 11).  Total protein,  albumin
and cholesterol were lower in  Treatment C than in Treatment B; however, Treatment C was not different
from the cage controls for these three measurements. On the other hand, these three serum chemistries
were significantly greater in Treatments B (air-exposed) and A than in the cage controls.  One common
cause of increased serum proteins is dehydration, which certainly could have resulted from the exposure
procedure. Increased cholesterol is nonspedfically associated with more chronic changes in the
cardiovascular,  hepatic, kidney, and pancreatic systems. Why Treatment C was less affected is uncertain;
however, the Treatment C-related decrease in  liver weight noted above may correspond to the decreased
ability of this treatment group to express these particular proteins. What toxicity might be associated is
unclear, especially in light of the similarity in these measurements to the cage control mice.

      Five additional clinical serum chemistries were analyzed (AST, BUN, glucose, ICD,  and  triglycerides)
and were found to be significantly different between the unrestrained, non-exposed cage controls and the
restrained and air-exposed controls (Treatment B). Increases in AST, BUN, and ICD were observed,
                                             EPA - 71

-------
whereas glucose and triglycerides were decreased. Although these differences were statistically significant,
they are difficult to ascribe to a specific toxicity because the magnitude of most of the changes would not be
considered of biological significance in human clinical medicine. Interestingly, Treatment C showed an even
more pronounced difference from the cage controls than did Treatment B (Table 11), possibly reflecting the
altered liver weights and serum chemistry results discussed above.

        Increased AST, in humans, is typically associated with myocardial infarction, muscle and liver injury,
acute liver necrosis, or acute pancreatitis, but also may increase with acute stress. Increased BUN occurs
with impaired kidney function, salt and water depletion, hemorrhage, stress, and acute myocardial infarction.
 Glucose is decreased with hypoglycemia and liver disease, but is typically increased with stress.  Liver cell
 injury is associated with an increase in ICD, for which this measurement is both sensitive and specific;
however, malnutrition has been shown to sometimes increase ICD. A decrease in triglycerides is
associated with stress and malnutrition. It is likely that all of the effects can be accounted for by  food and
fluid restriction  and restraint-induced stress.  However, it is possible that the treatments may also have
some effect on liver and heart tissue. Table 15 shows the significant clinical chemistry and peripheral blood
responses observed in Treatment B as related to potential causes of these changes from the human clinical
literature (Wallach,  1978).
                                             EPA - 72

-------
Table 15.  Potential Causes of Clinical Chemistry and Blood Neutrophil Responses
Measured
Parameter
AST
BUN
Glucose
Protein
ICD
Albumin
Triglycerides
Cholesterol
% Neutrophils
Treatment
B
t
t
4
t
t
t
4
t
T
Stress
t
t
t


t
4

t
Dehydration

t

t





Food Depri-
vation


4
4
t
4
4
T

Liver
Injury
T

4
4
t
4

t

Heart
Injury
t
t





t
T
                                            EPA-73

-------
Potential Confounds       The carpet study protocol was founded on the premise that two different
carpets previously shown by Anderson Laboratories to induce severe neurotoxicity or death would produce
similar effects when retested under analogous conditions in the laboratories of both Anderson and EPA.  In
addition, it was anticipated that carpet-related responses in exposed mice would be distinguishable from
sham, dean-air exposed control mice.  The biological end points evaluated by EPA included those used in
the standard Anderson Laboratories protocol and several additional biomarkers indicative of systemic organ
function or toxicity. However, following carefully conducted experiments and after thorough analysis of the
study data, no biologically significant effects attributable to carpet vapor exposure could be discerned. All
treatment groups, A, B, and C, appeared essentially unaffected; only when the restrained clean-air controls
were compared to unrestrained, non-exposed cohorts did there appear a consistent difference. The
occasional small, but statistically significant changes in one or another biomarker in the actual carpet-
exposed groups, although notable, could not be reasonably attributed to a toxic syndrome. Although this
lack of response would appear to support the contention that the carpets tested simply did not possess
inherent toxicity, it would seem reasonable that various factors, which could have influenced the response or
its detection, be examined carefully as potential confounds.

Animal Model  The use of Swiss-Webster (SW) mice in these studies must be considered a potential
source  of substantial variability.  The carpet-effect in the SW, an  outbred strain, is  inherently variable from
mouse  to mouse (as reported by Anderson  Laboratories), and with regard to the nonlethal effects described,
appears to be quite transient and sporadic.  The strain of mouse used in the EPA portion of the study
(including gender, age and size, and even vendor) was identical to that  used by Anderson.  A complete
microbiological evaluation of the mice, both upon receipt and in sentinels, verified the health status and lack
of infection in the animals.  The mice were housed in an AAALAC-certified vivarium upon receipt and care
was taken to avoid an infectious outcome over the course of the  study (about 10 days including the 7-day
acclimatization). The Anderson mice, otherwise the same, were  housed in a facility ostensibly clean and
                                              EPA - 74

-------
healthy, but actually of unknown microbiological status (e.g., ducts, air conditioning, etc.). Whether some
relatively passive organism residing in the Anderson mice could render them 'susceptible" as compared to
those of EPA seems unlikely, but is unknown.  Moreover, by what mechanism a frequently rapid-onset,
acute response might result from such an interaction is also unknown.
Exposure Factors  The large variability in animal response described previously by Anderson, even within a
given run of four animals, raises the question of exposure. The exposure system used in these studies by
EPA was designed after that in use at Anderson Laboratories.  The aquarium source chamber and plumbing
were identical.  However, there were some essential differences in the actual exposure method used in the
EPA study compared to the standard Anderson exposure protocol.  These differences arose from the desire
to standardize and better control the quality of the exposure Itself.  The EPA tests used zero-grade bottled
air that was certified "clean" by the air chemistry co-investigators working on this project This bottled air
was humidified through a distilled water trap and was provided to a manifold connected to the inlet port of
the chamber.  The chamber air was drawn from this manifold at a flow rate similar to that used in
Anderson's tests (7 LPM). The excess air was exhausted to the room.  Hence, the air passing through the
source (carpet) chamber was as dean as possible (as certified in test samples). This procedure contrasts
with the unfiltered "room air" drawn into the chamber system at Anderson Laboratories. The contaminant
status of room air is probably quite variable, but previous spot samples that EPA chemists collected at
Anderson Laboratories did noi indicate unique components that would lead to the conclusion that this
difference in source air is the origin of the biologic differences. Similarly, it would seem unlikely that
streaming of air through the EPA chamber would somehow avoid entraining the diffusion-distributed vapors
that would have emanated from the carpet during the one-hour incubation or during the test run.  However,
this possibility merits direct testing and validation because the inlet and  exit outlets on the exposure
chamber are on the same face and no provision is made to mix air within the chamber.
                                             EPA - 75

-------
       After the carpet test series was completed, quality assurance checks revealed that the humidity
sensor used in the EPA test system had failed over the course of the study.  This failure was not abrupt, but
was a slow loss of accuracy; previous experience with these sensors had never encountered a failure and
the effect on the dilution air adjustments was minor and not noticed. The result of the failure was that the
humidity, rather than being standardized at 50%, ranged from 18.7% to 29.2%. The effect of this on the
carpet emission is uncertain. Similarly, how this compares to the earlier runs with these carpets by
Anderson Laboratories is uncertain because Anderson Laboratories does  not control humidity in the
laboratory and records room humidity with a simple "home-style" hygrometer.  Given that Anderson
Laboratories has tested many of the sample carpets during the winter season, it is likely that the humidity
range of the EPA test was not unusually deviant from the typical conditions in Dedham, MA,  though this
difference needs further investigation.

       Each animal was sealed and secured into individual  plethysmographs with its head protruding into
the glass exposure unit by a thin rubber dam with a sized hole. The standard head hole used in the EPA
tests  was slightly smaller than that used in the Anderson Laboratories system, and the gauge of the rubber
dam was somewhat thinner.  The hole size adopted was determined as a balance between the restraint
provided by the dam and the comfort of the animal. Ancillary tests conducted by EPA suggest that the
slightly smaller hole size may reduce breathing frequency slightly, but does not appear to affect the form of
the tidal breath trace, indicating no exogenous bronchoconstrictive stress  on the animal. Because tidal
volume depth cannot be accurately measured in this plethysmographic arrangement, it is possible that there
was a slight difference in the depth of each breath between the laboratories involved, but it would seem
unlikely to be of such magnitude as to affect the dose to the animals and, hence, their response.

Carpet Factors The lack of response may reside in the heterogeneity of the carpets and the samples
thereof. The CPSC samples were selected randomly from various locations of the test carpets without
                                             EPA • 76

-------
regard for use areas or other potential variables. With "carpet" being the toxicant as best as can be
currently defined, it seems quite likely that regions of the total carpet area would have less or none of the
factors contributing to the observations of toxitity by Anderson Laboratories. Even Anderson Laboratories
reports that some test results of carpet from the same source are not readily reproduced for reasons
unknown.  Such a possibility suggests that retests of these carpets or parallel tests as are being conducted
at Anderson Laboratories as part of the overall test plan for the ORD Carpet Study could result in disparate
findings. At this point in time, there is no way of establishing a probability that carpet heterogeneity and
sample  distribution events could occur. Additional potential confounding factors might arise from differences
in storage and handling of the original test samples as compared to the samples used in the ORD study,
but in light of the wide range of handling conditions prior to testing in Anderson Laboratories, this variable
would appear to not be a major confounder if reasonable care in storage of the samples is followed.

Conclusion  There appeared to be no severe toxic effects associated with exposure to the off-gassing of
the two  tested complaint carpets.  Incidental findings, of statistical significance, but unlikely to be of
biological significance, were observed.  Of all the effects that were observed, only the number of falls in the
functional observational battery would be suggestive of  an "adverse" effect (Table 16).
                                              EPA-77

-------
Table 16. Summary of lexicological Findings

Treatment A
TBAA*«MAM* D
reatment o
Treatment C
Adverse
Postexposure

Irritation
Irritation
Postexposure
Postexposure
Postmortem
Postmortem
Postmortem
Postmortem

Postmortem

Postmortem

Postexposure


Postexposure
Postexposure
Postmortem
Postmortem
Postmortem
Postmortem
Postmortem
t Falls off Jar

Possibly Adverse
i Frequency (ASTM)
t Pulmonary Irritation



A Hemoglobin
t BAL Lymphocytes


t Liver Necrosis
t Thymlc Necrosis

T Sensory Irritation
t Lacrtmation
t Hyper Alertness



t Heart Necrosis
t Heart Vessel Necrosis

t Thymlc Necrosis
Adversity Unknown
t Disruption Index



T BAL Protein






t Tall Pinch Response
t Click Response



T Pinna Hemorrhage
t Pituitary Hemorrhage


4- Frequency (ASTM)



4- Liver Weight
i Hemoglobin

t Heart Necrosis
t Heart Vessel Necrosis




T Dilated Pinna


t BAL Protein
4- Serum Protein/Albumin
4- Serum Cholesterol
t Pinna Hemorrhage
t Pituitary Hemorrhage
                                          EPA - 78

-------
       Approximately the same number of "possibly adverse* effects occurred in the three treatment
groups, with almost all treatment groups showing an effect in each of the three categories of measurements:
irritation, postexposure (including general appearance and the functional observational battery), and
postmortem evaluation (Table 16).  Most likely, this indicates spurious findings relative to the number of
unprotected multiple comparisons performed. It is interesting that Treatment A, which showed some
evidence of pulmonary irritation (not significant) without a change in rate, also had an increase in BAL
protein and lymphocytes, whereas Treatment B, which showed more sensory irritant patterns, also had
more lacrimation. Treatment C had more postmortem signs of systemic toxicity (decreased liver weight and
small changes in serum chemistry), but had less histopathological signs of liver compared to Treatments A
and B.  In conclusion, based on this assessment of irritation, neurobehavioral effects and a general toxicity
screen, there is no indication that exposure to off-gassing from these two carpets poses a toxicological
threat
                                             EPA - 79

-------
References
Alarie, Y. (1973) Sensory irritation by airborne chemicals. CRC Critical Reviews in Toxicology, pp. 299-363.

Alarie, Y. (1981) Bioassay for evaluating the potency of airborne sensory irritants and predicting acceptable
levels of exposure in man. Fd. Cosmet Toxicol. 19:623-626.

Beaton, J.M., J.D. Prejean, R.D. Irwin, J.K. Dunnick, D.S. Baal, H.D. Giles, and AA Bartolucci (1990) The
neurobehavioral assessment of the effects of 28-day administration of acrylamide on B6C3F1 mice." Paper
presented at the 8th International Neurotoxicology Conference: Role of Toxicants in Neurological Disorders,
Little Rock, AK, October.

Bos, P.M.J., A. Zwart, P.G.J. Reuzel, and P.C. Bragt (1992) Evaluation of the sensory irritation test for the
assessment of occupational health risk.  Critical Reviews in Toxicology 21(6):423-450.

Brown, LJ. (1980) A new instrument for the simultaneous measurement of total hemoglobin, %
oxyhemoglobin, % carboxyhemoglobin, % methemoglobin and oxygen in whole blood. IEEE Transactions
On Biomedical Engineering, V BME—E-27, 3, pp. 132-138

Creason, J.P. (1989) Data evaluation and statistical analysis of functional observational battery data using a
linear models approach. J. Am. Coll. Toxicol. 8:157-169.

Feldman, D.B. and J.C. Seely (1988) Necropsy Guide: Rodents and the Rabbit  CRC  Press, Inc. Boca
Raton, FL; pp 51-76
                                            EPA-80

-------
 Ohio, AJ., T.P. Kennedy, G.E. Hatch, and J.S. Tepper (1991) Reduction of neutrophil influx diminishes
 lung injury and mortality following phosgene inhalation.  J. Appl. Physiol. 71(2) 657-665

 Irwin, S. (1968) Comprehensive observational assessment: la. A systematic, quantitative procedure for
 assessing the behavioral and physiologic state of the mouse. Psychopharmacologia (Berlin) 13:222-257.

 Moser, V.C., J.P. McCormick, J.P. Creason, and R.C. MacPhail (1988) Comparison of chlordimeform and
 carbaryl  using a functional observational battery. Fund. Appl. Toxicol. 11:189-206.

 Moser, V.C. (1989) Screening approaches for neurotoxictty - a functional observational  battery. J. Am. Coll.
 Toxicol. 8:85-93.

 Moser, V.C. (1990) Approaches to assessing the validity of a functional observational battery. Neurotoxicol.
 Teratol. 12:483-488.

 Moser, V.C. (1991) Applications of a neurobehavioral screening battery. J. Am. Coll. Toxicol. 10:661-669.

 Moser, V.C. (1990) Application and assessment of neurobehavioral screening methods in rats. In Advances
 in Neurobehavioral Toxicology: Applications in Environmental and Occupational Health, edited by B.L
Johnson. Chelsea, Ml: Lewis Publishers; pp. 419-432.

Operator's Manual IL282 CO-Oximeter, Instrumentation Laboratory, inc. (1977)
Lexington, MA
                                             EPA - 81

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Smialowicz, R.J., J.E Simmons, R.W. Luebke, and J.W. Allis (1991) Immunotoxicological assessment of
subacute exposure of rats to cartx>n tetrachloride with comparison to hepatotoxicity and nephrotoxicity.
Fund. Appl. Toxicol. 17: 186-196.

SAS Institute Inc. (1990) SAS/STAT User's Guide, Version 6. Gary, NC/ SAS Institute. 1990.

Standard Test Method for Estimating Sensory Irritancy of Airborne Chemicals. American Society for Testing
and Materials, ASTM Designation E-981-84 (also appendix A)

Tegeris, J.S. and R.L Balster (submitted) Comparison of the acute behavioral effects of alkylbenzenes
using a functional observational battery in mice.  Fund. Appl. Toxicol.

Tegeris, J.S. (1991) "Acute Behavioral Effects of Alkylbenzenes Evaluated Utilizing a Functional
Observational  Battery and Schedule-Controlled Operant Behavior.* Ph.D. dissertation, Medical College of
Virginia (Richmond, VA).

Tepper, J.S. and D.L Costa (1992) Will the mouse bioassay for estimating sensory irritation (ASTM E-981-
84) be useful for evaluation of indoor air contaminants. Indoor Environ. (1992)

Tilson, H.A. and V.C. Moser (1992) Comparison of screening approaches. NeuroToxicology 13:1-14.

U.S. Environmental Protection Agency (EPA) (1991) Neurotoxidty Test Guidelines Addendum 10, Pesticides
Assessment Guidelines Subdivision F.  Publication Number PB91-154617,  Springfield Va. National
Technical Information Services.
                                             EPA-82

-------
Wallach, J. (1978) Interpretation of Diagnostic Test: A Handbook Synopsis of Laboratory Medicine. Little,
Brown and Company, Boston, MA.
                                           EPA -83

-------
Figure Legends

Figure 1.  Diagram of the exposure system for evaluating carpet emissions.

Figure 2.  Mean body weight of mice in each treatment group, recorded before each of the four exposures.

Figure 3.  Mean frequency of breathing of mice during the control period: (a) collapsed over all four
exposures for each treatment, and (b) collapsed across treatments for each of the four exposures.

Figure 4.  Percent decrease in frequency of breathing of mice for each of the four exposures during the
exposure  period:  (a) individual mouse data for each treatment for each exposure, and (b) mean percent
decrease  collapsed across treatments for each of the four exposures.

Figure 5.  Mean percent change in frequency of breathing of mice for each of the four exposures during the
recovery period: (a) collapsed over all four exposures for each treatment, and (b) collapsed across
treatments for each of the four exposures.

Figure 6.  Percent incidence of mice in each treatment group receiving a rating of none, slight, moderate, or
severe sensory irritation during the exposure periods.  Data are collapsed across all four exposures.

Figure 7.  Percent incidence of mice in each treatment group receiving a rating of none, slight, moderate, or
severe pulmonary irritation during the exposure periods. Data are collapsed across all four exposures.

Figure 8.  Percent incidence of mice in each treatment group receiving a rating of none, slight, moderate, or
severe disruption index. Data are collapsed across all periods of all four exposures.
                                             EPA-84

-------
 Figure 9.  Percent incidence of mice in each treatment group showing lacrimation following each of the four
 exposures.

 Figure 10. Percent incidence of mice in each treatment group showing dilated pinna vessels following each
 of the four exposures.

 Figure 11. Incidence of mice in each treatment group falling off the jar 0,1,2, or 3 times, after the second
 exposure  (day 1) and the fourth exposure (day 2).

 Figure 12. Incidence of mice in each treatment group showing decreased, the same, or increased scores in
 response  to the tail-pinch stimulus.  The score for each mouse was calculated as the difference from that
 mouse's preexposure value, and ranged from -1 ("
-------
Figure 16. Mean serum chemistry values:  (a) cholesterol, (b) protein, and (c) albumin.  Data are presented
for mice in each treatment group and the non-exposed cage-control mice.

Figure 17. Mean lavage values: (a) glutathione in nasal lavage fluid, and (b) protein In lung lavage fluid.
Data are presented for mice in each treatment group and the non-exposed cage-control mice.
                                            EPA-86

-------
HIGURE 1
                                                                                          Zero Grade
                                                                        Flow Control
                                                                          System
                                                                                                     £
                                                                                                     UJ

-------
   30
      FIG. 2 Mean Postexpo^ure Body Weight    Treatment
   28-
05
D)
g>26^
'(D
   24-
   22
                   2         3
                 Exposure Number
                                                    A

                                                    B

                                                    C
                                                          ui

-------
.? 250
            Fig. 3 Control Period
                       B
                   Treatment
                2         3
               Exposure Number
                  EPA-89

-------
              Fig. 4  Exposure Period

>s
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0)
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                       EPA - 90

-------
       Fig. 5  Recovery Period
O
   i
0

§•  o
0)
  -2
O)

c
CD -
  -5
                    B

                 Treatment
        1
  2       3

Exposure Number
                  EPA - 91

-------
FIG. 6  SENSORY IRRITATION - EXPOSURE
LU
O
z
UJ
9
o
  100 {
80 -
   60 -
   40 -
  .20 -
    0
                B      C
                TREATMENT
                                       8!
                                       UJ
                               MONE
                              SLIGHT
                            MODERATE
                          SEVERE

-------
FIG. 7  PULMONARY IRRITATION - EXPOSURE
in
o
Z
Ul
o

o
  100
80 -
60 -
   40 -
   20 -
    0
                                      s
                                      £
                                      UJ
                           SLIGHT

                          MODERATE

                         SEVERE
               B      C


              TREATMENT

-------
FIG. 8  DISRUPTION INDEX - COLLAPSED
UJ
O
z
HI
Q
o
  100 f
80 -
60 -
   40 -
   20 -
   0
        A
            B      C
           TREATMENT
                                     £
                                     UJ
                            NONE
                           SLIGHT
                         MODERATE
                        SEVERE

-------
FIG. 9  LACRIMATION
                                ?

                                0.
                                Ul
                      EXPOSURE 4
                    EXPOSURE 3
                   EXPOSURE 2
                 EXPOSURE 1
     B       C
    TREATMENT

-------
UJ
o
UJ
g
o
    FIG. 10  DILATED PINNA VESSELS
  120 (-
  100 -
9  80 -
-  60 -
   40 -
   20 '-
    0
                                          UJ
                                EXPOSURE 4
                              EXPOSURE 3
                             EXPOSURE 2
                            EXPOSURE 1
               B      C

              TREATMENT

-------
FIG. 11  JAR TASK PERFORMANCE - DAY 1
           B        C
            TREATMENT
 JAR TASK PERFORMANCE - DAY 2
          B        C
           TREATMENT
               EPA - 97

-------
    FIG. 12 TAIL PINCH RESPONSE
        DAY 1 & 2 COMBINED
UJ
O
z
HI
o
o
16
14
12
10
 8
.6
 4
 2
 0
              B      C
             TREATMENT
2
UJ
                             » DAY 0
                            >DAYO
                           = DAYO
                         
-------
     FIG. 13  CLICK RESPONSE
UJ
o
z
UJ
9
o
       DAYS 1 & 2 COMBINED
UJ
                            EXTREME
                          CLEAR
                         SLIGHT
                        NONE
             B     C

            TREA JIENT

-------
. 14  ALERTNESS ON DAY 2
     B       C
    TREATMENT
                      EXCITED
                    ALERT
                   LOW
                 STUPOR
                              g

-------
                             Asbestos Tozlclty and GSH-dependent  Protection   14




20. Gulumian,   M.;   Sardianos,  F.;   Kllroe-Smlth,   T.;   Ockerse,   G.   Llpid




    peroxidation  in  microsomes  induced  by  crocidolite  fibers.  Chem.   Biol.




    Interact. 44:111-118; 1983.



21. Bonneau,  L.;  Pezerat,  H.  Etudes  des  sites donneurs  et  acceptures  d'an



    election en surface des andantes. J. Chem. Phys. 80:273-280;  1983.



22. Kamp,  D.  W.; Graceffa,  P.; Pryor,  W.A.;  Weitzman,  S.A. The role of  free



    radicals in asbestos induced diseases. Free Rad. Biol. Med.12:293-315;1992.



23. Fontecave, M.; Mansuy, D.;  Jaquen,  M.; Pezerat,  H.  The stimulatory effects



    of  asbestos as NADPH-dependent  lipid peroxidation in rat liver microsomes.



    Biochem. Jt 241:561-565; 1987.



24. Morehouse, L.A.;  Thomas,  C.E.;  Aust, S.D. Superozide  generation by NADPH-



    cytochrome  P-450  reductase: The effect of iron chelators  and the role of



    superozlde in microsomal  lipid  peroxidation. Arch.  Biochem.  Biophys.  232:



    366-377; 1984.



25. Aust, S.D.; Morehouse, L.A.; Thomas, C.E.  Role  of metals in  oxygen radical



    reactions. Free Rad. Biol. Med. 1:3-25; 1985.



26. Diplock, A.T. Vitamin E,   In: Fat  soluble vitamins, their biochemistry and



    their  applications;  Diplock,   A.T.,  ed,  Technonic  Publishing  Co.  .Inc.,



    Lancaster-Basal;   1985:154-224.



27. Kornbrust,  D.J.;  Mavis,  R.D.  Relative susceptibility of  microsomes  from



    lung, heart, liver, kidney, brain and  testes to lipid peroxidation: Correl-



    ation with vitamin E content. Lipid  15:315-322; 1980.




28. Burk, R.F. Glutathione-dependent protection by rat liver microsomal protein



    against lipid peroxidation. Biochim. Biophys. Acta,  757:21-28;  1983.

-------
                                                      Table:!
Chrysotile-mediated enzymatic  llpid  peroxidation  in  rat  lung microsomes supplemented with vitamin E in presence  of


GSH and other quenchers of reactive  oxygen  species.
Incubation system
Microsomes
4 NADPH (0.4 mM)
4 Chrysotile (500 ug)
Complete
+ GSH (1 mM)
4SOD (100 units)
+ Mannitol (1 mM)
4Catalase (ISO units)
4 B-Carotene (0.5 mM)
Control
group
0
0.56+0.04
0.4840.01
2.5040.35
1.2740.17C
1.8340.21NS
1.7740.23NS
1.804p.22HS
1.9840.31NS
4 Vitamin E
group
0
0.1940.06
0.1640.04
1.2340.17
0.3040.06a'(tt)
0.6740.04a'(a)
0.7040.05C>(b)
0.7440.04C'(a)
0.7240.08°' (b)
% Protection by
vitamin E
-
-
-
51
76
63
55
59
64
Values are mean 4 SE (n-3) and expressedas nmol MDA formed /ag protein.   Complete " Microsomes 4 NADPH 4 Chrysotile

                                           •WLst»*t*Iv*-
Letters without parentheses - Compared with icomplete systems* Let
                                           h


trol groups.  ap< 0.01;  p< 0.02; °p< 0.05; NS * Not significant.
Letters without parentheses  - Compared with icomplete systems* Letters  in  parentheses  " Compared with respective con-
                                            h

-------
                                                      Tablet2
Effect of chrysotile on the activity of vitamin E regeneration factor in rat lung mlcrosomes supplemented with
vitamin E in presence of GSH and other quenchers of reactive oxygen species.
Incubation system

Mlcrosomes + Ascorbate
Mlcrosomes + Ascorbate + GSH (ImM)
Complete
+ GSH (ImM)
+ SOD (100 units)
+ Mannitol (1 mM)
+ Catalase (150 units)
+ B-Carotene (0*5 mM)
w ^ «_*•>••• MW ^ «» jf fiiv£ £ IK •••
20 min.
0.096+0.006
0.032+0.002
0.164+0.009
0.100+0.005b
0.117+0.004a
0.120+0.005b
0.115+0.009a
0.110+p.010b
.grfiup. 	
40 mln.
0.108+0.004
0.036+0.003
0.194+0.016
0.115+0.005a
O.130+J0.006a
0. 129+0. 003a
0.120+p.015b
0.124+0.001a
	 +.Yltaml
20 mln.
0.080+0.006
0.015+0.001
0.120+0.009
0. 046+0. 002a
0.079+0.006b
0.078+0.010°
0. 081+0. 006b
0. 076+0. 005b
£.E_grouB_ 	
40 mln.
0.089+0.007
0.025+0.002
0.146+0.008
0.058+0.006a
0. 085+0. 009a
0.088+0.008a
0.090+0. 01 lb
0.085+0.012b
Values are mean + SE (n-3) and expressed as ^^35-500*  ComPlete " Mlcrosomes + Ascorbate + Chrysotile,
Letters - Compared with respective complete systems.  p<0.01;  p<0.02;  p<0.05.

-------
                                                     Table:3
Effect of chrysotlle on the vitamin E
of GSH and other quenchers of reactive
Incubation system

Microsomes
+ NADPH (0.4 mM)
+ Chrysotile (500 ug)
Complete
+ GSH (1 mM)
+ SOD (100 units)
+ Mannitol (1 mM)
+ Catalase (150 units)
+ B-Carotene (0.5 mM)
content in rat lung microsomes
oxygen species.
Control
group
0.70+0.08
0.38+0.08(d)
0.404<).07(d)
0.26+0.05(b)
0.6440.11d
«c
0.31+p.lOws
Q.3W.QB*S
0.3640.07NS
0. 33^.08^
supplemented with vitamin E in the presence

+ Vitamin E
group
1.92+0.06
1.6l40.06(d)
(t>)
1 .-5040. 08 v
1.06:M).08(a)
1.99+0.09b
1.49+0.04b
1.454p.02b
1.5240.04b
1.5540.07b
Values are  mean +  SE (n-3) and  expressed as n  moles/mg protein. Complete -  Microsomes  + NADPH  + Chrysotile.



Letters in  parenthesis  • Compared with microsomes  only.  Letters  without parenthesis - Compared with respective



complete systems.     ap<0.001; bp<0.01; Cp<0.02; dp<0.05; NS • Not significant.

-------
                                                      Tablet4

Effect of  chrysotile on  the glutathione-S-transferase activity profiles in rat  lung  microsome8  supplemented with

vitamin E in presence of  GSH.
Incubation system



Microsomes

      + NADPH (0.4 mM)

      + Chrysotile (500 ug)

Complete

      + GSH (1 mM)
                                      Control
                                      group
                                     + Vitamin E
                                     group
50.42+4.79

150.89+10.11

149.71+11.75

181.35+10.21

79.43+9.24*
49.33+3.88

121.01+9.25

115.60+10.40

143.34+9.75(b)

54.30+8.29a'(NS)
                        % Protection
                        by vitamin E
                                                                                                        21

                                                                                                        32
Enzyme activity is mean+SE  (n - 3) and expressed as nmol CDNB conjugated/mg protein/mln.

Complete " Microsomes + HADPH + Chrysotile.  Letters without parentheses - Compared with respective complete system.

Letters in parentheses - Compared with respective control group.  ap<0.02;   p<0.05; NS - Not significant.

-------
16


14
Sho-
O)
0)
   4


   2


  . O-1-
            T
          «/•'?'.
        . S t .' ft •
       ',*,*"' '/•',
         •v/u
           ' t\
         Control
                      FIG. 15 Hemoglobin
                                                                  UJ
                       A             B
                         Treatment

-------
— 1 I /on
5
ri25-
o
v 100-
Q) 7c
o 75~
0 50-
1 25-
£ n

'"T .





•"









I 3

I2
B1-
Q)
co o-
  4-
  *
  1
0)
CO
        Control
Control
       Control
                hig.1t> berum uhemistries

                                  T
                           B


                           T
                                 B
              A           B
               Treatment
                        EPA -102

-------
    0.6
    0.5-
 E
 §>  0.4-
 0  n •*
 c  U.o-
    0.2-
    0.1-
                  Fig. 17
              Nasal Lavage
                         I
        Control
                  A      B
                  Treatment
   200
   180-
I 160-
.£  MO-
TS  120:
   100-
    80:
    60-
    40-
    20-
0)
o>
CD
CO
               Lung Lavage
        Control
                  A      B
                  Treatment
                                i
                    EPA -103

-------
                   APPENDIX A



SUMMARY OF FOB DATA FOR EPA FORMAL REPLICATION STUDY
                    EPA -104

-------
SUMMARY OF FOB DATA FOR EPA FORMAL REPLICATION STUDY




Neuromuscular Function:
Jar Task
fell Ox
1x
2x
3x
Grip Strength
dropped Ox
1x
2x
3x
Body Tone
1 hypotonia
2 slightly flaccid
3 normal
4 hypertonia
CARPET A
samples 1,6
Test Day
0
1
2
CARPET B
samples 2,3
Test Day
0
1
2
CARPET C
samples 4,5
Test Day
0
1
2


4
2
1
1

8
0
0
0

0
1
7
0

2
1
1
4

8
0
0
0

0
2
6
0

1
3
3
1

8
0
0
0

0
4
4
0

6
1
1
0

8
0
0
0

0
0
8
0

5
3
0
0

7
0
1
0

0
2
6
0

3
4
1
0

7
0
1
0

0
2
6
0

4
2
2
0

8
0
0
0

0
0
8
0

4
2
2
0

8
0
0
0

0
1
7
0

7
1
0
0

8
0
0
0

0
1
7
0
                                 EPA -105

-------




Righting Reflex
1 normal
2 slightly slow
3 difficult
4 not present
Body Posture
1 lying on side
2 pelvis flat
3 upright
4 hunched
Body Tift
1 normal
2 head tilts
3 shoulder leans
4 body lists
CARPET A
samples 1,6
Test Day
0

8
0
0
0

0
0
8
0

8
0
0
0
1

8
0
0
0

0
0
8
0

8
0
0
0
2

8
0
0
0

0
0
8
0

8
0
0
0
CARPET B
samples 2,3
Test Day
0

8
0
0
0

0
0
8
0

8
0
0
0
1

7
1
0
0

0
0
8
0

8
0
0
0
2

7
1
0
0

0
0
7
1

8
0
0
0
CARPET C
samples 4,5
Test Day
0

8
0
0
0

0
0
8
0

8
0
0
0
1

7
1
0
0

0
0
8
0

8
0
0
0
2

8
0
0
0

0
0
8
0

8
0
0
0
EPA-106

-------




Ataxic Gait
1 none
2 slight
3 somewhat
4 marked
5 severe
Abnormal Gait Score 1 none
2 slight
3 somewhat
4 marked
5 severe

Inverted Screen
fast <30 sec
slow £30 sec
hanging
dropped
CARPET A
samples 1,6
Test Day
0

8
0
0
0
0

5
3
0
0
0





1

6
2
0
0
0

1
3
4
0
0

5
2
1
0
2

7
1
0
0
0

1
4
3
0
0

5
2
1
0
CARPET B
samples 2,3
Test Day
0

8
0
0
0
0

5
3
0
0
0





1

8
0
0
0
0

0
2
5
1
0

4
2
1
1
2

6
2
0
0
0

1
0
6
1
0

5
0
2
1
CARPET C
samples 4,5
Test Day
0

8
0
0
0
0

3
5
0
0
0





1

8
0
0
0
0

1
3
3
1
0

3
4
1
0
2

8
0
0
0
0

1
2
5
0
0

5
3
0
0
EPA -107

-------




Missteps
1 none
2 few
3 some
4 legs hanging
Sensorimotor
Measures:
Forelimb Placing
present
absent
Air Puff Response
1 none
2 slight
3 dear
4 extreme
CARPET A
samples 1,6
Test Day
0

7
1
0
0
1

5
3
0
0
2

3
5
0
0
CARPET B
samples 2,3
Test Day
0

5
3
0
0
1

3
4
1
0
2

4
2
2
0
CARPET C
samples 4,5
Test Day
0

4
4
0
0
1

5
3
0
0
2

6
2
0
0



8
0

0
2
6
0

8
0

0
0
8
0

8
0

0
2
5
1

8
0

0
2
5
1

8
0

0
0
5
3

8
0

0
2
4
2

8
0

0
0
6
2

8
0

0
1
5
2

8
0

0
1
4
3
EPA-108

-------




Click Response
1 none
2 slight
3 clear
4 extreme
Tail Pinch Response
1 none
2 slight
3 dear
4 extreme
CARPET A
samples 1 ,6
Test Day
0

0
4
4
0

0
2
6
0
1

0
7
1
0

0
2
6
0
2

0
7
1
0

0
2
5
1
CARPET B
samples 2,3
Test Day
0

0
4
3
1

1
3
4
0
1

0
3
5
0

0
1
5
2
2

0
4
4
0

0
1
5
2
CARPET C
samples 4,5
Test Day
0

0
6
2
0

0
0
7
1
1

0
4
4
0

0
1
5
2
2

0
7
1
0

0
1
4
3
EPA -109

-------




Activity and
Excitability
Measures:
Alertness
1 stupor
2 low
3 alert
4 hyperalert
Handling Reactivity
1 low
2 slight
3 active
4 moderate
5 high
CARPET A
samples 1,6
Test Day
0
1
2
CARPET B
samples 2,3
Test Day
0
1
2
CARPET C
samples 4,5
Test Day
0
1
2
.



0
0
8
0

1
5
2
0
0

0
0
8
0

0
4
4
0
0

0
2
6
0

0
5
3
0
0

0
0
7
1

1
3
4
0
0

0
1
6
1

0
5
2
1
0

0
0
5
3

1
2
4
1
0

0
0
8
0

1
4
2
1
0

0
0
8
0

2
3
2
1
0

0
0
8
0

1
1
6
0
0
EPA-110

-------




Activity Level
1 none
2 low
3 somewhat low
4 active
5 clear
6 hyperactive
Rears
X
SEM
Clonic Movements
1 none
2 smacking
3 quivers
4 mild tremors
5 severe tremors
6 myodonus
7 convulsions
CARPET A
samples 1,6
Test Day
0

0
0
2
3
3
0

10.0
2.4

8
0
0
0
0
0
0
1

0
1
3
2
0
2

11.5
3.0

8
0
0
0
0
0
0
2

1
1
3
1
1
1

8.6
2.7

7
0
1
0
0
0
0
CARPET B
samples 2,3
Test Day
0

0
1
2
2
3
0

7.4
2.4

8
0
0
0
0
0
0
1

0
0
2
3
2
1

7.6
2.7

8
0
0
0
0
0
0
2

0
0
2
1
2
3

13.3
32

7
0
1
0
0
0
0
CARPET C
samples 4,5
Test Day
0

0
0
1
3
4
0

9.5
2.4

8
0
0
0
0
0
0
1

0
0
2
3
3
0

9.1
2.5

8
0
0
0
0
0
0
2

0
0
1
1
6
0

7.3
1.8

8
0
0
0
0
0
0
EPA-111

-------




Tonic Movements
1 none
2 extension
3 opisthotonus
4 emprosthotonus
5 popcorn
6 convulsion
CARPET A
samples 1,6
Test Day
0

8
0
0
0
0
0
1

8
0
0
0
0
0
2

8
0
0
0
0
0
CARPET B
samples 2,3
Test Day
0

8
0
0
0
0
0
1

8
0
0
0
0
0
2

8
0
0
0
0
0
CARPET C
samples 4,5
Test Day
0

8
0
0
0
0
0
1

8
0
0
0
0
0
2

8
0
0
0
0
0
EPA-112

-------




Other Measures:
Tilted Screen
up>2x
even>2x
down>2x
1,1,1
Vocalizations
present
none
Bizarre Behaviors
present
none
Stereotypies
present
none
Diarrhea
present
none
CARPET A
samples 1,6
Test Day
0
1
2
CARPET B
samples 2,3
Test Day
0
1
2
CARPET C
samples 4,5
Test Day
0
1
2


4
1
3
0

0
8

0
8

0
8

0
8

1
2
3
2

0
8

0
8

0
8

0
8

1
2
3
2

0
8

0
8

0
8

0
8

6
0
2
0

0
8

0
8

0
8

0
8

4
1
3
0

0
8

0
8

0
8

0
8

4
2
2
0

0
8

0
8

0
8

0
8

5
1
2
0

0
8

0
8

0
8

0
8

2
1
3
2

0
8

0
8

0
8

0
8

2
0
6
0

0
8

0
8

0
8

.0
8
EPA-113

-------




General Appearance
Measures:
Facial Swelling
present
absent
Chromodacryorrhea
present
absent
Lacrimation
1 none
2 mild
3 severe
Gasping
present
absent
Cyanosis
present
absent
CARPET A
samples 1,6
Test Day
0
1
2
CARPET B
samples 2,3
Test Day
0
1
2
CARPET C
samples 4,5
Test Day
0
1
2



0
8

0
8

8
0
0

0
8

0
8

8
0

2
6

0
7
1

0
8

0
8

3
5

1
7

1
4
3

0
8

0
8

0
8

0
8

8
0
0

0
8

0
8

8
0

4
4

0
6
2

0
8

0
8

7
1

3
5

0
6
2

0
8

0
8

0
8

0
8

8
0
0

0
8

0
8

8
0

3
5

0
8
0

0
8

0
8

4
4

0
8

4
4
0

0
8

0
8
EPA-114

-------




Exophthalmus
present
absent
Palpebral Closure
1 eyes open
2 slight droop
3ptosis
4 eyes shut
Piloerection
present
absent
Salivation
1 none
2 mild
3 severe
Splotchy ears
present
absent
CARPET A
samples 1 ,6
Test Day
0

0
8

8
0
0
0

0
8

8
0
0

0
8
1

0
8

8
0
0
0

1
7

8
0
0

6
2
2

0
8

8
0
0
0

0
8

8
0
0

1
7
CARPET B
samples 2,3
Test Day
0

0
8

8
0
0
0

0
8

8
0
0

0
8
1

0
8

8
0
0
0

2
6

8
0
0

7
1
2

0
8

8
0
0
0

0
8

8
0
0

5
3
CARPET C
samples 4,5
Test Day
0

0
8

8
0
0
0

0
8

8
0
0

0
8
1

0
8

7
0
1
0

0
8

8
0
0

5
3
2

0
8

8
0
0
0

0
8

8
0
0

3
5
EPA-115

-------
       DRAFT REPORT
     Double Blind Study
Biological  Effects of Carpets
     Anderson Laboratories, Inc.
      Dedliam, Massachusetts
             KL-i

-------
CAP.PET RTTTTW PFPftPT
DATE  OF REPORT:   A
                        CXHMT BTOPY REPORT
Z.   V00UW1UI •OOULBY

This study is a double blind evaluation of biological potency of
•nice ions fron two earpAt.R (Experiment A, samples 1, 6,
Experiment C, samples 4, 5)  and one control (Experiment B,
samples 2, 7).  Each is tested two times in the randomized order
determined by Consumer Product Safety Commission, (CPSC) .

The questions being addressed ask:

1.   Is there a measurable biological effect in animals following
     •xpocuro to th* t««t •unplec?
2.   uo The rest data reveal airter«nce» I>«LW««H ui« errectb or
     the carpet sample* and the eontx-el oanplo?
3.   How do the findings from Anderson Laboratories, Inc. relate
m < T».-1 i r»o Pr-^r-.ji n^ S rmc

The  sample custodian receives the sample, transcribes
identification and places the sample into a chamber which he then
seals.   The contents, if any are, not visible.  He positions the
vdiuple  chamber in the test laboratory.  At the completion of the
test the sample custodian repackages the sample to be returned to
the  CPSC.

Sample  Preparation

Three one square foot pieces of a test sample formed into
cylindrical ehape  with face fiber euteido rn.ro plaood in the
wliauibvj. .   Hume lieeliuy paU» ait; u»cJ Lw waiui Lite Ail temperature
to 37°C.

Animals

For  the  test,  male Swiss Webster mice are positioned in the  glass
• iiluml vliojiiU«A •   AUv KtsoU «Ai.«*ia» XtiUw Ulm w«iiCxoa. wjl.X«iav^.  A
flexible seal  around the neck of the animal allows the animals  to
                                              .   .
side arm wnich serves as a whole body plethy»nograph.  Itooa air
(7 liters/minute)  Is used for ventilation of the chamber.   During
baseline and  recovery periods the air is taken directly  into the
animal exposure chamber.  During the animal exposure, the  air is
Cf>A:EU-W.VPS                                                5/17/93
                             Page  1  of  16

-------
 CARPET STUDY REPORT
 DATE OF REPORT:   *
 drawn through the sample chamber and then to the animal exposure
 chamber.

 Respiratory activity is detected and recorded by microphones
 attached  to the plethysmograph and connected to a high speed
 recorder  and computer.

 Respiratory Effects

 These data provide information concerning irritant chemical
 presence  and potency in the test atmosphere.  The upper and lower
 airway reflexes are studied by ASTM E 981 "Estimating Potency of
 Air Borne Irritant Chemicals.*1  The graphic indication of sensory
 irritation [(51), upper airways] is a diagnostic pause or slowing
 at me completion or liutplxaUloii a* »««ii wu liawingt* of
 individual animal respiratory movements.  The respiratory rate
 decreases proportionally.

 Pulmonary irritation [ (PI) , lower airways] is detected as a
 change in the slope of the respiratory tracing at the end of
 expiration which may not be accompanied by a rate change.  The
 moderate  or severe effects are reported.

 Animal Evaluation

 Acute toxic effects of the nervous system are studied by an EPA
 protocol  (Functional Observational Battery (FOB) by Virginia
 Moser)  designed to detect neurological changes through systematic
 observation of animals.   One day prior to study and following
 •ach  «xp&*uL-«, animal* are *Lberv*<2 and the status c.f each is
 recorded  using this FOB.

 T«»t  Cliaiubex.  Muni Luring

 Temperature and humidity arc measured in specified locations
 throughout  the testing.   Total volatile organic compounds (TVOC)
 is measured following each animal exposure.

 Results and Discussion

The summary of results is presented on Table 1.
Tlie sLudy »lii»«*«O LtoLli  w«tiwrjf «iii«3 £>olMiuim«y l&c J La Llun In
animal » VApuaeO tw  wai.pvL «iui»vluit» (CApviituviiL* A and C) .
sensory effect was  slight or moderate never severe.  The
pulmonary effect was severe for two animals in each experiment.
Hcithcr ocnaory nor nodcrate/acvcre pulnonary irritation io oeen
on records of Experiment B (control samples 2 and 7) .  FOB data


EP»:EPA-lt>T.VPI
                             Page 2 of 16

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                   Summary of  Findings
                        Double Blind Study,
                  Anderson Laboratories,  Inc.
                                                   ir
                                                   o
                        CARPET
                        Sample 1,6
                    CARPET
                    Sample 4,5
                   AIR
                   Control 2,7
 end point
 Sensory Irritation
 Pulmonary Irritatian
 FOB Extreme changes*
  appearance   (
              »
  activity excitability
  neuromuscular ,
 Death from Toxicit/
  during exposure
  after exposure
slight
severe, two animals

9/9
7/9
12/13

0/8
2/8
* # test categories showing extreme change
unblinded 5/12/93 ar*J 5/13/93
study in conjunction with EPA, CPSC
slight/ moderate
severe, two animals

8/9
9/9
13/13

0/8
3/8
                              Table 1
no
no

2/9
1/9
0/13

0/8
0/8

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CARPET STUDY REPORT
DATE OF REPORT:  *
•hows that the emissions studied in Experiments A and C caused
clear changes of animal behavior and appearance.

There were no deaths due to toxicity during the exposure period
for any experiment.  A total of 5 animals died following the
fourth exposure (day 2) on days 3, 5, 6 end 7.  Two of these
   »»le were 
-------
 MfiY 2B '93 14:55    flNDERSON                          no*
 CARPET STUDY REPORT
 DATE OF REPORT:  A
 II.   IKTRODUCTIOH

 This study is a double blind evaluation of biological potency of
 •HuXvoAwiio r«-wM« ua*«-wu w«»w«.ea eunpxea*   vrwo oz  'CAC aa&pxea ore
 carpet,  one is a control.   Each cample is tested two tines in a
 randomized order.

 The  questions being addressed ask:

 1.    Is  there a measurable biological  effect  in animals following
      exposure to the test  samples?
 2.    Do  the test data reveal differences between the effects of
      the carpet samples and the control sample?
 3.    How do the findings from Anderson Laboratories,  Inc.  relate
      to  the findings of the EPA team?

 A similar study is being conducted by  EPA staff and  contractors
 at Research Triangle Park.  The protocols of  the Anderson
 Laboratories and EPA (RTP) differ in certain  details.  In
 particular,  the poet exposure treatment of animals will introduce
 variation into the data collected.

 III.  METHODS

 A.    Exposure System

      1.    Air and Humidity

           a.    Air Source

           The source of the air for all studies is the
           laboratory.   During baseline and recovery  periods, the
           air is pulled directly from  the room  into  the glass
           animal exposure  chamber.  During animal exposure,  the
           air is drawn from the room through  the sample chamber
           and through a 4  inch glass connection (3/4" ID)  to the
           animal exposure  chamber.

           b.    Air Flow Control - Calibration

           Air flow is 7 liters/minute,  moved  by a peristaltic
           pump (Cole Panner)  downstream of the  animal exposure
           system.   The air flow is controlled by a flow meter
           (Gilmont)  which  is calibrated by comparison to a soap
           bubble meter (SKC)  each day  before  animal  exposures.
           The dry gas meter is used to check  air flow at the

EPA:E>A-«PT.W>S                                                5/17/93
                             Page 4  of 16

                           AL-fc

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 CARPET STUDY REPORT
 DATE or REPORT:
                 ef the •oanple chamber before— and  a-fter each
           animal exposure.   This information  is recorded in
           laboratory record books.

           c.    Humidity

           The humidity of the ambient air is  recorded  at 15
           minute intervals  throughout each animal exposure
           interval.  A sling psychrometer (Bacharach,  Inc.,  PGK,
           PA)  is used to determine  room air humidity according  to
           the prescribed schedule.

      2.    Exposure System/Aquarium

           a.    Source and Preparation

           Two jiew glatii*  aquaria  were obtained Izoiii a local  pet
           supply store.   The sealant adhesive in  the interior of
           the chamber was removed as far as possible by means of
           a sharp blade.  A plastic reinforcing band and lip
           around the open edge of the chamber is  not removed.
           After removal  of  the sealant, the chamber is vashed
           with vater and Alconox and wiped dry with 95% alcohol.
           At  the completion of each set of four exposures with  a
           single sample ,  the chamber was again cleaned with
           water,  Alconox and alcohol.

           b.    Chamber Pace and  Fittings

           The  open side  of  the chamber is covered by a three
           panel assembly.   Two side panels (10.25 by 2.5 inches)
           are  fashioned  from plastic faced on the inside by
           Teflon film.  The central panel (10.25  by 14.75 inches)
           is glass.   Duct tape is used to hold the composite
           panel together.   Nylon fittings are inserted into the
           side  panels.  During use, the front panel is attached
           to the  aquarium with duct tape.

           c.    Heating

           Home  heating pads are  used to warm  the  system. One pad
           measures 11.5 by  15 inches and is placed under the
           bottom  of the chamber,  the second measures 20 by  30
           inches  and is positioned  on the top, back and sides.
           Th« air tanporatur* ie hotted to 37«C by turning both
          exposure begins.  The temperature is adjusted by
lP*:tPA-MT.Wf|                                               5/1T/W
                             Page 5 of 16

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 fWY 20 *93 14:57    flNDERSON                         703 P23
CARPET  STUDY REPORT
DATE OF REPORT:   *
           changing settings  of each switch.  During exposures,
           the settings  are typically on high.

           d.    Insulation

           A double layer of  metal faced fiberglass insulation is
           used to cover all  of the sample holding chamber  during
           the experiment.

           e.    Test Sample Source and Placement

           Each test sample is delivered to the laboratory  on  the
           day preceeding its use.  The samples are to have been
           provided as three  one  square foot pieces of a test
           material.  The diagonal corners of each piece are
           fastened together  to form a cylinder.  The face  fiber
           is  the external surface of the cylinder.  Two of the
           cylinders are placed directly on the floor of the
           chamber parallel to the long dimension of the aquarium.
           The third cylinder is  positioned on top of the first
           two canplac.   Th«  chamber ie fehen e«al«d until «tudy
           the following day.

           f.    Blinding Precautions

           The samples are received in our laboratory in a  Federal
           Express delivery box.  After working hours of the day
           of  receipt, the sample custodian opens the box,
           transcribes all identification into a sample book
           (which is kept in  his  posession) and places the  sample
           pieces into o chamber, which he -then eeale.  The
           ehambor ic entirely oovorod by a layer of duot ^ape oe
           that the contents, if  any, are not visible.  The sample
           custodian places the sample chamber in the test
           laboratory.   At the completion of the test, the  sample
           custodian opens the chamber/ removes and repackages the
           sample in the original delivery box.  The sample is
           returned to the sender.

     3.    Exposure Chamber with  Plethysmograph

           a.    Source and Preparation

           The animal exposure chamber is custom made by a  glass
           blower according to the drawings of the ASTM E 981
           publication (Appendix  I).  Between samples, it is
           washed with Alconox, dried with 95% alcohol and  then
£PA:!PA-m.WP$                                               5/17/93
                             Page 6 of 16

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 CARPET STUDY REPORT
 DATE OF REPORT:  *
           air dried.  Between trials with a  single  sample the
           glass chamber is wiped out with 95% alcohol.

           b.    The Flethysmograph
                   nr« positioned In the  sidearms of the qlass
           aninal chamber.   The bead extends through a hole into
           the central cylinder.  A flexible seal around the neck
           of the animal allows the test  animals to breathe the
           test atmosphere  while the body is enclosed within the
           sideann (closed  with a hard rubber stopper) .   The neck
           seal is made of  a latex dental dan (medium gage)
           reinforced and held in place by duct tape.  A central
           hole in the latex dam is of a  size appropriate for the
           animal weights and is made with a cork borer.
           Typically,  the hole through the reinforcing duct tape
           is size 8,  through the latex,  size 6.  The reinforced
           dan is carefully positioned in the chamber and the duct
           tape seal  checked for smooth fit.

           c.    Transducers and Attachment

           The four transducers are miniature microphones
           manufactured by  Fafcuda Denshi  (Japan) .  Each  microphone
           is *tt-»ff>»»rt hy a short: piece of flexible PFC  tubinq to
           the sample  port  on a sideann.  The cable is directly
           connected  to the Could R5 3400 recorder.

     4.    Exposure Measurement System

           a.    Temperature System and Calibration

           The temperature  measurement* ar* made hy means of a
           coie Farmer •rnermister/tfiermoineter.  Tim Ui«i.ini»tcA«,,
           range -40 to 100°C, are manufactured by YSI,  Inc.  and
           are NIST traceable.   The device has been calibrated by
           comparison  of digital output to thermometer readings
           using hot and cold water as convenient test conditions.
           The thermometer  will be provided to EPA for reference
           measurements at  a later time.

           During testing,  three temperature probes are  used.
           They are positioned at sites identified by the EPA in
           the protocol,  one is outside the sample chamber between
           the heating pad  and the bottom glass surface,  two is
           outside the sample chamber between the top glass
          .surface and the  heating pad, and the third is inside
           the sample  chamber in air.

EPA:E»A>KP7.M>S                                                5/17/93
                             Page 7 of 16

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 DRY 20."93 14:59    WitrouN                          7^
 CARPET STUDY REPORT
 DATE OF REPORT:   *
           b.    Other Monitoring

           Oxygen,  carbon dioxide  and chamber pressure are  not
           measured.   Total volatile organic chemicals  (TVOC) are
           measured by flane  ionitation detector  (Rosemont  )
           calibrated against a  methane standard before each use.
           This measurement is made folloving each animal exposure
           cession  by attaching  the sample chamber outlet to the
           inlet of the FID device.

 B.  . Animals

     1.    Procurement Specification

           Swiss Webster outbred male mice are obtained from
           Taconic  Farms,  Germantown, New York.  They are
           delivered  by truck and  arrive on Tuesday of each week.
           The  purchase weight specified is 13 to 15 grams.  Ten
           percent  of the animals  are weighted at delivery  to
           confirm  the animal weights.

     2.    Housing  Conditions

           For  one  week before testing, animals are housed  in an
           animal room with controlled heat, ventilation and light
           (12/12).   No other species is kept in this facility.
           The  food (Formulab Chow 5008, Purina Kills)  is
           available  ad lib and  is used within its marked shelf
           life.  Dedham tap  water is available except  during
           actual experimental procedures.  The bedding is  Bed O
           Cobs (The  Andersons)  changed 2 times/week.  Animals are
           housed in  groups of 10  for a minimum of 7 days prior  to
           test.

           After testing has  begun, animals are housed  in groups
           of four.   The exposed animals are kept in a  separately
           ventilated compartment  of the same animal room.

     3.    Health Evaluation

           Animals  are evaluated by brief visual examination and
           by body  weight measurements at receipt and before
           selection  for testing.  The animals are between  25.5
           and  28 grams at the initiation of the study.

C.   Respiratory Frequency Measurements


EPA:£PA-RPT.W»»«                                               5/17/93
                             Page 8  of 16

                             flL-10

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CARPET STUDY REPORT
DATE OF REPORT:  A
     1.   Data Acquisition System

          The data acquisition system is described  in the ASTK E
          981 protocol.  The computer hardware was  selected by
          Dr. Yves Alarie, author of  the protocol because of  its
          suitability for the intended uses.

          The software was developed  for this use at the
          University of Pittsburgh vhere the validation was
          conducted .

          In addition, at intervals,  the program output is
          directly compared against results of a hand counted
          recorder tracing.

     2.   Subjective Evaluation of Waveforms

          Scoring Criteria

          a.  Sensory Irritation

          The graphic indication of sensory irritation is a pause
          or slowing at the completion of  inspiration as seen  on
          tracings of individual animal respiratory movements.
          As the pause becomes longer with increased potency  of
          the irritant exposure, the  respiratory rate decreases
          proportionally.   Copies of  tracings showing the
          examples of SI and FI are included on Appendix II.
          Example 1 is a classic example of a response to a
          chemical having strong sensory irritant properties.
          Example 2 is a slight SI response but a recognizable
          change from normal.   In the presence of a detectable
          pattern change (example 2)  the calculated mean group
          rate change of baseline is  used  to quantify the
          response.   Rate change is summarized as maximum %
          deviation (three minute duration) from normal baseline
          value for each exposure.  If no  pattern change is found
          a  rate change is not an indication of sensory
          irritation.

          b.    Pulmonary Irritation

          This is detected as  a change in  the slope of the
          respiratory tracing  at the  end of expiration or
          initiation of the next inspiration.  The  pattern change
          may not be accompanied by a rate change.  The severity
          of the effect is categorized as  slight, moderate or
          severe as  defined in the ASTM £981 protocol.  The
                            Page 9 of 16

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     28 '93 J5:00    flKDERSON                          703 PJ.3
 CARPET STUDY REPORT
 DATE OF REPORT:   A
           effect is described as slight if the pattern tracing
           shows only a rounding of the expiratory peak.  A
           tracing resulting  from exposure to a pulmonary irritant
           of moderate potency is described as a flattening of the
           expiratory pattern with indications of a hook or tail.
           During expiration  the severe effect shows a more
           pronounced change  of slope vith an accentuated tail.
           These patterns are printed in the ASTM £981 protocol
           vith  examples in Appendix II.

      In  our laboratory only  moderate or severe pattern changes
      are reported.

D.    Functional Observational Battery (FOB)

      The description of this evaluation procedure and the scoring
      form are included as Appendix III.

      Test Procedure

      One day prior  to study, animals are observed and scored
      using the  EPA  FOB.

      At  the conclusion of each animal exposure period, the
      animals are removed from the exposure chamber and placed in
      a prepared cage vith food vater and bedding.  After 15
      minutes, the animals are observed and scored according to
      the written description of the EPA FOB.

      As  an exception to the  EPA procedure, animals are placed on
      a three sided  elevated  shelf (as contrasted to a low
      laboratory cart having  4 sides} for observation of gait,
      activity and posture.   The shelf is cleaned after each
      animal  is  observed.

E.    Study Design

      1.    Exposure  Protocol  - Sequence of Events

           Check and adjust air flov.

           Measure room humidity.  Start to heat chamber
           containing sample.

           Position  thermisters to determine temperatures, record
           findings  at tc and at 15 minute intervals throughout
           the study.
                                                        5/17/W
                             Page  10  of  16

                             flL-13,

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CARPET STUDY REPORT
DATE OF REPORT:  *
          Weigh and record animal weights and Bark tails for ZD.

          Position each mouse in plethysmograph with haad
          extending into the central core of the exposure
          chamber.

          Close open-end of each animal chamber sidearm with a
          hard rubber stopper.

          Ventilate animal exposure chamber using room air at a
          rate of 7 liters/minute.

          Fix microphone to the sampling port on each sidearm.

          Insert thermometer into central sampling port of animal
          chamber .

          Allow 15 to 20 minutes for animals to adjust to the
          chamber.

          Collect 15 minute baseline respiratory rate data on
          recorder and computer.

          Observe record for signs of pulmonary and sensory
          irritation.

          Connect sample chamber to the animal exposure chamber.

          Collect respiratory rate data on recorder and computer
          for 60 minutes.

          Observe record for signs of pulmonary and sensory
          irritation.

          Disconnect sample chamber from animal exposure chamber.
          Mark chart.   Continue ventilation of animal chamber
          vith room air.

          Determine TVOC in test atmosphere.

          Collect respiratory rate data on recorder and computer
          during IS minute recovery period.

          Observe record for signs of pulmonary and sensory
          irritation.

          Remove animals from exposure chamber,  place in
          container vith food and water.
                            Page  11  of 16

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 CARPET STUDY REPORT
 DATE OF REPORT:   *
           Evaluate each animal using fOB after a minimum of 15
           minutes in container.

           Return animals to animal room for desired internal.

      2.    Experimental  Protocol

           For each experiment  (A,B,C) there is a sequence of four
           animal exposures.  Each group of animals is exposed two
           times  on day  one followed by two times on day two.
           There  is a minimum of two hours between the end of the
           first  exposure of the day and the start of the eecond.
           Body weights  are determined and recorded before each
           exposure.

      3.    Study  Protocol

           A total of six experiments were planned for the study,
           two experimental samples and one control sample.  Two
           examples of each were to have been provided to each
           test lab in a random order by the CPSC.  Because of an
           error,  one sample was incorrectly provided to Anderson
           Laboratories,  Inc. but not to EPA.  The data from the
           incorrect  sample (number 3) have been discarded.  A new
           sample has been provided by CPSC and has been tested at
           Anderson Laboratories as sample 7 (Appendix 4).

F.    Data  Analysis and  Statistics

      The data are summarized (as we have been advised by M. Mason
      of EPA)  by  combining samples 1 and 6, samples 4 and 5 and
      samples  2 and 7.   No statistical analysis is offered.

XV.   RE8ULT8

A.    Experiment  A (Samples 1 and 6)

      2.    Exposure System

           The temperature and humidity are reported on Tables  1
           through 8,  Appendix V.

           TVOC's measured by flame ionization detector
           (calibrated against methane standard) ranged from  4.4
           ppn, high  to  2.4 ppm, low.

      2.    Body Weight Data

e»A:EM>WT.*S
                            Page 12 of 16

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 CARPET STUDY REPORT
 DATE OP REPORT:  *
           Day one, the mean starting weight of the 8 animals was
           26.3 grains.  Day 2, the mean starting weight was 23.7
           grans.  This represents an approximate 10% body weight
           loss over the course of one day.  The weights following
           the exposures are not used for this calculation due to
           the possibility of dehydration effects.

      3.   Irritation Measurement

           a.   Sensory—Irritation f£I)

           Examination of the record shoved a change in the
           r*«pir»t.r>ry p»t:t:«rn which i* defined as SI.  No
           irritation pattern was noted in two exposures and in a
           third exposure the numerical change was at the no
           effect level (<12%).  For the remaining 5 exposures,
           fha thT-*« mint!*.* VA!UAK WArA 14, 1I>, 17. 20 and 23%.
           This is at the borderline between slight and moderate
           effect.

           b.   Pulmonary Irritation (PI)

           The tracing of each animal is examined and scored
           4uri.ng fi.v* i.rtt*x-vr*l* in •»«>* *wpA*uv«.  Thie reeulfee
           in a maximum ot 160 observations,  examination ot tne
           record shows a change in the respiratory pattern
           defined as PI.  In the first two exposures (day 1,
           samples 1 and 6), the PI was classed as moderate in
           only 3 of 80 observations.  During day two (exposures 3
           and 4) of OO obaervoti,on» fehc TZ wao ooered ae moderate
           once and severe 20 times.  Two animals reacted
           strongly, the others did not.

      4.    Functional Observational Battery (FOB)

           The observations have been grouped as neuromuscular
           function, activity and excitability and general
           appearance.   For eaoh obe*rvation,  each individual
           score is compared against the preseore value for the
           group of animals being studied.  The number of
           observations outside the preseore range for the group
           have been presented in Appendix VI.  In addition, the
           observations showing a severe effect (maximal deviation
           from normal)  are listed on Table 2.

           Deaths
CPA:EPA-*»T.WPS                                                5/17/93
                             Page 13 of 16


                            0L-IS

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 fifty 20 '93 15:04    flNDERSON                         703 Pl7
CARPET STUDY REPORT
DATE OF REPORT:  *
          There were no toxieity related death* during Uits
          exposures.  There were, however, 2 deaths which
                   on day* 9 and 6 o£ the experiment.
6.   Experiment B (Examples 2 and 7)

     1.   Exposure System
                               V.

          TVOC iiivakuxviucnU* xcui^c £AWIU 2.1 ppu, high to l.C ppn,
          low.

     2.   Body Weight Data

          Day one, the mean starting weight of the 8 animals was
          25*5 grano.  Day two, the atoan charting waight vac 3E.O
          grava.  Thi« represents an approaii»»t» 9% Krw
-------
CARPET STUDY REPORT
DATE OF REPORT:  *
          which are outside the prescore range for the group have
          been presented in Appendix VI.  The only observations
          shoving a change distinct from normal are vocalization,
          piloerection, and ear petechiae.  These are presented
          in Appendix  on Tables 3.

          Deaths

          There were no toxicity related deaths.

     Experiment C (Samples 4 and 5)

     1.   Exposure System

          The temperature and humidity are reported on Tables 17
          through 24, Appendix V.

          TVOC measurements range from 5.4 ppm, high to 3.7 ppm,
          low.

     2.   Body Weight Data

          Day one, the mean starting weight of the 8 animals was
          26.0 grams.  Day two, the mean starting weight was 23.8
          grams.  This represents an approximately 9% body weight
          loss over the course of one day.  The weights following
          the exposures are not used for this calculation due to
          the possibility of dehydration effects.

     3.   Irritation Measurement

          a.   Sensory Irritation

          Examination of the record showed a change in the
          respiratory pattern which is defined as SI.  An
          irritation pattern is noted in all exposure records.
          The maximum mean group % decrease from baseline rate
          (three minute duration) are 12, 12, 12, 13, 14, 14, 15
          and 18%.  This describes a consistent effect reflecting
          sensory irritants having slight potency.

          b.   Pulmonary Irritation

          The tracing of each animal was examined and scored
          during five intervals in each exposure.  This results
          in a maximum of 151 observations (two animals died from
          accidental eauc«c during •xpecura four).  Examination
          of the record showed no detectable change in the

     n.U»S                                               S/17/W
                            Page 15 of 16


                          flL-ll-

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 CARPET STUDY REPORT
 DATE OF REPORT:  A
           respiratory pattern defined as PI during exposures 1
           and 2.   During day two (exposures 3 and 4) of 71
           observations the PZ was scored as moderate 2 tines and
           severe 24 tines.  The effect was strong in three
           animals and absent in others.

      4.    Functional Observational Battery

           The observations have been grouped as neuromuscular
           function, activity and excitability and general
           appearance.  For each observation, the individual
           animal  score is compared against the prescore value for
           the group of animals being studied.  The number of
           observations which are outside the prescore range for
           the group have been presented in Appendix VI.  The
           observations shoving a severe effect (a maximal
           deviation from normal) are listed on Table 4.

           Deaths

           There were no toxicity related deaths during the
           exposures.  There were, however, 3 deaths which
           occurred on days 5 (two deaths) and 7 of the
           experiment.

DISCUSSION

Information  was received by phone from Mark Mason that the
samples were grouped as 1/6, 2/3 and 4/5.  Because the records of
our sample custodian did not confirm the grouping of similar
elements,  Hark Mason was contacted for discussion and
instructions.   A  replacement sample was received from CPSC on May
5th.  All  usual blinding procedures were followed.  The sample
was tested on Kay 10th and llth.  For this report, therefore,
Experiment B includes samples 2 and 7.  On May 12th, Anderson
Laboratories,  Inc. was informed again by phone that samples 2 and
7 are the  control materials.  May 13th a letter was received from
CPSC which identifies 1, 6 (Experiment A) and 4, 5  (Experiment C)
as carpet  samples.  Experiment A and Experiment C were carpets.

The data from Experiment A indicates the presence of sensory
J.... J. «-~..k ..*.__. £ ....»._ 1 .. *.»._ k._..l. _*._.._*,*._.._.  «1._ _C*»VC ___
changes ot the  sample as a result of heating, instability of  the
•>tijin«*l ( »>M^H.iiiH«i> •.»*• etui*** i.M.«ntJil«i*X wlcllll** iiP lnl»r««itl IIMIM «»T  !.!«»-
test sample with its absorbent layers resulting in emission and
remission of  the chemicals biologically potent.
EM:EP*-IPT.WPS                                                S/17/93
                            ' Page 16 of 16

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 CARPET STUDY REPORT
 DATE OF REPORT:  A
 The pulmonary irritation response was primarily shown by two
 individual animals  (one with cample 1 and one with sample 6) and
 vas pronounced on the second day.  This increased response on the
 second day is fairly typical of the effects noted with previous
 carpet samples tested in this laboratory.  The effects which were
 identified by way of the FOB showed several changes compared to
 prescore which were not mirrored in the sample results.  In the
 observations grouped as alertness/excitability the greatest
 change from normal included alertness, handling and reactivity,
 activity and rearing.  Both increased and decreased activity
 scores were recorded.  Although the vocalization scores were
 rather different from prescore the comparison with the control
 I »wl 1 1 -.<• I *M! lit*. I  111*. «>rr«>i:l mlijlil  IM. i »1«t !.*>>! l.ti t.lm £>VOt1Mi3uv* ttm
 well  as to the test exposure.

 In the group "general appearance*1, facial swelling, lacrimation,
 gasping, palpegbral closure and ear petechiae are the findings
 wnicn were nor consistent wirn prescore or control,  u-ne general
 appearance group is primarily scored as present or absent and
      T-»pT-»«»T»t' » r»1»»r rtif f»r*»tm« from t.h« «t.»irt:
-------
      Appearance Data Summary
      Extreme deviation from pre test values
test
facial swelling
bleeding
lecrimation
gasping
cyanosis
exophthalmus
palpebral closure
piloerection
ear petechiae
% observations showing
sample 1 ,6
34
3
13
52
6
6
13
9
63
j extreme deviation from
sample 4,5
25
13
13
37
17
13
7
0
50
pre test
sample 2,7
0
0
0
0
0
0
0
3
32
Aftderson Laboratories,-Inc,

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Extreme deviation from pre test values
3
3 test
alertness
handling reactivity
activity
vocalization
air puff
| click
tail pinch
jjj clonic movements
* tonic movements
«
% observations she
sample 1,6
25
28
22
40
3
19
3
0
0
wing extreme deviation
sample 4,5
17
37
10
33
3
3
3
3
3
from pre test
sample 2,7
0
0
0
19
0
0
0
0
0

-------
8
s
in
8
       Neuromuscular Data Summary
         Extreme Deviation from Pre test values
% 0
test
jar
grip strength
body tone
righting reflex
body posture
ataxic gait
gait score
impaired gait
inverted screen
mis steps
reach reflex
tilted screen
body tilt
bservations showii
sample 1,6
19
9
22
13
56
6
13
25
19
16
31
19
0
ig extreme deviati
sample 4,5
27
27
20
13
5O
7
17
27
23
3
50
2O
17
on from pre study
sample 2,7
0
0
0
o
0
o *
o ^
o
o
0
0
o
0
 ; Anderson Laboratories, Inc.

-------
    APPENDIX I
    ASTM E 981
Anderson Laboratories, Inc.

-------
Due study

MOUNB number
Mf USk
MM** HIM fcllOtrfcit
Tilted ICreeD lest
mmf* 9 rtmr« UP.TTVEN.noWN O trit«)
Mis-Heps
mk:M
^oreunib placing
MlflUl: 1 J
Onp strength
Handling reactivity
rwA 1-3
Lacrunation
nnk- 1-3
Filpebral closure
I«\k: M
Salivauon
mk: 1-3
pyoereciion
MMMl: U
ExophihBlmus
ninul: 1 J
Cyanosis
gtntal- U (indictu when I
aspmg
quintal: 1.2
racial swelling
Stnul: 1.2
leeding (eye.ear.nosc i
ouinul- 1.2 (indicate wliicln
Body lone
raid: M



-















Test period
•



































i



















Ohser















i


nn
. i
.
* • *•
*








1 •
i
!
1
I




:'i















Righting renex
Rears
ce»nt- * mn (3 min>
Body posture
rfcicripiive- M
Body tilt
rwik-M
Qonic movements
I i : . !
i i :
I i
Tonic movements :
detcrtpttve- l-f >
Gait score
rink- 1-5
Impaired gan
Ataxic gait
rtnk  1-5
\lenness •
ink M
Activtry
»nk:l-«
Di&rrnea
ninul- 1.2
kir pun response
r»k- M
Click response
rwik: M
Tail pinch response
rwk: M
invened screen test
• KC ie c1imb.HANO.DKOP
vocalizations
qn.nul- l.2«lf*S)
dttcripllvtr icpclilivt bch«v«on
ittieriplivf unuiuit bchivien
comments
i





:



t
*
i
i











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t



















i
i
i


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'




i
I




i






-------
      Appendix II
     EXAMPLES OF
RESPIRATORY TRACINGS
  Anderson Laboratories, Inc.

-------
I    !
                                                      ii

-------
t>coce

-------
        Appendix
FUNCTIONAL OBSERVATIONAL
          BATTERY
     Anderson Laboratories, Inc.

-------
HYBRID FUNCTIONAL OBSERVATIONAL BATTERY                  VCMoser
FOR USE WITH MICE EXPOSED TO CARPET SAMPLES                ManTech Environ. Tech.
                                                                     reviled 1/14/93

Mice will be individually tested A pre-exposure. or baseline, test will be conducted (preferably the day before exposures
     begin, or else immediately before the first exposure). Post-exposure tests will be initiated 10-15 minutes after removal
     from the exposure chamber. At a minimum, tests will be conducted after the second and fourth exposures, and more
     often as necessary to document behavioral changes. Tests are performed in the order listed below.
                •
Type of data:
     Dadescriptive data. Note-more than one description is possible.
     R«nnk order data
     Q»quaTital, or yes/no data
     Mnterval or continuous data, including count data

Jar task (I) - Place mouse on 1-gallon glass jar. hanging from the rim of the jar by only one hind leg. Count how many times,
     out of three tries, the mouse falls off the jar (usually the mouse pulls up to stand upright on the jar rim).
                                                                                                  »
Tilted screen test (I) - Holding the screen at a 45* angle, place the mouse sideways (horizontal). Count how many times the
     mouse either rotates and walks up the screen (UP), walks straight across the screen (EVEN), or rotates downward and
     walks down (DOWN). This is repeated three times, with a maximum of 20 sec on each try.

Mis-steps (R) - How often the mouse slips a paw down between the wire mesh while on the tilted  screen.
      1) none, paws are placed correctly on wire mesh
     2) legs slip down only few times
     3) legs slip down about half of the steps
     4) legs are hanging between mesh with no attempt to pull them up

Hold mouse by tail and lower it towards edge of wire mesh screen.  Watch for forelimb placing response as mouse reaches for
     screen, then allow mouse to grab edge of screen and test grip strength.

Forelimb placing (Q) - Note extension and reaching with forelimbs as mouse reaches towards screen. Allow up to 5 seconds
     for response to take place.
     1) placing response is present
     2) no response

Grip strength (I) - Raise up the mouse until the screen is about perpendicular. Count the number of times, out of three tries, the
     mouse drops the screen before it reaches the 90* point

Holding the mouse in hand, assess the following measures.

Reactivity to'being handled (R) - The extent of activity and resistance to being held.
     1) low. no resistance, mouse does not move
     2) moderately low, slight resistance, some movement
     3) active, constantly moving around in hand
     4) moderately high, frantic movement, may be tense or rigid in hand
     5) high, squirming, or twisting, or attempting to bite

Lacrimation (R) - evidenced by wetness around eyes
     l)none
     2) slight
     3) severe

Palpebral closure (R)
     1) eyelids wide open
     2) eyelids slightly drooping
     3) eyelids drooping approximately half-way
     4) eyes completely shut

-------
Involuntary motor movements (D)
  Qonie » Repetitive contractions and relaxations of muscles
      Dnone
      2) repetitive movements of mouth and jaws, smacking
      3) fine quivers of limbs, ears, head, or skin
      4) mild tremors, moderately coarse
      5) arvere or whole body tremors, extremely coarse
      6)myoclonicjerks
      7) clonic convulsions
 YOGJC • Prolonged contractions of muscles
      Dnone
      2) contraction of extensors such that limbs are rigid and extended
      3) opisthotonus - head and body rigidly arched backwards
      4) emprosthotonus • bead and body rigidly extended forward
      5) explosive jumps into the air with all feet leaving the surface
      6) severe clonic and/or tonic convulsions resulting in dyspnea, postictal depression, or death

Gait acore (R) • Degree of any abnormality of gait excluding ataxia (see below). If only ataxia present, then gait score * 1.
      ataxic score > 1
      l)none
      2) slightly abnormal
      3) somewhat abnormal
      4) markedly abnormal
      5) severely abnormal

•impaired gait (D) • Note, if mouse did not move during the 2-min observation period, it may be gently prodded in order to
      observe the gait.  If gait score is 2 or higher, the type of impairment should be indicated here.
      l)none
      2) hindlimbs show uncoordinated placement, exaggerated or overcompensated movements, or are splayed
      3) walks on tiptoes, hindlegs perpendicular to surface
      4) flat foot walk, teg(s) flat on surface, crawling

Ataxic gait (R) - Swaying, lurching, rocking, stumbling
      l)none
      2) slight but definite
      3) somewhat, can locomote without falling
      4) marked, falls over occasionally
      S) severe, cannot locomote without falling

Alertness (R) • level of arousal in the open field
      1) very low. stupor, coma, slight or no vibrissae movement
      2) tow. some head or body movement, occasionally attends to surroundings
      3) alert,'interested in surroundings, exploration, sniffing
      4) high, tense, excited, sudden darting or freezing

Activity (R) - amount of activity in the open field
      1) lethargy, no body movement
      2) low, somewhat sluggish, little movement
      3) somewhat tow. some exploratory movements
      4) tow but active, exploratory movements but mostly walking with very little or no rumfing
      S) clearly active, exploratory movements, includes walking and running
      6) high, very active, darting or running

Varrhea (Q)
      l)none
      2) present

-------
Salivation (R) • evidenced by wetness around mouth and chin
      Doone
      2) slight
      3)aevere

Piloerection (Q)
      1) no piloerecnon
      2) indicates presence of piloenxtion. coal does not lie down after stroking

Exophthalnras (QT
      Dnone
      2) indicates presence of bulging eyes

Cyanosis (Q) • evidenced by blueness of skin, paws, ears, or tail
      l)none
      2) present, indicate where

Gasping (Q) - evidenced by laborious and/or convulsive breathing
      1) none
      2) present

Facial swelling (Q)
      l)none
      2) present

 Bleeding of eyes, ears, or nose (Q)
      1) none
      2) present, describe where

Body lone (R) - Assess the resistance of abdominal muscle.
      1) hypotonia, completely flaccid, limp
      2) slightly flaccid, abdomen shows slow return when compressed
      3) body tone present, abdomen has resistance when compressed
      4) hypenonia, body stiff, abdomen displays great resistance

Righting reflex (R) • Holding mouse between palms of the hands, flip hands over so that mouse is on its back. Do this several
      times, rating overall ease with which it turns over and regains normal posture
      1) flips over immediately
      2) slightly uncoordinated, but flips over within 1-2 sec
      3) difficulty turning over, takes several seconds
      4) cannot turn over within 10 sec

Place mouse in open-field (can-top with 3-inch lip around the perimeter) for exactly 2 minutes. During this time, the number
      of rears is counted and other observations are made.

Rearing (I) - Defined as  each time the front legs of the mouse come completely off the surface, although the mouse does not
      necessarily have to raise itself up. Includes when the mouse uses the side or lip of a can top as support, also includes
      instances when the mouse lifts front paws for grooming.

Body posture (D)
      1) lying on side
      2) completely flattened, pelvis flat on surface
    i 3) sitting or walking upright, pelvis off surface
      4) hunched, back raised up

Body tilt (R)
      1) typical posture,  with head straight forward
     2) head tilts to one side .
      3) hand and shoulders lean or tilt to one side
      4) whole body leans or tilts to one side, including falling over

-------
Stimulus reactivity • performed while mouse is sluing on open field

Air puff response (R) • Blow into face of mouse.
     1) no motion or response
     2) flight or sluggish reaction, e.g., blink or flinch
     3) elev faction, visible startle response
   •t 4) exaggerated reaction, e.g.. jumps or flips into air

Cfick response (R)* position clicker approximately 3 cm above the back of the mouse and make sudden sound.
     1) no reaction or response
     2) slight or sluggish reaction, some evidence that noise was heard, e.g.. ear flick
     3) clear reaction, visible startle response, quick darting
     4) exaggerated reaction, e.g., jumps, bites, or attacks

Tail pinch response (R) - metal tweezers are used to squeeze the tail approximately 1-2 cm from the tip
     1) no reaction or response
     2) slight or sluggish reaction, some evidence that pinch was felt, e.g., tail flick
     3) clear reaction, visible response or jump, quick darting
     4) exaggerated reaction, e.g.. jumps, bites, or attacks

Inverted screen tests 0) • Place mouse on screen and invert.  Measure seconds necessary for mouse to climb to the top. Note
     "D" if mouse drops off. or "H" if mouse remains hanging, to a maximum of 60 sec. During the time-0 test, mice will be
     given a total of 3 chances in order to "train" the mouse to climb to the top within 20 sec. A notation will be made as to
     how many trials were required or if a mouse is unable to invert after 3 trials.

Vocalizations (Q) • Note number of vocalizations, whether or not provoked by handling, testing, etc.
     1) none, or only 1 or 2 instances
     2) 3 or more instances

Siereorypy • record any behaviors thai are excessive or highly repetitive such as circling, stereotypic grooming, pacing.
     repetitive sniffing, or head weaving.

Bizarre behavior • record any unusual behaviors such as self-mutilalion. Straub tail (tail straight up), retropulsion. writhing,
     flopping, spinning, or attacking.

Other - includes soiled fur. fur discoloration, crustiness around face or eyes, emaciation, or any other findings of interest.

-------
         APPENDIX IV
COMMUNICATION OF UNBLINDING
  AND SAMPLE REPLACEMENT
      Anderson Laboratories, Inc.

-------
          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                  OFFICE OF RESEARCH AND DEVELOPMENT
                AIR AND ENERGY ENGINEERING RESEARCH LABORATORY
                  RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711
May 4, 1993
Dr. Rosiland Anderson
Anderson Laboratories Inc.
30 River Street
Dedham, MA  02026
Fax: 617-364-6709
Dear Dr. Anderson,

After our conversation  last  Friday,  I  spoke with Dr.  Schaeffer at
CPSC and with Mr.  Ezra  Chan,  your  sample custodian for the split
sample test phase.   It  is  clear to me  that an inadvertent mixup
occurred in preparation of the third sample that was sent to
Anderson Labs.   I  cannot reveal the  details of the mixup without
foiling the blinding procedure so  please bear with me until after
we have swapped  results, at  which  time I'll explain what
happened.  Please  repeat the exposure  sequence with the sample
that CPSC is sending out today. You should receive the package
by 10 AM Wednesday,  May 5th.  Please  follow the established
blinded procedure  for sample loading and testing. Pair the new
data with exposure series  number two and disregard the original
data, it is not  relevant to  the test plan.

Please accept my apologies for the delay and extra effort this
mistake has caused.   I  realize that this will make it necessary
to move the date for exchanging preliminary reports to Monday,
May 10th.  Please  call  me  later this week and we will discuss
details regarding  exchange of preliminary reports.

Sincerely,
Mark Mason
Project Coordinator
cc:  Dan  Costa
     Robert Dyer

-------
                                                     MAY 13 £93
          U.S. CONSUMER PRODUCT SAFETY COMMISSION

                    WASHINGTON. D.C. 2OSO7
Rosalind Anderson, Ph.D.
Anderson Laboratories Inc.
30 River Street
Dtdhll, HA 02026
Dear Dr. Anderson:

     This letter serves to officially reveal the order in which
carpet aubsamples and their sham controls were shipped to an
Environmental Protection Agency  (EPA) contractor, Acurex
Environmental, and Anderson Laboratories during the phase Z
evaluation of the carpet toxicity bioassay.  Six shipments were
sent by the Consumer Product Safety Commission  (CPSC) staff to
the sample custodians at each testing laboratory at staggered
intervals during March, 1993.  Four shipments were Federal
Express packages that contained two subsamples  (1 and 2) each of
two different carpets  (A and 6) sealed in labeled Tedlar bags.
Two packages containing labeled bags without carpet were sent to
indicate that control tests should be run with no carpet in the
source chamber.  The testing was intended to be "blinded" so that
the individuals conducting the animal experiments did not know
the identity of the samples being tested.  The order in which the
six packages were shipped are tabulated below along with the
dates the shipments were made, the source identification, and the
contents of the labeled bags.
Shipment
1
2
3
4
5
6
Date
Karch 4, 1993
March B, 1993
March 16, 1993
March 22, 1993
March 25, 1993
March 29, 1993
Source ID
Carpet Al
Control 1
Control 2
Carpet Bl
Carpet B2
Carpet A2
Contents
Pink C&rpet
Empty
Paper
Blue Carpet
Blue Carpet
Pink Carpet
     Some explanation is  needed in regard to  the  control
shipments 2  and  3,   Prigr tG  the initiation Of  the  BtUCty;  it WU
agreed that  a package solely  containing  an empty  bag would serve

-------
to signal that a control experiment was to be performed at the
testing laboratories.  As a result, shipment 2 contained an empty
bag.  However, ^flt,irir1nr^cJl^fjffihj^r\s
-------
            APPENDIX V
TEMPERATURE AND HUMIDITY VALUES
         Anderson Laboratories, Inc.

-------
TEST NUMBER:  |921

SAMPLE SOURCE:  CPSC SAMPLE 1
                               TABLE 1»  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM!
BOTTOM OUT-
SIDE S2
(°C)
72.6
73.7
74.6
75.4
76.0
75.9
75.7
?LE CHAMBER
TOP OUT-
SIDE S7
(°C)
42.3
43.4
45.0
47.1
47.4
47.8
47.9
AIR Al
(°C)
35.3
36.4
32.8
33.0
33.4
33.3
33.2
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
23.0
23.0
24.0
24.0
24.0
24.0
24.2
ROOM
HUMIDITY
(%)
38.0
38.0
37.0
38.0
38.5
38.5
38.5
ROOM
TEMPERATURE
<°F)
71
71
71
71
71
72
71
                                                                                                       0°

                                                                                                       1^
                                                                                                        I
                                                                                                       -J
                                                                                                       ct

-------
TEST NUMBER:  |922
SAMPLE SOURCE:  CPSC SAMPLE 1
                                            EXPERIMENT A

                               T&BLB 2S  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
(°C)
75.4
75.7
76.0
76.7
76.8
77.2
76.3
>LE CHAMBER
TOP OUT-
SIDE S7
(°C)
48.0
48.1
47.8
47.5
47.1
47.0
47.1
AIR Al
(°C)
37.9
38.2
38.0
37.1
36.6
36.7
37.6
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
23
23.5
24.5
24.5
24.0
24.0
24.0
ROOM
HUMIDITY
(*)
38.0
38.0
37.5
38.0
36.5
36.5
36.5
ROOM
TEMPERATURE
(OF)
71
71
71
71
71
71
71

-------
TEST NUMBER:  |923
SAMPLE SOURCE:  CPSC SAMPLE  1
                                            EXPERIMENT A


                               TABLE 31  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM1
BOTTOM OUT-
SIDE S2
(°C)
73.9
74.4
75.6
76.1
76.0
76.5
76.4
?LE CHAMBER
TOP OUT-
SIDE S7
(°C)
39.2
40.4
41.3
42.3
42.7
42.3
43.8
AIR Al
<°C)
35.7
35.6
34.0
33.5
33.7
33.6
33.6
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
23.5
24.0
24.0
24.0
24.5
24.5
24.0
ROOM
HUMIDITY
(%)
37.0
36.5
36.1
36.0
36.0
36.0
36.0
ROOM
TEMPERATURE
<°F)
70
70
70
70
70
70
70
                                                                                                       o
                                                                                                       IT

-------
TEST NUMBER:  |924
SAMPLE SOURCE:  CPSC SAMPLE 1
                                            EXPERIMENT A


                               TABLE 4S  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
<°C)
76.3
76.9
76.6
77.0
77.4
77.8
78.0
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
46.8
47.0
47.0
46.8
46.6
46.6
46.6
AIR Al
(°C)
35.2
35.3
34.0
33.9
33.8
33.8
34.0
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
23.0
23.0
24.0
24.5
25.0
25.0
25.0
ROOM
HUMIDITY
(%)
36.0
36.0
35.5
35.5
36.0
36.5
36.5
ROOM
TEMPERATURE
(°F)
70
70
70
70
70
70
70
                                                                                                       T
                                                                                                       t
                                                                                                       -J

-------
TEST NUMBER:  |962
SAMPLE SOURCE:  CPSC SAMPLE 6
                                            EXPERIMENT A

                               TABLE 5s  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM1
BOTTOM OUT-
SIDE S2
<°C)
74.3
75.2
75.0
75.6
76.2
75.9
76.4
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
38.0
37.8
39.0
39.0
39.9
40.5
40.7
AIR Al
(°C)
34.2
35.2
33.5
34.1
34.4
34.2
34.9
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.0
23.0
23.5
24.0
24.0
24.0
24.0
ROOM
HUMIDITY
(%)
45
45
46
46
46
45
46
ROOM
TEMPERATURE
(°F)
68
69
70
70
70
70
70
                                                                                                        ci

-------
TEST NUMBER:  |963
SAMPLE SOURCE:  CPSC SAMPLE 6
                                            EXPERIMENT A

                               TABLE 61  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
(°C)
72.6
74.8
77.5
76.5
76.0
76.0
75.8
>LE CHAMBER
TOP OUT-
SIDE S7
(°C)
45.6
45.6
44.0
43.3
43.2
43.1
43.1
AIR Al
<°C)
36.6
36.9
36.1
37.0
37.4
36.4
37.5
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.5
23.5
24.0
24.0
24.0
24.0
24.0
ROOM
HUMIDITY
(%)
45
46
46
46
46
46
46
ROOM
TEMPERATURE
<°F)
70
70
70
70
70
70
70
                                                                                                       I

-------
TEST NUMBER:  I964
SAMPLE SOURCE:  CPSC SAMPLE 6
                                            EXPERIMENT A

                               TABLE 71  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM!
BOTTOM OUT-
SIDE S2
(°C)
78.4
78.8
78.9
78.9
78.8
78.7
79.1
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
36.2
37.7
38.9
39.9
40.3
41.1
41.5
AIR Al
(°C)
32.0
34.6
33.8
34.1
34.2
34.0
35.6
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.0
23.0
24.0
24.0
24.0
24.0
24.0
ROOM
HUMIDITY
(*)
47
46
45
45
45
45
45
ROOM
TEMPERATURE
<°F)
70
70
70
70
70
70
70
                                                                                                      i
                                                                                                     -J

-------
TEST NUMBER:  *965
SAMPLE SOURCE:  CPSC SAMPLE 6
                                            EXPERIMENT A

                               TABLE 8:  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM!
BOTTOM OUT-
SIDE S2
<°C)
70.2
73.4
73.6
73.3
72.9
72.7
72.0
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
43.5
42.8
41.4
39.8
39.3
39.1
39.0
AIR Al
(°C)
34.0
35.3
34.8
34.0
33.7
33.6
34.3
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.5
24.0
24.0
24.0
24.0
24.0
24.0
ROOM
HUMIDITY
(*)
44
44
44
44
44
44
44
ROOM
TEMPERATURE
(°F)
70
70
70
71
71
71
70
                                                                                                      i
                                                                                                      -j
                                                                                                      Q

-------
TEST NUMBER:  |925
SAMPLE SOURCE:  CPSC SAMPLE 2
                                                       B
                               TABLE 91  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM!
BOTTOM OUT-
SIDE S2
(°C)
65.4
67.0
66.8
66.4
66.1
66.6
67.5
>LE CHAMBER
TOP OUT-
SIDE S7
(°C)
43.5
44.8
45.7
46.0
46.4
46.5
47.1
AIR Al
(°C)
37.1
38.7
37.5
37.5
37.3
37.3
39.1
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.5
24.0
24.5
24.5
25.0
25.0
24.0
ROOM
HUMIDITY
(%)
36.0
36.0
36.0
36.0
36.0
36.0
36.0
ROOM
TEMPERATURE
(°F)
71
71
71
71
71
71
?1

-------
TEST NUMBER:  1926
SAMPLE SOURCE:  CPSC SAMPLE 2
                                            EXPERIMENT B

                              TABLE 101  TBMPERATORB, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM!
BOTTOM OUT-
SIDE S2
(°C)
66.5
65.8
65.4
65.7
65.9
65.6
65.7
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
42.0
41.9
41.6
41.2
40.9
40.8
41.2
AIR Al
(°C)
37.2
37.2
35.1
34.6
34.6
34.6
36.0
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
23.5
23.5
24.0
24.5
25.0
25.0
24.5
ROOM
HUMIDITY
(*)
36.0
36.0
35.0
35.0
35.0
35.0
35.0
ROOM
TEMPERATURE
(OP)
71
71
70
70
70
70
70

-------
TEST NUMBER:  |927
SAMPLE SOURCE:  CPSC SAMPLE  2
                                            EXPERIMENT B

                              TABLE lls  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
(°C)
66.0
66.0
65.0
64.4
64.9
64.7
65.6
PLE CHAMBER
TOP OUT-
SIDE S7
<°C)
37.5
39.0
39.4
39.7
39.9
40.0
40.5
AIR Al
(°C)
34.2
35.5
33.8
33.7
33.9
33.8
35.6
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.0
23.5
24.0
24.5
25.0
25.0
24.5
ROOM
HUMIDITY
(«)
29.0
29.0
29.0
29.0
27.0
27.0
27.0
ROOM
TEMPERATURE
(°F)
70
71
71
71
71
71
71

-------
TEST NUMBER:  ft928
SAMPLE SOURCE:  CPSC SAMPLE 2
                                            EXPERIMENT B


                              TABLE 121  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
<°C)
67.2
67.9
66.8
66.4
66.6
66.2
66.1
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
43.0
43.1
42.6
42.2
41.9
42.0
42.2
AIR Al
<°C)
38.8
39.1
36.8
35.5
35.2
35.8
37.2
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
23.5
23.5
24.0
25.0
25.0
25.0
24.5
ROOM
HUMIDITY
(%)
28.0
28.0
27.0
27.0
27.0
27.0
27.0
ROOM
TEMPERATURE
(OF)
70
70
70
70
70
70
70
                                                                                                       cr
                                                                                                       3-

                                                                                                       Jl
                                                                                                       cr

-------
TEST NUMBER:  |1034

SAMPLE SOURCE:  7
                                            EXPERIMENT B


                              TABLE 13|  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
(°C)
66.6
66.8
65.0
65.0
65.4
65.8
65.9
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
39.8
39.9
41.8
43.5
44.7
44.9
45.5
AIR Al
(°C)
35.1
35.4
35.8
36.8
37.5
38.0
38.2
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
22.0
22.0
23.0
23.5
23.5
23.5
23.0
ROOM
HUMIDITY
(%)
55
55
55
55
55
55
54
ROOM
TEMPERATURE
(°P)
70
70
70
71
71
72
72
                                                                                                       LP

                                                                                                       ^
                                                                                                       ct

-------
TEST NUMBER:  11035
SAMPLE SOURCE:  7
                                            EXPERIMENT B

                              TABLE 14s  TBMPBRATOBB, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM1
BOTTOM OUT-
SIDE S2
(°C)
68.0
67.7
67.1
67.1
67.0
67.0
67.1
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
43.3
43.4
44.2
44.3
45.1
45.0
45.0
AIR Al
(°C)
39.1
39.4
39.1
39.2
39.3
39.2
39.3
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.0
23.0
23.0
23.5
24.0
24.0
24.0
ROOM
HUMIDITY
(%)
54
54
54
54
54
54
55
ROOM
TEMPERATURE
(OF)
72
72
72
73
74
74
74

-------
TEST NUMBER:  11036
SAMPLE SOURCE:  7
                                             EXPERIMENT B

                              TABLE  151   TEMPERATURE,  HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
IS MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
(°C)
65.3
65.6
65.5
65.0
65.2
65.5
65.3
>LE CHAMBER
TOP OUT-
SIDE S7
(°C)
41.7
41.4
40.9
40.4
40.2
40.2
40.3
AIR Al
<°C)
38.6
35.9
35.4
35.5
35.5
35.1
35.6
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
21.5
22.0
22.0
23.0
23.5
23.5
23.5
ROOM
HUMIDITY
(%)
55
55
55
55
54
54
54
ROOM
TEMPERATURE
<°F)
71
71
71
71
72
72
72
                                                                                                       10

                                                                                                       cr

-------
TEST NUMBER:  |1037
SAMPLE SOURCE:  7
                                             EXPERIMENT B

                              TABLE  16»  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
(°C)
70.2
70.1
70.1
69.9
69.9
69.6
70.1
>LE CHAMBER
TOP OUT-
SIDE S7
(°C)
43.1
43.3
43.7
43.2
43.0
43.1
43.8
AIR Al
<°C)
39.7
39.6
38.8
38.2
38.5
38.5
39.6
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
23.5
24.0
24.0
24.5
24.5
24.5
24.0
ROOM
HUMIDITY
(%)
56
56
56
56
58
58
58
ROOM
TEMPERATURE
(OF)
73
73
72
72
72
72
71
                                                                                                      in

-------
TEST NUMBER:  I944
SAMPLE SOURCE:  CPSC SAMPLE 4
                                            EXPERIMENT C

                               TABLE 17  TEMPERATURE, HUMIDITY  RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM!
BOTTOM OUT-
SIDE S2
<°C)
68.1
68.4
69.8
71.0
71.3
71.4
71.5
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
44.2
44.8
45.1
45.1
45.3
45.6
45.7
AIR Al
(°C)
36.2
36.4
35.1
35.2
35.3
35.0
35.0
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.0
23.5
23.5
23.5
24.0
24.0
24.0
ROOM
HUMIDITY
(%)
36
36
36
37
37
37
37
ROOM
TEMPERATURE
(OF)
70
70
70
70
70
70
70
                                                                                                       LO

-------
TEST NUMBER:  1945
SAMPLE SOURCE:  CPSC SAMPLE 4
                                            EXPERIMENT C

                              TABLE 16s  TBMPBBATORB, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM1
BOTTOM OUT-
SIDE S2
<°C)
65.3
65.9
67.6
68.0
68.2
69.4
69.9
>LE CHAMBER
TOP OUT-
SIDE S7
(°C)
48.0
47.8
47.6
47.0
46.8
46.6
46.8
AIR Al
<°C)
34.6
35.0
34.8
34.5
34.5
36.0
36.0
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
23.0
23.5
24.0
24.0
24.0
24.0
24.0
ROOM
HUMIDITY
(%)
37
37
37
37
37
37
37
ROOM
TEMPERATURE
(°F)
71
71
70
70
70
71
71
                                                                                                      I/
                                                                                                      4

-------
TEST NUMBER:  |946
SAMPLE SOURCE:  CPSC SAMPLE 4
                                             EXPERIMENT  C


                              TABLE 19S  TBMPBRATORB, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
(°C)
68.5
69.6
71.3
72.3
73.6
73.8
72.5
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
43.1
45.3
46.1
46.7
46.4
46.3
46.5
AIR Al
(°C)
37.0
37.7
33.0
33.1
33.1
33.4
35.0
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.0
23.0
23.5
23.5
23.5
23.5
23.0
ROOM
HUMIDITY
(%)
39
39
39
39
39
38
39
ROOM
TEMPERATURE
<°F)
70
70
70
70
70
60
70
                                                                                                         I
                                                                                                        -J

-------
TEST NUMBER:  |947
SAMPLE SOURCE:  CPSC SAMPLE 4
                                            EXPERIMENT C

                              TABLE 20X  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM!
BOTTOM OUT-
SIDE S2
(°C)
72.9
72.8
73.8
74.2
74.7
74.0
74.1
>LE CHAMBER
TOP OUT-
SIDE S7
(°C)
48.1
48.3
48.0
47.9
47.8
47.6
47.7
AIR Al
(°C)
36.5
35.8
37.6
38.4
39.0
39.7
39.9
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.0
23.0
23.5
24.0
24.0
24.0
24.0
ROOM
HUMIDITY
(%)
39
40
40
39
39
41
41
ROOM
TEMPERATURE
(°F)
70
70
70
69
70
70
70
                                                                                                      r*-
                                                                                                       i

-------
TEST NUMBER:  |958
SAMPLE SOURCE:  CPSC SAMPLE 5
                                            EXPERIMENT c

                              TABLE 211  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM1
BOTTOM OUT-
SIDE S2
(°C)
69.7
70.3
71.5
71.5
71.8
71.9
71.2
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
44.6
45.9
46.5
47.2
47.6
48.1
48.5
AIR Al
<°C)
35.8
36.4
36.1
36.5
36.7
37.1
38.0
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.0
23.0
23.5
23.5
24.0
24.0
23.5
ROOM
HUMIDITY
(%)
48
48
47
47
43
48
48
ROOM
TEMPERATURE
<°F)
70
70
70
70
70
70
70
                                                                                                      QO
                                                                                                      in

-------
TEST NUMBER:  |959

SAMPLE SOURCE:  CPSC SAMPLE 5
                                            EXPERIMENT C


                              TABLE 221  TBMPBRATORB, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAM1
BOTTOM OUT-
SIDE S2
<°C)
72.2
72.6
72.5
72.4
72.3
72.7
71.6
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
42.6
44.4
43.5
42.9
41.5
41.4
41.5
AIR Al
<°C)
39.5
39.6
38.5
38.2
37.6
37.4
37.8
MOUSE
CHAMBER
SAMPLING
PORT
(°C)
23.0
23.0
23.5
24.0
24.5
25.0
24.5
ROOM
HUMIDITY
(%)
48
47
47
48
48
48
48
ROOM
TEMPERATURE
(OF)
71
71
70
70
70
71
71
                                                                                                     cr

                                                                                                     tf
                                                                                                      i

-------
TEST NUMBER:  I960

SAMPLE SOURCE:  CPSC SAMPLE 5
                                            EXPERIMENT C


                              TABLE 231  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
<°C)
72.8
72.1
74.5
74.4
74.3
74.4
73.8
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
38.0
43.8
45.6
45.9
46.7
47.1
47.6
AIR Al
(°C)
37.1
38.1
38.0
38.6
39.2
39.2
39.4
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
23.0
23.0
24.0
24.5
24.0
24.0
24.0
ROOM
HUMIDITY
(%)
47
47
48
48
48
48
48
ROOM
TEMPERATURE
(°F)
70
70
70
70
70
70
70
                                                                                                       o
                                                                                                       >o

                                                                                                       -J

-------
TEST NUMBER:  |961
SAMPLE SOURCE:  CPSC SAMPLE 5
                                            EXPERIMENT C

                              TABLE 24S  TEMPERATURE, HUMIDITY RECORD
TIME
START BASELINE
TIME 0 (START EXPOSURE)
15 MIN
30 MIN
45 MIN
60 MIN
75 MIN
SAMI
BOTTOM OUT-
SIDE S2
(°C)
71.2
71.3
70.8
71.4
68.6
68.3
68.5
>LE CHAMBER
TOP OUT-
SIDE S7
<°C)
44.6
44.9
45.5
45.5
45.6
45.6
45.8
AIR Al
(°C)
38.5
38.9
38.2
38.7
38.8
38.9
40.0
MOUSE
CHAMBER
SAMPLING
PORT
<°C)
23.5
23.0
23.5
24.0
24.0
24.0
24.0
ROOM
HUMIDITY
(%)
46
46
46
46
45
45
45
ROOM
TEMPERATURE
(°F)
70
70
70
70
70
70
.70
                                                                                                     0
                                                                                                     -J

-------
   APPENDIX VI
FOB, EXPERIMENT A
Anderson Laboratories, Inc.

        AL-kl

-------
             ACTIVITY / EXCITABILITY
                     Sample 1, 6
                      DAYS 1,2
OBSERVATION
alert
handling reactive
activity
vocalization
air puff
click
tail pinch
clonic
tonic
rears
PRE SCORE
#OBS X SCORE
7X3, 1X2
7X3, 1X2
5X4, 3X5
8XA
8X2
7X2, 1X3
8X2
8X1
8X1
3-11
# OBS OUTSIDE
PRE SCORE RANGE
15
11
17
10
5
7
8
31
1
20
#
OBS
32
32
32
32
32
32
32
32
32
32
%OUT
OF RANGE
47
34
53
31
16
22
25
97
3
63
r-
  P/A = present/absent
  ep17
  ANDERSON LABORATORIES, INC.

-------
    ACTIVITY/ EXCITABILI
       EXTREME CHANGES, Samples 1,6
                DAYS 1,2
OBSERVATION
alert
handling reactive
activity
vocalization
air puff
click
tail pinch

REARS


PRE SCORE
#OBS X SCORE
7X3,1X2
7X3,1X2
5X4, 3X5
8XA
8X2
7X2, 1 X3
8X2

45/8
5.6

OBSERVATIONS SHOWING
EXTREME SCORE
6X STUPOR, 2X HYPER
9X LOW,
6XNONE, 1X HYPER
13X PRESENT
1X EXTREME
6X NONE
1X EXTREME

84/32
2.6
11X NO REARS
TOTAL #
OBS
32
32
32
32
32
32
32




p/A = present/absent
epactiv16

-------
    Neuromuscular Function
             Samples 1, 6
              DAYS 1,2
OBSERVATION
jar
grip strength
body tone
righting reflex
body posture
body tilt
ataxic gate
gait score
impaired gait
inverted screen
mis-steps
reach reflex
tilt screen
PRE SCORE
# OBS X SCORE
7X0,1X1
7X0,1X1
8X3
8X1
8X3
8X1
8X1
8X1
8X1
7XH, 1XFAST
8X1
8X1 (PRESENT)
8X3 up
# OBS OUTSIDE
PRE SCORE RANGE
13
8
30
23
20
11
4
31
29
14
15
10
17
TOTAL #
OBS
32
32
32
32
32
32
30
31
29
32
31
32
32
% OUT
OF RANGE
41
25
94
72
63
34
13
100
100
44
48
31
53
IF*
*£.
 EPN16A

-------
            iNeuromuscuiar i-unction
         EXTREME CHANGES Samples 1,6
                    DAYS 1,2
OBSERVATION
jar
grip strength
body tone
righting reflex
body posture
ataxic gate
gait score
impaired gait
inverted screen
mis-steps
reach reflex
tilt screen
PRE SCORE
# OBS X SCORE
7X0,1X1
7X0,1X1
8X3
8X1
8X3
8X1
8X1
8X1
7XH, 1XFAST
8X1
8X1 (PRESENT)
8X3 up
OBSERVATIONS
EXTREME SCORE
6X 3 FALLS
3X 3 DROPS
7X HYPOTONIA
4X NOT PRESENT
19X HUNCHED
2X MARKED
4X SEVERE
8X SCORE 4
6X DROP
5X LEGS HANGING
1 0X ABSENT
6X 3 DOWN
#
OBS
32
32
32
32
32
30
31
29
32
31
32
32
%
EXTREME
19
9
22
13
59
7
13
28
19
16
31
19
r
e-
\n
 EP9
 ANDERSON LABORATORIES, INC.

-------
   GENERAL APPEARANCE
            Samples 1, 6
             DAYS 1,2
OBSERVATION
face swelling
bleeding
lacrimation
salivation
diarrhea
gasping
cyanosis
exophthalmus
eye closure
piloerection
ear petechiae
PRE SCORE
8XA
8XA
8X1
8X1
8XA
8XA
8XA
8XA
8X1
8XA
8XA
# OBS OUTSIDE
PRE SCORE RANGE
11
1
20
0
0
16
2
2
14
3
20
Total #
OBS
32
32
32
32
32
31
32
32
32
32
32
%OUT
OF RANGE
34
3
63
0
0
52
6
6
41
9
63
r
 P/A = present/absent
 EPAPEAR3

-------
            GHRERAL APPEARANCE
          EXTREME CHANGES, Samples 1, 6
                     DAYS 1,2
OBSERVATION
face swelling
bleeding
lacrimation
gasping
cyanosis
exophthalmus
eye closure
piloerection
ear petechiae
PRE SCORE
8XA
8XA
8X1
8XA
8XA
8XA
8X1
8XA
8XA
OBSERVATIONS
EXTREME SCORE
11X PRESENT
1X PRESENT
4X SEVERE
1 6X PRESENT
2X PRESENT
2X PRESENT
4X EYES SHUT
3X PRESENT
20X PRESENT
#
OBS
32
32
32
31
32
32
32
32
32
%
EXTREME
34
3
13
52
6
6
13
9
62
r-
ts
>I
 EPA16 MAX
 P/A =PRESENT/ ABSENT
 ANDERSON LABORATORIES, INC.

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     OTHER OBSERVATIONS
            SAMPLES 1, 6
  OBSERVATION	FREQUENCY
  POPCORN                       2
  FALL OVER                       1
  NO ACTIVITY                    12
  BLEEDING EYE                    1
  REPETITIVE  MOTION
  FOOT                           2
  CIRCLE                         2
  NOSE BUMP                     4
  BUMP INTO WALL                  1
ANDERSON LABORATORIES, INC.

-------
   APPENDIX VII
FOB, EXPERIMENT B
Anderson Laboratories, Inc.

-------
           ACTIVITY / EXCITABILITY
                   Samples 2,7
                     DAYS 1,2
OBSERVATION
alert
handling reactive
activity
vocalization
air puff
click
tail pinch
clonic
tonic

rears
PRE SCORE
#OBS X SCORE
8X3
7X3,1X2
4X4, 4X5
8XA
7X2,1X3
8X2
4X1 , 4X2
8X1
8X1

1-10
# OBS OUTSIDE
PRE SCORE RANGE
0
0
0
6
2
4
9
8
0

5
TOTAL #
OBS
31
31
31
31
31
31
31
31
31

31
%OUT
OF RANGE
0
0
0
19
6
13
29
26
0

16
P/A = present/absent
ep11
ANDERSON LABORATORIES. INC.

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            ACTIVITY / EXCITABILITY
          EXTREME CHANGES, Sample 2,7
                     DAYS 1,2
r-
OBSERVATION
vocalization
PRE SCORE
#OBS X SCORE
8XA
# OBSERVATIONS SHOWING
EXTREME SCORE
6X PRESENT
OBS
31
EXTREME
19
 p/A = present/absent
 ep13
 ANDERSON UBORATORIES, INC.

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            Neuromuscular Function
                   Samples 2,7
                    DAYS 1,2
OBSERVATION
jar
grip strength
body tone
righting reflex
body posture
body tilt
ataxic gate
abnormal gait score
impaired gait
inverted screen
mis-steps
reach reflex
tilted screen
PRE SCORE
# OBS X SCORE
3X0, 1X1
4X0
4X3
4X1
4X3
4X1
4X1
4X1
4X1
4XH
4X1
4X1 (PRESENT)
4X0 (DOWN)
# OBS OUTSIDE
PRE SCORE RANGE
0
0
2
1
5
0
0
9
9
8
0
0
3
#
OBS
31
31
31
31
31
31
31
31
31
31
31
31
31
%OUT
OF RANGE
0
0
6
3
16
0
0
29
29
26
0
0
10
V
 EPAN2A
 ANDERSON IABORATORIES INC.

-------
              iwuromuscular Function
            EXTREME CHANGES, Samples 2,7
                       DAYS 1,2
   OBSERVATION
PRE SCORE
# OBS X SCORE
OBSERVATIONS SHOWING
EXTREME SCORE
TOTAL #
OBS
                           NONE
l/J
  EPAN2A MAX
  ANDERSON LABORATORIES. INC.

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           GENERAL APPEARANCE
                   Samples 2,7
                    DAYS 1,2
OBSERVATION
face swelling
bleeding
lacrimation
salivation
diarrhea
gasping
cyanosis
exophthalmus
eye closure
piloerection
ear petechiae
PRE SCORE
8XA
8XA
8X1
8X1
8XA
8XA
8XA
8XA
8X1
8XA
8XA
# OBS OUTSIDE
PRE SCORE RANGE
0
0
2
0
0
0
0
0
0
1
10
Total #
OBS
31
31
31
31
31
31
31
31
31
31
31
% OUT
OF RANGE
0
0
6
0
0
0
0
0
0
3
32
44
 p/A = present/absent
 EP15
 ANDERSON LABORATORIES, INC.

-------
           UhNhHAL APPEARANCE
           EXTREME CHANGES, Samples 2,7
                        DAYS 1,2
 OBSERVATION
PRE SCORE
# OBSERVATIONS
EXTREME SCORE
Total
#OBS
                                  EXTREME
 ear petechiae
4XA
10X PRESENT
    31
32
EPAR 2,7 max
P/A ^PRESENT/ ABSENT
ANDERSON LABORATORIES, INC.

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     OTHER OBSERVATIONS
            SAMPLES 2, 7
 OBSERVATION	FREQUENCY
 REPETITIVE MOTIONS
 FOOT                           1
 CIRCLE                         4
ANDERSON LABORATORIES. INC.
                AL-7-6

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   APPENDIX VIII
FOB, EXPERIMENT C
 Anderson Laboratories, Inc.

        AL-7?

-------
           ACTIVITY / EXCITABILITY
                    Sample 4, 5
                     DAYS 1,2
OBSERVATION
alert
handling reactive
T activity
• _ 	 .,. ,.
•^j
oO vocalization
air puff
click
tail pinch
clonic
tonic
rears
PRE SCORE
#OBS X SCORE
8X3
6X3, 2X2
7X4, 1X3
8XA
8X2
8X2
7X2, 1X1
8X1
8X1
1-8
# OBS OUTSIDE
PRE SCORE RANGE
15
11
17
10
5
7
8
30
1
16 (3 UP, 13 DOWN)
#
OBS
30
30
30
30
30
30
30
30
30
30
%OUT
OF RANGE
50
37
57
33
20
23
27
100
3
53
P/A = present/absent
ep14
ANDERSON LABORATORIES, INC.

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           ACTIVITY / EXCITABILITY
         EXTREME CHANGES, Sample 4, 5
                   DAYS 1,2
OBSERVATION
alert
handling reactive
activity
vocalization
air puff
click
tail pinch
clonic
tonic
PRE SCORE
#OBS X SCORE
8X3
6X3, 2X2
7X4, 1X3
8XA
8X2
8X2
7X2, 1X1
8X1
8X1
OBSERVATIONS SHOWING
EXTREME SCORE
5X STUPOR
1OX LOW, 1X HIGH
2X NONE, 1X HYPER
10X PRESENT
1X EXTREME
1X EXTREME
1X EXTREME
1X MYOCLONUS
1X EMPROSTHOTONUS
#
OBS
30
30
30
30
30
30
30
30
30
%
EXTREME
17
37
10
37
3
3
3
3
3
P/A present/absent
epio
ANDERSON LABORATORIES, INC.

-------
     Neuromuscular Function
             Samples 4, 5
              DAYS 1,2
OBSERVATION
jar
grip strength
body tone
righting reflex
body posture
body tilt
ataxic gate
gait score
impaired gait
inverted screen
mis-steps
reach reflex
tilt screen
PRE SCORE
# OBS X SCORE
6X0, 2X1
7X0,1X1
8X3
8X1
8X3
8X1
8X1
8X1
8X1
7XH, 1XFAST
8X1
8X1 (PRESENT)
8Xup
# OBS OUTSIDE
PRE SCORE RANGE
9
11
29
20
17
13
2
21
21
10
16
15
15
TOTAL #
OBS
30
29
30
30
29
30
28
30
30
30
30
30
30
% OUT
OF RANGE
30
38
97
67
59
43
7
70
70
33
53
50
50
oO
0
 EPAN4,5

-------
             Neuromuscular Function

          EXTREME CHANGES, SAMPLES 4,5

                     DAYS 1,2
OBSERVATION
jar
grip strength
body tone
righting reflex
body posture
body tilt
ataxic gate
gait score
impaired gait
inverted screen
mis-steps
reach reflex
tilt screen
PRE SCORE
# OBS X SCORE
6X0, 2X1
7X0, 1X1
8X3
8X1
8X3
8X1
8X1
8X1
8X1
7XH, 1XFAST
8X1
8X1 (PRESENT)
8X3UP
OBSERVATIONS
EXTREME CHANGE
8X3 FALLS
8X3 DROPS
6X HYPOTINIA
4X NOT PRESENT
1X ON SIDE, 14X HUNCHED
5X SHOULDER OR BODY LIST
2X SEVERE
5X SEVERE
8X4
7X DROP
1X LEGS HANGING
15X ABSENT
6X 3DOWN
TOTAL
#OBS
30
29
30
30
29
30
28
30
30
30
30
30
30
%
EXTREME
27
28
20
13
3
17
7
17
27
23
3
50
20
r-
i
oO
  EPAN4.5 max


  ANDERSON LABORATORIES, INC.

-------
           GENERAL APPEARANCE
                  Samples 4, 5
                   DAYS 1,2
OBSERVATION
face swelling
bleeding
lacrimation
salivation
diarrhea
gasping
cyanosis
exophthalmus
eye closure
piloerection
ear petechiae
PRE SCORE
8XA
8XA
8X1
8X1
8XA
8XA
8XA
8XA
8X1
8XA
8XA
# OBS OUTSIDE
PRE SCORE RANGE
7
4
16
2
0
11
5
4
9
0
15
Total #
OBS
30
29
30
30
30
30
30
30
30
30
30
%OUT
OF RANGE
23
14
53
7
0
37
17
13
30
0
50
oC,
 p/A = present / absent
 EPS
 ANDERSON LABORATORIES, INC.

-------
    UtNLKAL APPEARANCE
       EXTREME CHANGES, SAMPLES 4,5
                DAYS 1,2
OBSERVATION
face swelling
bleeding
lacrimation
gasping
cyanosis
exophthalmus
eye closure
ear petechlae
PRE SCORE
8XA
8XA
8X1
8XA
8XA
8XA
8X1
8XA
OBSERVATIONS
EXTREME SCORE
7X PRESENT
4X PRESENT
4X SEVERE
11X PRESENT
5X PRESENT
4X PRESENT
2X EYES SHUT
15X PRESENT
#
OBS
30
29
30
30
30
30
30
30
%
EXTREME
23
14
13
37
17
13
7
50
r-
 ep6
 P/A = PRESENT/ABSENT
 ANDERSON LABORATORIES, INC.

-------
     OTHER OBSERVATIONS
            SAMPLES 4, 5
 OBSERVATION	FREQUENCY
 POPCORN                          3
 NO ACTIVITY                        5
 BLEEDING NOSE                     2
 BLEEDING EYE                       -1
 REACHING WITH ONE ARM              1
 SPASMODIC CHIRPING                 1
 REPETITIVE MOTION
 CIRCLE                            3
 WALK OFF EDGE                     3
ANDERSON LABORATORIES. INC.

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REVIEW OF PHASE I OF EPA/ORD CARPET STUDY
           Prepared for the U.S.E.P.A.
          Richard B. Schlesinger, Ph.D.

     Department of Environmental Medicine
       New York University Medical Center
               New York, NY
                 June 1,1993

-------
       This report provides  my  views of the  Phase I  component  of  the
 EPA/ORD carpet study as  described in the written reports  and in oral
 presentations at EPA/HERL on May 26 and 27th, 1993.
  GENERAL CONCLUSION
       The goal of Phase  I was to perform, to the extent possible, replicate
  studies at EPA/HERL and at Anderson Laboratories. The study design was
  originally provided by EPA and was subsequently modified by a peer review
  panel. The experiments at both sites were conducted within the constraints
  imposed by the protocol. With this in mind, the study as performed by EPA
  clearly conformed to GLP, and was conducted with appropriate and adequate
  QA in all components and for both the bioassays and the chemical/physical
  characterization of carpet emissions.  Some concern  about data analysis for
  the FOB  is expressed, but this is not  a major problem. Accordingly, it is my
  opinion that the EPA did  perform a scientifically valid study of the effect of
  carpet emissions on mice, and was not able to find  any toxic effects which
  could be ascribed to the carpets tested under the conditions imposed by the
 experimental design.  Furthermore, the levels of emissions of any potentially
 toxic chemicals from these carpets was very low, and unless there  was some
 exotic interaction between these chemicals, the lack of biological response is
 not surprising.
       On the other hand, the study as performed by Anderson Laboratories
 did not conform to GLP,  inasmuch as  the double blind condition was not
 maintained,  the  animal housing was  substandard (possibly resulting in
 compromised mice), and the data  presentation and analysis for the FOB and
 analysis of the respiratory waveforms are of major concern. The lack of
 double blind conditions at Anderson Laboratories could have resulted in
 exaggeration of the severity of response for  the FOB and  the respiratory
 waveform analyses, which tend to be somewhat subjective in nature under
 ideal conditions.  Fu therm ore, the  inadequate  housing of  the mice at
 Anderson Laboratories could have resulted in some change in their health
 status, perhaps increasing susceptibility to even low  levels of  chemicals
 emitted by the heated carpets or,  more likely, to some combination of these
 emissions and stress /restraint. However, this conclusion cannot be supported
with hard evidence, since no necropsy was performed after exposure nor was

-------
 there any provision for sentinel (colony control) animals in the Anderson
 facility protocol.
 SPECIFIC CONCERNS
      Double Blind Nature of the Study
      One of the most important conditions of the study that must be
 maintained is its double blind nature, especially since some of the bioassays
 tend to be subjective. To this end, and in both laboratories, a sample custodian
 received the  carpet samples and loaded them into the source chamber. The
 chamber was then taped so the carpet was not visible, and this  source
 chamber was transported to another area for connection to  the exposure
 chamber. Thus, theoretically, the technician actually perfoming the exposures
 should not be aware of whether the exposure was to any carpet emissions or
 was a sham control.
      At EPA, the individual performing the exposures was  not the same
 individual  who performed the bioassays. Furthermore, the technician who
 attached the  source chamber to the exposure chamber was not the same
 individual who performed the actual  exposures. Thus,  the  individual
 analyzing the data was unaware of the exposure being performed, except for
 any suspicion based upon response. However, in a number of cases, the sham
 exposure resulted in greater responses than those noted with carpet samples
 in the source chamber, which would serve to suggest a lack of bias towards
 exaggeration of responses to carpet samples.
      At Anderson Laboratories/ as at EPA, samples were received and loaded
 by the sample custodian. However, only one other technician was responsible
 for performing pre-exposure screening, for connecting the source chamber to
 the exposure chamber, for  conducting the exposures,  for obtaining the
 biological data, and generally also  for  rating the FOB and scoring the
 waveform  respiratory data. There was, therefore, opportunity for  this
individual to know whether the source chamber was loaded with carpet or
 was a  sham  exposure. This had the potential to  bias the data analysis.
Furthemore,  a TVOC monitor was used after the  exposures by the same
technican that conducted the exposure, which provided this individual with
additional opportunity to know whether  the exposure was sham or carpet,
since the carpet exposures were characterized by higher emissions than the
                         PR-

-------
 sham exposures. No on-line monitors were used by EPA during or after the
 exposures; all such measures were performed separately.  Based upon the
 above,  it is my conclusion that the study as performed at Anderson
 Laboratories was dearly not double blinded.

       Measurements of Sensory and Pulmonary Irritation
       Changes in respiratory rate were monitored by computerized systems
 in  both laboratories. However,  the waveform  analysis  is  somewhat
 subjective. From discussions, it was noted that the technician at Anderson
 Laboratories would occasionally adjust the gain or sensitivity of the recording
 device,  which would  serve to change the apparent scale of the waveform
 tracing.  This change in gain was not always noted on the recordings, and had
 the potential to result in conclusions of exaggerated responses. Futhermore,
 the technician would stop and start the recorder during the measurement
 period; any shift in baseline would not be known with such a procedure.
       Ideally, all respiratory tracings obtained at both EPA and Anderson
 Laboratories should  have been read by readers at both sites, so as to provide
 some inter-laboratory comparison. From discussions, it was concluded that
 the reader from  EPA did look at some tracings obtained at Anderson
 Laboratories and found reasonable agreement when tracing scales were not
 changed during recording. However, it was also noted that when both readers
 did not agree, that the Anderson Laboratory reader tended to rank the effect as
 more severe than did the EPA reader. As indicated above, the lack of double
 blind conditions may have affected conclusion as to the degree of severity of
 response.
       At EPA, respiratory waveforms and rates were recorded during the
 entire period of the exposure, as well as in pre- and post-exposure periods. At
 Anderson Laboratories, tracings were recorded only during discrete intervals
 during these times. There were, for example, three such periods during each
 animal exposure period. Furthermore at EPA, all breaths were analyzed. On
 the other hand, at Anderson Laboratories, the tracings were scanned and only
 series  of breaths that met some criterion, which is  not  dear to me, for
 moderate to severe changes were analyzed. Thus, the  database at EPA was
larger, and provided a better basis for determination of any change due to
toxicant exposure.

-------
      Presentations by Anderson Laboratories indicated that sham control
 exposed animals consistently had scores of zero for all parameters, indicating
 no effect compared to pre-exposure levels.  On the other hand,  control
 animals at EPA did show changes from pre-exposure levels, which in some
 cases were greater than those following carpet emission  exposures. The low
 control levels for Anderson would further serve to exaggerate any response
 seen  following carpet expousre. Furthermore, in my experience,  there are
 always some control animals that show some response.  If such animals are
 removed  from the study, it would further serve to exaggerate effects in
 toxicant exposed animals.

      Animal Housing Facility/Animal Health Status
      The animal  housing facility at EPA met appropriate standards. The
 facility at Anderson Laboratories did not. This latter  consisted of a separate
 smaller room (about 12 ft x 12 ft) within a larger laboratory room in which
 exposures were performed. The relative humidity and  temperature within
 the housing room was  not rigidly controlled.; a  through the wall air
 conditioner was apparently used for some ventilation. Airflow was from the
 laboratory into the animal room, and then out an exhaust This is opposite
 from  what should be maintained, namely positive pressure  within the
 animal housing room driving air from the animal quarters into some other
 space. Under the conditions at Anderson  Laboratories, any contaminants,
 chemical or biological, present in the larger laboratory room would be drawn
 into the animal quarters. Since the mice were housed for  at least one week in
 this facility prior to their use, it is quite possible that  their condition was not
 the same as that of the mice properly housed  at EPA. But since no  sentinel
 animals were  necropsied at Anderson Laboratories, any adverse effect of
housing in their facility is not known. However, it is possible that the mice
may have become hypersensitive to any low level carpet emissions, or more
likely to a combination  of stress plus these emissions, due to some pathogen
or other airborne contaminant entering the housing quarters.
      All  animals  exposed at EPA underwent a  necropsy. However,  those
exposed at Anderson Laboratories were not subjected to a valid  necropsy.
Thus, in the latter case, the cause of death following  exposure to carpet
emissions is unknown, and  the health status of the animals compared  to
those  at EPA is unknown. This lack of information is  a major problem  in
                         PR.-B

-------
 attempting to understand the differences in responses obtained at the two
 study sites.

       Room Air v. Zero Air/Carpet Water Content
       Air entering  the  source chamber,  and  eventually the exposure
 chamber, was room air at Anderson Laboratories and humidified zero air at
 EPA. From discussions at EPA, it was determined that the air at Anderson
 Laboratories had an RH of 30-50%. This is comparable to that used at EPA,
 which was actually lower than expected. Thus, differences in humidity of air
 entering the experimental system  is likely  not a factor accounting  for
 differences in biological response.
       During discussions at EPA, a suggested possibility for such differences
 was differences in water content of the carpet samples. In order to account for
 biological response differences,  all of  the  samples used  at Anderson
 Laboratories  would  have had to have a greater water content than the
 samples used at EPA. Based upon the sampling scheme used to obtain carpets
 for testing, the  probability of this  occuring is essentially nil. Thus, it is
 unlikely that  differences in moisture content account for differences in
 biological responses between the two  laboratories.

 RECOMMENDATIONS
       There are various routes which may be taken to attempt to resolve the
 apparant discrepancy between results in the two laboratories. One approach
 would be to have the study repeated by another, independent laboratory, but
 this would be quite difficult, since it would also have  to be repeated at EPA to
 obtain some baseline for comparison.  It may be better to attempt to determine
 the reasons for differences in response. This could be done by having EPA
 personnel together with Anderson personnel repeat the study at Anderson
 Laboratories with  EPA exposure equiptment, EPA  double  blind study
procedure  and Anderson mice, which would under complete necropsy
following each exposure series. This would go a long way to help resolve the
apparent "disprepancy" in results of the two laboratories.

-------
 Review of EPA and Anderson carpet experiment*

 Harriet A. Burge

 Based strictly on the quality of the report* (including description of
 tests, results, discussion,  and quality control plans) and on the post
 exposure pathology data from EPA,  one would have to place more
 confidence in the EPA results than in those of Dr. Anderson's lab.
 However, the negative case is clearly difficult to prove, and positive
 results tend to be more persuasive even when the study designs are less
 rigorous (or less rigorously described).

 The data presented by the  EPA appear to Bake a good case for little or
 no effect in spite of the  fact that total VOCs were elevated in the
 presence of carpet, and eome recognized toxins were measured (although
 in low levels).  It should be noted that we already knew that carpeting
 emits VOCs.  Zt would have been useful for the EPA report to contain
 examples of actual tracings  that demonstrated slight, moderate or
 severe respiratory effects (these were included in Anderson's report).
 Without these,  it is not possible to determine whether or not both
 groups interpreted the tracings in the same way.

 Since Anderson's results differ from those of the EPA,-and no obvious
 reason is apparent, the case continues to be unresolved (i.e.,  we
 don't know whether or not  the carpet causes mouse toxicity).  Zt is
 still possible  that some difference between the systems that controls
 the nature of exposure to  the carpet is responsible for the disparate
 results.   Zt is also possible that some inadvertent action on the part
 of one (or both)  of the investigative groups is controlling the outcome
 of these experiments independent of the carpet exposures.  Z suggest
 that during the next phase,  at least 1 EPA observer attends Anderson's
 experiments,  and that Dr.  Anderson and/or a person she designates
 attend the EPA  experiments.   Z would also suggest that an outside
 observer attend both sets  of experiments (a panelist would be a likely
 choice,  especially if one  of the panel feels especially capable of
 evaluating the  respiratory function tests).  Z would also suggest that
 the  person (at  both sites) responsible for observing the nice and
 recording observations be  blinded to the concurrently collected ambient
measurements, since the temperatures at the bottom of the tank appear
to provide a  clear indication of absence of carpeting in the chamber.
An additional control should be a "no complaint* carpet that did not
produce effects in Dr.  Anderson's lab.

Zf,  following the  next series of experiments, a clear indication should
exist that  exposure to the carpet is causing toxicity in mice, Z would
suggest that the experiments be run under more normal temperature
conditions.   It is true that offgassing can be stimulated by heat.
However,  in the real  world of carpeting, it is probably quite unusual
for  carpet materials  to reach these temperatures in occupied
residential or  office interiors.

With respect to public release of this data, my first choice would  be
not to release  information until the discrepancy problem has been
solved.   However,  since some release will probably be necessary, Z

-------
 would suggaat a carefully wordad atataaant atraaaing that tha  EPA
 •xpariaanta did not daaonatrata an affact uaing aathoda that tha  •xpart
 panal conaidarad appropriata,  but that tha EPA faala that tha  iasua  ia
 important anough to continua taating.

 Spaoific Coaaanta:

 Dr.  Andaraon atraaaaa that tha EPA poat axpoaura traataant ia  diffarant
 and  that thia introducad variation' into tha data collactad.  Sha
 doaan't diacuaa thia furthar.   Killing tha mica for pathology  (aaeuaing
 thia ia tha diffaranca aha aaani)  obvioualy. would pravant obaarvation
 of lata daatha dua  to traatnant,  but would not affaet diffaraneaa
 obaarvad during tha axpoaura axpariaanta.

 Zt ia difficult (without actually aaaing  tha procadura) to iaagina why
 a "low laboratory cart having  4 aidaa" would produca diffarant raaulta
 froa a thraa-sidad  alevatad ahelf in tha  FOB atudias

 Microbiological data:

 A* axpactad,  thaaa  raaultc ara unraaarkabla and provida no inaight as
 to poaaibla aadiatora  of aithar tha "major" affacta aaan by Dr.
 Andaraon or tha Binimal affacta of carpat  axpoaura aaan by tha EPA.  Aa
 •tatad in tha raport,  aicrobial analyaia on aaaplaa collactad long
 aftar allagad axpoaura/conplaint  apiaodaa  nay not (and, in fact,  ara
probably not)  rapraaentativa of that axpoaura.  At tha tiaa of taating,
unlaaa  tha  carpating was supporting activa aicrobial growth that would
ralaaaa  VOC'a,  it ia unlikaly  that, in a atatic ayataa of thia aort/
particulata axpoaura to biological aganta  would occur.

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 Specific comments on the aicrobiology report:

 Pg 5 (also on Pg 8):  The use of the word "significantly" implies that
 •oae statistical tact vac used.  It is antiraly possible for vary email
 consiatant diffarancaa to ba atatiatieally significant, and aultiple
 tasts on thasa sample* could vail hava producad auch significance.
 Actually, all you can say la that tha lava Is appaar to ba siailar.

 Pg 7:  Othar raaaona for the variability batvaan cultura media include
 tha overgrovth by members of tha aucorales on HEX and 2% KEA.

 Z diaagraa that tha cultura  raaulta from R-800-3516 did not changa
 aftar storage.  Gliocladiua  positiva plataa vant from .12 to 1 and
 Trichoderaa positiva plataa  vant froa 2 to 16.  This indicataa a claar
 changa that is not rafloctad in nuabers and points up the fact that
 number* alona ara of little  uaa in this kind of study.  Note that
 Asperglllua glaueua ia no longer a valid species nane, and that either
 the actual species should be determined, or the taxon listed as
 Aspergillus glaueua group.

 The slightly higher levels and larger diveraity of taxa recovered froa
 R-B00-3516 aay also ba due to noraal variance in fungal populations in
 carpet,  or to variance in tha aathods uaed.  Actually, X vould consider
 R-BOD-3S16 to be considerably different than tha other tvo samples.
 Only Cladosporiua is consistently frequent across all three carpet
 types.   R-800-3516 has higher frequencies (by a factor of at laaat tvo)
 for Panicilliua,  Aapargillus,  yeast, Alternaria, Gliocladiua, and
 Trichodaraa.   Z developed the following chart from your data to aafce
 this evaluation.

Panicilliua
Cladoaporiua
Aspergillus
yeast
Rhitopus
Neurospora
Alternaria
Gliocladiua
Trichodaraa
R872-72
24
33
18
4
7
0
4


R-800-1205
Before After
32
26
15
4
0
2
0


22
32
9
0
4
2
0


R-800-3516
Before After (Storage)
72
37
44
11
4
2
6
22
4
74
44
37
7
0
4
9
2
30
Coaparing fungal counts per graa of carpet and par gran of duet is
irrelevant, and gives the  (possibly) erroneous impression that the
current samples contained  fever colony foraing units than thoaa in the
listed literature citations.  Zn fact, tha frequency of Penicillium,
Aspergillus, Gliocladiua,  and Trlchoderaa is an  indication that R-800-
3516 is probably "contaminated."

pg 9:  There is at least one paper in the literature that related dust
recoveries to airborne recoveries  (Cravesen 1978*).  A bigger problea

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 here ia the fact that you measured CPU/gram of carpet rather than par
 gran of duat.  Carpat ia unlikely to become airborne,  and  you hava no
 idea of tha fraction of recoveries that vara from duat in  tha carpet or
 were from fungi and bactaria adharing tightly to  tha  earpat fibara that
 ara unlikaly avar to become airborna.  Thia is why va uaa  duat rather
 than earpat.

 •Grevesen S. 1978. Identification and prevalence  of eulturable
 aesophilic aicrofungi in houaa duat fro* 100 Danish homes.   Comparison
 between airborne and duet-bound fungi.  Allergy 33(5):268-72

 Tha endotoxin part of thia report ia weak.   For example, how was
 endotoxin extracted from tha carpet?  Extraction  method controla  how
 auch endotoxin you get even fron leaa conplex substrates than carpet.
 Haa the aaaay uaed been checked for interference  by other  carpet/dust
 components?  Note that the endotoxin aaaay  ia a bioaaaay that ia  easily
 perturbed by extraneoua materials in environmental samples.   Also, a*
 for bacteria and fungi, it ia irrelevant to compare levela  recovered
 from carpet to level* recovered from duat.   Endotoxin  ia well-known  to
 •tick quite tightly to eurfacea in way* that would be  unlikely to allow
 aarosolization,  but would allow releaae into waahing aolutiona.

 There ie conaidarably more literature on the microbiology of carpet
 duat than ia lieted in the referencea.   Considering the "volatility"
 and  visibility of thia project,  the EPA would be wise  to conduct  an  in-
 depth and critical literature review on carpet research.
                                                                     r
Tables:   What ia the minimum level of aensitivity?  i.e., vhat does
 "below detection limit mean?  Zf thia ia different for each table or
entry, then  it would be better to use 
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                                           Lawrence Berkeley Laborator
                                              1 Cyclotron Road   Berkeley. California 94720
          Energy & Environment Division                (510) 486-4000 • FTS 451 -4000
 June 1. 1993
 Dr. Robert Dyer
 Associate Director (MD-51)
 Health Effects Research Laboratory
 U.S. Environmental Protection Agency
 Research Triangle Park, NC  27711

 RE: Review of Phase 1 of the EPA/ORD Carpet Study

 Dear Dr. Dyer:

       This letter report contains my review comments on the results of Phase 1 of the
 EPA/ORD carpet study. These comments are based primarily on the reports provided
 by the EPA study team and Anderson Laboratories, Inc. (AL) and on the oral
 presentations made at HERL on May 26, 1993. In addition, the group  of reviewers
 separately interviewed the EPA study team and Dr. Anderson on May 27.

       It is my opinion that the EPA team adequately reproduced in their laboratory the
 apparatus and procedures developed at AL to measure the respiratory and  neurotoxic
 effects of carpets on mice. This was accomplished through numerous discussions with
 Dr. Anderson and by reciprocal visits, including one week at AL in which the EPA team
 worked side-by side with the AL technician. The comparability of the apparatus is, in
 part, demonstrated by the temperature data.  The temperature range in the source
 chamber (location Ai) at AL was 32-40° C; at EPA the range was 36-39* C,  The
 temperature range in the mouse exposure chamber at AL was 22-25° C; at EPA the
 range was 22-26° C with one value tt 30° C. EPA made one significant modification to
 the apparatus which was to use humidified zero-grade air as the inlet air for the system.
 This is a justified improvement resulting in a more controlled test environment  As a
 result, the humidities of the inlet air were somewhat different  At AL the range was
 27-58 % RH; at EPA the range was 19-29 % RH. Other differences between the test
systems  were the use of Swiss-Webster mice from different suppliers; behavioral
examinations after every exposure at AL and only after the second and fourth exposures
at EPA; and the use of thinner mouse collars with somewhat smaller holes at EPA.
None of these differences would be expected to have an obvious impact on the ability of
the systems to detect the toxic effects of emissions from carpets.

      The focus  of Phase I of the study was to attempt to replicate the previously
reported AL results by conducting simultaneous experiments at both laboratories using
carpets that had been shown by AL to have severe adverse effects on mice.  The
experiments were  to be replicated  to provide a larger sample size and the  possibility of

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  statistical analyses.  Blinding procedures were to be used at both laboratories to ensure
  that the individuals collecting the data did not know the contents of the source
  chambers.

         In my opinion, the research conducted by EPA was of very high quality.
  Experts from various laboratories within EPA, as well as outside contractors, were
  brought together to participate in the study.  The team consisted of nationally  and
  internationally recognized experts in emissions testing, chemical characterization,
  microbiology, and toxicology.  The animals were properly housed and cared for.
  Sentinel animals were used  to assess the  colonies for sub-chronic disease. The blinding
  procedures built into the study were effective and strictly adhered to. These blinding
  procedures included receipt of the samples by an offsite contractor, loading of the
  source chambers by this contractor, use of separate observers for both the irritation tests
  and the Functional Observational Battery (FOB) that were not present when the mice
  were loaded into the chambers or when the mouse exposure chambers were connected
  and disconnected from the source chambers, and chemical analyses conducted by another
  team using a separate but equivalent apparatus with no mice.  The data for the
  pulmonary irritancy (PI) and FOB  tests were  rigorously analyzed in a manner that would
  tend to increase  the chance of finding false positive results (/.«., the analyses were
  conservative).  Extensive quality assurance procedures were used'throughout all aspects
  of the study, including the use of another offsite contractor to review procedures.

         The same cannot be said about the quality of the research conducted at AL. The
  most serious problem, which could have  had a significant impact on the results of the PI
  and  FOB tests, was the likely breach of the blinding procedures at AL. This breach may
  have started from the time the samples first arrived at AL by Federal Express.  The
  packages were delivered in the afternoon at approximately 3 pm and sat on the
  secretary's desk until the sample custodian arrived at 7 pm. The package for Test 2, the
  first blank, was marked •empty* on the outside by CPSC and not weighted to compensate
 for the weight of carpet.  This package would have been visible and accessible to all
 personnel since the entire facility is quite small. For each sample, the sample custodian
 loaded  the  contents of the package  into the source chamber, taped the chamber to
 conceal  the contents, placed the chamber on t cart, wheeled the cart into the testing
 laboratory, and left  The next morning the laboratory technician started the test.  This
 technician performed all aspects of the test His functions included making the baseline
 sensory irritancy (SI) and PI measurements and then hooking the mouse exposure
 chamber up to the source chamber. At this point, it is quite possible that the contents
 of the source chamber could be viewed through the connecting port on the  source
 chamber. After the one hour exposure period, the technician removed the exposure
 chamber from the source chamber and measured the concentration of TVOC an the
 atmosphere of the source chamber using a simple hydrocarbon analyzer which
 presumably produces a result within a few minutes and provides a readout.  The results
 presented by AL. show a distinct difference between the TVOC concentrations of empty
 and carpet-loaded source chambers. The TVOC concentrations for Experiment B, the
 blank, are reported to be 1.6-2.1 ppm as  methane.  The TVOC concentrations for
Experiment A were 2.4-4.4.  For Experiment  C, the concentrations were 3.7-5.4 ppm.
With carpets, the highest concentrations would occur at the end of the first  exposure.
Based on all of their previous data using the same system (i.f., the analysis of hundreds
                                   PC. -  12

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   — » .*•
                         s =» i   lr.c*oor-
 of samples), the technician would probably know it that point whether the source
 chamber was empty or contained carpet,  Next, the technician performed the FOB.
 Another possible clue that a blank was being tested would be the clean SI and PI tracing
 reported for the blanks. Test 3, another blank, was an inadvertent test of computer
 paper. The results of this test have  not been reported by AL. When AL was informed
 of the sample pairings at the end of the study, AL indicated that their records showed
 that Tests 2 and 3 were not pairs. Another sample  was sent, this time an empty bag
 with the box weighted with paper. However, since AL had been informed of the
 pairings and undoubtedly knew that two pairs of carpet samples  had already been tested,
 it would be easy for them to assume that  this final sample was indeed another blank.

        It is surprising and of some concern that Dr. Anderson did not recognize the
 relatively easy ways in which the blind could be broken at AL and did not  take any
 steps to eliminate the potential problems.

        The extent to which breaking the  blind might have had on the results produced
 by AL is impossible to assess.  However, experience shows that the anticipation of
 results can introduce significant biases into subjective measurements, such as the PI and
 FOB tests.  This as why blinding procedures are used in scientific investigations.

       Such biases cannot explain the extreme behavior effects or the deaths reported by
 AL for Experiments A and C with carpets.  Some other factor may be involved.  One of
 the other reviewers (R. Schelsinger) raised the possibility of sub-chronic disease making
 the animals more susceptible to stress and toxic exposure. Another possibility is  that
 stress induced by the collars and restraint in the plethsmographs  might have made the
 mice more susceptible. J. Tepper  told the reviewers that mice can die as the result of
 having their head shoved through the hole in the collar or from forcing their way out of
 a collar. Interestingly, Dr. Anderson told the reviewers that unrestrained mice exposed
 to emissions from carpets exhibit severe behavioral effects but not death. AL has not
 attempted to determine the cause of death of the mice from their tests.

       It is possible that there is some subtle phenomena occurring that is not directly
 related to exposures  to emissions of toxic  chemicals from carpets. Other than factors
 involving the  source and health of the mice, the major difference between  the apparatus
 at the two laboratories is EPA's use of humidified zero air.  The humidities of inlet air
 at AL were higher than those at EPA, but the typical difference is only about 10 % RH.
 It is difficult  to postulate a mechanism, either biological  or chemical, whereby this small
 difference could have such a dramatic effect

       I reviewed all of the chemical emissions data provided in the reports from
Acurex Environmental Consultants and Research Triangle Institute (RTI).  The multi-
sorbent method  used by both laboratories for the analysis of volatile organic compounds
(VOCs) is appropriate for this application as it measures  a broad spectrum  of compounds
 with high sensitivity.  The DNPH method used for  the carbonyl  compounds is the best
available method for  this class of compounds.  An intercalibration was performed
 between  Acurex and RTI to ensure comparability of the  data. In addition, numerous
calibrations and other quality assurance procedures  were  used by both laboratories for
the chemical analyses.
                                      -13   3

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         The TVOC emissions from both carpet samples were elevated compared to what
  would be expected at room temperature, but still quite low compared to emissions of
  TVOC from "wet* sources, such as adhesives, paints, and other coatings. During  the
  four exposure periods (4 hours total) the total emissions of TVOC were only 4-5  mg.
  This is equivalent to 14-17 mg nv* , which compares to total emissions of TVOC from
  new styrene-butadiene rubber latex carpets over 24 hours of 1-26 mg m-> (Hodgson,
  AT., J.D. Wooley, and J.M. Daisey, 1993,  Emissions of volatile organic compounds from
  new carpets measured in a large-scale environmental chamber, J. Air Waste  Manage.
  Assoc. 43: 316-324). The composition of the VOC samples wts also unremarkable.  Both
  carpet samples were dominated by Cn • Cu alkene hydrocarbons and siloxane
  compounds. The siloxanes were also emitted by the aquarium.  Carpet A  had  higher
  emissions of butylated hydroxy toluene and formaldehyde.  The alkene hydrocarbons
  would be expected to have relatively low toxicity.  Formaldehyde might play a role in
  sensory irritation, but would not be expected to cause behavioral effects or death  in
  mice. In summary, the chemical emissions data do not seem to provide any  clues about
  the cause of the severe effects reported by AL.
                                                          f
        Additional work as required to resolve the differences between the two
  laboratories regarding the PI and FOB results and the deaths.  Firstly, I recommend that
  the raw data be exchanged between the two laboratories.  The investigators may
  interpret the other laboratory's respiratory tracings  differently and, thus, account  for
  some of the differences in the PI results that were observed. The FOB results presented
  by AL could benefit from the statistical analyses available at EPA. It is impossible to
  fully evaluate these  results as they are now presented because of their highly condensed
  summary form. For example, differences among exposures for a test or between
  replicates for a treatment are obscured.  Secondly, additional data obtained by AL should
  be examined.  The issue of reproducibflity  could be assessed by comparing the results
 obtained by AL during this study to their previous results for the same carpets. The
 results of the experiment with paper would provide another control against which to
 evaluate the carpet results. Thirdly, an attempt should be made to determine the  cause
 of death of mice at AL.  Complete autopsies art needed.  Relatively simple  experiments
 could be conducted to evaluate the potential roll of the hole size and thickness of the
 mouse collars in causing  death. Other experiments using known mixtures  of VOCs  could
 be conducted.  Finally, additional tests with carpets and controls could be performed in
 which the blinding procedures were strictly adhered to by both parties.  This might
 involve both AL and EPA teams making simultaneous observations at AL.

       I would focus on  efforts to understand the disparity in the Phase I results  before
 proceeding with additional experiments. If additional experiments still seem warranted,
 they could be conducted  with a limited number of carpet samples in the new all-glass
 chamber as suggested by D. Costa.  It would be of particular value to establish dose-
 response curves for any observed effects. The SI and PI tests should definitely be
separated from the FOB test.  The SI and PI tests should follow ASTM £981 in which •
single exposure  is used since the EPA data suggest that the test procedure  of multiple
restrained exposures produces measurable stress in the mice.  The FOB test should be
conducted with  mice not  restrained by collars to eliminate this confounding  factor.
                                      PC.-I4

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       I recommend that the summary report, "Evaluation of Carpet Toxicity - Phase I,*
by R. Dyer and D. Costa be amended to specifically address the comparison of the
results obtained by EPA and those obtained by AL.  The high quality and the
thoroughness of the research conducted at EPA should be emphasized. It is justified to
conclude that even when all reasonable efforts were made to replicate the apparatus and
procedures used by AL, it was not possible to reproduce any of the results  of AL
showing the study carpets to be toxic to mice.

       I further recommend that EPA sponsor a scientific forum on the issue of carpet
toxicity to mice to include other researchers and organizations who have either tested the
same carpets using similar methods or have experience with these types of tests.  Such a
meeting might generate additional insight into the potential causes of the toxic effects
reported by AL.

       Please contact me if you have any questions regarding these review comments.
Thank you again for the opportunity to participate in an interesting and important
research effort
                                      Sincerely,
                                      Alfred T. Hodgson
                                      MS 70-193A
                                      510-4S6-5301
                                      FAX 486-6653
                                       -   15

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                REPORT TO EPA ON EPA/ORD CARPET STUDY
                         D. E. McMillan
            University of Arkansas for Medical Sciences

      This report is an independent report written by the
 author listed above.  The report will review the  data
 provided to him in written form as well as the data
 presented at the meeting held at EPA on May 26-27, 1993.
 The focus of this report will be on the Functional
 Observational Battery (FOB) data provided by Anderson
 Laboratories (AL) and the EPA; however,  some general issues
 regarding experimental design and conduct of the  experiments
 will be included.

 I.  Quality of the research that was conducted
      A.  Carpet Samples
      The decision was made to test samples from two
                   •
 different carpets about which complaints had been received.
 Although it makes sense to begin testing with carpets
 presumed to be toxic, the study of used carpets is a
 complicating factor.  Even if both AL and EPA had confirmed
 a toxic  effect from carpet emissions, it would not have been
 possible to establish whether the toxicity resulted  from  the
 manufactured carpet, or from contamination during use and
 subsequent  handling of the carpet.   Further testing  would be
required to answer this question.   Since the EPA  was not

-------
 able to replicate the AL findings this has become a moot
 point; however,  in the future it might be appropriate to
 conduct some tests with new samples of the carpets listed as
 suspect to avoid this problem.

     B. AL study
     AL reported large effects in almost all treatment
 groups including the death of 5 exposed animals.  Sham
 exposed animals  showed remarkably few effects, thereby
 establishing a large treatment effect.  There are a number
 of problems with the experiments conducted at AL that
 somewhat  limit the interpretation of their data.  The first
 problem concerns the double blind design of the study.
 Samples were received at AL in the late afternoon and were
 placed by the courier on the desk of a secretary.  It is not
 clear who signed for the delivery, but apparently the sample
 container sat on the desk with no security until
 approximately 7:00 PM at which time the cample custodian
 arrived,  removed the sample,  placed it in the source
chamber and sealed the chamber.  The sample custodian then
moved the chamber to the test room where it remained until
the next  morning.  The lack of security of the sample to
this point allowed a number of opportunities to break the
blind.  However, assuming that there were no deliberate
attempts  to break the blind, the testing procedure almost
certainly did so.

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      The next morning the technician who conducted all
 subsequent testing initiated heating of the carpet samples
 and placed the animals in the exposure chamber.    During
 exposure the technician measured the rate and patterns of
 respiratory responding of the animals.  During this period
 the technician constantly monitored the animals.   Dr.
 Anderson stated on several occasions how clean (lacking in
 effect) the data were from the control animals, which
 certainly is consistent with the data in the written report.
 Since the same technician conducted the FOB,  after
 completing the respiratory measurements,  it would  be almost
 impossible for this technician not to know at the  time of
 FOB testing whether an animal had been exposed to  carpet
 emissions or sham exposure.  If there was any doubt about
 group identity at this point, the measurement of total
 volatile organic chemicals by flame ionization detection by
 the same technician, would eliminate that doubt.   Thus, it
 seems unlikely that the AL observations for the FOB were
 done according to a blind procedure as specified.
      Another problem with the experiments done at  AL is the
 data analysis.   As I understand their procedure for the FOB,
 on  the  day  prior to exposure to carpet emissions the 8 test
 animals are observed and scored on the FOB.  On the basis  of
 these pre-exposure observations,  a range is established for
 each group.   Subsequently,  the FOB is repeated four times
 after sham  or carpet-emission exposure.   Data are  reported
as number of  animals falling outside the range.  Based on

-------
 the relatively small number of  control observations relative
 to the number of treatment  observations, it would be
 expected that many experimental values would fall outside
 the control range.  This  was clearly the case for the
 treatment groups,  but not for the sham exposure groups.
      Reasons that might account for the difference between
 sham and exposure groups  include an effect of the carpet
 emission exposure, bias due to  loss of the blind, or other
 yet to be determined factors.   The manner in which the AL
 data are presented makes  further detailed analysis of the
 data very difficult.   It  is unclear, for example, whether or
 not the effects reported  by AL  are seen repeatedly in only a
 few animals,  or are seen  sporadically in other animals.  All
 of the data are heavily derived so that the absolute
 comparability of groups before, during and after exposure
 becomes very difficult.   Dr.  Anderson indicated that she
 would  be willing to supply  less derived data for further
 examination of this issue.

     C.  EPA Study
     The EPA study appears  to have been carefully conducted.
The chambers  at EPA were  loaded by outside personnel.   The
FOB was conducted by individuals very well trained in
conducting  this battery and they were not the same personnel
that conducted the other  tests.  There does not appear to
have been much opportunity  for  those conducting the testing
at EPA  to have broken the blind (barring the possibility of

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 fraudulent conduct of the scientists,  which seems most
 unlikely).
      Relative to the rather simple analysis conducted by AL,
 the statistical analysis applied to the data developed by
 the EPA was sophisticated.  The statistical analysis  of the
 EPA data gives this reviewer greater confidence in the EPA
 findings than is possible from the AL  data  analysis.
 However, some of the EPA data also were presented in  a
 derived form (percentage incidence, percent change from
 control, etc.)  that made it very difficult  to determine the
 comparability of control and treatment groups before
 exposure and other details of what actually happened.   I
 also found the 3-dimensional bar graphs that they used for
 the presentation of some data difficult to  follow,  but this
 may be a personal reaction against this form of graphics.
 Clearly, the EPA data could be presented in a form that
 would provide more information than the present version
 does.
      In summary, the general design and conduct of the EPA
 studies appears to be more rigorous than that done by AL and
 from a scientific viewpoint I am inclined to place much
 greater confidence in their data than  that  from AL.
 Nevertheless, there other possible explanations for the
 differences  between EPA and AL findings and since the
welfare of the  public exposed to carpets is at issue  it
seems  clear  that further studies should be  done to determine
the reasons  why AL finds effects that  EPA cannot replicate

-------
 and to  further determine whether or not carpet emissions
 constitute  a public health problem.

 II. INTERPRETATION OF THE DATA
      Using  their criterion of treatment values falling
 outside the range of control values, AL finds evidence of
 sensory irritation and changes in the FOB including changes
 in their groupings of altertness/excitability, neuromuscular
 function and appearance.  It should be noted that the data
 analysis done by AL  (proportion of animals that fall outside
 the control range established by pre-exposure observations
 in the  same animals) gives equal weight to both increases
 and decreases in the magnitude of the dependent variables.
 In some instances the changes that they measured
 consistently moved in the same direction.  In other
 instances both increases and decreases occurred, so that
 their treatment effect was to observe an increase in
 variability of the treatment group relative to the control
 group.   It  is possible that some of these differences would
 not be  significant when analyzed by more rigorous
 statistics.  Although the interpretation of the AL data are
 limited by  the presumption of the broken blind and the
minimal statistical evaluation, it seems unlikely that the
AL effects  would disappear with more rigorous attention to
these problems.  This is particularly true with respect to
the deaths  that they observed in the treatment groups.

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      The EPA investigators found  few significant
 differences.  In some instances the significant differences
 they found were due to changes in the control group over
 tine,  or were found in only one of the two treatment groups.
 On the basis of this analysis the EPA's conclusion that they
 found no differences seems appropriate.  In fact, based on
 the analysis of the data presented, both AL's conclusion
 that there clear differences between sham exposure and
 actual exposure to carpet  emissions and EPA's conclusion
 that there were no differences, are appropriate.  At the
 review,  Dr.  Virginia Moser presented a preliminary analysis
 of the EPA data using the  AL» method of analysis.  This
 preliminary analysis did not account for the differences
 between laboratories.   Obviously, differences in statistical
 rigor  cannot account for the significant death rate at AL
 which  was not observed at  EPA.
     Although I have little expertise in the analysis of
 source materials,  the chemistry data appear to support the
 EPA  findings.   There is no toxic  chemical identified in the
 carpet emissions in an amount sufficient to produce the
 observed  toxicity.   Although the  subject of toxic effects of
mixtures  has not been well studied by toxicologists, the
very low  levels of toxic chemicals make any powerful
synergistic  effects unlikely, although impossible to
eliminate entirely.

III. FOCUS OF THE REPORTS

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      Both  the draft report suppled by AL and that suppled by
 EPA are  appropriately focused on the fundamental issues.
 The AL includes an executive summary, an adequate
 description  of the methods and procedures, and a rather
 brief results section.  Most of the relevant data a
 presented  in accompanying appendices.  After brief mention
 of  the problem that occurred with sample submission, the AL
 report concludes with the obvious, namely that exposure to
 carpet emissions produced large effects in the exposed
 animals  relative to sham exposure.
      The draft report from the EPA is broader, but this is
 not inappropriate.  The EPA study included a great deal of
 additional testing including tests on the identification of
 source emissions, postmortem evaluations, quality assurance,
 etc.   The  additional data required the expansion of the
 results  section of the report as well.  The discussion
 section  of the EPA draft also includes a section that
 speculates on some of the reasons that might relate to the
 reasons  why  EPA was not able to replicate the results
 obtained by  AL.
      In  summary, both draft reports are appropriately
 focused, despite some dissatisfaction of this reviewer with
the details  of the data presentation in both draft  reports.
The bottom line is that AL has replicated their previous
results.   EPA, despite an intensive effort, has not been
able to  replicate the AL findings.  The studies conducted by
EPA are  superior scientifically to those conducted  by AL;
                              8
                         D O -^ *

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 however, it does not seen likely that any deficiencies in
 the AL procedures could account for all of the large
 differences that they obtained.
      Because of the publicity surrounding putative  problems
 with carpet emissions and the economic issues  associated
 with these studies the issue of possible fraud on the  part
 of scientists at AL, or EPA must be raised.  Fortunately,
 there is no evidence that scientists at either institution
 have in any way acted inappropriately.   Visits between
 laboratories have occurred.  Both laboratories appear  quite
 willing to allow others to examine their data  in detail.
 The presumed loss of the blind at AL relates to the small
 size of their operation and lack of sufficient personnel to
 permit the isolation of experiments from each  other and not
 to any intentional attempt to violate the blind conditions
 of experimentation.

 IV.  APPROPRIATE NEXT STEPS
      It is the opinion of this reviewer that EPA cannot
 allow this matter to drop at this time.  Although their
 attempt to replicate the AL results has failed, the issue of
whether or not carpet emissions constitute a public health
problem is not resolved and further testing is required.
The  following recommendations and the reasons  for making
them are offered:

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     A. Replication
     An independent laboratory should conduct an independent
 systematic replication of the data.  Because of the
 political  sensitivity of the issue this laboratory should
 have no association with EPA, AL, the carpet industry, or
 anyone else already associated with the controversy.
 Alternatively,  EPA and AL night conduct a joint study.  For
 example, a replication might be done at EPA and supervised
 by  EPA personnel using AL equipment, staff and animals, or
 vice versa.
     B. Systematic replication
     Any replication should not be an exact replication in
 the opinion of  this reviewer.  A better exposure system
 should be  used  to study carpet emissions.  New carpets of
 the type previously implicated as problem carpets should be
 investigated.   At least one increased emission exposure
 level should be studied.  If EPA failed to replicate the AL
 result because  their methods lacked sensitivity, effects may
 be  seen at a higher exposure level.  Great care should be
 taken to separate respiratory testing from FOB testing so
that the blind  cannot be accidentally broken.  Perhaps
 consideration should be given to the use of different
animals for  respiratory and FOB testing with the FOB animals
receiving  whole body exposure, since the EPA's data seem to
 indicate that the restraint is very stressful and could
contribute to the FOB effects.  The statistical analysis to
be applied to the data should be specified as part  of  the
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 replication attempt.  Consideration should also be given to
 study of emissions from unheated carpet,  since the heated
 carpet may not model most real world exposure.  An
 completely objective behavioral measure should be added to
 the test procedure.  Since experimental bias is an issue in
 these experiments, the addition of a behavioral procedure
 that does not require observer judgments would be a welcome
 addition.  Measurements of spontaneous locomotor activity or
 schedule-controlled responding are suggested.
      C. Laboratory Differences
      Attempts to determine reasons for the differences  in
 laboratory findings should continue to be pursued.  Current
 methods of risk assessment often place emphasis on the
 extreme result, even when conflicting studies are
 scientifically stronger.  Once a report of toxicity enters
 the literature, several negative reports may be required to
 decrease the perception of toxicity.  Therefore, it remains
 important  to continue to explore reasons for the
 differences between labs.  If it could be established that
 something is causing effects at AL that is only remotely
 related to exposure to carpet emissions,  or that something
 is happening at EPA to prevent them from obtaining what are
 real effects of emissions,  the entire issue would be
 resolved.   Some of the hypotheses to explain reasons  why
 laboratory results differed evolved from discussions  at the
review.  These hypotheses include a role for water vapor in
the carpet  samples affecting the toxicity of the emissions,


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a role for conditioned stress during multiple carpet
exposures, differences between laboratories in animals in
the  outbred strain that was used, possible pathogens in the
laboratory, variability in the samples submitted to the
testing  laboratories and others.  These and other hypotheses
should be tested.
     D.  Cost-Effectiveness Considerations
     The reviewer realizes that the suggestions for
additional action may not be very helpful to EPA because
they are broad, expensive and time consuming.
Unfortunately, for the reasons outlined, I see few
alternatives.  If forced to prioritize among these choices I
would suggest that EPA simultaneously pursue as extensive a
systematic replication as funding and time permit with the
replication to be conducted at an independent laboratory.
At the same time investigations into the reasons for the
different results should continue, beginning with a complete
data exchange.  EPA and AL staff should meet to discuss
possible reasons for the differences, prioritize the order
in which the hypotheses about testing are scheduled for
testing and begin to do the appropriate tests.  It is  in the
best interests of both EPA and AL, as veil as the health of
the public and the carpet industry, that these issues  be
resolved as soon as possible.
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