ISSUE PAPER ON T?C

       1>E hEALTH ASSESShCNT DOCUMENT

                    FOR

            CARBON TETRACHLORIDE
                Presented  to:

         The Science Advisory Board
                Prepared by:

    U.S. Environmental Protection Agency
     Office of Research and Development
Environmental Criteria and Assessment Office
            Cincinnati,  OH  45268

      Project Manager:  Cynthia Sonich
               November, 1982

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                             TABLE OF CONTENTS

                                                                      Page
1.   INTRODUCTION	    1-1

2.   STATEMENT OF ISSUES	    2-1

     2.1.   STRATOSPHERIC OZONE	    2-1
     2.2.   SELECTION OF NOELs/LOAELs:   RATIONALE	    2-2
     2.3.   SELECTION OF CARCINOGENICITY STUDY USED IN THE
            UNIT RISK ASSESSMENT:  RATIONALE	    2-3
     2.4.   USE OF MUTAGENICITY DATA AS AN INDICATOR OF
            GENOTOXICITY 	    2-5
     2.5.   SELECTION OF ABSORPTION COEFFICIENTS:  RATIONALE ....    2-6
     2.6.   CHANGES TO THE CARCINOGENICITY SECTIONS OF THE DOCUMENT.    2-8

            2.6.1.   Qualitative 	    2-8
            2.6.2.   Quantitative	    2-8

3.   RESPONSE TO PUBLIC COMMENTS	    3-1

     3.1.   AIR PRODUCTS AND CHEMICALS, INC	    3-1

            3.1=1=   Literature Survey 	    3-1
            3.1.2.   Carcinogenicity 	    3-2
            3.1.3.   Risk Assessment 	    3-3
            3.1.4.   Proposed Alternative Procedure	    3-4
            3.1.5.   Other Comments	    3-6

     3.2.   E.I. DU PONT DE NEMOURS AND COMPANY	    3-9

            3.2.1.   Stratospheric Ozone 	    3-9
            3.2.2.   Toxicology	    3-11
            3.2.3.   Carcinogenicity - Human 	    3-13
            3.2.4.   Unit Risk Estimate for Cancer	    3-14

     3.3.   MUTAGENICITY COMMENTS BY AIR PRODUCTS AND DU PONT. ...    3-17

     3.4.   OFFICE OF DRINKING WATER, U.S. EPA	    3-21

            3.4.1.   General Comments	    3-21
            3.4.2.   Specific Comments 	    3-21

APPENDIX A. ADDITIONAL REFERENCES TO BE INCORPORATED OR CONSIDERED
            FOR INCORPORATION INTO THE HEALTH ASSESSMENT DOCUMENT
            FOR CARBON TETRACHLORIDE 	    A-l

APPENDIX B. REVISION OF CHAPTER 10.  MUTAGENICITY	    B-l
                                     ii

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                                  FOREWORD

    The Health  Assessment Document  for  Carbon Tetrachloride  has been  pre-
pared for the Office  of Air Quality Planning  and Standards by  the  Environ-
mental  Criteria and  Assessment Office,  Cincinnati, Ohio.   For  additional
information or  clarification contact  Dr.  Jerry  F.  Stara,  Director,  ECAO-
Cincinnati or Cynthia Sonich, Principle Author, ECAO-Cincinnati.
                                     111

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                              1.   INTRODUCTION
    The purpose of this issue paper is two-fold.  It is written in an  effort
to focus upon the key  scientific  issues discussed within the document which
are subject  to  judgment mainly because  of  lack of data  and  to clarify  any
judgments which  involve policy  decisions.   Secondly,  it will  address  the
public comments received to  date.   In  this  regard,  this paper will  evaluate
all of the major issues involved in assessing the potential health impact of
carbon  tetrachloride.   Hopefully,   all  questions regarding  scientific  con-
clusions and decisions will be clarified through the statement of issues and
response to public comments.
    The Office of Health  and Environmental  Assessment, in consultation  with
an Agency  work group,  has  prepared  this health  assessment  to  serve as  a
"source document" for  EPA  use.   Originally  the health assessment was  devel-
oped for use by  the Office of Air  Quality  Planning and Standards,  however,
at the  request  of the  Agency  Work Group on  Solvents,  the assessment scope
was expanded to address multimedia aspects.
    In  the  development of this assessment  document,  the scientific litera-
ture has  been inventoried,  key  studies have been  evaluated, and summaries
and conclusions have been  prepared so that  the chemical's toxicity and  re-
lated characteristics  are  qualitatively  identified.  Observed effect  levels
and dose-response relationships are discussed evaluating the  potential toxi-
city of CC1..   Unit risk  estimates for cancer are calculated  to provide  a
media-specific measure of carcinogenicity.   This  information  can  then  be
placed in perspective with observed environmental levels.
                                     1-1

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    Writing of the document commenced June, 1981 and was completed December,
1981. A complete  time  table is provided in Table  1.   Slight revisions were
made prior to its binding in March,  1982 and  subsequent release to the pub-
lic.  Since that time, the  authors  have remained current with regard to new
literature and have reviewed past literature searches in an effort to locate
new or previously overlooked references.  Although additonal references were
uncovered, they  do  not change the  final  conclusions  reached  in  the docu-
ment.  Some of these findings  will,  however,  be incorporated into the docu-
ment prior  to final publication.   Additional references were  cited  in the
public comments  received  and will also  be  considered.   All such references
are listed in Appendix A.
    It should  be noted  that  this  document has undergone  extensive review
both within and outside of  the Environmental  Protection Agency prior to the
request for public comment  and submission  to  the Science Advisory Board.  A
list of reviewers  appears in  the  front of the  document.   The reference to
the  "authors"  of the  Health  Assessment Document  on  Carbon  Tetrachloride
(HAD-CCl^) throughout  this issue  paper includes  those scientists partici-
pating in  the  peer  review  process.   The participating  offices are included
in Table 1.
                                     1-2

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                                 TABLE  1-1

                   Time  Table  for Completion of the Health
                Assessment Document for Carbon Tetrachloride
  Date
               Activity
 6/1/81

 7/27/81


 7/30/81


 8/17/81


 8/81



 8/81

 8/81



11/81


12/81
 1/82




 2/82

 2/25/82
Begin literature search and writing

First Office  of Health  and Environmental
Assessment review begins

Toxic   Substances    Priority    Committee
meeting

First Office  of Health  and Environmental
Assessment review completed

Environmental   Criteria   and   Assessment
Office-Cincinnati  internal  and  external
review

Office of Research and Development review

Second Internal Review Draft of the docu-
ment  completed for  the  Toxic  Substances
Priority Committee

Second  and final  Office  of  Health  and
Environmental Assessment review completed

Final  document  completed   incorporating
Office   of   Health   and   Environmental
Assessment, Office of Research  and Devel-
opment,  Toxic  Substances  Priority Commit-
tee,  Environmental   Criteria  and  Assess-
ment  Office  internal  and  Environmental
Criteria  and   Assessment  Office  external
comments

Office  of  Public  Affairs  approval  and
clearance  for  printing  as  a  draft  for
public comment

Final changes made to the document

Final  document  submitted  to  Office  of
Health  and Environmental  Assessment  for
signoff
                                     1-3

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                             TABLE 1-1 (Cont.)
  Date                                           Activity


 3/82                             Document  printed by the  Center  for Envi-
                                  ronmental Research  Information

 4/26/82                          Federal  Register  notice of  availability
                                  and request for  public comment

 7/7/82                           Public comment period ends

12/9/82                           Science Advisory Board  and public comment
                                  review meeting
                                    1-4

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                          2.  STATEMENT OF ISSUES
2.1.   STRATOSPHERIC OZONE
    The main  issues  concerning  the relationship between  CCl^ emissions  and
stratospheric ozone are:
    1) does CC1.  contribute to the depletion  of the ozone  layer?
    2) is the ozone layer presently being  depleted?
    3) what are the  actual  health and environmental effects attributable  to
       depletion of the ozone layer?
Since none of  these  questions can be  definitively answered,  this topic  be-
comes an issue.
    In theory, laboratory  evidence indicates that  it  is  most probable  that
CCl^ can contribute  to  ozone depletion.   However,  it  is  not  known what  the
net effect of COL  is  on stratospheric  ozone  nor of  the  combination of  a
number of  volatile pollutants such as methyl chloroform,  CFC-11,  CFC-12  and
CCl^  for  example.   Furthermore,   the  data  are inadequate  to  conclusively
indicate that depletion of the ozone layer is presently occurring.
    The authors  of the  HAD CCl^  recognize  that ozone depletion  cannot  be
defined as a present problem.  However, in keeping  with the Agency's  mandate
to protect the environment for present and  future generations,  the  authors
are acting conservatively  by recognizing  a potential  problem  area if it  is
allowed to go unchecked.
    Thus,  it is recommended  that  all  factors  contributing to  ozone depletion
be examined.   Once sufficient data are obtained,  the  issue can be  re-exam-
ined  ana  the decision can  be appropriately   revised.   However,  it is  pres-
ently maintained  that  it is  not  known if depletion of  the  ozone layer  is
occurring  but  if  it were  to occur (as the  laboratory data suggest),  there
exists the potential for the following primary effects:
    1) increased incidence of non-melanoma skin cancer in  humans
                                    2-1

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    2) possible  increased  incidence  of malignant  melanoma skin  cancer  in
       humans
    3) possible crop yield reductions
    4) possible killing of marine organisms.
    This position requires a  revision of the document as  presently  written.
The main reason  for revision  is the use  of  additional data published  since
December, 1981 and  reviewed  more thoroughly  since March,  1982.   The  appro-
priate sections of  the document  will be revised to indicate the  theoretical
nature of the problem and its possible effects.
2.2.   SELECTION OF NOELs/LOAELs:  RATIONALE
    The  studies  summarized in  "Table  14-1.   Dose-Related  Toxic   Effects  of
Carbon Tetrachloride on  Humans  and  Animals," includes all  studies available
for review which provided  information on dose, exposure duration, test ani-
mal and  effect(s).   The  summary table:  "Table 14=5. Reported  No-Effect and
Low-Effect Levels  for Toxicity  of  Carbon Tetrachloride"  is extracted  from
Table 14-1.  Selections  were  made when possible,  for each species  and  each
exposure duration  (acute,  sub-chronic  and chronic)  for those  studies  pro-
viding a NOEL (no-observed-effect level)  or  NOAEL  (no-observed-adverseeffect
level) and corresponding LOAEL  (lowest-observed-adverse-effect  level).   When
multiple studies were found on  the  same species for the same exposure  dura-
tion, the  study  providing the  highest NOEL  (or NOAEL)  or lowest LOAEL was
selected.  For example,  as noted in Table  14-1,  Korsrud  et  al.   (1972)  re-
ported  increased liver  fat,  increased liver  weight   and increased  liver
enzyme  levels  in  rats  given a  single  dose  of  40  mg/kg (CC1.  per  body
weight)  by  ingestion.   Murphy  and  Malley (1969)  reported similar  effects:
increased  liver  weight  and  fatty  infiltration and  some  liver  necrosis  in
rats  given  a single  dose  of 1600  mg/kg (CCl^ per  body  weight) by  inges-
tion.  The Korsrud et al. (1972) study  is included  in Table 14-5  rather than
                                     2-2

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the Murphy  and Malley (1969) study  since effects were  observed at  a  lower
oose, hence, it is the lowest-observed-adverse-effect level (LOAEL).
    Only oral  and  inhalation exposures are considered because they are most
useful  for  risk assessment.   One dermal exposure  study  was  found in  the
available literature providing the appropriate  dose  and  exposure information
(Kronevi et al.,  1979).   However,  there exists  no approved methodology  to
extrapolate from the  dose and effects observed following a  dermal exposure
in  animals  to corresponding  dose and  effects  in humans.  Studies adminis-
tering  CCl^ via  intraperitoneal, subcutaneous,  intratracheal and  other  in-
jection routes though important  in the qualitative determination of effects,
are not useful for quantitative hazard assessment.
2.3.   SELECTION  OF  CARCINOGENICITY  STUDY  USED  IN  THE  RISK  ASSESSMENT:
       RATIONALE
    Six positive animal  carcinogenicity  studies  were  considered for use  in
determining the unit  risk estimate  for the  carcinogenicity  of  CCl^ because
they contained sufficient dose and exposure  information  on the  test animals.
These were  the mice studies by Edwards et al.  (1942) and the  NCI (1976),  the
study on rats  and  mice  by Weisburger  (1977),  the rat  studies by Reuber  and
Glover  (1967) and the NCI (1976) and the  hamster  study by  Delia  Porta et al.
(1961).
    Weisburger  (1977) tested CCl^  by  oral   intubation  in  Osborne-Wendel
rats  and B^C-F,  mice  of both  sexes.   However,  the  study was  not  used
since the author  did not  report the  low dose but  rather only  the maximum
tolerated dose for each  species and  sex, and also did not  report  percent
survival.   Delia  Porta  et  al.  (1961)  orally administered  CC1.   to  Syrian
golden hamsters.   It is the only report found  in  the available  literature  of
the  induction  of  tumors in  hamsters  by CCl^.   It is not  used  for  risk
assessment  since the  researchers provide no  information on  control  animals
                                     2-3

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and because  of the  small  number of  animals  in the  study (10  of each  sex
originally, 5  of  each sex surviving to  the  end of the  experiment).   Reuber
and Glover (1967)  administered  CCl^  by subcutaneous  injections  to  inbred
Buffalo male and female rats.  This study cannot be used for  risk  assessment
due to the inappropriate  route  of exposure since the mechanism  of distribu-
tion  is  dissimilar to that  of  the oral route and subsequent  distribution.
The NCI  (1976)  performed  a bioassay  of  trichloroethylene in which CCl^  was
usea as the positive control.  Osborne-Mendel  rats of both sexes were admin-
istered CCl^ via  oral gavage for 78  weeks.  Although this study is  used by
the National Research Council in determining  the  carcinogenic  risk  assess-
ment  for  CCl^ due  to the dose  levels  used  and the  appropriate  length  of
the study, it  is  not recommended here to use  this  study because of  the  low
survival  rates and the low  absolute  incidence  of hepatocellular  neoplasms
(< 535).   This  low incidence  may possibly be  the result of the  resistance
of this rat strain to chlorinated hydrocarbons.
    Fortunately, two carcinogenicity  studies are useful  for  risk  assessment
of  CCi^.   Edwards et  al.  (1942)  administered  CC1,   via stomach  tube  to
inbred strain  L mice.   The mice were  given  46 administrations  of  CCl^  over
a 4 month period  (2  or  3  times  per  week) and found to  be highly susceptible
to the induction of  hepatomas.   The NCI (1976) performed a bioassay  on  tri-
chloroethylene  in  which CC1. was used  as  the positive control.   Male  and
female  B C,F,   mice  were  given  CCl^  by  oral  gavage  for  78  weeks  (5
times per week).   Both  sexes  were found to be highly susceptible  to  hepato-
cellular carcinomas.
    In  the final  selection   of  a  study for  use  in  the carcinogenic  risk
assessment, all  aspects of  the  studies under consideration are  examined.
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Both the  Edwards et  al.  and  NCI studies  orally  administered  CCl^.   Both
used chronic  exposures.   However, the  NCI study  is  chosen for  use in  the
risk  assessment for  CCl^  in  this  document  due  to  the  more  appropriate
length of exposure (16 weeks vs. 78 weeks).
2.4.   USE OF MUTAGENICITY DATA AS AN INDICATOR OF GENOTOXICITY
    Included inthe original  scope  of this document was  a discussion of  the
hypothesis of  some  researchers, that CC1,  causes cancer by a  non-mutagenic
(possibly threshold*) mechanism although it has also been stated  that avail-
able animal  data do  not conclusively  define CC1.  as  being  non-mutagenic.
Nor does  the  available  literature  conclusively  define  CC1.  as  genotoxic.
This has become  a controversial issue primarily since the evidence  of  muta-
genicity is inconclusive  with regard to a carcinogenic  mechanism.   However,
it was  decided to review all  evidence  indicating that  CCl^ may cause  can-
cer through a mutagenic or non-mutagenic mechanism.
    Under the  non-mutation  hypothesis,  one could  postulate  that only  those
levels  of  CC1.  that  induce  organ toxicity are  likely   to  pose a  carcino-
genic risk to  humans.   However, with current  data available to us  as  indi-
cated in  the  mutagenicity  chapter,   our  present  conclusion  is that these
studies do not provide a conclusive  judgment  on the mutagenic  potential of
carbon  tetrachloride.   Furthermore,  some  binding studies  show  that   CCl^
metabolite(s)   interact with  macromolecules  (e.g.,  DNA)  in both in  vitro and
in  vivo  systems  which  are suggestive   that CC1. may be genotoxic.    It
*The  term "epigenetic" has been used to describe  those chemicals that cause
 cancer but do not cause genetic damage.   The term has been used to also im-
 ply a threshold.  Some toxicologists  believe that chemicals which only pro-
 duce tumors at toxic dose levels are also epigenetic  carcinogens.   There is
 considerable  controversy  over the  use of  the term  epigenicity when des-
 cribing carcinogenic mechanisms.   Because of this confusion,  the term "epi-
 genetic" will either be deleted or better defined throughout the HAD-CC14.
                                     2-5

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is noted  that  although several researchers  maintain  that toxic effects  are
concurrent with liver tumors, it has not been established that  tissue  damage
is a  necessary  precursor to  CCl^ carcinogenesis.   Thus,   it  is  presently
recommended that "... further investigation, particularly in regard to geno-
toxic potential,  is indicated  to elucidate  the  carcinogenic  mechanism  of
action for carbon tetrachloride."
    Thus, the position in the  document  following thorough review all  of  the
literature to date is that "... the  evidence is inadequate to  conclude that
carbon  tetrachloride  is  not  genotoxic."   A  discussion  of  the  specific
studies leading to this conclusion is provided in  section 3.3.  of  this issue
paper.
2.5.    SELECTION OF ABSORPTION COEFFICIENTS:  RATIONALE
    The decision to use a 40%  absorption coefficient for exposure  via inha-
lation is based on two studies and one report:
       30.4% (McCollister et  al.,  1951)
       57-65% (Lehmann and Schmidt-Kehl,  1936)
       30% (Stokinger and Woodward, 1958).
    McCollister  et  al.  (1951)  investigated the  absorption of CCl^  by  in-
halation  using  Rhesus monkeys.    Three  female  monkeys inhaled  99.9%    C-
labelled  CC1.   vapor  at  an  average  concentration  of  290  mg/m3  for  139,
300 or  344  minutes.   By  calculating the difference between inhaled and  ex-
haled air, the researchers concluded that the monkeys  absorbed  an  average of
30.4% of the total amount of CC14.
    Lehman  and  Schmidt-Kehl  (1936)  studied humans exposed  to  CCl^ via  in-
halation.   In  separate experiments,  individuals  (number  unknown)  were  en-
closed  in  a room of  C£L  vapors  for varying  amounts  of time.  The percent
CC1.   absorbed  was calculated from the  difference between the  concentration
of CC1.  in  the inhaled  air and  the  amount  found in  the  exhaled  breath.
The reported range was 57-65%.

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    Stokinger and Woodward  (1958)  report an "accurate" absorption  factor of
30% via inhalation.   However,  their conclusion is not referenced.
    Although  done  on  monkeys,  the  McCollister  et  al.  study is  the  best
available.   The  Lehmann and  Schmidt-Kehl data  are  excellent  as work  done
over 50 years ago.   However, in the context of what  we  know  today,  there are
serious drawbacks both in  the  assumptions that  were made  in deriving  the
57-65%  uptake data  and  in  the  experimental  procedures  that  were  used.
Specifically, but  briefly, 1)  it  is highly  unlikely that  an  equilibrium
between alveolar air and blood  will  be established within a 30 minute expo-
sure period; 2) the  10 m3 chamber  used  for  these experiments  is  rather
small; 3) only two subjects volunteered  for these exposures; 4) the analyti-
cal methods  used lacked the sensitivity  of today's methods.  The  coefficient
reported  by  Stokinger  and Woodward,  by  their own admission,  was meant  for
use in the  emergency  situation.  Although they  do not reference their  con-
clusion, it does reflect the results of the McCollister et al.  study.
    Generally, when  human data are available and  good,  they are used in risk
assessment,   in  this instance,  however, problems have been associated  with
the human data.   The monkey data  are better.  However,  in  an effort to be
most protective yet realistic, a compromise was made to arrive at an absorp-
tion coefficient for  exposure  via  inhalation of 40%  (the  tradeoff  being
slightly  more protective  than  the good animal experiment would indicate yet
not as strong"as the poorer human data  would indicate).   The  Stokinger  and
Woodward  report  is not  overlooked  but is used as  supporting evidence of the
results reported by  McCollister et al. and may in fact be  reflective of it.
                                     2-7

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    The decision to use  a 100% absorption  coefficient  for exposure  via  in-
gestion is  based  primarily on the  lack of sufficient  data.   One  study  and
one report are cited:
       80% (Marchland et al.,  1970)
       50% (Stokinger and Woodward,  1958)
Again, Stokinger and Woodward do not reference their  conclusion  and no paper
reporting a 50% absorption coefficient via ingestion could  be found  in  the
available   literature.    Studying  the   distribution  of   CCl^   in   rats,
Marchland et  al.  (1970)  noted that at  least  80% of the  ingested  CCl^  was
eliminated within 10 hours via the  lungs  in control animals.   This indicates
that at least 80%  of the  CCl^ was  absorbed.   Thus,  in an effort  to be most
protective and in light of the available  data, a 100% absorption coefficient
for exposure via ingestion is  used.
    It is obvious from  this discussion that the supporting data are scanty.
Nevertheless,  such interpretations  and subsequent conclusions must  be made
and  the  resulting  assumptions used  to  perform present  day risk calcula-
tions.  It is hopefully understood  that  as  additional data become available,
these coefficients should be improved.
2.6.   CHANGES TO THE CARCINOGENICITY SECTIONS OF THE DOCUMENT
2.6.1.   Qualitative.  The only change necessary to  the qualitative section
of the document with  reference to the carcinogenicity  of  CCl^  is  to incor-
porate the  IARC classification  scheme  as  related to  CCl^.   This will  be
incluaea as a part of the summary section of Chapter 11.
2.6.2.   Quantitative.   It is  recognized  that  the  Appendix  to  the docu-
ment:  "Unit  Risk Estimate for Cancer" should  provide additional explanation
ana rationale for the method  employed.   As  suggested  by the Science Advisory
Board through their discussions at  the September,  1982  meeting reviewing the
"Quantitative  Carcinogen  Risk Assessment," the  Carcinogen Assessment Group
                                     2-8

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has prepared such an expansion for its  "Evaluation of  the  Carcinogenicity  of
Acrylonitrile."  The changes  so  made to  the  Health  Assessment Document for
Acrylonitrile will be incorporated into the CCl^ document as appropriate.
    The information  appropriate  for  inclusion to the  CCl^ appendix is  con-
tained within  the  Quantitative Estimation section of  the Evaluation of the
Carcinogenicity of Acrylonitrile  (November 2, 1982).   This includes a  dis-
cussion of the procedures for  the  determination  of  unit risk and a  descrip-
tion of the low-dose extrapolation model.  Methods of  data selection as  well
as the actual  calculation  of the unit  risk  estimates and  their  interpreta-
tion  will also be  included.  Alternate  approaches  and their  consequences
will be discussed.   In  order to provide  perspective,  a section  on  relative
potency will  be  included.   The purpose of this section  will be to compare
the  potency  of  CCl^ with  other carcinogens  including  the other  carcino-
genic solvents.  A histogram representing the frequency distribution of  the
potency indices of  54 suspect carcinogens  will be included  and  accompanied
by the data in tabular form.
    The  quantitative evaluation  of  the  Carcinogenicity  of CCl^   has  been
incorporated  into  an appendix at the  end of  the  HAD-CCl^.   It is  recog-
nized that the Science Advisory Board  has suggested,  in their review of the
other solvent documents, to  incorporate the appendix  into  the document.   The
revised CCl^  appendix  can be  incorporated  into the Carcinogenicity chapter
of the document.   However,  it is left as an appendix  for review by the  SAB.
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                       3.  RESPONSE  TO PUBLIC COMMENTS
3.1.   AIR PRODUCTS AND CHEMICALS,  INC.
3.1.1. Literature Survey.
    "The  bibliography  appears to  be reasonably  complete.   Some  additional
    recent references which could be of interest are listed  below ..."
    The additional  references  provided  on environmental measurements,  envi-
ronmental fate and  biochemical data are appreciated  and will  be incorporated
or considered for incorporation  into  the  document as  appropriate.   Articles
disputed as inaccurate or obsolete may not be used although it  is  within the
scope to provide as complete a document  as possible.
    "The discussion on natural sources is  incomplete.   Bacteria and algae in
    the  sea,  volcanoes,  and  other  natural sources are known to  generate
    halocarbons."  References were provided.
    Some  of  the references cited on  natural sources  will  not  be  included.
The report by Inn et al.  (1981)  discusses gaseous constituents  in  the  plume
from eruptions  of Mount St. Helens.  However,   CCl^  is not  mentioned in the
report.  Increased concentrations of methyl chloride were measured,  but this
is hardly justification for inferring that volcanic eruptions  are  a natural
source for CCl^.
    The report by Singh et  al. (1975) proposes the  formation of atmospheric
CCl^ from tetrachloroethylene.  While this  information should  and will  be
incorporated into  the document  it  will not be used  to identify  a  natural
source.   Instead,   it  will  be  used  to  identify CCl^ as  the  researchers
state,  a  "secondary anthropogenic  pollutant"  since the  tetrachloroethylene
is primarily anthropogenic in origin.
    The  study  by Jacquez and Mukerman  (1979) addresses the  production  of
haloform  precursors,  i.e.,  trihalomethanes,  by  water  pipe  bacterial  films.
Carbon tetrachloride is not normally  considered a trihalomethane  and is not
a by-product of  the chlorination process.  The  authors state that  "—  the
                                     3-1

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major  trihalomethane  specie  resulting from  the chlorination  of  bacterial
films  was  the known carcinogen chloroform."   The report is, thus,  inappro-
priate for inclusion in the
    "The statement  . . .  that the ubiquity of  the substance is an  indication
    of  the  anthropogenic  origin   is  the  result  of  incorrect  reasoning.
    Natural  sources will  tend  toward  ubiquity more  than  will  artifical
    sources.   The  latter  give  more  localized  effects.   See  the  data  of
    Bozelli ... Singh and others for confirmation of uneven distribution."
    The statement  relating  ubiquity to  the  anthropogenic  origin of CCl^ in
the document does  need  to be clarified.  It  was based on  research  articles
Discussing not  only source,  but also atmospheric half-life,  persistence  and
distribution.   It  is the reported  levels of  CC1, which  are an  indication
of its anthropogenic origin.  The statement on page 1-1  will  be  expanded  and
clarified to address this point.
3.1.2.   Carcinogenic! ty.
    "We agree  with the disclaimer  on  pps.  14.18 and  A. 6 (of the
    that the upper bound  risks ... are implausible.   The standard  bioassays
    by NCI  are not described by them  as  being suitable  for  risk assessment
    purposes.  Certainly, this  positive control group dosed  at  deliberately
    toxic levels,  offers no  hope  of  developing  any dose response  informa-
    tion. "
    The disclaimer is not  that the upper  bound risks  are  implausible  but
rather that the upper  bound  of risk is presently regarded as having  limited
plausibility.  This  is because of  the inconclusive nature of the  available
evidence  for  the  mutagenicity  of  CCl^.   The  inappropriateness  of the  NCI
bioassays is not equivalent to  "no  hope."   The information on cancer  mechan-
isms and the dependence  of  such mechanisms on  dose  is admittedly incomplete
and poorly validated.  As a consequence, it is not  clear that high dose  ex-
periments, with concomitant toxic effects,  are truly unrelated to lower dose
carcinogenicity ,  as  the commenter  contends.  Therefore,  as long  as  low-dose
or moderate-dose studies are  unavailable, the  high-dose  studies  will  be used
for risk assessment.
                                     3-2

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    "... carbon  tetrachloride  is a  classic example  of  a nongenetic  (some-
    times  termed epigenetic)  carcinogen.   This  is  substantiated  amply  by
    oata presented  in this  report.   The  chronic effects  are dependent  on
    dose rate (pps.  2.4,  2.6, 8.17); there  are  enormous  sex  and species dif-
    ferences (8.2).   There is a clear  NOEL (8.23) and the chronic  damage  is
    reversible upon  cessation  of dose  (8.21).    The  substance is  not  muta-
    genic  (10.5) nor  teratogenic  (9.7-8),  even though administered at  doses
    that produce maternal toxicity,  and  sometimes  fetal toxicity.   There-
    fore,  it is  clear that tumors arise only after  prolonged  organ-damaging
    treatment, and not as the result of genetic effects.

    The nongenetic "proof" given by the commenter is  only evidence  of toxic-

ity.  Since  adequate long-term studies involving a large number of  animals

exposed at low or medium doses do not  exist,  the argument that  organ damage

is  a  precursor to cancer  is not sustained.   Furthermore,  it  has  not  been

concluded  that  CC1.   not  mutagenic  but   rather  that  the  information  is

insufficient to  allow  any  conclusion to be made  concerning  the genotoxicity

of CC14.

3.1.3.   Risk  Assessment.   Air  Products  provided  a  lengthy  discussion  on

risk assessment.  Some of  the  points  raised will be  addressed  here.   Others

contained  some  misconceptions  in concept,  mathematics,  chemistry  and  logic

and will be addressed in  section 3.1.5.  Other Comments.

    "A  major  failing  of  most  risk  assessment efforts in  the  past has  been
    the attempt  to  use a  mathematical  exercise  as  the  only  component,  ig-
    noring the available scientific data which  should modify the rote appli-
    cation of a formula."

    "... the risk assessment 	 from the  carbon  tetrachloride data — used
    only one  data point  from  an NCI  positive control  rat  feeding  of  that
    material to  develop  a human risk  assessment  ...  The Agency did  attach
    (a) cautionary statement  ...  We believe  this to be  a  proper evaluation
    of  this  attempt  at risk assessment,  and is  appropriate for many  other
    substances as well."

    Perhaps the  most important  statement  made by  the  commenter  is that  a

systematic procedure must  be developed  for incorporating the  many  different

kinds of  biological  information into the  quantitative risk assessment  pro-

cess,  especially  since the  treatment of  carcinogens is so different  from

that of toxicants (i.e., non-carcinogens,  non-mutagens).   Currently,  several
                                     3-3

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subjective judgments must be made  during  the risk assessment, not  the  least
of  which  is the  decision that  sufficient  information  exists  to  term  the
chemical  a potential  carcinogen.   Unfortunately,  due  to the  poor  under-
standing  of cancer  mechanisms,  metabolic  pathways,  species differences  and
due to  the lack of  adequate  moderate dose  cancer studies, these  judgments
(which are only  some of the sources  of uncertainty), must be made.   Other
sources of uncertainty  are  the  quantitative procedures used, and the  origi-
nal judgments or assumptions made  by  the  researchers.  Yet regulation  is  in
order if a substance has been shown to cause cancer.   The  Agency is continu-
ally working on new approaches and welcomes  additional information  on  cancer
and toxicity  risk assessment  techniques.   The  commenter's only  suggestion
was not to act at all.
    One interpretation  of  the  negative comments  is  that the many  decisions
and judgments, along with the many types  of information used in  arriving  at
the risk  calculation are evidently obscured and need to  be  stated in some
explicit manner.  An attempt was made,  however,  the extent of the  questions
raised implies that  still  more  detail is  needed.  As noted in  section 2.6,
additional discussion and explanation  will be incorporated  into the  document.
3.1.4.   Proposed Alternative  Procedure.   The  proposal  by  Air  Products  is
given in  two  steps.   The first  deals with how  to decide if a chemical  is a
potential human carcinogen.  The second deals with  the  method of  risk cal-
culation once it is decided that the  chemical  is a potential  human carcino-
gen.  The  first  step is essentially a  recommendation for a sequential pro-
ceoure with all decision points  and criteria clearly  defined:
    "It is necessary first to validate  the experimental data, and  to  deter-
    mine  its  relevance to humans  ...   It  is  then  necessary  to attempt  to
    understand the mechanism by which the  putative  carcinogen  acted,  geno-
    toxic or non-genotoxic; whether the pharmacokinetics of humans  resembles
    that of the  animal;  whether the  tumor was a  new type  or merely a  (sig-
    nificant?) increase  in  common  types;  and  finally,  whether  epidemiology
    is available to  help set an  upper risk limit or to  modify the  animal
    data.  A  decision-tree  approach  	  is  most helpful in integrating the
    other necessary  data with the bioassay."
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    The proposal has merit.   Much of this procedure  is already followed  by

EPA, although as noted  above,  it is not evident  to  the reader of the  docu-

ment.  This will be clarified in the revised  version  of the  HAD-CCl^.

    The  second  step is basically  the  "NOAEL-uncertainty  factor"  approach

used with systemic toxicants (defined as non-carcinogens,  non-mutagens):

    "If, after a decision-tree  type evaluation of all the  data,  a  decision
    is  reached  that a  substance  is  an  animal carcinogen that also poses  a
    potential hazard to  humans under reasonably  expected circumstances,  an
    extrapolation  of bioassay  data  should  be  made.   This  extrapolation
    should  utilize  all  available  data  and  be  carried  out  to   some  no-
    observed-effect level not  far from the  experimental  limits.  Most  good
    bioassay data  will  allow  reasonably  accurate  extrapolation  to  the  1%
    incidence.    There   are,  however,  several  NCI  bioassays  performed  at
    obviously highly chronic levels  which  are  not  suitable  even for  this
    purpose...   It  is  not  important  which   "model"  is used  for  this  part;
    most fit well and agree  within the data  limits."

    "Once  the  1% (10~2) risk  point and  its  statistical error ranges  have
    been found,  a safety factor of  the desired magnitude  is applied...   This
    is the allowable dose for the experimental animal at the desired risk."

    "This  allowable dose is  then adjusted   for  humans by  multiplication  by
    appropriate  factors utilizing  the  data from  the decision  tree  which
    justified the conclusion that the substance posed  a human risk.   Factors
    greater than one are used when the data  support  a  larger acceptable dose
    for humans than animals,  factors  lower  than  one for the  opposite  cases.
    Factors to be considered include those mentioned above:   type  and hazard
    of  the tumor  in question,  exposure  and  absorption routes  and  times,
    relative metabolism and pharmacokinetics,  saturable repair or  conversion
    mechanism,  and so on.  The  more  data  that are available,  the  more  care-
    fully the final dose can  be set.   This  rewards good science and encour-
    ages data gathering."

    This  approach  is  currently  under investigation   by  the  Agency.   The

specific ideas in the American  Industrial Health Council have  not been con-

sidered  since the  paper was  not  available  when  this  document  was  written.

The  commenter  does not  go  far enough,  though,   in  this  proposed approach.

Some procedure  must exist for  the  usual  situation where the ideal data  do

not  exist.   When  no information  exists for  the   subject chemical  concerning

human or animal metabolism, human or  animal  kinetics,  human carcinogenicity,

or  moderate- or  low-dose-induced  animal carcinogenicity, when  no consensus
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exists on  the  mechanism of  action of a  carcinogen,  and  when  the  cellular
mechanisms for  cancer initiation  and  growth are  not  well understood,  some
approach must be in place to use in regulating a potential carcinogen.
    There  are  other areas  in  this proposed  procedure which  should be  ex-
panded, mainly  involving  the calculations.   The mathematical  areas of  sta-
bility, reliability,  robustness and accuracy all  need to be explored.   The
quantitative effect  of certain decisions must  also  be  investigated.   For
example,  how does the probit model differ  from the multistage?  How does the
maximum likelihooo  estimate differ from  a Bayesian approach?   What is  the
magnitude of change in "acceptable  risk-specific dose" if a 90% or 99%  con-
fidence limit is used instead of 95%?  How should  goodness-of-fit  enter  into
the risk  calculation?  All of  these  issues  and others are currently  being
investigated by  the  Agency.  With some issues,  the 1% response-uncertainty
factor  approach  is  definitely   inferior to  the  low-risk   extrapolation
approach;   with  others,  the  proposed approach  is  a  decided  improvement.
Thus,  this indicates that more investigation is needed.
    In  short,   the  proposed  alternative  approach has merit.   It  can  be
discussed  at  the next methodology meeting but  cannot be incorporated  into
the present document.
3.1.5.   Other Comments.
•   "The statement in Sec.  2 that  carbon  tetrachloride will  fail  to volatize
    if it separates as lower lower layer  under  water is incorrect.   The rate
    of  volatilization will  be slowed,  because of  the  need  for  diffusion
    through the  water, but  it  will not be stopped.  Carbon  tetrachloride is
    not insoluble in water, only slightly  soluble."
    This revision is valid and will be made.
    "The effort  to  determine  the annual  intake of carbon  tetrachloride  from
    realistic data  in Sec. 4.4  is applauded.  Too often  these  calculations
    are based  on unsupported assumptions.  However, we believe that  use of
    U.S. data  on food consumption from the FDA  would  have been more  appro-
    priate, and  that  the  use of Bayonne,   NJ  air data  as typical of the en-
    tire  U.S.  is incorrect.   See the  Bozzelli data   for  other  New  Jersey
                                    3-6

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    sites, ana the Singh data for other  (although probably not  typical)  U.S.
    sites.  Similarly,  the water data probably are biased toward  higher  than
    average levels.  See the  data made  available by  the EPA in  conjunction
    with  the  VOC  in Drinking Water  Proposal  (47 FR  9350)  for other  (still
    incomplete) data.
    The  "typical"  air  data were  not those of New Jersey,  rather only  the
"maximum"  level  was from  New  Jersey.   The  statement on  p.   4-21  will  be
clarified and additional data will be incorporated as  appropriate.
    Several issues  were raised  with regard  to  risk  assessment  which  con-
tained misconceptions and misinterpretations.  These  are discussed individu-
ally below.
•   The commenter states several times that the  risk  assesment  appears to be
    a mathematical procedure which ignores biological  theory and data.
    The section on unit risk estimation  is being expanded in part to explain
more fully  the biological data considered  prior to  the risk  estimation as
well as the information directly used in the risk calculation.
    The  commenter  suggests  that pharmacokinetic  models are appropriate  and
    necessary for quantitative risk  estimation.   In particular, the  comment-
    er states  that  the tissue-carcinogen must be at  least  of second order
    and that it implies a nonlinear dose-response curve.
    EPA  has  found  no information to date which shows  the  carcinogen-tissue
interaction to be  a mass-action chemical reaction  or which shows that  that
order of  a  carcinogen  reaction direclty  indicates  the shape of  the popula-
tion dose-response curve.  When such information  becomes available pharmaco-
kinetic information will be used in the risk assessment approach.
    The  commenter states  that specific information is  not considered  in the
    risk  assessment, namely background rate,  exposure pattern,  time-to-tumor
    data, non-genetic mechanisms and toxicity-based NOELs.
    The  background  rate  is  included  directly in the risk calculation,  as
described  in  the  Federal Register  (45  FR  79351).   Several  proposals  are
being  investigated  by  EPA  for incorporating  directly the exposure  pattern
(including  intermittent  and partial  lifetime  exposure), time-to-tumor  data
                                     3-7

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and non-genetic  or  partially non-genetic mechamisms  into  the risk  calcula-
tions.  No consensus has been reached as of  this  date.   Toxicity-based NOELs
and NOAELs are currently  not used by EPA in cancer risk estimation  because
the NOEL  (or NOAEL)  is  not  statistically  based,  and  further,  because  the
connection between toxic effects and cancer  development is  not at all clear.
    The commenter states  that  the  EPA risk assessment  has no  biological
    foundation.
    In addition to devoting  an entire chapter to  the  biological  issues asso-
ciated with carcinogenicity,  EPA  also  has  demonstrated its concern  for such
factors by choosing  one  of  the few  mathematical  models with  any  supporting
biological theory.   Biochemical  evidence  (interpreted as  kinetic/metabolic
information) is  not  included because of the insufficient data  available to
be of use in the estimation procedure.
    The commenter implies that it is inappropriate  to assume  humans  to be as
    sensitive as the most sensitive animal.
    When  sufficient  information  on  species  metabolism and  cancer  response
exist, then such information has  been used  for study  selection.   Since human
studies on  carbon tetrachloride  carcinogenicity  are  virtually  nonexistent,
the human-animal  sensitivity question  cannot be  answered.  The  conservative
approach is chosen.   It must be emphasized  again  that data are  not  yet suf-
ficient in  scope to allow  quantitative modification of the  risk assessment
procedure.  Desirable  data include:  rates  of production  of  the  active me-
tabolite for different exposure  levels, relation between  circulating levels
ana target  organ concentration,  relation  between  observable tissue  damage
ana cancer  risk, relation  between  intermittent  or short-term  exposure  and
lifetime cancer risk,  and  the differences  between species for each  of these
factors.
                                     3-8

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3.2.   E.I. DU PONT DE NEMOURS AND COMPANY

3.2.1.   Stratospheric Ozone

    3.2.1.1.   REVISIONS —

    The commenter  provided new information  and additional  references  (some
    of which  were released  after the completion  of  the  document) for  in-
    clusion into the document.

    The new information is appreciated.   As  stated  in Section 2.1., informa-

tion contained within these new articles  will be incorporated into  the  docu-

ment.

    "The NAS in 1979  (NAS,  1979b) listed four categories  of effects antici-
    pated  from  increased  UV-B, which, in turn,  would result  from  depletion
    of total ozone.  They were:
    (1)  Increased incidence of nonmelanoma skin cancer in humans.
    (2)  Increased incidence of malignant melanoma  skin cancer in humans.
    (3)  Significant crop yield reductions.
    (4)  Appreciable killing of marine organisms.
       The assessment for three of  these  categories has  changed substantial-
    ly."

    It is  recognized  that  the NAS  assessment  for  melanoma,  crop damage  and

mortality  of  lower marine organisms  has changed.   This change consists  of

the removal of the quantitative estimates of damage contained within the  NAS

1979  report.   Although this  change will  be recognized in  the document  it

shoulo be  noted  that  the removal of  these  quantitative estimates  of  damage

is not equivalent  to  belief in the relative safety of CCl^.   The  danger  of

such  effects  occurring is   still  possible;  however,  the  mechanisms  are

fraught with uncertainties so as to make quantification difficult.

    "Reaction rates and other basic  data in the  computer models  have been
    revised, with  the result that calculated future  depletion when CFCs  are
    considered alone  has  been sharply reduced  from  16.5% to  5-7%  for most
    model  calculations, or to about one-third  the  earlier values.   A similar
    proportinal  decrease  occurs  for  emission scencarios involving  carbon
    tetrachloride."

    NAS  (1982)  estimates of  ozone  reduction are 5-9%,  not  5-7% as stated.

Note that  NAS (1982)  also pointed out  the sensitivity of the ozone  reduction

to  N02,  namely, a  doubling of  atmospheric  N02 leading to  ozone  reduction
                                     3-9

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of 10-16%.  These  ranges  are not exact  nor  are they statistical  confidence
limits.  Along  with the  observation  that atmospheric  NCL  seems  to be  in-
creasing, this adds another  source  of uncertainty to the steady-state  esti-
mate of ozone reduction.  The MAS report is still based on one- and two-di-
mensional models.   Since  three-dimensional  air  pollution  models  exist,  a
comment will also  be  added that future  research should evaluate  the  uncer-
tainty introduced by restricting the models to two dimensions  or less.
    3.2.1.2.   SKIN CANCER TRENDS —
    "With recent  revisions  of calculated  future  ozone  depletion,  it is  in-
    correct to  allude that carbon  tetrachloride  may increase  the  incidence
    of certain  forms  of skin cancer.  While epidemiological  evidence  indi-
    cates that the incidence of skin  cancer  is  increasing, this increase  has
    occurred in  a  period when there  is  no  indication  from actual  measure-
    ments that total ozone is being depleted, nor  is there any  indication of
    an increase in UV-8 ....   Thus there is  no  evidence or rational  basis to
    connect current  epidemiological  trends  in skin cancer  incidence with
    ozone depletion or carbon tetrachloride emissions."
    Although current epidemiological  trends  in  skin  cancer incidence are  in-
conclusive  with  regard  to  ozone depletion or CCl^ emissions,  safety  has
not been demonstrated.  Thus, if any  mechanisms relating sunlight  to melano-
ma are plausible then "may increase"  (as opposed  to  "will increase") is cer-
tainly correct.
    3.2.1.3.   SPECIFIC  LOCATIONS  OF  MISLEADING  COMMENTS  ON  ENVIRONMENTAL
EFFECTS ON CARBON TETRACHLORIDE EMISSIONS — Specific comments were:
    A. Carbon tetrachloride considered as  the only  emission  affecting  total
       ozone,  and  absence of  discussion  of multiple perturbation  calcula-
       tions.
       HAD-CC14 pages 2-2, 5-2,  6-5.
         This comment  is wrong.   In  each  case, the phrase  is "may contri-
         bute," implying uncertainty and  other causes.
    B. Failure  to  distinguish  adequately  between  the  real  atmosphere  and
       model calculation or attribution  of predictive value to model calcu-
       lations .
                pages 2-2, 6-5,  6-6, 6-7.
                                    3-10

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         These pages will  be  revised to reflect  more accurately, the  model
         uncertainties and to  distinguish data from model predictions.

    C.  Use of  early  reports on  effects  of ozone depletion with  inadequate
       mention of subsequent technical revision.
       HAD-CC14 pages 2-2,  4-3,  6-6,  6-7.

         As stated in section 2.1. of this issue paper,  these  sections will
         be so revised.

    D.  Misleading discussion on skin  cancer.
       HAD-CC14 pages 2-2,  4-3,  11-36.

         These discussions  are  not misleading.   The verbage  used on  pages
         2-2 and 4-3  is such that it  reflects the plausibility  of  an associ-
         ation.  The  discussion on page 11-36  is  abstracted from MAS  (1982).

    E.  Lack of perspective on  potential climate effects.
       HAu-CCl4 page  4-3.

         Again,  the   statement  is   "This   might...bring  about   climatic
         changes",  i.e.,  it is plausible.  It is  irrelevant that  in  terms  of
         CFC emissions, the MAS  (1982)  report does  not expect  "important"
         changes in climate.

3.2.2.    Toxicology.
    "The overall effect of  this  selection  (of studies)  is  to  present  carbon
    tetrachloride  (0014)  in  a  light so  as  to make   more  strict control
    mandatory."

    In preparing such documents, the  authors  critically  review all available

literature, make  scientific judgments about  the specific  studies and  draw

scientifically defensible conclusions relating to the health hazard  and risk

assessments for  the  chemical.   The  accusation  of  pre-selecting studies  to

reach a  biased conclusion is incorrect.   The studies are  clearly discussed

and criticized in chapter  8.   The   selection of  studies  for  use  in  risk

assessment is  further defended in chapter  14  and is included as an  issue  in

this paper (section 2.3.).

    DuPont  contends  that  "...   the  chronic  inhalation  study  conducted  by
    Adams (1952) [sic] ...  has not (been)  given  the appropriate balance ..."
    and that "... although conducted  in 1952,  [sic]  the  Adams  study  is sound
    and  stands  today  as  a good  reference  point  in assessing  the subchronic
    toxicity of CC14."
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    The Adams (1950 is the correct citation) study is not described  in  great
aetail for scientific reasons as  noted in the document.  The  data presented
in the Adams  study  are  incomplete, because  numbers  of animals tested,  sur-
viving, or affected are  not given and it is not possible to  determine  what
measurements  were  made  at  different  exposures.   Therefore, we  are in  dis-
agreement with DuPont  that "...  the Adams study  is sound and stands  today  as
a good reference point in assessing the subchronic toxicity  of
    "...  in  controlling for  human exposures  (setting  exposure  limits),  a
    good  portion  of  the data  needs to  be de-emphasized  (rodent  studies)
    while another part  (monkey  studies) needs more  careful analysis.   Here
    is a  good  example of the tenet  that  toxicological evaluations  are  most
    relevant when the information obtained  from animal surrogates  is in  a
    species which handles the compound  in a manner  most like man.   In  this
    case we have the data (granted the information in monkey and man is  con-
    siderably less complete than  that in rodents) and  should be willing  to
    use it."
    The suggestion to use the monkey studies leads  one to believe  that  the
commenter  does not  understand   the   quantitative  issues  involved  in  risk
assessment.  The authors agree  that  "...  the monkey may be the  appropriate
animal for extrapolation to  man."  However,  the data  on monkeys exposed  to
CC1   are  insufficient  in  this  case.   Different monkeys  were tested at  3
concentrations:  2  female  monkeys  tolerated  100 ppm  CCl^  via  inhalation
for 232 days;  2 male monkeys tolerated 50 ppm  CC1.  via inhalation  for  277
days;  1 male monkey tolerated 25 ppm CC1. via inhalation  for 212 days.   It
is not clear if five  monkeys were tested  in total or  if  they are  the  only
monkeys tolerating  the  doses.  Nevertheless, these  data  are hardly  suffi-
cient for risk assessment.
    Roaent data are used almost exclusively to  predict the effects  of  CCl^
in man  because they  are the most appropriate.   Rationale is  provided  in
chapter 14 of  the HAD-CCl^  and  sections 2.2. and 2.3.  of this issue paper.
                                    3-12

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Only rodent studies provided  sufficient  information for use in  risk  assess-
ment.  Differences in species sensitivity as related to  humans is  considered
in the risk assessment methodology by the  use  of dose per body  surface  area
as the  conversion between  species.   The authors  of  the HAD-CCl^  recognize
that the  magnitude  of the  dose and length  of exposure are  related to  the
effects produced by a given chemical.  This is one  reason why in the  absence
of human  data,  animal  data are carefully  selected for use in extrapolation
to  equivalent  human  dose  risk  assessment  considering dose  and  exposure
information.
    "The  teratogenicity  and other reproductive effects  section  does a  good
    job of reviewing the pertinent data.   The  review does not properly  point
    out that when reproductive changes (testicular  histology, aspermatogene-
    sis)  have  been  produced  in  experimental  animals, the  dose  used  was
    extremely high and the  route  of treatment sometimes not relevant (i.e.,
    intraperitoneal).   Changes  seen regarding  teratogenic,  embryotoxic,  or
    reproductive effects have been seen only  following  higher doses."
    This  comment  is well-taken.  The  high dose  and  inappropriate route  of
exposure  for  use in risk  assessment will be  specifically  mentioned.   How-
ever, note  that a general  statement is made in  chapter 14 addressing  these
issues and rendering such studies  inappropriate.
    The comments  specifically  pertaining  to  the  mutagenicity  of CCl^  and
the mechanism  of  carcinogenicity  of CC1,  are  addressed in  section  3.3.  of
this issue paper.
3.2.3.   Carcinogenicity - Human.
    "The  study...  (by  Blair,  1979)...  had several limitations  that weaken
    its results  and  make  it  difficult to  interpret."  DuPont lists  such
    weaknesses.   "Thus,  based  on a  closer look  at  the  original  article,
    support for the statement on p. 11-37 that  'human  data  as reported  by
    Blair et  al.  (1979),  also  are consistent with this conclusion1  ['that
         is a potential human carcinogen1]  is weak."
    The comments made on this section are  basically  correct  and it is agreed
that  the  epidemiologic  evidence  for  the  carcinogenicity  of CC1.  is  weak.
                                    3-13

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The preliminary  study  by Blair  et al.  (1979)  provides  the best  available
information.   It is recognizably weak because it is a  preliminary  ecological
study using proportionate mortality ratios.  This is stated  in  the document;
however, it will be modified to more strongly state these  weaknesses.   Since
it is preliminary and ecological,  it is  presented  in such a manner indicat-
ing that  it  is  not  possible to  identify  associations  between effects  and
exposure  but  rather to  merely defend  the need  for  further  more  advanced
epidemiologic  studies in this area.  The comment that  "... the  study did  not
take  into  account  possible  geographic  or  socioeconomic  differences   in
mortality rates  ..." is  inappropriate  for this level  of study.   No control
is claimed.  Thus, despite the fact that the study is  preliminary  and  itself
cannot indicate  the  carcinogenicity  of CC1. to humans,  it does not contra-
dict the  hypothesis  generated by  the  animal  studies that CCl^ is a  poten-
tial human carcinogen.   The  statement  on  page  11-37  will  be  rewritten  to
reflect a more cautious conclusion.
3.2.4.   Unit  Risk Estimate for Cancer.
    The general  criticism is  to  expand the discussion  of uncertainties  or
    delete the risk assessment.
    The EPA's  decision  has  been  to  include a  risk  assessment.   The  best
possible  estimate  is presented  and,   therefore,  the  uncertainties must  be
discussed.  The necessary extent of such a discussion  is difficult to  judge.
Certain factors contributing to the uncertainty are quantifiable;  others  are
not.   There  is  currently  no  accepted  manner  for  combining subjective  and
quantitative  uncertainties into one  range  of values,  although  much research
has been  performed  in  this  area.   Moreover,  the  commenter is  correct  in
warning that  even the  best  discussion could  be  totally  ignored, with  the
risk estimate  "accepted  as  fact."  The discussion on  uncertainties is being
expanded.   Unfortunately, there is no  way to completely  prevent misinterpre-
tation of the risk estimates.
                                    3-14

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    "The  linearized  multistage  model  is  only one  of  eight  possible  risk
    extrapolation  models   (i.e.,   probit,   Mantel-Bryan,  logit,   Weibull,
    one-hit, multi-hit,  linear,  multistage)  that could  have been  used  in
    this  analysis.    This  narrow  approach  should  be pointed  out  to  the
    reader...  The reader should also be informed that the use of  models,  in
    general, and the  linearized multistage  model,   in   particular,  is  not
    widely accepted by the scientific community.  For  example, Squire  (1981)
    points out that  'no  models can actually  be based on biological  events,
    since these are not known for any carcinogens."1

    Many models exist; the eight cited  by  no means form  a complete  listing.

Based on advice  by  internal  scientists  and expert scientists from industry,

acaoemics and  other  governmental groups, EPA  maintains  that the  multistage

model is  still  preferable  over the others as  a general  approach.   Upper

limit risk estimates based on  the multistage model have  several  mathematical

advantages and some  supporting mechanistic theories  which  the  others  lack.

Thus, the choice of a "default" model is based  on the  consensus  of scientif-

ic reviewers, and not prior policy.  Squire's  statement  is wrong  if  strictly

interpreted since the probit is based on a  distribution  of  discrete  biologi-

cal  events  (instances of cancer).   His intent,  that biological  mechanisms

are not known is, of course,  true,  although mechanistic theories  do exist.

    3.2.4.2.   MORE DOCUMENTATION FOR "LIMITED PLAUSIBILITY"  —

    "The  reasons  for the unit risk estimates  being  'presently regarded  as
    having limited plausibility' should be  more fully  documented.  First,  it
    should be  pointed  out that  the data base  is of  poor  quality for  risk
    assessment because  the  doses  were  very  high and produced  essentially
    100% response...  We also  emphasize that in  the estimation  of risk the
    relevant dose is that seen by the target tissue  rather than  the  adminis-
    tered dose.  This relevant dose is  necessarily smaller than  the  adminis-
    tered dose...  It should also  be  pointed out that the linearized multi-
    stage mooel is the most  conservative risk assessment model and  that the
    estimates of potential risk are actually the  upper 95%  confidence limits
    on potential risk.   This approach,  in effect, uses  mathematical  sophis-
    tication to  cover  up two layers of conservatism.  EPA  has  the  right  to
    use  such  overly conservative  procedures;   however,  EPA  also   has  an
    obligation to clearly describe their methodology  to decision  makers."

    As stated  under  the  previous comments,  the discussion of uncertainties

and  limited  plausibility of  risk assessment will be expanded.   However, the

extent  of  the  expanded documentation  has  not  yet  been  decided.   Some
                                    3-15

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phrases,  however,  are misleading.   First,  since mechanisms  are not  known,
one cannot  say that  data  based  on  high exposure  levels are  "...  of  poor
quality for risk assessment  ...", although several theories exist as  to why
high-exposure  responses  are  poor  indicators  of  low-exposure  responses.
Second, the  high "doses" as  used by  NCI are not  only selected because of
"positive controls,"  but often are  chosen to guarantee some difference in
response  from  that of the control  group.  Third, the  linearized  multistage
model  is  not  the  most  conservative  since  the  one-hit and  linear  models
produce higher risk  estimates  (assuming more than  2 points).  Fourth,  the
use of  upper  confidence limits is  clearly  stated in  the document  (p.  A-l,
A-3 twice, A-A four times,  A-5,  A-6 twice).   Fifth,  since  the true risk is
not known, the estimated risk could  be an underestimate, so that  the  phrase
"overly  conservative"  is  unjustified.   Sixth,  the  methodology  has  been
clearly described  and published  in  the  Federal  Register; it  is  not  use of
"mathematical  sophistication to cover  up ...  conservatism" as stated  by the
reviewer.   Nevertheless,  additional explanation  will  be provided as indi-
cated in  section 2.6.  Note also that target  tissue  dose may not always be
lower than administered  dose,  depending on how  the  word "dose" is  defined.
For example,  if the  commenter  is talking about  total  dose,  he is  correct.
However,  compounds  exhibiting accumulation and  nonuniform  distribution  may
result  in higher target tissue concentrations than the  exposure  concentra-
tions.  For example,  DDT (or DDE)  accumulates in  adipose  tissue to  levels
(ppm of tissue) higher than the daily  dose  (ppm  of  diet).   If  adipose  tissue
were a target organ in DDT toxicity, the  commenter would be  in error.   Other
examples of such behavior are readily found.
    3.2.4.3.   UNIT RISK AND EXPOSURE —
    "The  unit  risk  estimate  is meaningless without relating it  to exposure.
    A potential hazard  isn't  a  risk until there  is  exposure.   The quantita-
    tive risk assessment is incomplete and of  little  value  until  exposure is
    quantified and evaluated in the risk assessment."
                                    3-16

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    The definition of "risk assessment" is not clear nor agreed upon  by  most
scientists,  not even  by  the Society for Risk  Analysis.   The phrase  used  in
this  document  describes  the risk  estimation process  up  to the  point  of
specific locations  and exposure  scenarios.   Some suggestions  for the  next
step, application to  a specific exposure, are  given  on pages A-4 and A-5  of
the document.
    3.2.4.4.   MORE THAN MODELING —
    "Quantitative  risk  assessment  involves  more  than  the  oose-response
    modeling of  tumor incidence  data collected  in animal  studies.   To  be
    useful  and  have  scientific meaning,  the results  of  the animal  studies
    must be  related  to the findings of mutagenicity, metabolism,  and epide-
    miologic studies and the presence of no-observed-effect-levels (NOEL)..."
    As  long  as  the mechanisms  are  unknown,  as  long  as nongenetic  carcino-
genicity remains a vague theory,  until  it can be shown that  carcinogens act
wholly as "threshold" or wholly as  "non-threshold" toxicants, any statements
relating mutagenicity and  (non-cancer) toxicity  to cancer  risk  are merely
conjecture.  Quantitative  documentation containing pharmacokinetics  showing
that  CCl^  must  be metabolized  to  produce  toxic effects  is welcome.   Once
such  data  are  obtained,   expansion of the  risk  assessment section is  in
order.  Any  such  modification would also  need qualifiers,  since  metabolism
is  not  the only  determinant  of  toxicity,  others  being  distribution  to
tissues and any detoxification or elimination mechanisms.
3.3.   MUTAGENICITY COMMENTS BY AIR PRODUCTS AND DU PONT
    Air Products and  Chemicals, Inc.  and  E.I.  DuPont DeNemours and  Co.  com-
mented  that CC1.   is not  mutagenic.   The position  taken  in HAD-CCl^  that
the  availaole  scientific data are  inadequate  to conclude  that CC1.  is not
a mutagen.   The metabolism of CC1. to a  reactive intermediate, such as the
trichloromethyl  free radical  (»CC13)   (Reynolds  and  Moslen,  1980;  Trudell
et  al.,  1982),  results in covalent binding to  nuclear protein,   lipid,  and
                                    3-17

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DMA  (Diaz  Gomez and Castro, 1980a).   This suggests that  metabolic  products
of CC1A have  the potential to  react  with DMA  and that the  failure to  ob-
serve a mutagenic effect may be due to inadequate  testing protocols.   Until
better data  are available, it  is premature  to conclude  that  CC1,  is  car-
cinogenic by a nongenetic mechanism.
    The negative mutagenicity studies mentioned in  DuPont's comments on page
5  of part 2  were  carried  out with  exogenous activation systems  (S9  mix)
which may  be  inadequate for the  metabolism of CCl^.   Even if the  S9  acti-
vation system  were adequate  for metabolism  of CCl^,  the primary  reactive
metabolite  of   CC1.   ('CC1,)   is  so  reactive   that  it  may   have   been
scavenged  by  microsomal  protein and  lipid  before entering  the  bacterial
cell, thereby not  having  the  opportunity to  react  with the DNA of  the test
organism.  Metabolically  activated CC1A  has  been  shown  to  bind to  micro-
somal protein and lipid in  vitro  (Uehleke  et  al.,  1977; Reynolds and Moslen,
1980) and to bind to  and inactivate the protein responsible for the metabo-
lism  of  CC1.:    the  cytochrome  P-450  component  of  the  mixed  function
oxidase system  (DeGroot  and Haas, 1980).  Additional  testing  using  adequate
protocols  that  take  into  account  the  above  two   factors  (adequacy of  the
exogenous  metabolic system  and  ability  of  the  reactive metabolite(s)  to
reach the  bacterial  DNA)  is  necessary  before a  decision can  be  made  re-
garding  the  mutagenic potential  of  CC1..    The  negative   mutagenicity  data
reported by Uehleke et al.  (1977) were inconclusive also  because concentra-
tions of  CC1.   that resulted  in  toxicity  greater  than  10K were  not  tested
and  it  was  not specifically  stated  in  the  paper whether  rat,  mouse,  or
rabbit microsomes were used in  the S9  activation system.
                                    3-18

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    Because of  the problems  described in  the previous  paragraph  (extreme
reactivity  of  C£L  metabolites  and  scavenging  of  the  metabolites   by
microsomal  components),  test  systems  utilizing  endogenous  activation  for
investigating  the   mutagenic  potential  of  CC14  are  preferable  to  those
utilizing exogenous activation.   Callen et al. (1980) carried out  a  study  in
yeast, which possesses endogenous  activation  and  is capable of assaying  for
point  mutations and  DNA  damage.   Positive  mutagenicity  and  DMA  damage
results were reported,  suggesting that C£L  may have genotoxic potential.
    DuPont commented (page 5, part 2)  that  no evidience of covalent  binding
to  nuclear  DNA in  mouse  and rat  liver tissue was  found by Rocchi et  al.
(1973).  Rocchi et  al.  found evidence  of covalent binding  to  DNA  isolated
from mice pretreated  with 3-methylcholanthrene.   In  this  same  study it  was
also  shown  that  rat or  mouse  microsomes,  plus  cofactors  and  activating
enzymes,  metabolized CC1.  to a  substance that bound to calf  thymus DNA _in
vitro.  Furthermore, covalent  binding of CCl^ metabolites  to liver  nuclear
DNA, protein,  and  lipid was  also found  by Diaz  Gomez and  Castro  (1980a).
DuPont is evidently unaware  of three  recent  publications  by Diaz Gomez  and
Castro (1980a,b,  1981)  because  only one study  published  in  1975  by this
group was mentioned in DuPont's comments on  page 6  of part 2.
    DuPont commented on page 6 of part 2 that  Uehleke et al.  (1977)  measured
binding of  ^CCl.   to  nucleic acid.   This  study  contained  no  data on  the
binding of  ^CCl.  to nucleic  acid.    Data  on the  binding of  metabolically
activated CCl^  to  microsomal protein  and lipid and  to added serum  albumin
were  presented.   Significant binding  to microsomal  protein and lipid  was
reported.
    DuPont commented on page 2 of part  2  that two  studies  demonstrating that
CC1.  does not  induce unscheduled DNA  syntheses   (DOS)  in  hepatocytes   of
                                    3-19

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rats exposed in_ vivo were  omitted  in the mutagenicity chapter.  The  chapter
has been revised and includes a  review  of these studies.  The revised  chap-
ter is in Appendix B.   These studies are  specifically  reviewed  on pages  17
ana 18 of Appendix B.
    Mirsalis and Butterworth  (1980)  tested two doses of  CCl^  in an  in vivo
UDS  assay:    10 mg/kg  and  100 mg/kg.    The  LD5Q  for  CC14   in  rats  is
2800 mg/kg.   It was not  determined in this study at  what dose  hepatic cell
toxicity would occur under the conditions used.   Therefore,  it  is  not  clear
that  adequate  doses  of  CC14 were  tested.  Also,  it is  not  clear  whether
the 2-hour time period  between  exposure of the  rates to CC1. and  isolation
of the hepatocytes was  sufficient  for observation  of UDS.   If  Mirsalis and
Butterworth had  shown that  the 2-hour  exposure period  was sufficient for
activation of  the CC1A  to  a reactive  intermediate,  perhaps by  demonstrat-
ing alkylation of protein  by llf«CCl,,  the negative  results  they  obtained
would be  more convincing.   Thus,  this negative  result could be  due  to  an
inadequate dose or to an inadequate exposure time period.
    In a  recent  abstract, Mirsalis,  Tyson,  and  Butterworth (1982)  reported
negative results  in  the in_  vivo UDS assay  after exposure  of  rats  to CCl^
at  400 mg/kg,  which  is  a larger  dose  than  was used  in the  above  study.
However,  no  details  were reported  in  the abstract  and  it  is  not  known
whether even this dose was adequate.
    Craddock and Henderson (1978)  carried  out  an _in vivo UDS study in which
hepatocyte  nuclei were   isolated   and  then  assayed  for  radioactivity  by
scintillation  counting  rather than  by  grain counting.   This  method may  be
superior  to  the  whole-cell  grain   counting  procedure used  by  Mirsalis and
Butterworth (1980) as  described above, particularly  for chemicals that may
cause  low UDS activity,  because   a  small  effect  could  be  obscured  when
                                    3-20

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background cytoplasmic  grain  counts are  subtracted from  the  nuclear  grain
counts.   In  this  study,  Craddock  and  Henderson  used  a  CC1.   dose  of
4000 mg/kg,   which  is  significantly  larger  than  the  LD50  (2800mg/kg).
Negative  results  were  obtained  after  a  2-hour  exposure.    The  authors
suggested that this  result  may have been  due  to secondary effects,  such  as
lysosomal damage, which may result in release of DNA degradative enzymes.
    In  summary,  the  above  in vivo  UDS results  suggest that  CCl^ may  not
damage DNA.   However, additional in_ vivo UDS  studies at  doses just  below
those resulting in hepatotoxicity and at exposure  time periods  longer than 2
hours are  needed before  a  decision on  the  DNA damaging  potential of  CC1,
can  be  made.  Also,  use of  a  procedure  for  the  UDS assay  in  which  the
radioactivity of isolated nuclei  is  assayed, rather than one in which grain
counts of nuclei are corrected for grain counts  in the cytoplasm,  may better
allow for detection of low levels of UDS.
3.4.   OFFICE OF DRINKING WATER,  U.S. EPA
    Although these  comments were received and  disposed of via  internal re-
view procedures,  response will be repeated here.
3.4.1.   General Comments.  It is recommended that all units  be  consistent
throughout the document.   Conversions were  made  in the  document  as  far  as
scientifically defensible.   Further  conversions  would require  assumptions
which could  lead to  fallacious  amounts.   In such  cases the reported  doses
and units are preferred.
3.4.2.   Specific Comments.  The following specific comments were recieved.
    "7.   Compound  Disposition and  Relevant  Pharmacokinetics."   It will  be
    more appropriate to change this title to "Pharmacokinetic."
    HAD-CC14 page 7-1
                                    3-21

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     This is  not more  appropriate since  compound  disposition  is  dis-
     cussed in chapter 7 and it  is not included in  the general  category
     of  pharmacokinetics.   Pharmacokinetics  refers  to  concentrations,
     rates and products of the compound  in the body.  It does not  refer
     to disposition or distribution of the chemical, i.e., where  it ends
     up in the body.

Alumot et al.  (1976)  study shall  be  considered with caution  throughout
this  document  since  the  authors  admitted  that  chronic   respiratory
disease was widespread in their animal colony.
HAD-CC14 page 8-18

     It is  true  that Alumot et  al.  (1976) reported widespread  respira-
     tory disease in their animal colony.  However,  the disease  began at
     14 months.   The  study summarized on  page 8-18 is  on the  weanling
     rats studied by Alumot et al.  They were not  affected by  the respi-
     ratory disease.

Since  we  don't  have  Mallinckrodt ' s  report  on  the  possible  impurities
present in  the CCl^ sample, it  will be  inappropriate  to refute  Callen
et al.  (1980)  observations which  illustrate the genotoxic potential of
CC14.
         page 10-2
     The lack of  the  Mallinckrodt data is  mentioned on page  10-4.   The
     revised version of chapter  10 (Appendix B) contains the  additional
     information.

The  correct  reference  for  NCI's  bioassay  for  trichloroethylene  is
"Carcinogenesis  Bioassay   of   Trichloroethylene."   CAS  No.   79-01-6,
NCI-CG-TR-2.  U.S. Dept.  of Health, Education,  and Welfare.
HAD-CC14 page 11-7

     The citation  remains  correct on page  11-7 as  NCI, 1976.   However,
     the citation is in error  in the reference section  (chapter  15)  and
     will be corrected.

"Health Effects of Major Concern  and  Hazard Assessment" seems to be  a
more appropriate title for this section.

     This is  not  a more  appropriate title  since hazard assessment  can
     mean many things.  This  chapter deals only with the hazard  assess-
     ment relating to health.  Thus, the title  remains:  "Health  Effects
     of Major Concern and Health Hazard Assessment".
   HAD-CC14 page 14-1

This subsection should also list  pertinent  animal  ingestion  studies  such
as Korsrud et al.  (1972),  Alumot et al.  (1976),  etc.
HAD-CC14 page 14-18

     It does.  See Table 14-5.
                                3-22

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                                 APPEfCIX A
  Additional References to be Incorporated or Considered for Incorporation
        into the Health Assessment Document for Carbon Tetrachloride
Anderson, G.T.  et al.  1980.   Human  Exposure to  Atmospheric  Concentrations
of Selected Chemicals.  Reported  to EPA by Systems Applications,  Inc.   Con-
tract #68-02-3066.  May.

Asenov, A. et al.  1980.  Khim Ind. (Sofia).  2: 82.

Barber,  E.D.,  W.H.  Donish  and K.R.  Mueller.   1981.   A  procedure for  the
quantitative measurement of the mutagenicity  of volatile  liquids in the Ames
Salmonella/microsome assay.   Mutat. Res.  90: 31-48.

Berger, D.S. and F. Urbach.   1982.  Photochem. and Photobiol.  35: 187-192.

Bozelli,  J.W.  and B.B. Kerbekus.   1980.   Analysis of Selected  Volatile Or-
ganic Substances in Ambient Air.  NTIS, Springfield,  VA.  PB80-144694.

Bozelli,  J.W. et  al.   1980.   Analysis of Selected Carcinogenic Substances in
Ambient  Air in New  Jersey.   New  Jersey  Dept.  of Environmental Protection.
May.

Callen, D.F.,  C.R.  Wolf and R.M.  Philpot.   1980.  Cytochrome  P-450 mediated
genetic  activity  and cytotoxicity  of seven halogenated  aliphatic hydrocar-
bons in Saccharomyces cervisiae.  Mutation Res.   90:  31-48.

Cessi,  C.,  C.  Colombini and  L.  Mameli.  1966.    The  reaction  of  liver pro-
teins with a metabolite of carbon tetrachloride.  Biochem. J.  101: 46c-47c.
                                     A-l

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Clark, C.S. et al.   1982.   An Environmental Health Survey  of Drinking Water
Contamination of  Leachate from  a Pesticide Waste  Dump in  Hardeman  County,
Tennessee.  Arch. Environ. Hlth.  37(1): 9.

Cooper,  K.  and  C.  Witmer.   1982.   Low  oxygen tension and its  effects  on
CCl^  toxicity  and mutagenicity  in  the Ames test (Abstract  Bh-6).  Environ..
mental Mutagen Society 13th Annual Meeting, Feb. 26-March 1.  13: 99.

Craddock, V.M. and A.R. Henderson.   1978.   De_ novo  and repair replication of
DMA in liver of carcinogen-treated animals.  Cancer Res.  38: 2135-2143.

Dean, B.J. and G.  Hodson-Walker.  1979.  An in  vitro  chromosome assay using
cultured rat liver cells.   Mutat. Res.  64: 329-337.

De  Groot,  H.  and  W.  Haas.   1980.   02-Independent   damage of  cytochrome
P-450 by CCl^ metabolites in hepatic microsomes.  FEBS Lett.  115: 253-256.

Diaz Gomez, M.I. and J.A.  Castro.   1980a.   Covalent binding of carbon tetra-
chloride  metabolites to liver nuclear  DMA, proteins,  and  lipids.  Toxicol.
Appl. Pharmacol.  56: 199-206.

Diaz Gomez, M.I. and J.A.  Castro.   1980b.   Nuclear  activation of carbon tet-
rachloride   and  chloroform.    Res.   Commun.   Chem.   Pathol.   Pharmacol.
27: 191-194.

Diaz Gomez,  M.I.  and J.A.  Castro.   1981.  Reaction of  trichloromethyl free
radicals  with deoxyribonucleic  acid  bases.    Res.  Commun.  Chem.  Pathiol.
Phannacol.  32: 147-153.

                                     A-2

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Dolar, P. et al.   1981.   Exposure to Carcinogenic Chemicals  and Smoking In-
creases  Urinary Excretion  of  Mutagens  in  Humans.    J.  Toxicol.  Environ.
Hlth. .8(1-2).

Fishbein, L.   1976.   Industrial mutagens and potential  mutagens.   I.   Halo-
genated aliphatic derivatives.  Mutat. Res.  32: 267-308.

Harris, R.N. and M.W.  Anders.   1980.   Effect of Fasting, Diethylmaleate, and
Alcohols  on  Carbon  Tetrachloride-Induced   Hepatotoxicity.   Toxicol.  Appl.
Pharmacol.  56(2): 191.

Harris,  R.N.  et al.   1982.   Interaction Hepatotoxicity  of Chloroform and
Carbon Tetrachloride.  Toxicol. Appl. Pharmacol.  63(2): 281.

Henry, E.C.   1980.  Renal  Effects of  Inhaled  Carbon Tetrachloride  and the
Influence of  Inhaled  Isopropanol:  A  Comparison with  the  Hepatic  Effects.
NTIS, Springfield,  VA.  VR-3490-1776.

Hjelle,  J.J.  et  al.  1982.   Carbon  tetrachloride-ethanol   Interactions  in
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Jakobson, I. et al.   1982.   Uptake Via  the  Blood and Elimination of  10 Or-
ganic Solvents  Following  Epicutaneous Exposure of Anesthetized  Guinea Pigs.
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Jones, B.V.  and M.  Shah.   1982.   Clinico-chemical  Changes in  Goats Given
Carbon Tetrachloride.  Nord. Vet. Med.  34(1-2).
                                     A-3

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Keller, E.B. and  P.C.  Zamecnik.   1956.  The effect  of guanosine diphosphate
and triphosphate  on  the incorporation of labeled amino  acids into proteins.
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Kraybill,  H.F.   1978.    Carcinogenesis   Induced  by   Trace   Contaminants  in
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Kraybill, H.F.  1980.   Evaluation of Public Health. Aspects  of Carcinogenic/
Mutagenic Biorefractories in Drinking Water.  Prev. Med.  9(2): 212.

Kubic,  V.L.  and M.W. Anders.  1980.   Metabolism of  carbon  tetrachloride to
phosgene.  Life Sci.  26: 2151-2155.

Laseter,  J.L.  and  B.J.  Dowty.   1977.   Association  of Biorefractories  in
Drinking Water and Body Burden in People.  Ann. NY Acad. Sci.  298: 547.

Lee,  P.Y.  et  al.   1982.   Evidence for  Carbon Tetrachloride-Induced Lipid
Peroxidation in Mouse Liver.  Biochem. Pharmacol.  31(3): 405.

Liebovitz, B.  and B.V.  Siegel.   1980.  Antioxidants and Carbon Tetrachloride
Toxicity.  Fed. Proc.   (3 part 1): 511.

Louria, D.B.  and J.D.  Bogden.   1980.   The  Dangers  of  Limited  Exposure  to
Carbon Tetrachloride.  Crit. Rev. In Toxicology, CRC Press.   7(2): 177.

Lovelock, J.E.  1974.  Nature.  252: 292.
                                     A-4

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Lovelock, J.E. et al.  1973. Nature.  241: 194.

Lovelock, J.E.   1977.   Halogenated  Hydrocarbons in the  Atmosphere.   Ecotox-
icology and Environmental Safety.  1: 399.

Masuda, Y. and  T.  Murano.   1977.  Carbon tetrachloide-induced  lipid peroxi-
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McCann and Ames.  1976.  Proc. Natl. Acad. Sci.  73: 950.

McCann, J.,  and E. Choi, E.  Yamasaki,  and B.N.  Ames.   1975.  Detection  of
carcinogens  as  mutagens  in  the Salmonella/microsome  test:    Assay of  300
chemicals.  Proc. Natl. Acad. Sci.  72:  5135-5139.

Mirsalis, J.C.  and B.E. Butterworth.   1980.    Detection of  unscheduled  DMA
synthesis in  hepatocytes isolated from  rats  treated with  genotoxic agents:
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Mirsalis, J.C.,  C.K.  Tyson  and  B.E. Butterworth.   1982.   Induction of  DNA
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26 - March 1.  13: 102.

Nakajima, T.  et al.   1982.   Dietary Modification  of  Metabolism and Toxicity
of Chemical  Substances - With Special  Reference to  Carbohydrate.  Biochem.
Pharmacol.  31(6): 1005.
                                     A-5

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NAS (National  Academy  of Sciences).   1978.   Chloroform, Carbon  Tetrachlor-
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NAS.   1979a.   Stratospheric Ozone  Depletion by  Halocarbons: Chemistry  and
Transport.

NAS.  1979b.  Protection Against Depletion of Stratospheric  Ozone by Chloro-
fluorocarbons.

NAS.  1982.  Causes and Effects of Stratospheric Ozone Reduction:  An Update.

Noguchi,  T.  et al.  1982.   Selective  Early  Loss of  Polypeptides  in  Liver
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O1Donovan, D.J. and  T.M.  Dunne.   1977.  Structural and  Metabolic Effects of
Carbon Tetrachloride Administration in the Rat.   J.  Anat.  124(2): 490.

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Pohl,   L.R.,  R.V.   Branchflower,  R.J.  Highet,  J.L.  Martin,  D.S.   Nunn,  T.J.
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carbon tetrachloride.  Drug Metab. Disposit.   9: 334-339.
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Popp, J.A., S. Hisashi and  E.  Farber.   1978.  The protective effects  of di-
ethyldithiocarbamate and  cycloheximide  on the  mutliple hepatic  lesions in-
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Rocchi,  P.,  G. Prodi, S.  Gilli  and  A.M. Ferreri.   1973.  _In  vivo  and  in
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Saleh,  M.A.   1980.  Mutagenic  and Carcinogenic Effects  of Pesticides.   J.
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Sawicki,  E.   1977.   Chemical Composition  and Potential 'Genotoxic1  Aspects
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Shah,  H.,   S.P.  Hartman  and S.  Weinhouse.   1979.    Formation   of  carbonyl
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Res.  39: 3942-3947.
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Simmon, V.F.,  K. Kauhanen  and  R.G. Tardiff.   1977.   Mutagenic activity  of
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Sipes,  G.I.,  G.  Krishna and J.R.  Gillette.   1977.  Bioactivation  of carbon
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Trudell, J.R.,  B. Bosterling and  A.J.  Trevor.   1982.  Reductive  metabolism
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                                     A-8

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Uehleke, H., H. Greim, M. Kramer, and  T.  Werner.   1976.   Covelant binding of
haloalkanes to  liver  constitutents,  but absence of mutagenicity  on bacteria
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Uehleke, H., H. Greim, M. Kramer  and T.  Werner.   1977.   Metabolic activation
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Report No. 11, May 1981.
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Wuebbles, D.J.,  F.M.  Luther,  and  J.E.  Penner.   1982.   Effect of  coupled
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physical Research for publication.)
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            APPENDIX B
Rewrite of Chapter 10.  Mutagenicity

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                 THE .REPRODUCTIVE EFFECTS ASSESSMENT GROUP'S

                                 DRAFT REPORT

                 ON THE MUTAGENICITY OF CARBON TETRACHLORIDE
                                                    Peter E. Voytek, W.0.
                                                    Di rector
Prepared by

Sheila L. Rosenthal, Ph.D.
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This document is a preliminary draft.  It has not been formally released by
the EPA and should not at this time be construed to represent Agency policy.
It is being circulated for comment on its technical accuracy and policy
implication.

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                               TABLE OF CONTENTS
Introduction	1
Metabolism and Covalent Binding to Macromolecules 	 1
Mutagenldty Studies In Bacterial Test Systems	 . 7
Studies in Eucaryotic Test Systems	12
Studies Indicative of Primary DNA Damage	15
Suggested Additional Testing. 	17
Summary and Conclusions 	 	18
References	21
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                                 INTRODUCTION
     The mutagenic potential  of carbon tetrachloride (€014) has b
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assessed by evaluation of the results from seven bacterial  studies, one yeast
study, one 1n vitro mammalian chromosome damage study and two in vivo DNA
damage studies in rodents.  The majority of these studies were negative.
Information relating to the metabolism of CC14 and to covalent binding of
the metabolites to cellular macromolecu!es (including DNA) is presented before
the sections assessing the genotoxicity of €014.  This was done to set the
stage for the discussion of the largely negative results obtained in the
mutagenicity studies described below and for the suggestion that CC14 may be
a weak mutagen.  In addition, suggestions for additional testing are
presented.

METABOLISM AND COVALENT BINDING TO MACROMOLECULES
    The evidence described in the section suggests that CC14 is metabolized
in the liver to.highly reactive intermediates (the trichloromethyl  free
radical and phosgene).  The evidence also indicates that metabolically
activated CC14 covalently binds to protein, lipid, and DNA, suggesting that
CC14 mav nave genotoxic potential.

Metaboli sm
     CC14 is metabolized in the liver endoplasmic reticulum by the
cytochrome P-450 component of the mixed function oxidase system (Reynolds and
Moslen 1980).  The available evidence indicates that metabolism of CC14
results in the generation of the trichloromethyl free radical -CC^
(Reynolds and Moslen 1980, Trudell et al. 1982) and phosgene (Shah et al.
1979, Kubic and Anders 1980, Pohl et al. 1981).  These two substances are the
most likely of the metabolites to exhibit reaction with tissue macromolecules

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because of their high reactivity.  By using human cytochrome P-450
reconstituted in phospholipid vesicles, Trudell et al. (1982) have
demonstrated that *CCl3 is the major product of the reductive metabolism
of CC14 as determined by mass spectral identification of the adducts formed
between *CCl3 and the phospholipid dioleoyl phosphatidylcholine.
     Phosgene results from further metabolism of »CCl3 (Shah et al . 1979)
(see Fig. 7-1).
                      CC1 4
Pohl et al . (1981) measured the amount of phosgene (as diglutathionyl
dithiocarbonate) produced from the aerobic metabolism of 0014, CHC13,  and
CBrCl3 by liver microsomes (from phenobarbital -treated rats) plus cofactors.
The results indicate that phosgene production from CC14 is only 4% of  that
produced from CHC13.  Thus, the level of phosgene production from aerobic
metabolism of CC14 is small.  The card nogeni city and mutagenicity of
phosgene are currently under "investigation in Dr. B.L. Van Duuren's laboratory
at New York University Medical Center (Dr. Sipra Banerjee, personal
communication).  Metabolites of CC14 are so reactive that they bind to and
inactivate the cytochrome P-450 enzymes that were responsible for their
generation (suicide mechanism) (Vainio et al . 1976, Sipes e£ £]_! 1977, De
Groot and Haas 1980, Cooper and Witmer 1982).

Covalent Binding to Macromol ecu! es
     Metabolically activated CC14 has been found to bind covalently* to
    *Amount of label bound was determined after washing and extraction
indicating that the binding was covalent.
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lipid and protein both in vivo (Rocchl et al. 1973, Diaz Gomez and Castro
1980) and j£ vitro (Rocchi et al. 1973, Uehleke et al. 1977).  Uehleke et al.
(1977) measured covalent binding of 1 mM 14CC14 (0.25 Ci/mol) to
microsomal protein and lipid in liver microsome suspensions (5 mg protein/ml
plus cofactors) from phenobarbital-treated rabbits.  About 10% of the 14C
label was covalently bound to endoplasmlc reticulum protein and greater than
     i
30% was bound to microsomal lipid.  Extramicrosomal binding was evaluated by
the addition of 5 mg of bovine serum albumin per ml to the CCl4/m1crosome
mixture.  The binding of metabolically activated ^CCl4 to added bovine
serum albumin (1.4 nmol/mg in 60 min) was about 1.5% of that bound to
microsomal protein (20.0 nmol/mg) plus lipid (76.0 nmol/mg).  Thus, it appears
that binding of metabolically activated 14CC14 to extramicrosomal
macromolecules is negligible compared to binding to microsomal constituents.
(Mutagenicity studies were also described in this paper and are discussed in
the next section.)
     Evidence that the CC14 metabolite, phosgene, reacts with proteins was
obtained by Cessi et £j_. (1966) when they measured the in vivo binding of
CC14 to rat liver proteins and compared it to the in vitro acylation of
poly-L-lysine and serum albumin by phosgene.  Similar reaction products were
obtained in both systems, suggesting that phosgene reacts with the lysine
£-amino groups in proteins, leading to cross-linked carbonyl derivatives:
C1-C-C1 + 2	lysTne	  	^	lysine-fl-C-ft-lysine	
phosgene        proteins                          cross-linked proteins
                                      or
   Q           NH2        NH2                        NH-C-NH^
C1-C-C1  + ....lysine....lysine... 	> lysine	lysine
phosgene           protein                     cross-linked  protein
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Such cross-linked proteins would undoubtedly exhibit Impaired biological
activity.  It is also possible that similar cross-linking reactions of
phosgene can occur with ami no groups in DNA, resulting in alterations in  DMA
structure and function.
    Binding of metabolically activated CC14 to DNA was found by two groups.
Rocchi et aj_. (1973) have studied the binding of CC14 to nucleic acids and
protein.  14C-Labeled CC14 (367 umol/kg) was injected into rats and mice
and the amount of metabolite(s) of CC14 that covalently bound to liver DNA,
RNA, nuclear proteins, and cytoplasmic proteins was measured.  They reported
that significant amounts of labeled material were found associated with rRNA,
nuclear proteins, and cytoplasmic proteins in rats.  When the rats were
pretreated with 3-methylcholanthrene (5 mg, 24 hr before treatment with
0014), the amount of label associated with the macromolecules increased.   No
label was associated with DNA in the rat studies.  Similar studies in mice
indicated that DNA binding occurred (108 umol CCl4/mol DNA), but only after
pretreatment with 3-methylcholanthrene (1 mg, 24 hr before CC14 dosing).
     In an in vitro experiment, Rocchi et £l_. (1973) used rat or mouse liver
microsomes to activate labeled CC14 in the presence of calf thymus DNA.
They found that pretreatment of animals with 3-methylcholanthrene enhanced the
amount of label  associated with DNA.  Furthermore, pH 5 enzyme preparations
which contain activating enzymes (Keller and Zamecnik 1956), were also found
to increase the amount of label bound to DNA.  Therefore, from these results,
it appears that metabolites of CC14 can interact with DNA; however, for
optimal binding conditions, microsomal enzymes had to be activated with
3-methylcholanthrene and the binding assay had to be carried out in the
presence of pH 5 enzymes.
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     Diaz Gomez and Castro (1980a) have also measured binding of metabolically
activated CC14 to cellular macromolecules.   14C from 14CCl4 (specific
activity, 27 C1/mol) irreversibly bound in  vivo to liver nuclear DNA,  protein,
and lipids in strain A/J mice and Sprague-Dawl ey male rats.  Mouse and rat
liver nuclear DNA Isolated from animals given 14CCl4 16 hr before they
were killed exhibited a small but significant labeling (mice, 0.72 pmol/mg;
rats 0.52, pmol/mg).  The count from the assay done in the presence of
unlabeled DNA was subtracted from the experimental  counts before binding  was
calculated.  In contrast to the results of  Rocchi et aU (1973), induction of
liver enzymes by 3-methylcholanthrene  was  not required for binding of ^C
from 14CCl4 to DNA.  It should be mentioned that the purified DNA samples
contained 0.2% protein.  However, contamination by protein at this low level
could not account for all the covalent binding measured in the DNA sample.
     Significant in vitro binding of metabolically activated CC14 to
isolated mouse liver DNA (1.81 pmol/mg) was observed by Diaz Gomez and Castro
(1980a) in anaerobic Incubation mixtures containing microsomes and NADPH.  It
was also found that *CCl3 chemically produced by reaction of CC14 with
benzoyl peroxide interacted with DNA (826 pmol/mg).  This result suggests that
•CC13 may be the species involved in the binding to DNA.
     In addition to the above observations  that metabolites of CC14 bind  to
DNA, Diaz Gomez and Castro (1980a) also observed significant binding in vivo
of metabolically activated CC14 to rat liver nuclear protein and lipid. The
label bound to nuclear protein was 47.7 pmol/mg and that bound to nuclear
lipid was 113.5 pmol/mg.  The authors suggested that the binding of
metabolically activated CC14 to nuclear lipids is significant in terms of
the carcinogenicity of CC14, because nuclear lipid is derived from the
nuclear membrane which contains the P-450 necessary for activation of  CCl
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to the probable reactive metabolites *CCl3 and phosgene.   Since these
metabolites are highly unstable and therefore are not likely  to exist long
enough to travel from the endoplasmlc reticulum P-450 enzymes to nuclear
components, activation by nuclear membrane P-450 enzymes  Is more likely to
yield Interactions of the metabolites with nuclear components (e.g.,  DNA) than
will activation in the endoplasmlc reticulum.
     01az Gomez and Castro (1980b) have assessed the CC14 activation
potential of purified rat liver nuclei by measuring covalent  binding  of
nuclear activated CC14 to nuclear protein and lipid.  Binding to DNA  was not
measured 1n this study.  The results were compared to results obtained from
similar incubation mixtures containing microsomes instead of  purlfTed nuclei.
The incubation mixtures containing either nuclei (1.3 mg  protein/ml)  or
microsomes (1.56 mg protein/ml) were incubated for 30 min in  37.6 nM
^CCl4 (6.94 Ci/mol) and an NADPH generating system in an 02-free N2
atmosphere.
    The authors observed that the extent of binding to proteins in the nuclear
preparations was 43.5% of that observed for microsomes (nuclear suspensions,
21.9 pmol/mg; microsomes, 50.3 pmol/mg).  Binding to nuclear  lipids was 77.3%
of that observed for microsomes (nuclear suspension, 147  pmol/mg;  microsomes,
190 pmol/mg).  Thus, isolated nuclei were less efficient  than microsomes in
metabolizing (£14 but the results were within the same order  of magnitude.
     This study suggests that metabolism of CC14 to reactive  intermediates
can occur in nuclear membranes and indicates that the in  vivo binding observed
in the previous study (01az Gomez and Castro 1980a) may have  been due to
nuclear rather than microsomal activation of CC14-  It should be
mentioned,however, that the nuclear preparations were contaminated with trace
amounts of endoplasmic reticulum, which may have been sufficient to result in
at least part of the nuclear activation observed.
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     Diaz Gomez and Castro (1981) have published preliminary evidence that
•CCIs, chemically generated from the benzoyl  peroxide-catalyzed
decomposition of CC14, reacts primarily with guanine and adenine and to a
lesser extent with cytosine and thymine.  This result suggests that 'CC^
may bind to DNA in vivo by interaction with the deoxyribonucleic acid bases.
    In summary, it has been shown that CC14 is metabolized to reactive
intermediates (*CCl3 and phosgene).  It has also been shown that
metabolically activated CC14 binds to DNA, protein, and lipid.  These
results suggest that CC14 has genotoxic potential.  The negative results in
six of the seven bacterial mutagenicity studies described in the next section
may be due to inadequate metabolic activation in the test systems used or may
result from the scavenging by protein or lipid of any very reactive metabolic
intermediates formed (e.g., *CCl3 and phosgene) under conditions of
exogenous activation, thus limiting their availabliity for reaction with DNA.
Thus, test systems used to assess the genotoxicity of CC14 should
incorporate adequate metabolic activation and an indication that any highly
reactive metabolites formed were not scavenged by microsomal protein or lipid
before reaching the DNA of the test organism.

MUTAGENICITY STUDIES IN BACTERIAL TEST SYSTEMS
     Studies to determine the mutagenic activity of CC14 in the Salmonella
typhimurium revertant system have been primarily negative.  A review article
written by McCann et jil_. (1975) stated that an assay using Aroclor-induced S9
activation and strains TA 100 and TA 1535 was negative.  The McCann et al.
article contained no details of the procedure used to generate this negative
result.  Another review article (Fishbein 1976) in which no data were
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presented contained a statement that CC14 was not mutagenic when assayed in
a spot test with the TA 1950 strain.
     In-an abstract, Uehleke et al. (1976) reported that CC14 was not
mutagenic 1n liquid Salmonella typhimurium strains TA 1535 (test for base-pair
substitution) or TA 1538 (test for frame-shift mutation) and Escherichia coli
K12 Incubated with microsomes.  However, these results cannot be evaluated
because no data were presented.
     In a more detailed study, Uehleke et al. (1977) tested the mutagenicity
of CC14 in suspension assays with S^. typhimurium strains TA 1535 and TA
1538.  No mutagenic activity was observed.  About 6-9 x 10s bacteria were
incubated for 60 min under N2 in tightly closed test tubes with 8 mM CC14
and microsomes (5 mg protein) plus cofactors.  The mutation frequencies
(his"1" colony forming units/10^ his" colony forming units) were less than
10 for both strains and the spontaneous mutation frequencies were 3.9 +_ 3.7
for strain TA 1535 and 4.4 +_ 3.5 for strain TA 1538.  At this concentration of
CC14, survival of the bacteria was at least 90%.  Thus, the negative result
for 0014 cannot be interpreted since concentrations of CC14 resulting in
less than 90% survival should also have been  tested.  Dimethylnitrosamine,
cyclophosphamide, 3-methylcholanthrene, and benzo[a]pyrene were the positive
controls used in this study.  Although these  chemicals were mutagenic in the
presence of the S9 activation system, they may not be appropriate controls
because they in no way resemble halogenated alkanes.
     Because metabolically activated CC14 did not significantly bind to
exogenously added bovine serum albumin (see binding studies above), Uehleke e_t_
al. (1977) concluded that any reactive species generated by the microsomes may
not have distributed into the incubation medium and, thus, may have been
inaccessible to the test bacteria, resulting  in the negative mutagerH-ert-y-	,„
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response observed.  However, It is not clear from the description provided in
this report whether rat, mouse, or rabbit microsomes were used in the
mutagenicity studies.  It is clearly stated that rabbit microsomes were used
for the binding studies described above.  If mouse or rat microsomes  rather
than rabbit microsomes were used for the mutagenicity experiments, it cannot
be assumed that CC14 was sufficiently activated, since activation sufficient
for binding of 14CC14 to macromolecules was shown 1n this paper only  with
rabbit microsomes.  Another deficiency in this study is that the Ames strains
TA 98 and TA 100 were not used.  These strains contain an R factor plasmid
that increases the sensitivity of the tester strains to certain mutagens.
Because of these deficiencies, the negative mutagenicity results in this paper
are inconclusive.
     The mutagenicity of CC14 was also tested in a study designed to
evaluate the mutagenic potential of chemicals identified in drinking  water
(Simmon et al. 1977).  No mutagenic activity was detected with CC14.   The
authors tested 71 of the 300 chemicals that had been identified in public
water supplies.  0014 was tested in this study in a desiccator to assess
mutagenicity due to vapor exposure and to avoid excessive loss of CC14 to
the atmosphere.  The desiccator contained a magnetic stirrer which acted as a
fan to aid in evaporation of the measured amount of CC14 and to maintain an
even distribution of the vapors.  Plates were exposed to the vapors for 7-10
hr and then removed from the desiccators, covered, and incubated approximately
40 hr before scoring.  Mutagenic activity was not observed and no information
on toxicity was provided.
    This study by Simmon et al. (1977), although lacking some specific details
of the CC14 assay, clearly identifies certain trihalomethanes (CHBT3,
       , CHBrClg) as mutagens in the vapor assay in desiccators. Mettw*
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bromide, methyl chloride, methyl iodide, and methylene chloride were also
found to be mutagenic in the desiccator assay.  However, these seven
halogenated compounds did not require metabolic activation to exhibit
mutagenic activity.  It may be that CC14 itself is not mutagenic and the rat
liver S9 does not effectively metabolize CC14 to a potential mutagenic
reactive Intermediate (? •CCl3)r even though the demonstration of
mutagenicity oiMthree oHthe chemicals- tested [bis(2-chloroisopropyl )ether,
vinyl chloridev and vinyTidene chloride] required or was enchanced by this S9
mix.  It may also be that a reactive intermediate was formed, but it was too
reactive or short-lived to be detected in a test system that uses exogenous
metabolic activation.
    Another negative result for the mutagenicity of CC14 was obtained in a
recent study using the Salmonella/microsome assay in which escape of the
volatile compounds was prevented by the use of a specially designed, closed,
inert incubation system (Barber e_t £l_. 1981).  Seven of the ten halogenated
alkane solvents tested gave positive mutagenicity results when the Ames assays
were carried out in the closed incubation system.  Under standard conditions
(in which volatilization was not prevented), only 2 of the 10 solvents tested
gave a positive result.  Thus, the closed incubation system allowed for the
detection of five more mutagens than could be detected under standard
conditions.  CC14 was one of the three solvents tested that gave a negative
result in both the standard and closed incubation systems.  The investigators
indicated that CC14 was tested at concentrations high enough to produce
observable toxicity (determined by absence of background lawn).  The
Salmonella strains used were TA 1535, TA 1537, TA 1538, TA 98, and TA 100.
Levels of CC14 tested were 4.7, 5.7, 10.2, 12.3, and 18.4 umol per plate.
No dose-related response was observed.  The seven solvents that tested
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positive in this closed system did not require metabolic activation by S9 mix
prepared from Aroclor-induced rats (the S9 mix did activate the positive
control 2-aminoanthracene). It 1s possible that the S9 mix used, although
adequate for activation of 2-aminoanthracene, was not adequate to metabolize
the other three solvents (Including CC14).  It is also possible that active
metabolites, If formed, reacted with microsomal components (see below) before
reaching the bacterial DNA.
     In a recent abstract, Cooper and Witmer (1982) reported that exposure of
Salmonella strain TA 100 to CC14 for 20 minutes in a 1-ml liquid suspension
at low oxygen tension (3-ml vacutainer tubes) before preparation of plates
resulted in a twofold increase in revertants above background (background, 72
+_ 9 revertants; 5 umol CC14, 141 +_ 20 revertants).  Evidence for a
dose-response relationship was not reported in this abstract.  The weak
mutagenic result was observed in two separate experiments and only when fresh
rabbit liver S9 was used as the activation system.  It is unlikely that the
rabbit liver S9 alone was responsible for the mutagenic activity observed
because plate assays with rabbit S9 exhibited no mutagenic activity.  The
CC14 was spectrophotometric grade (Spectrar) purchased from Mallinkrodt (Dr.
Charlotte Witmer, personal communication).  CCl^ was toxic in this
suspension assay; 2 umol/ml caused 80% toxicity with microsomal activation and
20% without activation.  Addition of 0.1 mM EDTA to inhibit microsomal lipid
peroxidation decreased bacterial toxicity.
     The authors concluded that the suspension assay in the vacutainer tubes
may be a suitable system for testing volatile compounds that undergo a
reductive metabolism.  This weak positive result constitutes preliminary
evidence that CC14 may be mutagenic in the Ames assay, but only under
certain assay conditions (low oxygen tension, exposure of bacteria in	
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suspension In the presence of EDTA, and use of fresh rabbit liver S9).
     In summary the results from the above bacterial studies are Inconclusive,
since false negative results could have been obtained due to a number of
factors, including:
    1.  The activation systems used may have been inadequate for metabolism
         of CC14.
     2.  *CCl3 and phosgene, the primary reactive metabolites of CC14,
         are unstable and highly reactive.  Because exogenous activation
         systems were used in many of these studies, any *CCl3 or phosgene
         generated (assuming an adequate activation system) may have been
         scavenged by  microsomal protein or lipid before reaching the DNA.
     3.  Adequate exposure to CC14 may not have occurred if appropriate
         precautions were not taken to prevent the evaporation of 0014.

STUDIES IN EUCARYOTIC TEST SYSTEMS
    Call en e££]_. (1980) carried out a study on the mutagenicity of CC14 in
the D7 strain of Saccharomyces cerevislae, which contains an endogenous
cytochrome P-450 dependent monooxygenase activation system.  By using this
strain of yeast, Call en and his coworkers eliminated the need for the
exogenous type of metabolic activation system used in the above bacterial
studies.  Three different genetic endpoints can be examined with this system:
gene conversion at the trpS locus, mitotic crossing over at the ade2 locus,
and gene reversion at the ilvl locus.  The effect of CC14 (Mallinckrodt,
99+% pure) on these endpoints was measured by exposing cells in suspension
to 3.23, 4.31, and 5.13 g of CC14 per liter of buffer (21 mM, 28 mM, and 34
mM, respectively), well above the solubility level of CC14 in water (0.8 g/1
at 25°C).  Therefore, a dose-response relationship could not be obtained
because the dose was essentially the same in all cases -the solubility level
of CC14 in water at 37°C.  Escape of volatilized CC14 is not expected to
have occurred to any significant extent, because the incubations were carried
out in screw-capped glass tubes.  Although the dose is essentially constant, DRAFT
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amounts In suspension will vary.  Extracellular or membrane effects may result
in the high toxidty observed at 5.13 g/1.
    Results of the Callen et £l_. study are presented in Table 1.   A 1-hr
treatment of cells with CC14 at the highest amount tested (5.13 g/1)
resulted 1n significant increases 1n gene conversion (31-fold) and mitotic
crossing over (25-fold).  Gene reversion was also increased, but  to a lesser
extent (3-fold increase).  Survival was only 10% at this concentration of
CC14.  At the intermediate level (4.31 g/1) of CCl*;, much smaller effects
in the three genetic systems were observed (2- to 3-fold increases).  Survival
at this level was 77%.  Thus, the data in the Callen et al. (1980) study are
suggestive of a weak positive response, but additional  studies are needed
before it can be conclusively stated that CC14 causes genetic effects in
yeast.
    Negative results have been obtained in a recently developed in vitro
chromosome assay that utilized an epithelial-type cell  line derived from rat
liver (Dean and Hodson-Walker 1979).  This cell line has sufficient
metabolizing activity to activate various chemical mutagens and carcinogens
without the need for an exogenous activating system.  Sealed-flask cultures
were treated for 22 hr with CC14 dissolved in growth medium at 0.005, 0.010,
and 0.020 mg/1.  CC14 at these low concentrations did not induce  any
chromatid or chromosomal aberrations, whereas a number of direct-acting
mutagens and several requiring metabolic activation produced chromatid
deletions, gaps, and exchanges.  However, none of the other substances tested
was a heavily chlorinated compound.  In addition, one of these substances was
assayed at levels comparable to that used for CC14 and the remaining 10
compounds were assayed at doses several orders of magnitude larger.  The doses
chosen for each substance assayed were determined from cytotoxiclt^ assays.
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                                                            iiUiii.cMi.1 ai. tun, y/
                                                    0
         3.23
       4.31
        5.13
Survival
  Total colonies
  % of control
trpS locus (gene conversion)
  Total convertants
  Convertants/10^ survivors
ade2 locus (mitotlc crossing over)
  Total twin spots
  Mitotlc cross-overs/10* survivors
  Total genetically altered colonies
  Total genetically altered colonies/
      survivors
1 1 v 1 locus (gene reversion)
  Total revertants
  Revertants/lO** survivors
1454     1252      1120        152
 100       86        77         10
 285      331       350        506
   2.0      2.6       3.1        61.7
   1        3         3
   1.6      5.3       5.8
  11       19        16
   1.7
3.4
3.1
  38       41        57
   2.6      3.3       5.1
10
40.1
65

33.3
                     11
                      7.2
    aSource:  Adapted from Call en et aK. 1980
    bThe total number of colonies In the different classes represent total counts of colonies
from five plates in the case of survival, conversion and revertant-frequency estimations.  Mltotl
crossing over was estimated from counts of colonies growing on a total of 30 plates, 20 plates
containing medium on which all surviving cells grew and 10 plates containing medium on which only
trpS convertants grew.
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Apparently, CCl^ was very toxic to rat liver cells.  EDTA (0.1 mM)  has been
found to decrease the cytotoxicity of CC14, without affecting mutagenicity in
bacteria (Cooper and Witmer 1982), apparently by decreasing membrane lipid
peroxidation (Masuda and Murano 1977).  Perhaps addition of EDTA to a
mammalian in vitro chromosome assay, such as in the1study carried out by Dean
and Hodson-Walker (1979), would allow for the use of larger concentrations of
CC14.

STUDIES INDICATIVE OF PRIMARY DNA DAMAGE
     Mirsalis and Butterworth (1980) measured unscheduled DNA synthesis (UDS)
in primary rat hepatocyte cultures following in vivo treatment of adult male
Fischer-344 rats (200-250 g) with CCU (certified ACS grade, Fischer
Scientific Co.) by oral  gavage.  Control rats received corn oil by  gavage.
Acetylaminofluorine and dimethylnitrosamine were also tested.  At 2 hr after
treatment, the livers were perfused in situ and hepatocytes were isolated.
Approximately 6 x 105 viable cells were seeded in culture dishes containing
coverslips and allowed to attach to the coverslips for 90 min.  After the
coverslip cultures were washed, they were incubated in a medium containing 10
uCi [3H]thymidine (42 Ci/mmol) per ml for 4 hr.  The cultures were  washed
again and incubated in medium containing 0.5 mM cold thymidine for  14-16 hr.
The extent of UDS was assessed by autoradiography.  Net grains/nucleus were
calculated as the silver grains over the nucleus minus the highest  grain
count of three adjacent nuclear-sized areas over the cytoplasm.  The area of
the silver grains was counted rather than the grain number, so that densely
labeled cells where silver grains were touching could be accurately measured.
     Cells from control  animals ranged from -2 to -6 net grains/nucleus.
Treatment of rats with dimethylnitrosamine (i.p.) at 10, 1, or 0.1  m
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yielded 36.6, 6.4, and -0.9 net grains/nucleus, respectively;
dimethylnitrosamine at 10 mg/kg (p.o.) produced 22.2 net grains/nucleus.   Oral
doses of acetylaminofluorine at 50 or 5 mg/kg yielded 14.0 and 6.4 net
grains/nucleus, respectively.  CC14 at 100 or 10 mg/kg (p.o.)  yielded -3.2
and -5.1 net grains/nucleus, respectively.  Thus, dose-related increases  in
DOS were observed for dimethylnitrosamine and acetylaminofluorine, whereas
CC14 produced no response.
     In this study two doses of CC14 were tested:  10 mg/kg and 100 mg/kg.
The LDso for CC14 in rats is 2800 mg/kg.  It was not determined in this
study at what dose hepatic cell toxicity would occur under the conditions
used.  Therefore, it is not clear that adequate doses of CC14  were tested.
Also, it is not clear whether the 2-hr time period between exposure of the
rats to 0014 and isolation of the hepatocytes was sufficient for observation
of UDS.  In a study by Popp et_ £l_. (1978), in which CCl4-induced
hepatocellular changes were noted, the shortest exposure period studied was 6
hr.  If Mirsalis and Butterworth had shown that the 2-hr exposure period  was
sufficient for activation of the CC14 to a reactive intermediate, perhaps by
demonstrating alkylation of protein by 14-CCl3, the negative results
they obtained would be more convincing.  Thus, this negative result could be
due to an inadequate dose or to an inadequate exposure time period.
    In a recent abstract, Mirsalis, Tyson, and Butterworth (1982) reported
negative results in the in vivo UDS assay after exposure of rats to CC14  at
400 mg/kg, which is a larger dose than was used in the above study.  However,
no details were reported in the abstract and it is not known whether even this
dose was adequate.
     Craddock and Henderson (1978) carried out an in^ vivo UDS  study in which
hepatocyte nuclei were isolated and then assayed for radioactivity by
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scintillation counting rather than by grain counting.  This method may be
superior to the whole-cell  grain counting procedure used by Mlrsalls and
Butter-worth (1980) as described above, particularly for chemicals that may
cause low UDS activity, because a small  effect could be obscured when
background cytoplasmic grain counts are subtracted from the nuclear grain
counts.  In this study, Craddock and Henderson used a CC14 dose of 4000
mg/kg, which is significantly larger than the LD$Q (2800 mg/kg).  Negative
results were obtained after a 2-hr exposure.  A positive effect was observed
after a 17-hr exposure.  The authors suggested that this result may have been
due to secondary effects such as lysosomal damage, which may result in release
of DMA degradative enzymes.
     In summary, the above in vivo UDS results suggest that CC14 may not
damage DMA.  However, additional in vivo UOS studies at doses just below those
resulting in hepatotoxicity and at exposure time periods longer than 2 hr are
needed before a decision on the DMA damaging potential of CC14 can be made.
Also, use of a procedure for the UDS assay in which the radioactivity of
isolated nuclei Is assayed, rather than one in which grain counts of nuclei
are corrected for grain counts in the cytoplasm, may better allow for
detection of low levels of UDS.

SUGGESTED ADDITIONAL TESTING
    Suggested additional testing falls into five categories:
    1.  The DNA damage studies reported by Craddock and Henderson (1978) and
Mirsalis and Butterworth (1980), which suggest that CC14 does not damage DNA
following in vivo treatment of rats, should be corroborated.  Testing of
CC14 doses lower than the LD$Q (2800 mg/kg) but higher that those tested
by Mirsalis and Butterworth and for exposure time periods longer than 2 hr is
needed.
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    2. Additional data is needed to corroborate the Callen e_t jil_. (1980) study
in the yeast system, which utilizes an endogenous activation system and is
capable of assaying for point mutations, mitotic crossing over, and gene
conversion.  The Callen et^^. study is the only yeast study found so far.
    3.  Additional cytogenetic testing for chromosome effects in mammalian
systems is needed before CC14 can be considered to be adequately tested for
chromosome damage.  Because EDTA has been reported to decrease cytotoxicity
due to CCl4.in bacteria (Cooper and Witmer 1982), perhaps in vitro mammalian
liver cell cytogenetic assays should be carried out in the presence of EDTA so
that higher levels of CC14 could be assayed than were used in the Dean and
Hodson-Walker (1979) study.  In addition, in vivo cytogenetic studies such as
the bone marrow micronucleus test, are needed.
     4.  Corroboration of the preliminary evidence for the weakly mutagenic
response in the Ames test reported by Cooper and Witmer (1982) is needed.  The
same experimental conditions (fresh rabbit liver 39 and exposure of the
bacteria in suspension to CC14 under reduced oxygen tension in the presence
of EDTA) should be used and several concentrations of CC14 should be tested
to establish whether or not a dose-response relationship exists.
    5.  Studies on the ability of CC14 to reach reproductive organs and
cause germ cell  mutation were not available.  If results from the tests
suggested above for somatic cell mutation are positive, then studies assessing
heritable risk are needed.  See Mutagenicity Risk Assessments:  Proposed
Guidelines published in the Federal Register in 1980 for guidance on such
tests.

SUMMARY AND CONCLUSIONS
     CC14 has been tested for its mutagenic potential in bacteria, yeast,	
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and a mammalian cell line and for its DNA damaging potential  In rat
hepatocytes when administered In vivo.  Six of the seven point mutation
studies were negative.  The remaining study (Cooper and Witmer 1982) was
preliminary and only suggestive of a weak mutagenic response.
     In none of the negative studies was it shown that CC14 was activated or
metabolized by the exogenous S9 activation system used.  Metabolism of
2-am1noanthracene or vinyl compounds (used as positive controls) is probably
an inadequate indication that the activation system can metabolize 0014.
These substances are very different from CC14.  A better indication that the
activation system is sufficient for metabolism of CC14 may be to show that
it metabolizes 14CCl4 to intermediates that bind to macromolecules.  It is
also conceivable that potentially mutagenic reactive intermediates of CCI^
(such as the free radical -CC^ and phosgene) are generated in the
presence of an S9 activation system but that they are too short-lived to
interact with DNA in in vitro test systems.
    The Call en et aU (1980) study was designed to overcome this problem by
the use of an  in vivo activation system in yeast.  Positive mutagenicity and
DNA damage results were reported.  However, because of the lack of
corroborative studies, the evidence is not adequate to conclude whether or not
CC14 is genotoxic.  Binding studies by Rocchi jit aH_. (1973) and by Diaz
Gomez and Castro (1980a, 1980b, and 1981) indicate that metabolically
activated CC14 can interact with DNA.
     Therefore, the negative genotoxicity test results that have been reported
may be due to any of three (or more) factors:  (i) excessive volatilization
and escape of CC14 if appropriate precautions are not taken,  (ii) inadequate
activation of CCI^ by the S9 system used to a metabolite capable of causing
mutations (e.g., 'CCH or phosgene), or (iii) inability of any reactive—	>
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Intermediates formed to reach DNA before being scavenged by lipid and protein
(particularly under conditions of exogenous activation, such as in the Ames
test).
     Additional tests should be conducted in which appropriate measures are
taken to ensure that (1_) volatilization and escape of CC14 does not decrease
exposure of the test organism or cell to levels of CC14 that are too low to
be effective, (11) metabolic activation 1s occurring, and (111) DNA 1s exposed
to the activated chemical species.
    In summary, evidence described in this report is insufficient to allow any
conclusion to be made concerning the genotoxicity of CC14..  The borderline
results for binding of reactive intermediates to DNA (Rocchi et £l_. 1973, and
Diaz Gomez and Castro 1980a and 1981), the study of Call en et al_. (1980), and
the highly preliminary evidence for mutagenicity in the Ames assay (Cooper and
Witmer 1982) are insufficient evidence for genotoxicity, but are suggestive of
weak genotoxic effects and are an indication that further studies should be
done.
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Mirsalis, J.C., C.K. Tyson, and B.E. Butterworth.   1982.  Induction of DNA
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Simmon, V.F., K. Kauhanen,  and R.G. Tardiff.   1977.  Mutagenic activity of
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Trudell, J.R., B. Bosterling, and A.J.  Trevor.  1982.  Reductive metabolism of
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Uehleke, H., H. Greim, M. Kramer, and T. Werner.  1976.   Covelant binding of
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Uehleke, H., H. Greim, M. Kramer, and T. Werner.   1977.  Metabolic
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-------