DRAFT CRITERIA DOCUMENT
FOR BENZENE
FEBRUARY 1984
Prepared by
Li£e Systems, Inc.
Contract No. EPA-68-02-3659
for
HEALTH EFFECTS BRANCH
CRITERIA AND STANDARDS DIVISION
OFFICE OF DRINKING WATER
.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

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Disclaimer
This document is a preliminary draft. It has not been released
formally by the Office of Drinking Water, U.S. Environmental
Protection Agency, and should not at this stage be construed to
represent Agency policy. It is being circulated for comments
on its technical merit and policy implications.

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TABLE OF CONTENTS
PAGE
LIST OF FIGURES			iii
LIST OF TABLES		iii
I. SUMMARY		1-1
II-l
II. GENERAL INFORMATION AND PROPERTIES 		II-l
A.	Physical and Chemical Properties 		II-l
B.	Manufacturing and Uses .	II-l
C.	Extent and Significance of Problem	II-3
III. HUMAN EXPOSURE *	III-l
IV. PHARMACOKINETICS/METABOLISM	IV-1
A.	Excretion of Unchanged Benzene 		IV-1
B.	Metabolism of Benzene			IV-2
C.	Disposition of Benzene in Humans	IV-9
V. RELATIVE SOURCE CONTRIBUTION*
VI. HEALTH EFFECTS IN ANIMALS	VI-1
A.	Acute and Chronic Effects	VI-1
B.	Immunological Aspects of Toxicity	VI-8
C.	Potential for Mutagenesis and Leukemogenesis . .	VI-9
D.	Potential for Teratogenicity and Fetotoxicity. .
VII. HEALTH EFFECTS IN HUMANS	VII-1
A.	Acute and Chronic Toxicity 		VII-1
Aplastic Anemia; Pancytopenia	VII-3
Acute Myeloblastic Leukemia	VII-9
B.	Epidemiology 		Vll-ll
Studies of Persons Exposed to Benzene	VII-11
Studies of Persons with Possible Exposure
to Benzene 		VII-17
~Prepared by the Science and Technology Branch
i

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PAGE
VIII. MECHANISM OF TOXICITY 	 VIII-1
IX. RISK ASSESSMENT	 IX-1
X. QUANTIFICATION OF TOXICOLOGICAL EFFECTS 	 X-l
XI. REFERENCES 	 XI-1
ii

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LIST OF FIGURES
FIGURE PAGE,
1 Metabolic Pathway of Benzene in Liver 	 IV-21
LIST OF TAB^/s
TABLE	PAGE
1	Estimated Benzene Levels in Food	III-3
2	Foods Containing Benzene	III-4
3	Atmospheric Concentration of Benzene	III-6
4	Summary of Estimated Population Exposures to
Atmospheric Benzene from Specific Emission Sources. . III-9
5	Summary of Estimated Total Exposures of People
Residing in the Vicinity of Atmospheric Benzene
Sources 	 111-10
6	Studies of Potential Benzene Induced Teratologic
Responses by Inhalation 	 ....
7	Summary of Benzene Inhalation Teratology	VI-16
iii

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I • SUMMARY
Benzene is one of the world's major commodity chemicals.
It is derived from petroleum and coal and is used both as a solvent
and as a starting material in chemical syntheses. The numerous
industrial uses of benzene over the last century need not be
recounted here, but the most recent addition to the list of uses of
benzene is as a component in a mixture of aromatic compounds added
to gasoline for the purpose of replacing lead compounds as anti-
knock ingredients.
The best Known and longest recognized toxic effect of
benzene is the depression of bone marrow function seen in occupa-
tionally exposed individuals. These people have been found to
display anemia, leucopenia, and/or thrombocytopenia. When pancy-
topenia, i.e., the simultaneous depression of all three cell types,
occurs and is accompanied by bone marrow necrosis, the syndrome
is called aplastic anemia. In addition to observing this disease
in humans and relating it to benzene exposure, it has been pos-
sible to establish animal models which mimic the human disease.
The result has been considerable scientific investigation into
the mechanism of benzene toxicity.
Although the association between benzene exposure and
aplastic anemia has been recognized and accepted throughout most
of this century, it is only recently that leukemia, particulary
of the acute myelogenous type, has been related to benzene.

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1-2
The acceptance of benzene as an etiological agent in aplastic
anemia in large measure derives from our ability to reproduce the
disease in most animals treated with sufficiently high doses of
benzene over the necessary time period. Unfortunately, despite
extensive efforts in several laboratories, it has not been pos-
sible to establish a reproducible, reliable model for the study
of benzene-induced leukemia. The recent demonstration that
several animals exposed to benzene either by inhalation or in
the drinking water during studies by Drs. B. Goldstein and
C. Maltoni (cf. Section VI) suggests that such a model may be
forthcoming. Nevertheless, at this time it is not clear whether
bone marrow damage of the type that leads to aplastic anemia is
required for the development of leukemia.
Most studies of benzene toxicity have involved dosing
animals with benzene either by inhalation or by injection using
high doses to ensure a toxic reponse. Very few studies have
concentrated on the oral route of administration and none have
concentrated on administering benzene by mouth at the low doses
occasionally detected in drinking water. Thus, the evaluation
of benzene toxicity in this report takes advantage of the benzene
literature as it currently exists and cannot directly answer the
questions posed by the problem of benzene in drinking water,
although it is known that benzene can be absorbed via the GI
tract. Nevertheless there has not been a demonstration showing
bone marrow depression by benzene can be avoided by selecting an
alternate route of administration.

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1-3
The report will summarize the exposure of the population
to benzene with emphasis on exposure through water. The toxicology
of benzene in animals will be reviewed and the problem of attempts
to develop an animal model for benzene-induced leukemia will be
covered. Emphasis will be given to a discussion of modern theories
on the mechanism of benzene induced toxicity and the role played by
benzene metabolism. A summary of studies of potential mutagenicity
and teratogenicity is included. The extensive literature on both
the toxicity and carcinogenicity effects of benzene in humans is
described. Finally, a section on carcinogenic risk assessment has
been prepared.

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II. GENERAL INFORMATION AND PROPERTIES
A.	Physical and Chemical Properties
Benzene is an aromatic hydrocarbon, has the molecular
^formula C^H^ and a molecular weight of 78.1 (Weast^et al., 1965).
Under standard conditions, benzene is a colorless liquid with a
very characteristic odor. It is highly flammable (limits of flam-
mability in air of 1.5-8.0% by volume, and flashpoint of -ll.l'C)
and is volatile (vapor pressure of 100 mm Hg at 26*C). Benzene
is relatively soluble in water (1.8 g/L at 25"C) and miscible with
a variety of organic solvents. Its density, 0.8737 g/mL at 25"C,
is lower than that of water so that undissolved benzene floats on
top of water. The pure liquid freezes at 5.553'C and boils at
80.100®c (Ayers and Muder, 1964). The vapors of benzene are nearly
three times heavier than air (Lange and Porker, 1961), causing
them to settle in low places if the ambient air is relatively still.
Benzene forms a two-phase, minimum boiling azeotrope with
water at a benzene concentration of 91% by weight, boiling at 69 °C.
It also forms ternary azeotropes with other organic compounds and
water (Perry and Chilton, 1973; Lange and Forker, 1961; Horsely,
1974). This factor must be considered if evaporative purification
systems are used to remove benzene from water.
B.	Manufacturing and Uses
Benzene is produced in huge quantities in the U.S. A
total of 1488 million gallons of industrial and specification grades

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II-2
were produced in the U.S. in 1978, 96% of which came from petroleum
refining operations (1435 million gallons) and the remaining 4% of
which were derived from coke oven operations (53 million gallons).
The contributions from coke oven operations has diminished markedly
over an 11-year periods 91 million gallons in 1967; 65 million
gallons in 1977; and 53 million gallons in 1978 (U.S. ITC, 1979).
The U.S. ITC (1979) listed 32 manufacturers as petroleum refining
sources in 1978.
A very large portion of benzene is also a component in
gasoline (average concentration < 1% (Runion, 1975)). It is
important, particularly for the unleaded fuels, because of its
antiknock characteristics. For the past several years prior to
and including 1978, about 1650 million gallons of benzene were
used in gasoline (U.S. ITC, 1979). For the same period, most of
the industrial and specification grade benzene, approximately 1400
million gallons, were produced for chemical conversion, such as
the manufacture of ethylbenzene/styrene (in polystyrene plastics),
cyclohexane (in nylon), cumene/phenol (in phenolic resins for
construction, automobiles, appliances and numerous other uses) and
aniline (for urethanes and urethane elastomers) (U.S. ITC, 1979).
It is also a preliminary raw material for chemicals such as nitro-
benzene, maleic anhydride, chlorobenzenes, detergent alkylate (Mara
and Lee, 1978) and pesticides (OSHA, 1978).
A much smaller amount, e.g., < 2% (Mara and Lee, 1978)
is used for solvent purposes in such products as trade and indus-
trial paints, rubber cements, adhesives, paint removers, in the

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II-3
artificial leather, rubber goods and rotogravure industries, and
as a laboratory solvent (OSHA, 1979; Mara and Lee, 1978).
C. Extent and Significance of Problem
One study estimated that 79 million pounds of benzene
are lost annually during commercial production, storage and trans-
port (Walker, 1976). This is largely from petroleum cracking
facilities, but also from coke oven operations. These emissions
are related to operations such as equipment repair, the cleanup
of small spills and transfer of materials. Process equipment
such as blow down systems, wastewater separators, cooling towers
and storage facilities, and leaking production components and
seals contribute fugitive emissions as well. Operations with
gasoline (storage, transport and use) also contribute to the
total annual loss. Projections of emission from such sources
have been reported in detail by Mara and Lee (1978) and OSHA
(1978).
Due to benzene's volatility and solubility, it would
be likely to migrate easily through the environment. In addi-
tion to direct contamination of water, a certain proportion of
the benzene in the atmosphere will partition into water droplets
(e.g., in clouds) and enter surface waters as precipitation.
Unsubstituted benzene (chemically unmodified) does not react with
water, except at elevated temperature and pressure. Therefore,
hydrolysis is unlikely. Microbial degradation of benzene has been

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II-4
observed during wastewater treatment, indicating that biodegrada-
tion probably occurs naturally—though probably very slowly (Mara
and Lee, 1978). Based on their review of various laboratory
experiments with ultraviolet light, Mara and Lee (1978) have con-
cluded that atmospheric degradation by phcrt:ochemical reactions is
also possible under certain conditions. Limited absorption of
benzene by naturally occurring clays and humus may also occur.
In view of the heavy environmental emissions of benzene and the
limited natural removal processes, its widespread presence in
the environment is likely, however.

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Ill, HUMAN EXPOSURE
Humans may be exposed to benzene in drinking water, food, and air.
Detailed information concerning the occurrence of and exposure to benzene in
the environment is presented in another document entitled "Occurrence of
Benzene in Drinking Water, Food, and Air" (Letkiewicz et al. 1983). This
section summarizes the pertinent information presented in that document in
order to assess the relative source contribution from drinking water, food,
and air.
Exposure Estimation
This analysis is limited to drinking water, food, and air, since these
media are considered to be general sources common to all individuals. Some
individuals may be exposed to benzene from sources other than the three con-
sidered here, notably in occupational settings and from the use of consumer
products containing benzene. Even in limiting the analysis to these three
sources, it must be recognized that individual exposure will vary widely based
on many personal choices and several factors over which there is little
control. Where one lives, works, and travels, what one eats, and physiologic
characteristics related to age, sex, and health status can all profoundly
affect daily exposure and intake. Individuals living in the same neighborhood
or even in the same household can experience vastly different exposure
patterns.
Unfortunately, data and methods to estimate exposure of identifiable
population subgroups from all sources simultaneously have not yet been
developed. To the extent possible, estimates are provided of the number of
individuals exposed to each medium at various benzene concentrations. The
70-kg man is used for estimating intake.
a. Water
Cumulative estimates of the l/.S. populations exposed to various benzene
levels in drinking water from public drinking water systems are presented in
Table IV-I. The values in the table were obtained using Federal Reporting
Data Systems data on populations served by primary water supply systems (FRDS
1983) and the estimated number of these water systems that contain a given
1

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Table IV—i• Total Estimated Cumulative Population (In Thousands) Exposed to Beiuene In Drinking Water
Exceeding the Indicated Concentration
Number of
people served
In U.S.	Cumulative population (thousands) exposed to concentrations (uq/l) of:	
Syste» type (thousands) _>0. 5	>5	>10 >20 >30 >40	>50	>60	>70	>80	>90	>J0Q
Groundwater	73,473	1,037 >55	49 6.5 3.2 0.5 0.25	0.25 0.05	0	0	0
Surface water	UP,946	3,792 	0	_0 0.0	0.0 0.0	0.0	0.0	0.0	_j)	o
Total	214,419	4,829 155	49 6.5	3.2	0.5	0.25	0.25 0.05	0	0	0
<* of total)	(t00J[>	(2.3$)	(<0.1S)	(<0.1J)	(<0.1J)	(<0.1J)	(<0.l|)	(<0.1$>	(<0.1*) (<0.1j£) (0*)	(0?)	(0*>

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level of benzene. An estimated 4,829,000 individuals (2.3% of the population
of 214,419,000 using public water supplies) are exposed to levels of benzene
in drinking water at or above 0.5 ug/1 , while 155,000 individuals (< 0.1%) are
exposed to levels above 5 ug/1. It is estimated that 3,200 individuals are
exposed to levels greater than 30 ug/1. Of the approximately 4.7 million
people exposed to levels ranging from 0.5 to 5 ug/1, 3.8 million (79%) obtain
water from surface water supplies. However, all exposure to benzene in drink-
ing water at levels above 5 ug/1 is expected to.be from groundwater sources.
No data were obtained on regional variations in the concentration of
benzene in drinking water. The highest concentrations are expected to occur
near sites of oil spills and solvent use and also, in the case of groundwater,
near waste disposal sites.
Daily intake levels of benzene from drinking water were estimated using
various exposure levels and the assumptions presented in Table IV-11. The
data in the table suggest that the majority of the persons using public drink-
ing water supplies would be exposed to intake levels below 0.014 ug/kg/day.
Table IV-II. Estimated Drinking Water Intake of Benzene
Persons using supplies
exposed to indicated levels
Exposure level
(ug/1)
Population
% of Total
population
Intake (uq/kg/day)
2.0.5
4,829,000
2.3%
>0.014
>5.0
155,000
<0.1%
>0.14
>10
49,000
<0.1%
>0.29
>40
500
«0.1%
>1.1
Assumptions: 70-kg man, 2 liters of water/day.
An indication of the overall exposure of the total population to benzene
can be obtained through the calculation of population-concentration values.
These values are a summation of the individual levels of benzene to which each
member of the population is exposed. An explanation of the derivation of
these values is presented in Appendix C. The estimates were 3.5 x 10® ug/1 x
3

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7	A
persons (best case), 1.5 x 10 ug/1 x persons (mean best case), 1.2 x 10° ug/1
O
x persons (mean worst case), and 1.3 x 10 ug/1 x persons (worst case).
Assuming a consumption rate of 2 liters of water/day, population-exposure
values of 7.0 x 106 ug/day x persons (best case), 3.0 x 107 ug/day x persons
Q	Q
(mean best case), 2.4 x 10 ug/day x persons (mean worst case), and 2.6 x 10
ug/day x persons (worst case) were derived.
b.	Diet
Little information was obtained on the dietary intake of benzene. Of the
few foods with quantified levels of benzene, eggs contained the highest
amount; one egg may contain as much as 100 ug of benzene (Drill and Thomas
1979).
Dietary benzene intake as high as 250 ug/day has been estimated by the
National Cancer Institute from beef, eggs, and rum alone (Drill and Thomas
1979). Assuming that the average adult male weighs 70 kg, an intake of 250
ug/day would be equivalent to 3.6 ug/kg/day. In the absence of further data,
the dietary intake of benzene was assumed to be at that level. Variances in
individual exposure due to differences in diet could not be assessed.
It was expected that dietary levels of benzene would vary somewhat with
geographical region, with higher levels occurring in foods from areas near
sources of benzene. However, since benzene may occur naturally in foods
(Drill and Thomas 1979), geographical variations may be overshadowed by back-
ground levels present in the foods. Because of the limited data, no estimates
of variations in intake by geographical region could be made.
c.	Ai r
Exposure to benzene in the atmosphere varies from one location to
another. The highest level of benzene reported in the atmosphere was 1,100
ug/m^ (Pellizzari 1979 cited in Brodzinsky and Singh 1982). High l«vels,
averaging greater than 100 ug/rn"^, have been detected in other area;,. Normal
levels, however, are somewhat lower. Brodzinsky and Singh (1982) calculated
median air levels of benzene for rural/remote areas, urban/suburban areas, and
3
source dominated areas of 4.5, 8.9, and 9.6 ug/m , respectively.
4

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The monitoring data available are not sufficient to determine regional
variations in exposure levels for benzene. However, urban and industrial
areas appear to contain higher levels, as expected.
The daily respiratory intake of benzene from air was estimated using the
assumptions presented in Table IV-111 and the median and maximum levels for
benzene reported above. The estimates in Table IV-III indicate that the daily
benzene intake from air for adults in source dominated areas is approximately
3 ug/kg/day. In contrast, the intake calculated using the maximum level
reported is 360 ug/kg/day; few if any persons are believed to be exposed at
that level. The values presented do not account for variances in individual
exposure or uncertainties in the assumptions used to estimate exposure.
Table IV-III. Estimated Respiratory Intake of Benzene
Exposure (ug/m^)
Intake (ug/kg/day)
Rural/remote (4.5)
1.5
Urban/suburban (8.9)
2.9
Source dominated (9.6)
3.2
Maximum (1,100)
360
Assumptions: 70-kg man, 23 of air inhaled/day (ICRP 1975).
In addition to the available monitoring data, Mara and Lee (1978) have
provided estimates of atmospheric levels of benzene and the size of the
exposed population by applying air dispersion models to several benzene emis-
sion sources. The computed average annual concentrations and the size of the
populations exposed from each source are presented in Tables IV-IV and IV-V.
The data in Table IV-IV, which indicate that about half of the U.S.
population is exposed to average benzene concentrations betwoen fJ.3-13 ug/m »
were calculated by assuming that the individuals exposed remain at one loca-
tion (i.e., their residence) 24 hours per day. Table IV-V provides for
several scenarios concerning mobility of individuals (I.e., time is spent in
several locations rather than 24 hours at their residence). These latter
assumptions shift the estimated distributions to suggest that half of the U.S.
population is exposed to'average concentrations between 3.5-13 ug/m^.
5

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Table IV-IV. Summary of Estimated Population Exposures to Atmospheric Benzene
from Specific Benzene Emission Sources3
~	Comparison
Population exposed to benzene concentrations (ug/m )b		amona sources
	Annual average		*	(10 ug/m -
Source
0.3-3.2
3.5-13
13-32 > 32 Totalc
person-years)
Chemical manufacturing
6,000,000
1,000,000
200,000 80,000 7,300,000
27
Coke ovens
300,000

300,000
0.6
Petroleum refineries
5,000,000
3,000
5,000,000
8.0
Solvent operations
d

—
—
Storage and distribution
of gasoline
e

	

Automobile emissions
- urban
69,000,000
45,000,000
110,000,000
480
Gasoline service stations
- urban
30,000,000
2,000,000
32,000,000
61
People using self-service
gasoline


f 37,000,000
5.1
aPersons living in the vicinity of benzene sources are assumed to spend all their time in that location.
L
Data converted frcm ppb to ug/m by multiplying by 3.2.
Population estimate., are not additive vertically because of double-counting. Totals are rounded to two
significant figures.
dExact determination is impossible.
eAnnual average estimated at << 0.3 ug/m . The population exposed was not determined but is assumed to be very
smal1.
f	3
Estimated at 780 ug/m for 1.5 hr/year/person.
Source: Mara and Lee 1978

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Table IV-V. Summary of Estimated Total Exposures3 of Persons Residing in the Vicinity of
Atmospheric Benzene Sources
Number exposed
Vicinity of residence
Annual average benzene concentration (ug/m )
0.3-3.2	3.5-13 13-32 > 32	Total1
Comparison
b ,c
among source
(10° ug/mJ-
person-years)
Chemical manufacturing	3,900,000
Coke ovens	200,000
Petroleum refineries	3,250,000
Urban areas
3,100,000
100,000
1,750,000
110,000,000
200,000 80,000
7,300,000
300,000
5,000,000
110,000,000
32
0.6
14
800
aThe term "total exposure" is the sum of an individual's exposure to atmospheric benzene from a variety of
activities during a year. It is assumed that people spend part of their time away from their residence,
resulting in exposures to different benzene concentrations depending on their activity (i.e., commuting to
work, shopping, traveling to personal business). Nonurban exposures are not included in this analysis, but
are expected to r^nge from undetectable to 3.2 ug/m .
^Rounded to two significant figures.
cMedian values were used instead of the midpoint of the ranges to allow better comparison with Table IV-IV.
Source: Mara and Lee 1978

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The tables also present population-concentration estimates for benzene.
The addition of individual population-concentration estimates in Table IV-IV
results in a combined value of 5.8 x 10^ ug/m^ x persons; the addition of
estimates in Table IV-V results in a value of 8.5 x 10^ ug/m^ x persons. [It
should be noted that this addition may result in some double-counting (Table
IV-IV).] Assuming an inhalation rate of 23 m"* of air/day, a population-
exposure of 1.3 x 1010 ug/day x persons (Table IV-IV) or 2.0 x 10^ ug/day x
persons (Table IV-V) was calculated.
SUMMARY
Table IV-VI presents a general view of the total amount of benzene
received by an adult male from air, food, and drinking water. Four separate
exposure levels in air, five exposure levels in drinking water, and one expo-
sure level from foods are shown in the table.
The data presented have been selected from an infinite number of possible
combinations of concentrations for the three sources. The actual exposures
encountered would represent some finite subset of this infinite series of
combinations. Whether exposure occurs at any specific combination of levels
is not known; nor is it possible to determine the number of persons that would
be exposed to benzene at any of the combined exposure levels. The data pre-
sented represent possible exposures based on the occurrence data and the
estimated intakes.
Brodzinsky and Singh (1982) calculated a median urban/suburban air level
of benzene of 8.9 ug/nr based on air monitoring data. Assuming an air level
of 8.9 ug/m^ and the estimated benzene intake of 3.6 ug/kg/day from foods,
drinking water would be the predominant source of benzene exposure in the
adtilt male only at drinking water levels above 230 ug/1. An accurate assess-
ment of the number of individuals for which drinking water is the predominant
source of exposure cannot be determined from the data since specific locations
containing high concentrations of benze-.e in drinking water and low concentra-
tions of benzene in ambient air and fo^a are unknown.
Population-exposure estimates for benzene in drinking water and air were
presented previously. Estimates for drinking water ranged from 0.07-2.6 x 10a
ug/day x persons; estimates for ambient air ranged from 1.3-2.0 x 10^ ug/day
x persons. These estimates suggest that ambient air may be a greater source
8

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Table IV-VI. Estimated Intake of Benzene
from the Environment by Adult Mai as in ug/kg/day
(% from Drinking Water)
Concentration in

Concentration in air

drinking water
(ug/1)
Rural/remote
(4.5 ug/m3)
Urban/suburban
(8.9 ug/m3)
Source dominated
(9.6 ug/m3)
Maximum
(1,100 ug/m3)
0
5.1 (0%)
6.5 (0%)
6.8 (0%)
360 (0%)
0.5a
5.1 (0.27%)
6.5 (0.1%)
6.8 (0.1%)
360 (0.004%)
5.0b
5.2 (2.7%)
6.6 (2.1%)
6.9 (2.0%)
360 (0.04%)
10c
5.4 (5.4%)
6.8 (4.3%)
7.1 (4.1%)
360 (0.08%)
40d
6.2 (18%)
7.6 (14%)
7.9 (14%)
360 (0.31%)
Intake from each source (see Sections 5.1-5.3):
Water: 0.5 ug/1 :	0.014 ug/kg/day
5.0 ug/1:	0.14 ug/kg/day
10 ug/1:	0.29 ug/kg/day
40 ug/1:	1.1 ug/kg/day
Air:	4.5 ug/m^: 1.5 ug/kg/day
8.9 ug/m3: 2.9 ug/kg/day
9.5 ug/m3: 3.2 ug/kg/day
1,100 ug/m3:	360 ug/kg/day
Food:	3.6 ug/kg/day
a4,829,000 individuals using public drinking water systems are estimated to be
exposed to levels _> 0.5 ug/1 (2.3% of population using public water supplies).
^155,000 individuals using public drinking water systems are estimated to be
exposed to levels > 5.0 ug/1 (< 0.1% of population using public water
supplies).
c49,000 individuals using public drinking water systems are estimated to be
exposed to levels > 10 ug/1 (< 0.1% of population using public water
supplies).
d500 individuals using public drinking water systems are estimated to be
exposed to levels > 40 ug/1 (<<• 0.1% of population using public water
supplies).
9

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of exposure to benzene than drinking water on a general population basis.
Comparison of these estimates, however, may be deceiving since the same popu-
lation-exposure level can occur if: 1) a whole population is exposed to
moderate levels of a chemical or 2) some segments of the same population are
exposed to high levels and others to low levels. The population-exposure
values presented give no indication of the relative predominance of drinking
water and air as specific sources of benzene on a site-by-site or subpopula-
tion basis.
The relative source contribution data are based on estimated intake and
do not account for a possible differential absorption rate for benzene by
route of exposure. The relative dose received may vary from the relative
intake. In addition, the relative effects of the chemical on the body may
vary by different routes of exposure.
10

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REFERENCES
Brodzinsky R, Singh HB. 1982. Volatile organic chemicals in the atmosphere:
An assessment of available data. Prepared by SRI International, Menlo Park,
CA, for Environmental Sciences Research Laboratory, Office of Research and
Development, U.S. Environmental Protection Agency, Research Triangle Park,
NC. Contract No. 68-02-3452.
Drill S, Thomas R. 1979. Environmental sources of benzene exposure: Source
contribution factors. Prepared by Mitre Corporation for the U.S. Environ-
mental Protection Agency. EPA-570/9-79-004.
FRDS. 1983. Federal Reporting Data System. Facilities and population served
by primary water supply source (FRDS07), April 19, 1983. U.S. Environmental
Protection Agency, Washington, DC.
ICRP. 1975. International Commission on Radiological Protection. Report of
the task force of reference man. ICRP Publication 23. New York: Pergamon
Press.
Letkiewicz F, Johnston P, Macaluso C, Elder R, Yu W, Bason C. 1983.
Occurrence of benzene in drinking water, food, and air. Prepared by JRB
Associates, McLean, VA, for Office of Drinking Water, U.S. Environmental
Protection Agency, Washington, DC. EPA Contract No. 68-01-6388.
Mara SJ, Lee SS. 1978. Assessment of human exposures to atmospheric
benzene. Prepared by SRI International for Office of Air Quality Planning and
Standards, U.S. Environmental Protection Agency, Research Triangle Park, NC.
EPA-450/3-78-031.
Pellizzari ED. 1979. Information on the characteristies of ambient organic
vapors in areas of high chemical production. Prepared by Research Triangle
Institute, Research Triangle Park, NC, for U.S. Environmental Protection
Agency. Cited in Brodzinsky and Singh 1982.
11

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IV. PHARMACOKINETICS/METABOLISM
A. Excretion of Unchanged Benzene
Benzene toxicity in humans is usually caused by inhala-
tion of ambient air containing benzene vapor. Following cessa-
tion of exposure the body burden of benzene is reduced either by
exhaling benzene in the expired air or by metabolism. The exha-
lation of unchanged benzene has been studied in dogs (Schrenk,
et al., 1941), rabbits (Parke and Williams, 1953), mice (Andrews,
et al., 1977a) and rats (Rickert, et: al_. , 1979). Schrenk, e_t
al. (1941) exposed dogs to 800 ppm benzene by inhalation and
determined that the time was related to the duration of exposure
because of the tendency of benzene to accumulate in body fat.
Parke and Williams (1953) administered l^C-benzene orally and
recovered approximately 43 percent of the administered dose as
unmetabolized benzene in trapped exhaled air. Rickert, et_ al.
(1979) reported that the excretion of unchanged benzene from the
lungs of rats followed a biphasic pattern suggesting a two-
compartment model for distribution and a t\/2 of 0-7 hr. This
agreed with experimental t^/2 values for various tissues which
ranged from 0.4 to 1.6 hr. Andrews, e_t al^. (1977a) administered
benzene to mice subcutaneously and recovered 72 percent of the
dose in the air. Simultaneous treatment with both benzene and
toluene (Andrews, et a_l. , 1977a; Sato and Nakajima, 1979b) or
benzene and piperonyl butoxide (Timbrell and Mitchell, 1977)
increases the excretion of unchanged benzene in the breath.

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IV-2
These compounds appear to act by inhibition of benzene metabolism
which thereby leaves more benzene available for excretion through
the lungs.
B. Metabolism of Benzene
The metabolic pathway for benzene,'as it is currently
understood, is shown in Figure 1. Unlike some previous reports
of this pathway no figures are given indicating the percentage of
each of these metabolites which are formed because there is great
variability in these estimates. The primary causes of the vari-
ability are the dose dependency of excretion of unchanged benzene
versus its conversion to metabolites and the species studied.
It has been shown since the latter part of the nine-
teenth century that benzene is biologically converted to phenol
(Schultzen and Naunyn, 1867) as well as to catechol and hydro-
quinone (Nencki and Giocosa, 1880). The first detailed studies
of the metabolites of benzene formed in vivo were reported by
Porteous and Williams (1949a,b), and with the advent of ^C-
benzene these studies were improved upon by Parke and Williams
(1953). Extensions of this work in recent years have largely
concentrated on metabolism in various animal species, on the
mechanism of benzene metabolism using in vitro techniques and
on attempting to relate benzene metabolism to its toxicity
(Snyder and Koosis, 1975; Snyder, et al., 1977).
In a landmark series of papers (Porteous and Williams,
1949a,b; Parke and Williams, 1953) R.T. Williams outlined the

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Benzene
NADPH
P
mrH |
+	k
0» ~

Expired unchanged
phenylmercaplurlc
acid
benzene
oxide
glutathione
epoxy
NHAc transferase
SCH, — CH
I
COOH
0>
benzene glycol
H
OH.
epoxide	[L
hydrase	OH
Trans-Trans
Cts-CIs muconlc acid
muconlc acid COOH
spontaneous
CCOOH
COOH
+ CO.+ H.O
COOH
(dehydrogenase)
hydroqulnol (hydroqulnone) phenol
|0H
HO
catechol
PAPS
sulpho-confugates
Conjugations ¦*
UDPG	HO
glucuronlc-conjugates
hydroxyhydroqulnol
OH
OH
myiiyui ui
O
alkaline sails
potassium phenylsulfale
OOCH((CHOH),CHCO,K
L-— o——!
MFO a mixed (unction oxidase
UDPQ a uridine diphosphate
glucuronyl transferase
PAPS b 3'phospho-adenoslrv
S'-phosphosullate
phenyl glucuronlde
eliminated In urine
FIGURE 1 METABOLIC PATHWAY OF BENZENE IN LIVER

-------
IV-4
broader aspects of benzene metabolism in rabbits by identifying
most of the metabolites in urine as well as those in expired
air. He later demonstrated that about one percent could be
recovered in bile (Abou-el-Marakem, et_ a]^. , 1967). The major
hydroxylation product was phenol which, along with some catechol
and hydroquinone, is found for the most part in urine conjugated
with ethereal sulfate or glucuronic acid. Unconjugated phenol
has been found in mouse (Andrews, et al_. , 1977a) and rat (Cornish
and Ryan, 1968) urine after benzene administration. Parke and
Williams (1953) also reported on the occurrence of phenylmercap-
turic acid and muconic aid. The later, along with labeled carbon
dioxide found in the expired air, suggested that some opening of
the ring occurred. Andrews, et a_l. (1977a) estimated that a 25 g
mouse could metabolize, at most, approximately 1 mmole of benzene
per day.
Longacre (1980) compared the excretion of benzene
metabolites in C57/B6 and DBA/2 mice. He found that the patterns
of metabolites were qualitatively similar when the urine was
chromatographed on DEAE-sephadex, but closer analysis demon-
strated that although the two strains excreted equal amounts of
catechol, the DBA/2 animal excreted more phenol and less hydro-
quinone than the C57/B6. It has yet to be determined whether
these differences play a role in the greater susceptibility of
the DBA/2 mouse to benzene toxicity than the C57/B6. However,
these studies emphasize the necessity to reevaluate the

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IV-5
the metabolites of benzene for each new species or strain of animals
in which benzene toxicity is studied.
Benzene metabolism has been studied in liver homogenates (Snyder
et. al., 1967; Hirokowa and Nomiyama, 1962; Sakamoto et. al., 1957),
cell supernatant fractions containing microsomes (Snyder et.al., 1967;
Kocis et.al., 1968; Sakamoto et.al., 1957; Sato and Nakajima, 197a,b)
and microsomes (Posner et.al., 1961; Snyder et.al.,1967; Gonasun et.
al.,1973; Drew et.al., 1974; Harper et.al., 1975; Tunek et.al., 1978).
It is clear from these studies that benzene is metabolized in liver
microsomes of rat, rabbit, and mouse. Gonasun et.al. (1973)
demonstrated the first step is mediated by the mixed function oxidases.
Jerina and coworkers (Jerina et. al., 1968; Jerina and Daly, 1974)
have outlined a pathway for benzene metabolism which revolves about the
formation of benzene oxide, an epoxide of benzene, as the first
product (Figure 1). This highly unstable intermediate rearranges
non-enzymatically to form phenol as the major metabolite of benzene
found in urine. Catechol formation is thought to result from the
hydration of benzene oxide by the enzyme epoxide hydratase followed
by oxidation to catechol. The intermediate dihydrodiol was observed
in rat urine by Sato et. al. (1963). The enzyme dihyrdodiol
dehydrogenase has been identified and purified by Vogel et. al. (in
press) and is thought to mediate the oxidation of benzene of benzene
dihydrodiol to catechol. The evidence for the epoxide intermediate
is that the addition of the epoxide to liver preparations yields the
same metabolites as benzene (Jerina et. al.,

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IV-6
1968) and the addition of excess hydratase enzyme increases the
formation of catechol (Tunek, et^ a_l. , 1978). Thus, it appears that
different metabolic pathways.
The metabolic pathway leading to the formation of hydro-
quinone has yet to be established. It may be formed via passage
of phenol through the mixed function oxidase but other enzymatic
steps have not been ruled out. There is greater likelihood, on the
basis of iri vitro studies that the premercapturic acid, i.e., the
glutathione conjugate, is formed by the addition of glutathione to
the epoxide and the reaction is mediated by the glutathione
transferase enzyme (Jerina, et al., 1968).
The metabolism of benzene in liver preparations, i.e.,
homogenates, 9,000 g supernatants or microsomes, can be stimulated
by treating animals with enzyme inducing agents prior to sacrifice.
Benzene (Snyder, et: a_l. , 1967; Saito, et al. , 1973; Gonasum, et al. ,
1973), phenobarbital (Snyder, et_ al_. , 1967; Ikeda and Ohtsuji, 1971;
Drew and Fouts, 1974; Gut, 1978; Tunek, et ajU , 1979; Tunek and
Oesch, 1979), 3-methylcholanthrene (Drew and Fouts, 1974), DMSO
(Kocsis, e_t al^. , 1968) and chlordiazepam, diazepam and oxazepam
(Jablonska, et al^. , 1975) all induce benzene hydroxylase activity.
The Ln vivo significance of inducing benzene metabolites has been
questioned by Gut (1978) who has argued that induction of microsomal
benzene metabolism may not be reflective of the overall raste of
benzene metabolism because iji vitro systems do not provide an accu-
rate picture of the pharmacokinetics observed ijri vivo. Further
studies in which the effects of these inducers on metabolism

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IV-7
in vivo and in vitro in the same experiment as well as on toxicity
of benzene will be required to clarify this issue.
Conversely, direct addition of any of several chemicals
to the liver preparations in vitro can inhibit benzene metabolism.
Thus, carbon monoxide, aniline, metyrapone, SKF525A, aminopyrine,
cytochrome c (Gonasun, 1973), aminotriazole (Hirokawa and Nomiyama,
1962) and toluene (Andrews, et al., 1977a) have been shown to inter-
fere with benzene metabolism in vitro.
The unique behavior of the mixed-function oxidase system
that metabolizes benzene has recently been described (Tunek and
Oesch, 1979). These experiments, which employed control, benzene-
induced and phenobarbital-induced rat liver microsomes, determined
the effects of either metyrapone or Renex 190 in vitro on 7-ethoxy-
coumarin deethylation and benzene hydroxylation. As expected, it
was found that metyrapone or Renex 190 treatment inhibited 7-ethoxy-
coumarin metabolism in control microsomes. Considerably more inhi-
bition was observed in phenobarbital-induced microsomes. Pretreat-
ment with benzene, however, resulted in no greater inhibition than
with control microsomes. Furthermore, addition of either metyra-
pone metyrapone or Renex 190 to microsomes increased benzene hydroxy-
lation in both control and benzene-induced microsomes but not in
phenobarbital-induced microsomes. It is significant that while
Tunke and Oesch found that metyrapone increased benzene metabolism
in rat liver microsomes, Gonasun, et al. (1973) found that metyrapone
inhibited benzene metabolism in mouse liver microsomes. While
phenobarbital pretreatment may induce at least one of these

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IV-8
monooxygenases, benzene pretreatment may induce the benzene
monooxygenase forms(s) that is (are) normally present in control
microsomes.
Miller and Miller (1977) have for many years propounded
the concept that the toxicity or carcinogenicity of many xenobiotics
may result from the metabolic conversion of the xenobiotic to a
chemically reactive intermediate which covalently binds to either
cellular protein or nucleic acids. Adverse effects ensue as a
result of these structural alterations unless they can be repaired
by the various mechanisms available to the cell. Snyder, et^ al.
(1978) have studied the time course of the irreversible binding of
^H-benzene metabolite(s) to proteins in both mouse liver and bone
barrow. Covalent binding of benzene-dervied radioactivity
increased both with dose and frequency of dosing. Eventually the
binding in liver reached a plateau of the binding in bone marrow
decreased as benzene toxicity became severe. The decrease in
protein binding in the marrow was explained by a replacement of
protein by fat as the marrow became hypoplastic. Other labora-
tories have also studied tissue binding of radioactivity after
labeled benzene administration. Irons, et a_l. (1980) observed both
benzene matbolism and covalent binding to cellular marcomolecules
using the jln situ bone marrow preparation cited previously. Lutz
and Schlatter (1977) have shown that inhaled radiolabeled benzene
can covalently bind to rat liver DNA. Benzene was bound to the
extent of 2.38 umoles/mole DNA phosphate. Tunek, et a^. (1979)
have separated microsomal proteins after incubation with labeled

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IV-9
benzene and have partially characterized the proteins to which
benzene binds.
Tunek, et al. (1978) found that "the addition of either
glutathione or cysteine to microsomal preparations which metabol-
ize benzene had little effect on phenol formation but inhibited
covalent binding to microsomal protein. They suggested that the
immediate precusor to covalent binding was not benzene oxide but a
metabolite of phenol. In a subsequent effort (Tunek, et ajL., in
press) have shown that the quinone and semi-quinone derivatives of
hydroquinone readily form glutathione conjugates and have postu-
lated that these may be closer approximations of the actual reactive
metabolites. A similar mechanism was recently suggested by Irons,
et al. (in press).
C. Disposition of Benzene in Humans
The most frequent role of exposure to benzene by humans
is via inhalation. Toxic effects in humans have often been attri-
buted to combined exposure by both respiration and through the
skin. Thus, rotogravure workers were described as washing ink
from their hands in open vats of benzene (Hunter, 1962). Although
Lazarew, et al. (1931) claimed that benzene could be absorbed by
rabbits through the skin neither Cesaro (1946) nor Conca and
Maltagliati (1955) could demonstrate significant cutaneous absorp-
tion in humans. Nevertheless, small amounts of benzene absorbed
by this route may not have been detected.

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IV-10
Following exposure to benzene, humans, like animals,
eliminated unchanged benzene in the expired air (Sherwood and
Carter, 1970; Hunter, 1968; Nomiyama and Nomiyama, 1974a, 1974b;
Sato and Nakajima, 1979b; Srbova, ejt a_l. , 1950). The elimination
of unchanged benzene was quantitated in a series of studies by
Nomiyama and Nomiyama (1974a, 1974b) who exposed men and women
to benzene at levels of 52-62 ppm for four hours and determined
its respiratory disposition. A mean value of 46.9% of the benzene
was taken up in these subjects, 30.2% was retained and the remain-
ing 16.8% was excreted as unchanged benzene in the expired air.
Pharmacokinetic plots of respiratory elimination were interpreted
to indicate that there were three phases to the excretion described
by three rate constants. There were no significant differences
between men and women in these studies. Hunter (1968) who exposed
humans to benzene at 100 ppm detected benzene in expired air 24
hours later and suggested that it was possible to back extrapolate
to the concentration of benzene in the inspired air.
Determination of benzene metabolism in humans was first
evaluated as a measure of exposure. Yant, et al^. (1936) suggested
that since benzene metabolites in the urine could be detected as
ethereal sulfates it would be possible to estimate benzene exposure
by measuring the ratio of inorganic to organic sulfate. Normally
the inorganic sulfate is present at about four times the organic
levels. Exposure tends to increase the organic sulfate and lower
the inorganic. Hammond and Herman (1960) suggested that of total

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IV-11
sulfates, inorganic sulfates of 80-95% were normal, 70-80% indi-
cated some exposure to benzene, 60-70% suggested a dangerous level
of benzene exposure and 0-60% indicated that benzene levels were
sufficiently high to provide an extremely dangerous atmosphere
for humans.
In humans the sulfate is the major conjugate of phenol
until levels of approximately 400 mg/L are reached (Sherwood, 1972).
Beyond that level glucuronides are seen. Teisinger, et^ a_l. (1952)
exposed humans to benzene at 100 ppm for 5 hours and found that
the urine contained primarily phenol with small amounts of catechol
and hydroquinone. It would appear that benzene metabolism in humans
is similar to that in animals with respect to the production of the
major metabolites phenol, catechol and hydroquinone.

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V. RELATIVE SOURCE CONTRIBUTION
Incorporated in Chapter III - Human Exposure

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VI-1
VI. HEALTH EFFECTS IN ANIMALS
A. Acute and Chronic Effects
The early reports of Santesson (1897) and Selling (1916) of
benzene toxicity in humans were accompanied by descriptions of
experimentally induced benzene toxicity in animals. The observations
of pancytopenia and bone marrow depression in animals, similar to
those in man following chronic exposure to benzene, suggested that
animal models would be useful in the study of the mechanism of
benzene toxicity.
Santesson (1897) and Selling (1916) were able to reproduce
benzene toxicity in animals best when they administered the benzene
subcutaneously.
The first demonstration of benzene toxicity in animals that were
administered benzene by inhalation was reported by Weiskotten and his
colleagues (1920) who exposed rabbits and demonstrated findings
essentially similar to those reported by Santesson and Selling.
Although Weiskotten did not report the air concentration of benzene
in his studies, his description of the apparatus and of the amount of
benzene used in his experiments permit us to calculate the dose of
benzene by applying a first order differential equation (Snyder and
Kocis, 1975). It appears that he was able to demonstrate benzene
toxicity by exposing rabbits to a mean benzene concentration of
240 ppm. In later experiments it was shown that dogs exposed to
600 to 1000 ppm (Hough and Freeman, 1944) developed leukopenia mice

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VI-2
developed fatal anemia and leukopenia within 12-15 days at
similar air levels (Petrini, 1941) and rats, guinea pigs,
rabbits and monkeys exposed to 80-85 ppm developed leukopenia
(Wolf, et al. , 1956). Leukopenia was also reported in similar
studies when rats or dogs were exposed to benzene at 1000 ppm
(Nau, et al., 1966? Svirbely, et al., 1944). Deichmann, et al.
(1963)	showed that when exposing rats to benzene vapor at 831,
65 and 61 ppm significant leukopenia was observed within 2 to
4 weeks; at 47 and 44 ppm a less severe leukopenia was observed
at 5-8 weeks; no leukopenia was observed when the animals were
exposed to 31 ppm for 4 months, 29 ppm for 3 months, or 15 ppm
for 7 months. It has been argued that the duration of these
studies may not have been long enough to demonstrate leukopenia
at the lower doses but there does indeed appear to be a dose
times time relationship for the production of toxicity. Ikeda
(1964)	and Drew, et al. (1974) reported that repetitive dosing of
rats with 1000 ppm and 1650 ppm, respectively, produced leukopenia.
The data suggest that barring cases of hypersensitivity there
is in all likelihood a relationship between dose, time of exposure
and degree of toxicity in various species (Steinberg, 1949).
Four reports have been chosen to exemplify this relationship.
Latta and Davies (1941) administered benzene to' rats subcutaneously
at doses of 1760-3520 mg (2-4 ml) kg/day whereas Deichmann, et al.
(1963) exposed rats to benzene in the atmosphere and observed
toxic effects in the range of 65-831 ppm. Selling (1916) gave
rabbits benzene subcutaneously at a dose of 880 mg (1 ml) kg while
Weiskotten, et al. (1920) exposed rabbits to atmospheric benzene at

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VI—3
a level which has been calculated to be 240 ppm (Snyder and Kocsis,
1975). Although an initial transitory leukocytosis was frequently
observed the eventual result in each case regardless of the species
or the route of administration was leukopenia. At lower doses
more time was required but the eventual result was the same.
The predominant effect was neutropenia accompanied by an apparent
lymphocytosis which gradually disappeared as benzene attacked
lymphoid tissue. Latta and Daviea (1941) reported that lymphatic
tissue was more sensitive to benzene than myeloid tissue in rats
while Selling (1916) reported that the opposite was true in
rabbits. The neutropenia is characterized by a shift to the left
in the Arneth count which suggests that leukocyte maturation is
impaired. The leukopenia can occur rapidly and cell counts may
reach extremely low levels prior to death.
It is significant that the recent extensive studies of
Snyder, et al. (1978, 1980) in large measure confirmed these
/earlier studies. In these studies Sprague-Dawley rats and both
AKR/J and C57BL/6J mice were exposed to benzene by inhalation at
concentrations of either 100 ppm or 300 ppm 6 hours per day, five
days per week for life. In the first report they showed that the
rats exhibited lymphocytopenia, mild and decreased survival time.
The mice also demonstrated lymphocytopenia, anemia and decreased
survivial but these were accompanied by granulocytosis and
reticulocytosis. The second report, in addition to commenting upon
evidence for benzene induced carcinogenicity, also showed that
benzene induced bone marrow hypoplasia, anemia and lymphocytopenia.

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VI-4
There are only two studies of benzene induced hemato-
toxicity where the benzene was given orally. Wolf, et^ a_l. (1956)
used matched groups of 10 female rats and administered either olive
oil or benzene emulsified in 5% gum arabic. Thus, the benzene
was in effect given in water. In all, 132 doses were given
over a 187 day treatment period as single daily doses. The doses
ranged from 1-100 mg/kg/day. No effects were seen at 1 mg/kg,
slight leucopenia at 10 mg/kg, and both leucopenia and anemia at
50 and 100 mg/kg. No cell counts were reported. It may be
concluded that in these studies the threshold for benzene toxicity
was between 1 and 10 mg/kg. It is clear that further study of the
effects of benzene given in water is required to confirm the studies
of Wolf, ej; aJL. (1956), to relate the effects of benzene given by
other routes with those produced by benzene given orally and to use
the data in attempting to extrapolate to man.
The use of animal models to determine which cell type
is most sensitive to benzene in order that benzene toxicity in
man might be monitored with that cell type may in retrospect,
have been relatively unprofitable. In man, arguments have been
advanced to demonstrate that each of the cell types may be an
early indicator of benzene exposure if their levels in circulating
blood decrease. In animals, larger doses of benzene have been
given than those to which man is exposed in an attempt to condense
the course of the disease in time. Because of the extremely long
half-life of the red cell it is difficult to observe changes in red
cell counts during benzene exposure unless animals were exposed to low

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VI-5
doses for long period of time (e.g., Snyder, ej: a_l. , 1978, 1980).
Platelets are rather more difficult to measure and are not commonly
used as indicators of benzene exposure. Therefore, leukocytes
which suffer from neither drawback have usually been reported in
animal studies as the first cell type to be depleted. However,
that no conclusive evidence exists to show that benzene pre-
ferentially depresses the production of any individual cell line
in the bone marrow.
Attempts to study which circulating cell precursors were
most sensitive to benzene required an understanding of the func-
tion of the bone marrow. For each of the three major cell types,
the processes of cell maturation and proliferation must function
if an adequate number of each cell type is to reach the circulation
as a mature, functional cell. The fundamental cell of the marrow,
called the pluripotential stem cell, gives rise to each of the cell
lines and the process is controlled by a complex series of interac-
tions including hormonal influences, the microenvironment of the
bone, feedback mechanisms and probably other forces as well. Once
a stem cell is committed to the eventual formation of a specific
type of mature cell, it commences to mature and to undergo mitosis
to insure that the process of amplification results in an appropri-
ate number of mature cells. In the theory it is possible to inter-
fere with cell development by preventing these functions at any
stage of cell maturation.

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VI-6
Attempts to detect the stage of cell maturation most
sensitive to benzene have led to similar conclusions. Steinberg
(1949), Moeschlein and Speck (1967), Rondanelli, et al. (1970) and
Lee, et al. (1973) agree that the cells most sensitive to benzene
are the early committed cells actively engaged in cell prolifera-
tion and maturation. Thus, in the red cell line Lee, et al. (1974)
suggested that the pronormoblasts and to some extent the normo-
blasts were the most sensitive whereas undifferentiated stem cells,
reticulocytes and mature red cells were relatively resistant to
benzene.
Wildman, et al. (1976) however suggested that the reti-
culocyte may be a target for benezene since the addition to ben-
zene at a concentration of 0.113 M to reticulocytes in vitro
resulted in a decrease in heme and protein synthesis. Kahn and
Muzyka (1973) reported on changes in porphyrin metabolism in ben-
zene exposed workers after examining delta-aminolevulinic acid
(ALA), porphobilinogen (PGB), coproporphyrin (CP) and protopo-
rphyrin (PP) in brain, red cells and plasma of benzene exposed
rabbits. ALA, PBG, and PP accummulated in gray matter of brain
during chronic treatment with benzene (88 mg/kg, subcutaneously,
four times per week for 5-6 months). No changes in red cells or
plasma were seen. In 16 of 27 exposed workers an increase in red
cell ALA was seen. These studies taken together suggest that more
research is needed to determine whether or not benzene can inter-
fere with heme or hemoglobin synthesis at the reticulocyte level,
and if humans are sensitive at lower concentrations over time.

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VI-7
The use of colony forming unit (CFU) assays concentrating
on bone marrow cells in culture has contributed to our understanding
of targets for benzene and some of its hydroxylated derivatives.
Several years ago Uyeki, et aJL. (1977) showed that bone marrow cells
taken from BDF^ mice exposed to benzene by inhalation (4680 ppm, 8
hr.) displayed depleted of CFU-C (leucocyte precursors) on the day
following exposure but recovery was evident by seven days. Multiple
exposures enhanced the effect. Decreases were also observed using
the CFU-S assay (spleen colony forming units, erythroid precursors).
Green, et a_l. (1981) showed that at 103 ppm and higher CD1 mice
exposed for 6 hr/day for 5 days displayed a reduction in marrow
and spleen cellularity as well as a decrease in GM-CFU-C (granulo-
cytic macrophage colony forming units, committed macrophage pre-
cursors) from spleen but not from marrow. At 9.6 ppm for 50 days
no changes in marrow activity were seen but splenic cellularity
and CFU-S were elevated. At 302 ppm for 26 weeks marrow and spleen
cellularity, CFU-S and marrow GM-CFU-C were decreased. Harigaya,
et al. (1981) also demonstrated a depression of CFU-S in C57bl/dj
mice exposed to benzene (400 ppm, 6 hr/day) for either 9 days in-
termittently or 11 consecutive days. Wierda, et a_l. (1981), also
using cell culture techniques, have shown that single intraperi-
toneal injections of benzene resulted in a dose related inhibition
of splenic T- and B-lymphocyte responsiveness to mitogenesis.
These studies, taken together with those cited above, although
apparently relating benzene effects to different primitive cells
all indicate that benzene is affecting cell replication and matu-

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VI-8
B. Immunological Aspects of Toxicity
Early in this century it was recognzied- that benzene
had an adverse effect on immunological mechanisms. It was demon-
strated that susceptibility to tuberculosis (White and Gammon,
1914) and pneumonia (Winternitz and Hirschfelder, 1913; Hirschfelder
and Winternitz, 1913) were increased in benzene treated rabbits.
The reports of decreased production of red cell lysins, agglutinins
for killed typhoid bacilli and opsonins (Simonds and Jones, 1915)
and the absence of anti-bacterial antibodies (Camp and Baumgartner,
1915; Hektoen, 1916) in benzene intoxicated rabbits were all indi-
cations of depression of the production of various components of
the immune mechanism. Developments in the field of immunology
have led to studies of the effects of benzene in humans on several
immunological components which have been identified in recent
years. Smolik and coworkers (Smolik, et al., 1973; Lange, et al.,
1973a) studied a large number of workers exposed to but not seri-
ously intoxicated by benzene. They found that serum complement
levels, IgG and IgA were decreased but IgM levels did not drop and
were in fact slightly higher. These observations taken together
with the well-known ability of benzene to depress leukocytes which
themselves play a significant role in protection against infectious
agents may explain why benzene intoxicated individuals readily
succumb to infection and the terminal event in severe benzene
toxicity is often an acute overwhelming infection.

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VI-9
These authors also evaluated levels of leukocyte agglu-
tinins and found them elevated in selected individuals exposed to
benzene (Lange, et al^, 1973b). They extended this observation to
suggest that in some persons the picture of benzene toxicity may
in part be accounted for as an allergic blood dyscrasia.
Alterations of immunological function may also play a
role in the development of acute leukemia resulting from benzene
intoxication described above. Current concepts of immunology sug-
gest that a mechanism referred to as "immune surveillance" (Smith,
1970, 1972) is constantly at work to weed out cells which result
from mistakes in cellular genetics or genetic changes caused by
carcinogenic agents. The mechanism, while not completely under-
stood, appears to involve a recognition of surface components of
abnormal cells followed by immunological destruction of the cell
or clone or cells. Since some forms of benzene intoxication result
in hyperplasis of bone marrow with the occurrence of many bizarre
cellular species it may be presumed that some of these may be neo-
plastic. Damage to immunological mechanisms in benzene toxicity
may then impair the immune surveillance response with the resulting
development of leukemia.
C. Potential for Mutagenesis and Leukemogenesis
Benzene was found to have no mutagenic potential when
tested in Drosophila melanogaster (Nylander, et al., 1978). In
this experiment newly hatched larvae were exposed to media contain-
ing benzene at a concentration of 1% or 2%. The test system used

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VI-10
a stable X-chromosome (zDpw+le19) ag a control and a genetically
unstable sex linked genotype, sczw+. Mutation in the two systems
is measured by a shift in eye pigmentation; however, neither con-
centration of benzene showed mutagenic activity.
In a review article, Dean (1978) reported that benzene
was tested for mutagenic activity at a concentration of 20 and
600 uL/plate with five Salmonella typhimurium tester strains
(TA100, TA98 TA1535, TA1537 and TA1538) with and without metabolic
activation by 9,000 g supernatant fractions from liver microsomes.
No mutations were observed. Furthermore, higher levels of benzene
(0.088-880 mg/plate) also showed no mutagenic effect when S. typhi
murium tester strains TA98 and TA1000 were used with the addition
of 9,000 g supernatant fractions from both phenobarbital and
3-methylcholanthrene treated rats. Preincubation of benzene with
the metabolic activating system also produced negative results.
In addition, in this same set of experiments, a host-mediated
assay was performed in which mice were pretreated with phenobar-
bital and given two 0.1 mL subcutaneous injections of benzene.
The test organism was S. typhimurium strain TA1950. Again, no
increase in mutation rate was observed. In a similar study per-
formed at Litton Bionetics (1977) mutagenic activity of benzene
was evaluated using the S. typhimurium and the Saccharontyces
cerevisiae tests. No mutations were observed with or without
metabolic activation. Benzene also gave negative results in the
mouse lymphoma tests but was positive for sister chromatid ex-
changes in the rat bone marrow assay. It is possible that the

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VI-11
mutagenicity of benzene cannot be assessed with bacterial systems
because benzene may damage cells. Toluene is routinely used to
render the membranes of Eschirichia coli permeable to nucleotides
while allowing the cells to maintain both their structure and
their ability to synthesize DNA (Moses, 1974); however, these
bacteria are not viable and changes in the membrane are difficult
to detect by bright-field microscopy.
A recent report by Pulkrabek, et^ ad. ( 1980) showed that
benzene oxide, the presumed initial metabolite of benzene is muta-
genic for S. typhimurium. While the ability of benzene to cause
point mutations is in doubt, production of chromosomal aberrations
by benzene have been known for many years (Kissling and Speck, 1969;
Tough, et al_. , 1970). Pollini and Colombi (1964a; 1964b) noted a
high rate of aneuploid cell production in cultured cells and peri-
pheral lymphocytes from workers displaying severe benzene hemopa-
thy. A number of structural chromosome aberrations were noted in
lymphocytes cultured from workers exposed to benzene. Forni, e_t
al. (1971a; 1971b) have shown an increased incidence of stable and
unstable chromosome aberrations in rotogravure workers exposed to
benzene when compared with matched controls. During follow-up
studies of these workers the aberrations which persisted were found
later to be associated with leukemia. Kahn and Kahn (1973), Funes-
Cravioto, et a_l. (1977) and Picciano (1979) investigated cytoge-
netic effects of industrial exposure to benzene and found increased
numbers of chromosomal breaks and figures including rings, dicen-
trics, translocations and exchange figures in peripheral blood

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VI-12
cells. Chromosome aberrations area also common in individuals
with benzene associated leukemias (Forni and Moreo, 1967; 1969;
Hartwich, et a_l. r 1969; Sellyei and Keleman, 1971).
Tice, et al_. (1980) recently demonstrated excessive sis-
ter chromatid exchanges (SCE) in DBA/2 mice exposed to 3100 ppm
benzene by inhalation for four hours. The SCE frequency, which
was approximately doubled, occurred at a level of exposure which
did not cause chromosomal aberrations. By comparing the number of
SCE found in successive generations of cultured marrow cells, it
was determined that SCE occurred both as a result of exposure of
previously unexposed cells to benzene and because of the persistence
of lesions. The latter is a critical observation for the leukemo-
genic action of benzene because persistence of such lesions corre-
lates with carcinogenesis in other systems (Goth and Rajewsky, 1974;
Nicoll, et al., 1975).
In a recently reported study Meyne and Legator (1980)
administered benzen to CD-I mice either intraperitoneally or via
oral gavage at doses of 88, 440, or 880 mg/kg for three days and
subsequently measured chromosome aberrations and micronucleus
changes. Male mice were more susceptible to chromosome aberrations
than females regardless of the route of administration. Males were
also more sensitive to micronucleii formation when benzene was
given orally but not intraperitoneally. Females demonstrated an
increase in micronuclei when the benzene was given orally but were
less sensitive than the males. They demonstrated no increase when
the benzene was given intraperitoneally.

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VI-13
The significance of these studies resides in the finding
that benzene has been shown to induce leukemia in humans whereas
there is as yet no readily reproducible model for benzene-induced
leukemia in animals. Leukemia is known to spontaneously occur
with rather high frequency in some strains of mice and there is
abundant evidence that chemicals can induce leukemias in both mice
and rats (Shay, et al. , 1951; Hartman, et al., 1959; Huggins and
Sugiyama, 1966; Diwan and Meier, 1976; Ogui, et al., 1976). The
reports of Lignac (193 2) in the early 1930's that he had produced
leukemia in mice were based on a study in which he treated mice
with benzene subcutaneously at a dose of 30 mg/kg for a period of
17-21 weeks. Forty-four mice survived of which 8 were described
as having developed leukemia or a lymphosarcoma. Unfortunately
experimental details such as strain of mouse and diagonistic criteria
are unavailable. Furthermore, no controls were used to correct
for spontaneous neoplasms in these animals.
In an attempt to duplicate the results of Lignac, Amiel
(1960) treated Akr, DBA2,C3H and C57B1 mice with a weekly injection
of benzene (30 mg/kg) throughout their entire lifetimes. Neither
leukemia nor aplastic anemia we-re observed. In a more recent
study Ward, et al. (1975) used C57B1 mice and after gradually
increasing the dose from 450 rag/kg to 1.8 gm/kg continued to
treat the animals for 44 weeks, twice weekly with 1.8 gm/k^. For
the next 10 weeks a single dose at this level was given. The
experiment was terminated 104 weeks after the first injection.
Although a number of deaths due to bone marrow depression were

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VI-14
observed in the benzene treated animals no significant increase in
neoplastic disease was observed when comparing the benzene treated
animals with appropriate controls.
Oral dosing of Wistar rats with benzene at doses ranging
from 1-100 mg/kg in 132 feedings over a 187 day period resulted
in a dose dependent bone marrow depression (Petrini, 1941), but no
leukemia. Kirschbaum and Strong (1942) and Laerum (1973) painted
benzene on the skin of F strain and hairless mice, respectively,
but neither group displayed leukemias during extended observation
periods.
Using the inhalation route Wolf, et al_. (1956) treated
rats (9400 ppm, 1-10 exposures, 1-19 days; 6600 ppm, 70 exposures,
93 days; 4400 ppm, 28 exposures, 38 days; 2200 ppm, 133 exposures,
212 days; 88 ppm, 136 exposures, 204 days), guinea pigs (88 ppm,
193 exposures, 269 days; 88 ppm, 23 exposures, 204 days) and rab-
bits (80 ppm, 175 exposures, 243 days) using seven hour exposure
periods. No instances of leukemia were observed. Jenkins, ert al.
(1970) exposed 15 rats, 15 guinea pigs and 2 dogs to either 2614
ppm in 30 repeated exposures, 8 hrs/day, 5 days/week; 315 ppm
continuously for 90 days; or 179 ppm continuously for 127 days.
Again no leukemia was observed.
Two recent reports which will have a significant impact
on this field of study were published by Snyder, et a_l. (1978,
1980) and were based on a long term exposure protocol in which
Sprague Dawley rats and AKR/J and C57BL/6J mice were exposed to

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VI-15
benzene at 100 ppm or 300 ppm. In the first report they demon-
strated that Sprague Dawley rats exposed to benzene at 300 ppm for
6 h/d, 5 d/w exhibited lymphocytopenia, mild anemia and a slight
decrease in survival time. AKR/J mice had severe lymphocytopenia
and anemia along with granulocytosis and reticulocytosis. They
did not grow as rapidly as controls and did not survive as long.
A comparison of AKR/J and C57BL/6J mice exposed at either 100 or
300 ppm for life showed that anemia and lymphocytopenia occurred
in AKR mice and 20% of the exposed animals developed marrow hypo-
plasis. Anemia, lymphocytopenia, and neutrophilia accompanied
by a left shift were seen in C57 mice. In the second report
there was evidence for boner marrow hypoplasia in 33% of the
benzene exposed C57 mice as well as a significant increase in
hematopoietic neoplasms among which were six cases of thymic
lymphoma.
It has been suggested by Maltoni and Scartano (1979) that,
benzene when administered when administered by gavage can produce
leukemias and solid tumors. In a series of studies using 90 male
and female Sprague Dawley rats given 50 or 250 mg/kg benzene in
oil 4-5 days per week for 144 weeks they found that benzene
caused Zymbal gland tumors at both doses and that the females
were more sensitive than the males. They also observed
hemolymphoreticular neoplasias and mamary carcinomas.
They stressed that solid tumors were formed

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TABLE 6 STUDIES OF POTENTIAL BENZENE-INDUCED TERATOLOGIC
RESPONSES BY INHALATION
Reference
Gofmekler
(196-8)
Puskina et al.
(1968)
Vozovaya
(1975)
Vozovaya
(1976)
Hudak and
Ungvar
(1978)
Species	Exposure
rat	65 ppm
rat
rat
rat
rat
mouse
208 ppm
559 ppm
116 ppm
310 ppm
Duration
24 hr/day
10-15 days
before mating
throughout
pregnancy
4 no. prior
& throughout
pregnancy
A mo. prior
fit throughout
pregnancy
24 hr/day
days 1-14
of pregnancy
Fetal Wgt.
Comments
decreased
decreased
decreased litter
size
decreased litter
size
Ho malformations,
2 generations
No malformations
No malformations

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VI-18
TABLE 7.
SUMMARY OF BENZENE INHALATION TERATOLOGY
Study ¦ Speciea
Inhalation —7
Exposure
Study
Strain (ppn)
Decreased Decreased	Decreased
Material Total Crown
Body Body Runp
Duration Weight	Weight	Distance
Comments
or
Observations
Hazelton,
1975 (as
cited in
Murray, et
al. 1979T"
Rat
Sprague-
Dawley
0
10
50
500
Day 6 to
day 16
of
gestation
*(a)
Malformations 03)
Green. Rat
et al. 1978
Sprague-
Dawley
100
300
2,200
Day 6 to
day to 16
of
gestation
Missing sternebra*
Missing sternebra*
(most in females)
Missing sternebra*
Murray,
et al.
1979
Mouse
CF-1
500
Day 6 to
day 18
of
gestation
Missing sternebra*
Delayed skull ossi-
fication*; unfused
occipital*
Rabbit New	500	Day 6 to —	—	— Extra ribs*; luntoar
Zealand	day 18 of	spur(s)*
gestation
(a)	* = Statistically significant (p <0.05)
(b)	Exencephaly, angulated ribs, out-of-sequence ossification of forefeet

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VI-16
at doses where hematotoxicity was not seen. Thus, Maltoni and
Scarnato feel that benzene is a general carcinogen that is not
restricted to effects in the hemopoietic system. They argue that
since no epidemiological study has ever investigated the incidence
of benzene associated solid tumor formation, it may be lurking
waiting to be uncovered. Although effects of benzene previously
studied have suggested that route of administration, i.e. parenteral
or inhalation, do not effect the eventual disease, it may be that
oral administration results in effects not otherwise seen or
demonstrated.
D' Potential for Teratogenicity and Fetotoxicity
Watanabe and Yoshida (1970) injected benzene (2640 mg/kg)
subcutaneously to pregnant mice on day 13 of gestation and delivered
the fetuses on day 19. Although some incidence of cleft palate,
agnathia and microagnathia were observed these are common anomalies
observed in untreated mice and were not considered to be dose
related. Nawrot and Staples (1979) used the oral route and gave
benzene by gavage (264, 440 and 880 mg/kg) to pregnant CD-I mice
during either days 6-15 or 12-15. Despite some maternal lethality
and embryonic resorption no evidence of teratology was seen.
The results in Table 6 show the data from several studies
in which teratological effects were investigated in animals exposed
to benzene by inhalation. The results are that despite changes in
fetal dimensions or litter size no malformations were observed.
The data shown in Table 7 summarize four reports in which effects
on the mother as well as weight of fetus, length of fetus and
occurrence of anomalies are compared. The Hazelton study was

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VI-19
was characterized by the appearance of an exencephalic pup, a pup
with angulated ribs and two pups with ossification of the forefeet.
These represented one out of 151 pups, one out of 107 pups and 2
out of 107 pups, respectively. It was suggested that these effects
may have had a nutritional basis (Runner and Miller, 1956; Miller,
1962) or may have been chance events. The study was in any event
marred by lack of sufficient controls. The FDAA guidelines suggest
a minimum of 20 pregnant females in the control group but only 12
were involved in this study. Lack of sufficient controls may lead
to underestimation of spontaneous malformations in untreated animals.
In any event it is significant that Green et al. (1978) despite the
use of much higher benzene levels was unable to observe the
malformations seen by Murray et al. (1979). Thus, there does not
appear to be any strong evidence for a teratogenic effect of benzene.
There is ample evidence that benzene causes growth retardation. no
study has been performed to determine if benzene produces any
postnatal effects.

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VII. HEALTH EFFECTS IN HUMANS
A. Acute and Chronic Toxicity
Short term exposure to relatively high levels of benzene
primarily produce central nervous system effects. Such include
dizziness giddiness, exhilirat ion, nausea, vomiting, headache,
drowsiness, staggering, loss of balance, narcosis, coma, and death.
The level at which central nervous system effects will
occur in man is not clear from the literature. Hamilton (1931)
reviews the earlier literature on acute benzene poisoning, includ-
ing nineteenth century autopsy findings, and notes a few instances
in which central nervous system effects apparently persisted for
at least 12 days following a severe initial acute poisoning episode.
Gerarde (1960) provides a table summarizing acute effects in which
it is stated that 19,000-20,000 ppm for 5-10 minutes is fatal benzene
level; 7,500 ppm for 30 minutes is dangerous to life; 1,500 ppm for
60 minutes provides serious symptons; 500 ppm for 60 minutes leads
to symptoms of illness; 50-150 ppm for five hours produces headache,
lassitude, and weakness, and 25 ppm for 8 hours has no effect. The
NAS review (1976) states that exposure in the region of 25,000 ppm
is rapidly fatal.
It should be emphasized that mild central nervous system
effects appear to be rapidly reversible following cessation of ex-
posure. There is no evidence that they result in chronic brain
damage. Also of importance is that these effects appear to be

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VI1-2
concentration-dependent. Lower levels of benzene do not seem to
elicit these responses no matter how long the exposure.
Numerous recent reviews evaluating various aspects of
benezene toxicology have appeared. These include articles by
academic scientists in the open literature (Goldstein, 1977?
Snyder and Kocsis, 1975; Snyder, et al., 1977), efforts by scienti-
fic bodies such as the International Agency for Research on Cancer
(19 74), the National Academy of Sciences (1976) and the National
Cancer Institute (1977), and reviews performed as part of the regu-
latory process (NIOSH, 1974? NIOSH, 1977). Among the latter are
two previous efforts by the Environmental Protection Agency: "As-
sessment. of Health Effects of Benzene Germane to Low-Level Expo-
sure, " published by the Office of Health and Ecological Effects
in September 1978, and a document entitled "Ambient Water Quality
Criteria for Benzene," released by the Office of Water Regulations
and Standards, Criteria and Standards Division in October 1980.
Benzene has been a known hematological poison since the
19th century when Santesson (1897) described cases of aplastic
anemia in workers fabricating bicycle tires. The original associ-
ation of acute leukemia with benzene exposure was made in 1928
(Delore and Borgomano, 1928) and there is a reasonable likelihood
that benzene is a cause of acute myeloblastic leukemia. Other
hematological diseases have also been reported to be associated
with benzene exposure. The major question about the hematological

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VI1-3
effects of benzene pertinent to the regulatory process is the
dose at which they occur. The difficulties in arriving at firm
decisions concerning the dose of benzene responsible for adverse
effects are in part complicated by a lack of understanding of
the pathogenesis of benzene induced hematological disorders, and
in particular the relationship between aplastic anemia and acute
myelogenous leukemia.
Aplastic Anemia; Pancytopenia. Aplastic anemia is a
relatively rare, often fatal, disorder in man. Its diagnosis is
usually made on the basis of a significant reduction in the formed
elements of the blood: including a decreased white blood cell
count known as leukopenia, a decreased red blood cell count known
as anemia, and a decreased platelet count known as thrombocyto-
penia. A decrease in all three of these blood cell counts is
descriptively defined as pancytopenia. Only the more severe
cases, which are generally associated with a marked decrease in
the number of cells in the bone marrow, are usually called aplastic
anemia. The important point is that these are not distinct
diseases but rather a continuum of changes reflecting the severity
of bone marrow toxicity due to benzene toxicity. This is demon-
strated by studies in which following the observation of one
severely affected benezene-exposed worker, complete evaluation
of the work force revealed many other affected individuals with
effects ranging from a mild individual cytopenia to aplastic
anemia of sufficient severity to warrant hospitalization.

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VI1-4
Among the studies which have shown this wide range of
hematological response are those of Goldwater and his colleagues
(Goldwater, 1941; Goldwater and Tewksbury, 1941; Greenburg, et al. ,
1939) evaluating over 300 rotogravure printers in New York. A
change in the printing process had led to the exposure of these
workers to levels of benzene described as ranging from 11 to 1,060
ppm. There were 23 cases of significant cytopenias, 6 of whom
required hospitalization. Wilson in 1942 reported studies of
1,104 workers in a rubber factory in Ohio who were exposed to up
to 500 ppm benzene with an average of about 100 ppm. Mild hemato-
logical abnormalities were noted in 83, more severe pancytopenia
in 25 and 9 of the latter were hospitalized, 3 of whom died.
Savilahti (1956) reported that 107 of 147 Finnish shoe factor
workers were noted to have some hematological abnormalities. Con-
centrations of benzene, which had been in use for about 10 years,
were as high as 400 ppm. Of note is that Hernberg, et al. (1966)
performed a follow-up study of 125 of these workers 9 years later.
They noted some persistent cytopenias. One individual had devel-
oped acute leukemia and died. Another study with a long follow-up
is that of Guberan and Kocher (1971). They followed 216 of 282
workers for 10 years after cessation of benzene exposure. Four
individuals are reported to have persistent decrease in blood
counts and one patient had died of aplastic anemia 9 years after
cessation of exposure. Follow-up data suggesting mild persistent
anemia^workers in the rubber coating industry were presented by
NIOSH (1974). These individuals had been exposed to benzene levels
described as generally less than 25 ppm but ranging up to 125 ppm
prior to installation of control measures (Pagnotto, et al., 1961).

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VI1-5
Other large series of cases of aplastic anemia in
benzene-exposed work groups have been provided by Vigliani and
his colleagues in Italy, although these investigators have
focused primarily on leukemia (Vigliani and Porni, 1976; Saita
and Vigliani, 1962), and the studies of Aksoy, et al., in Turkey
(1971, 1972a, and 1978). In the latter, an outbreak of hematologi-
cal toxicity in leather workers was directly temporally related
to the use of an adhesive containing benzene beginning in about
1960. Aksoy, et al. (1972a) reported on 32 cases of significant
aplastic anemia in people exposed to benzene for four months to
fifteen years. . Exposure levels ranging from 150 to 650 ppm were
reported. In another study reported by this group (Aksoy, et al.,
1971) 51 of 217 apparently healthy workers were found to have some
hematological abnormalities, including 6 cases of pancytopenia.
These workers are described to have been exposed to 30 to 210 ppm
benzene, for 3 months to 17 years. It should be noted that the
exposure levels reported in this series of studies represent
occasional random measurements of what is in essence a cottage in-
dustry.
These studies of occupationally exposed groups are notable
for the association of benzene with pancytopenia in workers from
different countries and in different work settings where the only
common denominator appears to have been benzene. The clear temporal
relationship between the onset and cessation of hematological abnor-
malities and the use of benzene provides further evidence allowing

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VII-6
the conclusion that a causal relationship between benzene exposure
and pancytopenia is incontrovertible. This is further substanti-
ated by the ability to reproduce these findings in different
animal species (see Section V).
None of the above occupational studies, however, pro-
vides information concerning the lowest dose of benzene that might
be expected to produce cytopenic affects in man. Two studies of
occupationally exposed groups which do attempt to provide informa-
tion on the subject are by Doskin (1971) from the Soviet Union and
Chang (1972) from Korea. These studies in the non-English litera-
ture are described in some detail in the "Assessment of Health
Effects of Benzene Germane to Low-Level Exposure" (EPA, 1978). In
this assessment, it is emphasized that many details as to exposure
are not provided by Doskin or by Chang. Chang studied 119 workers
exposed to Benzene in an unspecified industrial area. Hematologi-
cal abnormalities were observed in 28: including 21 with anemia,
2 with leukopenia, and 5 with both. The author plots a graph in
which each of these affected individuals is characterized by dura-
tion of work on the abscissa and level of benzene exposure on the
ordinate. Based on this plot, the author obtained an exponential
function that implied a "threshold" of 10.0 ppm benzene for cyto-
penic effects. However, no hematological toxicity was observed in
the 18 workers exposed to 10 to 20 ppm benzene. A major problem
in interpreting this study is the absence of information concern-
ing the definition of work exposure concentrations for the individ-
ual employees.

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VI1-7
Doskin (1971) in the Soviet Union evaluated 365 individ-
uals employed for three years in what was apparently a new chemical
factory. Serial hematological studies were performed on the exposed
workers as well as the control group. Benzene exposure levels are
given j.n terms of the maximum permissible concentration which ap-
parently was 5 ppm. It is noted that benzene levels exceeded this
minimum permissible concentration two to eight-fold in 64% of the
measurements in the first year, 37% in the second year, and 3% in
the third year. This decrease in benzene levels paralleled a de-
crease in the number of workers who had hematological abnormalities.
In the first year close to 40% of the workers exhibited mild hemato-
logical abnormalities, the most common being thrombo^cytopenia
(95-155,OOO/mm^). Inasmuch as the maximal permissible concentration
in the Soviet Union at the time of the study was apparently 5 ppm,
these findings suggest that exposure of workers to concentrations
of 10 to 40 ppm benzene for less than one year produces mild
cytopenic effects. Interpretation of this study would be furthered
by information concerning the benzene monitoring system and the
actual levels recorded.
The qualitative abnormality that has received the most
attention in association with benzene exposure is that of cyto-
genetic changes in the nucleus of bone marrow cells or of circula-
ting lymphocytes of exposed individuals. Numerous case reports in
individuals with clear-cut hematological toxicity in association
with benzene-exposure have been well reviewed elsewhere (Wolman,
1977j EPA 1978). Studies of occupationally exposed groups include

-------
VII-8
the work of Forni, et a_l. (1971a) who compared cytogenetic findings
findings in 34 workers at a rotogravure plant with those of matched
controls. Exposure was to benzene alone, or benzene plus toluene,
with the benzene levels ranging well over 100 ppm. Workers exposed
to toluene alone were not different from the age and sex matched
controls. However, there was statistically significa n%t increase
in chromosomal abnormalities in the benzene exposed group. This
group also studied 25 individuals who had recovered from benzene
hematotoxicity (Forni, et al. , 1971b). There was a tendency to-
ward a decrease in unstable chromosome changes over time. However,
a persistence or an increase in stable chromosome changes was gen-
erally noted.
Tough and Court-Brown (1965) observed significant chromo-
somal damage in cultured lymphocytes from workers exposed to ben-
zene. In a further study (Tough, et^ al. , 1970) benzene-exposed
workers from three separate factories were studied along with con-
trol individuals from the same workplace. Unstable chromosomal
abberrations were observed in exposed workers but not in control
workers from a factory in which benzene levels were recorded as
25 to 150 ppm. In another factory with similar benzene concentra-
tions unstable abberrations were found in both control and exposed
workers, but in neither group in a third factory in which benzene
levels were recorded as approximately 12 ppm.
Certain of the qualitative changes in blood cell that are
described above would clearly be considered as adverse effects from

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VII-9
from which the public should be protected. Cytogenetic abnormali-
ties would appear to fall into this category in that they have been
associated with carcinogenesis, although absolute direct proof of
such a relationship in man has not been forthcoming. On the other
hand, it is difficult to assign clinical importance to small changes
within the normal range of such parameters as serum immunoglobulins.
Acute Myeloblastic Leukemia. Acute myeloblastic leukemia
is a cancer in which there is an abnormal proliferation of the hema-
tologic precursor cell which is believed to be the common progenitor
for granulocytic leukocytes, red blood cells and platelets. This
disease is mostly observed in adults and has an increasing incidence
with age, peaking in the sixth or seventh decade. There are a number
of variants of acute myelogenous leukemia which, for purposes of the
present discussion, can be considered to be part of the same disease.
These include acute myelomonocytic leukemia, promyelocytic leukemia,
and erythroleukemia.
Since the original report of Delore and Borgomano (1928)
there have been well over a hundred individual cases of acute myelo-
blastic leukemia or its variants in which an association with ben-
zene exposure has been reported. Obviously, the most any one case
report can do is to suggest an association. The credence that these
case reports give to the causal relation of benzene to acute myelo-
genous leukemia only in part reflects the number of cases. Particu-
larly impressive is the relatively common report of an individual
with aplastic anemia associated with benzene exposure who is fol-
lowed through a preleukemic phase into frank acute leukemia (Aksoy

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VII-10
et al_. , 1972b; 1976? Girard and Revol, 1970; Mallein et al. , 1971;
Tareef et al. , 1963). Also of note is the frequency with which
erythroleukemia is reported in association with benzene exposure.
This is a rare variant of actue myelogenous leukemia.
Also of note in the case reports is the sometimes long
delay between the cessation of known benzene exposure and the on-
set of acute leukemia (Aksoy et al. , 1972b; DeGowin, 1963; Guasch
et al. , 1959; Justin-Besancon et al., 1959; Ludwig and Werthemann,
1962; Robustelli della Cuna et al. , 1972; Saita and Vigliani, 1962;
Sellyei and Keleman, 1971; Vigliani and Saita, 1964). Among these
cases is that of DeGowin who noted a painter with acute leukemia
15 years after the diagnosis of a benzene-related aplastic anemia.
An even longer interval was reported by Justin-Besancon et al.
(1959) who observed a case of acute leukemia 27 years after
exposure to benzene. Chromosomal abnormalities and Pelger-Huet
anomaly were reported in a case of acute granulocytic leukemia
which occurred seven years after benzene-induced pancytopenia
(Sellyei and Keleman, 1971). One of the cases in the series of
Vigliani and Saita (1964) occurred 12 years after cessation of
occupational benzene exposure. Guasch, et al. (1959) reported a
case of acute myelogenous leukemia 6 years after onset of pancyto-
penia and also provided a relatively extensive review of earlier
case reports.
Taken together these individual case reports provide
relatively strong circumstantial evidence of a causal relationship

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VII-11
between benzene exposure and acute myeloblastic leukemia. In ad-
dition to the points raised above, among the more convincing as-
pects of this assemblage of case reports is that they come from
all over the world and represent diverse occupational exposure set-
tings which have in common substantial exposure to benzene.
B. Epidemiology
Formal epidemiologic methods have been used in studying
the relationship between exposure to benzene and the development
of leukemia. The studies have concentrated on industrial exposure
to benzene. Because it is rare for exposure to any industrial
chemical to occur in isolation, interpretation of these studies
must take into account that the excess occurrence of leukemia (or
of other diseases) may be due to confounding by other substances.
This section is divided arbitrarily into reports where
there was a reasonable likelihood that there was exposure to ben-
zene and reports where exposure to benzene either was uncertain or
was complicated by exposure to other solvents.
Studies of Persons Exposed to Benzene. Aplastic anemia
as a chronic effect of benzene exposure was recognized clinically
because it developed among persons who used solvents containing a
high proportion of benzene (25%+). Because some of the persons
with aplastic anemia eventually developed acute myeloblastic leu-
kemia, it was natural to conclude that high exposure to benzene
caused leukemia. However, epidemiologists evaluate the possibility

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VI1-12
that relatively short-term, low-level exposure to benzene leads
only to leukemia, but not to aplastic anemia.
The studies of Aksoy and his colleagues in Turkey pro-
vide a bridge between the clinical description of leukemia in per-
sons exposed to benzene and the epidemiologic evaluation of that
association (Aksoy et al. , 1966-1977). Between 1955 and 1960 a
solvent containing high levels of benzene was introduced into the
Turkish shoe industry (Aksoy and Erdem, 1978). In 1961 cases of
aplastic anemia were observed among these workers and cases of
leukemia appeared in 1967.
In 1974, Aksoy, et al. (1974b) estimated the incidence
rate of acute leukemia or preleukemia among shoe workers. Between
1967-73, 26 workers who had been exposed to benzene were admitted
to Turkish hospitals. On the basis of official records, Aksoy
estimated that there were 28,500 workers involved in the shoe, slip-
per, and handbag industry in which benzene is used as a solvent.
Assuming a seven-year follow-up period, the incidence rate of leu-
kemia was then 26/(28,500 x 7) = 28/199,500 person-years =
13/100,000/year. Aksoy compared this to an estimated incidence rate
of 6/100,000/year in the general population.
Because of methodologic shortcomings, these data of Aksoy
et al., are difficult to interprets
1. The definition of occupation used for the person with
leukemia differed from that used for the "official

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T7II-13
records." It is possible that a person with leukemia
was called a shoeworker whereas the same person ap-
peared on the official record as having another occu-
pation;
2.	No follow-up of the 28,500 workers with exposure to ben-
zene was carried out. It is possible that all cases of
leukemia were not ascertained;
3.	The comparison of incidence rate of 6/100,000/year is
for an unknown location and an unknown time;
4.	No age-standardization was done.
In a second report, Aksoy followed 44 pancytopenic pa-
tients who had had chronic exposure to benzene. Six of these
patients developed leukemia of unspecified type. Five of these
six patients had pancytopenia at the time leukemia was diagnosed.
Thus, a question can be raised as to the chronology of the diag-
nostic process. While there was no formal comparison of the rate
of leukemia in another group, 6/44 is a high proportion on grounds
of common knowledge.
Another bridge between clinical and epidemiologic evalu-
ation of benzene is in the report of Hernberg, et al. (1966). In
195 5, 149 persons in a Finnish shoe factory were heavily exposed
to benzene and more than 100 had blood abnormalities. In a follow-
up in 1964, one person had been identified as having developed leu-
kemia. While the number that might have been expected in an unex-
posed group was not estimated, it is clear that any estimate of
excess risk or absence of such risk would be very unstable.

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VII-14
Thorpe (1974) evaluated leukemia mortality among petro-
leum workers who had potential exposure to benzene as a constitu-
ent of petroleum products. Among eight affiliates of Exxon, 18
cases of leukemia were observed over a 10-year period. On the
basis of WHO age-specific mortality rates for leukemia, 23.2
deaths were expected. The data in this study are difficult to
interpret because of an uncertainty as to actual level of exposure
to benzene and because it is not clear that most cases of leukemia
in the study population were ascertained.
Infante, et_ al_. ( 1977a, b) provided data from a retro-
spective cohort study of workers at 2 "Pliofilm" production plants
in Ohio. Pliofilm was a product made from natural rubber suspended
in a solvent solution containing benzene. While actual measure-
ments of benzene exposure were not available until the early
1960's, levels between 1945 and 1975 were believed to be generally
within the contemporary standard (100 ppm in 1941 to 10 ppm in 1971).
Mortality between 1/1/50 and 6/30/75 was determined for 748 workers
employed between 1/1/40 and 12/31/49. There were 140 deaths from
all cases observed and 187.6 expected on the basis of age-time
specific deaths for U.S. white males. There were seven deaths ob-
served from leukemia in comparison to 1.4 expected on the basis of
U.S. white male mortality rates or 1.5 expected on the basis of
mortality rates from a comparison cohort of fibrous glass workers
(p <0.002). Of the seven leukemias, four were acute myelogenous,
two were monocytic and one was chronic myelogenous.

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VII-15
Rinsky, et al., published a follow-up study to the Infante
(1977) study. Rinsky used the idential cohort. His report was
based upon 98% vital status follow-up vs. 75% for the Infante study.
Among 748 workers who had at least one day of exposure to benzene
between 1940 and 1950, seven deaths due to leukemia occurred. In
the United States the death rates standardized for age, sex and
calendar time period, was expected to be only 1.25 leukemia deaths.
The standardized mortality ratio (SMR) is equal to 560; p <0.001.
The mean duration of benzene exposure was very brief and 437 (58%)
of the cohort were exposed for less than 1 year. The evaluation of
exposure to benzene of workers exposed five or more years showed
leukemia deaths that produce an SMR of 2,100. The leukemia cell
types were myelocytic or monocytic. Four additional cases of leu-
kemia were recognized but not included for technical reasons. Had
they been included in the cohort, the SMR would equal 3,780. Rinsky
reconstructed the past exposure to benzene at the two locations.
The analysis indicated that in some areas of the plant airborne
benzene concentrations rose occasionally to several hundred parts
per million (ppm), but for the most part, employee eight-hour time-
weighted averages (TWA) fell within the limits considered permissi-
ble at the time of exposure. These data indicate that benzene is
a human carcinogen at levels not greatly above the current legal
standard.
This study was critized by Tabershaw and Lamm (1977).
They state that some exposed groups at the two plants were not in-
cluded and that this report was a rediscovered cluster of leukemia.

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VII-16
These criticisms were answered by the authors; specifically, they
state that the study cohort was selected before they had any know-
ledge of the occurrence of leukemia.
This study provides the strongest epidemiologic evidence
of an excess of leukemia among persons exposed to benzene. However,
because of uncertainties as to the level of exposure and the gen-
eralizability of these data, this one study alone cannot be regarded
as definitive.
Ott, et_ a_l. ( 1978) and Townsend, et^ a_l. ( 1978) reported
mortality and health exam findings among individuals occupationally
exposed to benzene at the Michigan Division of Dow Chemical. In
the mortality study, 594 workers involved in three production areas
on or after 1/1/40 through 1/1/74. Between 1953 and 1972 the time
weighted-average exposure to benzene was estimated to be generally
less than 10 parts per million, although there were some exposures
above 30 ppm. Among the entire population 102 deaths were observed
and 128.2 were expected on the basis of age-time specific death
rates for U.S. white males. Two deaths from leukemia (leukemia,
acute myelogenous leukemia) were observed and 1.0 were expected.
A third person's death was attributed to pneumonia but the person
had acute myeloblastic leukemia. These data are too few to provide
an independent stable estimate of the relation between benzene and
leukemia.
In the report on health exam findings among 282 of this
cohort, Townsend, et al^. ( 1978) concluded that there was no indica-
tion that adverse effects of benzene had occurred in their cohort.

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VII-17
Studies of Persons with Possible Exposure to Benzene. In
a proportional mortality analysis of cause of death among 3,637
chemists, Li, et_ a_l. (1969) noted an excess of pancreas cancer
(36 observed, 22 expected) and of lymphatic and hematopoietic
cancer (94 observed, 59 expected). Included were 33 death
observed from leukemia in comparison to 25 expected. While it
might be expected that as a group chemists would have more exposure
to benzene than would the general population, no information on
exposure was available.
In a case-control study of leukemia in Japan, Ishimaru,
et al. (1971) studied 303 matched pairs of leukemia cases and
their controls, 30 of the cases and 124 of the controls had had
potential occupational exposure to jobs in which benzene and/or
medical X-ray exposure was likely. However, no information was
obtained on specific chemical agents, and it is speculative to
attribute the excess among the cases to benzene exposure.
In 1972 Redmond, et_ a_l. , evaluated mortality among 4,661
coke oven workers in 12 steel plants in the United States. Benzene
is one of the side products of coke production. Among all workers,
nine deaths from leukemia were observed and 10.8 were expected.
From 1976 through 1978, a number of reports have been
published on martality among U.S. rubber workers. (McMichael, et
al. , 1974, 1975, 1976a, 1976b? Andejelkovich, et al., 1976, 1977;
Monson and Nakano, 1976a, 1976b; Monson and Fine, 1978). A number
of solvents, including benzene, have been used in the production

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f H-n (»«*<**"« )*«" ^
of rubber products. In many of these reports there has been an
excess occurrence of leukemia, both myelogenous and lymphatic.
While the excess tended to occur in areas with relatively high
solvent exposure, no estimates of exposure to benzene were avail-
able.
Greene, et al., reported in 1979 the proportional cancer
mortality experience of 347 male employees of the U.S. Government
Printing Office. Benzene had been used at this facility only on a
limited basis, primarily in the bindery. There were 16 deaths from
leukemia observed and 11.6 expected overall. Among binders, there
were 5 deaths from leukemia observed and 2.8 expected. Among white
binding workers there was a significantly elevated population
mortality ratio of 315.
Vianna and Polan (1979) reported an excess occurrence of
lymphoma among a number of occupations where benzene and/or coal
tar fractions are used. Based on a stable number of deaths in New
York State, from 1950 through 1969, crude relative risks based on
mortality rates were: reticulum cell sarcoma—1.6, lymphosarcoma—
2.1, and Hodgkin's disease—1.6. These data share the limitations
of the Aksoy study in that occupation for the denominator of the
rate was estimated on the basis of census data and occupation for
the numerator was determined from the death certificate. Further,
no estimate of actual benzene exposure was possible*

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VIII-1
VIII. MECHANISM OF TOXICITY
The early studies on the mechanism of benzene-induced
bone marrow depression evaluated bone marrow and for the most part
emphasized morphology. The classical studies of Selling (1916) in-
cluded a description of rabbit bone marrow following chronic intoxi-
cation with subcutaneously administered benzene. The first signs
of bone marrow damage were evident on the second day of injection
with 1 mL/kg and by the ninth day aplasia was complete. All of the
cell types were damaged and gradually disappeared during the course
of treatment. Considerable evidence has developed to support the
concept that benzene produces its effect by inhibiting cell division.
Fewer mitotic figures were observed in the marrow of benzene intoxi-
cated animals and benzene has been shown to cause abnormal mitotic
figures (Pollini, et^ al^. , 1965). Recently Sammett, et^ a_l. ( 1979)
demonstrated that livers of partially hepatectomized rats failed to
grow back when the animals were treated with benzene, and D'Souza,
et al. (1979) reported that the remaining ovary in the hemi-spayed
rat did not undergo compensatory cell proliferation aftar treatment
with benzene. These data suggest that benzene inhibited cell pro-
liferation. Thus, it may be that the reason that benzene does not
act as a primary liver toxin but is highly effective against the
bone marrow is that liver cells do not normally undergo rapid cell
proliferation where|as rapid proliferation is a property of bone
marrow cells.
The effects of benzene on chromosomes will be discussed
under the section on the mutagenic potential of benzene but some

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VII1-2
reference to these effects is important here because they reflect
on mechanisms of cell replication. Chromosome aberrations follow-
ing benzene treatment or exposure have been observed by Kissling
and Speck (1969, 1972) Forni, et al. (1971a,b), and Tough, et al.
(1970). Although cellular damage which results in mitotic arrest
is readily observed, it is not clear where the initial attack
occurred. Thus, Moeschlin and Speck (1967) and Kissling and Speck
(1969, 1972) reported decreases in bone marrow uptake of tritiated
thymidine into DNA and tritiated cytosine into RNA after treating
rabbits with benzene subcutaneously. They claimed that benzene
inhibited the synthesis of both types of nucleic acid. Boje, et al.
(1970) made similar observations after exposing rats to benzene by
inhalation but suggested that the decrease may have been explained
by a number of effects such as degradation of nucleic acids, reuti-
lization of tritiated thymidine, changes in pool size or altera-
tion in the cell cycle. These observations require further clarifi-
cation.
The postulate that a metabolite of benzene mediates ben-
zene-induced hemopoietic toxicity is supported by several lines of
evidence. Studies in the rat, rabbit and dog have indicated that
decreased metabolism of benzene correlates with decreased toxicity.
Hirokawa and Nomiyama (1962) and Nomiyama (1962) have shown that
rats whose livers oxidized benzene less rapidly in vitro were less
susceptible to benzene poisoning. Abramova and Gadakina (1965)
showed that the administration of antioxidants such as propyl
gallate, cystine, cysteamine and methionine to rabbits decreased

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VII1-3
benzene metabolism in vivo and in vitro.and also decreased the leu-
kopenia seen after chronic benzene administration. Hough and Free-
man (1944) reported that dogs exposed to a mixture of benzene, to-
luene and xylene metabolized less benzene, had higher leukocyte
counts and survived longer than dogs exposed to benzene alone.
Each of these studies concluded that a decrease in benzene meta-
bolism is accompanied by a decrease in benzene-induced hemopoietic
toxicity.
Andrews, et al. (1977a) administered ^H-benzene to mice
(440 or 880 mg/kg) subcutaneously with or without toluene (2mL/kg)
a competitive inhibitor of benzene metabolism, ^-benzene and its
metabolites were measured in urine and tissues of the mice, and
toxicity was measured using the 59pe uptake method of Lee, et al.
(1974). Co-administration of toulene with benzene rendered benzene
less effective as an inhibitor of red cell 59pe uptake and reduced
the accumulation of benzene metabolites in urine. A 2:1 ratio of
toluene to benzene partially alleviated benzene toxicity, whereas a
4:1 ratio of toluene to benzene completely prevented benzene toxi-
city. The protective effect of toluene appears to result from the
inhibition of the conversion of benzene to a toxic metabolite.
A striking observation in this experiment was that levels
of benzene metabolites in bone marrow far exceeded levels in all
other tissues. Peak metabolite levels in bone marrow reached a
level of 900 nmoles/g wet weight but only 110 nmoles/g in blood.
The accumulation and persistence of such high levels of metabolites

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VII1-4
in bone marrow suggest the possibility that it is these metabolites,
rather than the covalently bound metabolites, that cause the
initial depression in bone marrow function. The accumulation of
benzene metabolites in bone marrow was apparently not due to the
uptake of metabolites from blood, since ^H-phenylsulfate, ^H-phenyl-
glucuronide and ^H-phenol did not concentrate in bone marrow after
iv injection. It was postulated, therefore, that the metabolites
may be formed and sequestered within bone marrow.
Rickert, et aJU (1979) described the distribution of
benzene and its metabolites in rats exposed to 500 ppm benzene in
the air. In this experiment, levels of free phenol, catechol and
hydroquinone were detected in blood and bone marrow. Furthermore,
levels of phenolic metabolites in bone marrow exceeded the respec-
tive levels in blood. These results paralleled those of Andrews,
et al. (1977a) who administered benzene subcutaneously to mice.
Therefore, the distribution of benzene metabolites was essentially
the same whether benzene was given via inhalation or by subcutaneous
injection.
Not all experiments, however, have demonstrated the
concentration of benzene metabolites in bone marrow. Bergman (1979)
used whole body autoradiographic techniques to localize 14C-benzene
and its metabolites in tissues of mice exposed by inhalation. The
amount of 14c_benzene was determined by low temperature autoradio-
graphy and the amount of l^C-benzene metabolites by autoradiography

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VI11-5
of dried, evaporated sections. No selective accumulation of ben-
zene metabolites was found in bone marrow. These results are dif-
ficult to rationalize in terms of the results of Andrews, £t al.
( 1977a) and Rickert, et a_l. ( 1979). However, Andrews, et^ al.
(1977a) determined benzene metabolites as conjugates of phenols
and Rickert, et a_l. (1979) determined metabolites by a gas-liquid
chromatography mass-spectrometric technique. These techniques are
more specific and analytical than whole body autoradiography. Ad-
ditionally, Greenlee, et^ a_l. (1980), using radioautographic techni-
ques, have recently observed that pyrocatechol and hydroquinone,
which are known metabolites of benzene, concentrate in hemopoietic
organs of the rat.
Recent studies using the ^9pe uptake technique to evalu-
ate benzene toxicity have added to the evidence linking benzene
metabolism with its toxicity. Longacre, et^ al_. ( 1980) demonstrated
a correlation between benzene metabolism and hemopoietic toxicity
in several strains of mice. In these experiments male CD-I, C57/B6
and DBA/2 mice were given ^H-benzene and both the red cell 59Fe
uptake and the levels of benzene metabolites in urine and tissues
were determined. A comparison between the most sensitive strain,
the DBA/2, and the least sensitive strain, the C57/B6, revealed
that the levels of benzene metabolites in the bone marrow and other
organs were higher in the more sensitive animals. Another experi-
ment demonstrated the primary role of the liver in benzene toxicity
(Sammett, et: aJL. , 1979). Sprague-Dawley rats that had undergone
partial hepatectomy (70-80% of the liver was removed) were given
^H-benzene, and benzene metabolism and toxicity were measured.

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VIII-6
Partial hepatectomy decreased the metabolism of benzene by 70% and
completely protected against benzene-induced hemopoietic toxicity
when compared to sham-operated animals that received benzene.
One explanation for the presence of high concentrations
of benzene metabolites in bone marrow is that these metabolites
are formed in bone marrow and thereby accumulate in that tissue.
Andrews, et al. (1977b) have shown that subcellular fractions from
rabbit bone marrow contain benzo(a)pyrene hydroxylase, a mixed-
function oxidase enzyme. Benzo(a)pyrene hydroxylase activity is
highest in the microsomal fraction, was inducible as a result of
treatment of rabbits with 3-methylcholanthrene and was inhibited
by low concentrations of 7,8-benzoflavone. More recently, hydroxy-
lation of benzene to phenol has been shown to occur in rabbit bone
marrow in vitro (Andrews, et al., 1979). In these experiments,
^H-benzene metabolism was determined in the microsomal fraction of
rabbit femoral bone marrow. Cytochrome P-450 (26-51 pmoles/mg mi-
crosomal protein) were detected in bone marrow microsomes.
^H-benzene metabolism (2 pmoles benzene equivalents/mg microsomal
protein/min) required the presence of an NADPH-generating system
and was inhibited 80% in the presence of a C0s02 (9:1) atmosphere.
The products of benzene metabolism were phenol and an unknown
metabolite.
Recently, Irons, et al. (1980) have described the meta-
bolism of benzene in rat bone marrow that was perfused in situ.
The left common iliac artery and vein were cannulated, the isolated

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limb was perfused with whole rat blood and ^4C-benzene was intro-
duced through the head of the femur into the marrow space. Blood
was recirculated and collected at successive time intervals. Bone
marrow was collected at the end of the experiment "for determination
of metabolites. Radiolabeled phenol, catechol and hydroquinone
were isolated from both blood and bone marrow. In these studies
benzene metabolites accumulated in the marrow much as they do in
vivo. The rate of benzene metabolism in marrow iis much lower than
liver, an observation probably related to the low level of mixed-
function oxidase activity found in bone marrow.
Despite evidence showing that benzene can be metabolized
in bone marrow, production of toxic metabolites of benzene by bone
marrow may be insufficient to produce bone marrow depression.
Sammett, et al. (1979) recently demonstrated that partial hepatecto-
my protected rats and mice from benzene-induced depression of
erythropoiesis. The protective effect was accompanied by a decrease
in urinary levels of benzene metabolites, a reduction of soluble
benzene metabolites in bone marrow and a lowering of covalent
binding of reactive metabolites of benzene to bone marrow protein.
Although bone marrow can metabolize benzene, apparently benzene
metabolism in the liver plays a more important role in the develop-
ment of bone marrow toxicity. These previous reports of protection
against toxicity in phenobarbital-treated animals (Ikeda and
Ohtsuji, 1971; Drew and Fouta, 1974) reflect the fact that pheno-
barbital probably increased the detoxification rate in liver. On
the other hand, inhibition of metabolism by toluene and also by

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VII1-8
aminotriazole (Hirokawa and Nomiyama, 1962) protected animals by
decreasing the rate of formation of toxic metabolites. Thus, it
appears that a metabolite formed in liver is transported into the
marrow where it is converted to a compound which cannot be removed
from the marrow and accordingly accumulates (Andrews, et al., 1977b;
Rickert, et al., 1979) leading to a metabolic impairment expressed
as bone marrow depression. Similar mechanisms may play a role in
benzene-induced leukemogenesis.

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L\ - !
IX. RISK ASSESSMENT
It is not intended here to develop a new risk "assess-
ment for benzene. This section will report and comment on the
existing literature as it relates to the development of risk
assessments for benzene.
Benzene holds a unique position in industrial chemistry
because of its extensive use for more than 100 years and the fact
that new uses are continually developing. Its first heavy use was
in the 19th century (Hunter, 1962) in the rubber industry where it
was an excellent solvent for rubber latex.- Some of the first cases
of benzene poisoning were observed among women who painted benzene-
based rubber cement on cans to seal the lids (Selling, 1910). In
each, upon evaporation of the benzene the hardened rubber remained
and provided either molded rubber products, rubberized fabrics, or
rubber seals for cans. Benzene poisoning was also observed
extensively in the rotogravure printing industry in this country
(Mallory, 1939) because it was used as a rapidly drying solvent for
the various colored inks in high speed printing presses. Almost any
process that has required a good aromatic solvent has made use of
benzene because of its properties plus its low cost.
In addition to its use as a solvent, benzene has been used
extensively as a starting material in chemical syntheses. Following
World War II with the development of the plastics industry, benzene
utilization increased dramatically because it serves as a source for
the synthesis of the monomeric units of polystyrene plastics. The

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This is ]J~3 ) 32T-3 b -fke vvexf sK«+.
the establishment of an MAC value (maximum allowable concentration)
of benzene in the workplace by the newly formed American Conference
on Governmental Industrial Hygienists (ACGIH) in the late 30's-early
40's. ACGIH standards are voluntary and do not carry the force of
law. However, attempts to comply with thes.e recommendations were
reportedly pursued. -In 1946 an MAC of 100 ppm was allowed in the
workplace (Zenz, 1978). In 1947 the standard was reduced to 50 ppm
as a time weighted average over an eight hour day. Further . .
reduction to a 25 ppm TWA over eight hours was applied in 1948 and
a 25 ppm ceiling was added in 1963. Thus, not only was the exposure
restricted to an average of 25 ppm over a workday, but by applying
a ceiling, no excursion above 25 ppm, even for brief periods, was
allowed. In 1970 the TWA was reduced to 10 ppm and by 1974, when
OSHA and NIOSH came into the picture, the 10 ppm was complemented
with a 25 ppm ceiling (NIOSH, 1974). In 1976, OSHA and NIOSH
reached the conclusion that benzene was a leukemogen, and the 10
ppm standard was not considered sufficient to protect the worker.
Further^ discussion of the OSHA conclusions is provided in the
following excerpt from a Supreme Court syllabus (Supreme Court,
1980).
OSHA noted that there was "no dispute" that
certain nonmalignant blood disorders, evi-
denced by a reduction in the level of red
or white cells or platelets in the blood
could result from exposures of 25-40 ppm.
It then stated that several studies had
indicated that relatively slight changes
in normal blood values could result from

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IX-2
total amount of benzene used is controlled by the availability of
resources for its manufacture (Anonymous, 1973). It ranks with
ethylene and propylene, also precursors to plastics, as the most
heavily produced organic chemicals in the world. Other major uses
of benzene have been described by Fick (1976) who showed that ben-
zene was essential for the production of ethylbenzene (an intermedi-
ate in styrene production) cumene, cyclohexane, aniline, maleic
anhydride and numerous other compounds made in smaller quantities.
It is also added to gasoline as part of the aromatic fraction which
is replacing alkyl lead compounds as anti-knock ingredients. It is
unlikely that the use of benzene in industry will be abandoned, but
the International Workshop on Benzene (Truhaut and Murray, 1978)
recommended that all use of benzene as a solvent should be discon-
tinued since there are excellent substitutes available. Thus, the
only recommended use of benzene is in chemical syntheses.
Recommendations to limit exposure to benzene in the work-
place came soon after the problem of benzene toxicity was recognized.
Thus, in 1922, Alice Hamilton, one of the pioneers in industrial
medicine, wrote a telling report on "The growing menace of benzene
(benzol) poisoning in American industry." In part because of the
alarm she raised, attempts to control benzene exposure were insti-
tuted on a voluntary basis and she found it possible to report in
1928 on "The lessening menace of benzol poisoning in American
industry." The problem continued, however, and the description of
extensive benzene poisoning in the rotogravure printing industry
in New York (Mallory, et al., 1939) was in part responsible for

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that the nomnalignant effects of benzene	>c Map.TY-fr »
exposure justified a reduction in the	(n ^ \j r ./ )
permissible exposure limit to 1 ppm.*c'	"rfce
.	5nfH
The result was an extended legal battle in which the American
Petroleum Institute, the American Iron and Steel Institute and the
Manufacturing Chemists Association prevailed over the Department of
Labor in a decision by the Supreme Court. The Court ruled that the
rationale for lowering the permissible exposure limit was based not
on any findings that leukemia has ever been caused by exposure.to
10 ppm of benzene and that it will not be caused by exposure to
1 ppm, but rather on a series of assumptions indicating that some
leukemias might result from exposure to 10 ppm and that the number
of cases might be reduced by reducing the exposure level to 1 ppm.
The court further required that OSHA determine that it is reason-
ably necessary, appropriate, and feasible to remedy a significant
risk of material health impairment. Therefore the standard remains
at 10 ppm.
The National Academy of Sciences undertook to report on
the benzene problem. In 1977 the Committee on Toxicology of the
NAS reviewed the health effects of benzene, most of which have
been cited in this report, and recommended that further research
sufficiently below the levels at which adverse effects have been ;
observed to assure adequate protection for all exposed employees.M
43 Fed. Reg., at 5925. . While OSHA. concluded that application of
this rule would lead to an exposure limit "substantially less
than 10 ppm," it did not state either what exposure level it
considered to present a significant risk of harm or what safety
factor should be applied to that level to establish a permissible
exposure limit.

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IX-4
exposures below 25 ppm and perhaps below
10 ppm. OSHA did not attempt to make any
estimate based on these studies of how
significant the risk of nonmalignant
disease would be at exposures of 10 ppm or
less.(a) Rather, it stated that because of
the lack of data concerning the linkage be-
tween low-level exposures and blood abnormali-
ties it was impossible to construct a dose-
response curve at this time.(b) OSHA did
conclude, however, that the studies demon-
strated that the current 10 ppm exposure
limit was inadequate to ensure that no
single worker would suffer a nonmalignant
blood disorder as a result of benzene ex-
posure. Noting that it is "customary" to
set a permissible exposure limit by apply-
ing a safety factor of 10-100 to the lowest
level by applying a safety factor of 10-100
to the lowest level at which adverse effects
had been observed, the Agency stated that the
evidence supported the conclusion that the
limit should be set at a point "substantially
less than 10 ppm" even if benzene's leukemic
effects were not considered. 43 Fed. Reg.,
at 5924-5925. OSHA did not state, however,
As OSHA itself noted, some blood abnormalities caused by ben-
zene exposure may not have any discernible health effects, while
others may lead to significant impairment and even death. 43 Fed.
Reg. at 5921.
(b)	"a dose-response curve shows the relationship between differ-
ent exposure levels and the risk of cancer [or any other disease]
associated with those exposure levels. Generally, exposure to
higher levels carried with it a higher risk, and exposure to
lower levels is accompanied by a reduced risk." 581 F.2d, at
504, n.24.
OSHA's comments with respect to the insufficiency of the data
were addressed primarily to the lack of data at low exposure
levels. OSHA did not discuss whether it was possible to make a
rough estimate, based on the more complete epidemiological and
animal studies done at higher exposure levels, of the signifi-
cance of the risks attributable to those levels, nor did it dis-
cuss whether it was possible to extrapolate from such estimates
to derive a risk estimate for low-level exposures.
(c)	OSHA did not invoke the automatic rule of reducing exposures
to the lowest limit feasible that it implies to cancer risks.
Instead, the Secretary reasoned that prudent health policy
merely required that the permissible exposure limit be set". . .

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IX-6
was needed to clarify the mechanisms of benzene-induced diseases.
These sentiments were echoed in the report of the Safe Drinking
Water Committee of the Academy in 1977, when they quoted a figure
of 10 ug/L of benzene as the highest observed concentration in
finished water but failed to estimate the upper 95% confidence
estimate of lifetime cancer risk per ug/L for lack of sufficient
data.
The U.S. Environmental Protection Agency prepared four
documents on the health effects of benzene which were concerned
with an assessment of health effects, an assessment of environmen-
tal exposure and a population risk assessment. The first (U.S.EPA,
1978) was a complete review of the metabolism, cytogenetic and
embryonic effects; a review of the chronic toxicity of benzene
in animals; and a review of the pancytopenic, leukemogenic and
other toxic effects of benzene in man. Briefly, the conclusions
indicated that benzene was leukemogenic and pancytopenic in man
and caused genetic damage. There was doubt that the available
data could be used to derive a dose-response curve since most
evaluations of exposure in the face of benzene toxicity indicated
high doses but documentation of benzene toxicity at low doses
was poor.
The second, a contractor report prepared for the U.S.EPA
by Mara and Lee (1978), was a document on human exposures. The
report suggests that although there is clearly human exposure to
benzene in water, food and in some cases, soil, exposure via

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IX-7
these routes is minimal and the main exposure pathway was consid-
ered to be via the air. Sources of benzene included chemical
manufacturing plants, coke ovens, gasoline service stations,
petroleum refineries, solvent operations, storage, and distribu-
tion centers for benzene and gasoline, and exhausts from automo-
bile emissions in urban areas. Because of the paucity of data
and the fact that most of it was collected at specific points,
it was necessary to make a variety of assumptions with respect to
potential human exposure. One involved the use of dispersion
models. Estimates were made of the number of people exposed to
the lowest measurable concentrations of benzene, namely, 0.1 ppb.
A number of uncertainty factors were cited which clearly affected
the accuracy of the modeling results. Nevertheless, the report
estimated that the results were not in error by a factor greater
than an order of magnitude. The sources which lead to most human
exposure were reported to be gasoline service stations and urban
exposure to auto emissions. It was estimated that 87,000,000
people living in the vicinity of gasoline stations may be exposed
to benzene at levels of 0.1-1.0 ppb as an annual average with the
worst eight hour exposure to range from 1.0-10 ppb. An additional
31,000,000 people may be exposed on the average to 1.1-2.0 ppb
with possible 8 hour excursions to between 10.1 and 20 ppb. Among
urban exposures due to auto exhaust it was estimated that
68,337,000 people were exposed at the lower doses described above
and 45,353,000 at the higher dose conditions. It must be stressed
that the intent of this report was to estimate exposure but not to
measure responses to the exposure.

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IX-8
The final report U.S. EPA, 1979) in the series was an
attempt by the EPA Carcinogen Assessment Group (CAG) to establish
a risk assessment for ambient exposures to benzene and the final
report was issued in 1979. Since that was a report on carcinoge-
nesis, there was no emphasis on toxicity of benzene and accordingly,
a risk assessment on the pancytopenic effects of benzene should be
done independent of this CAG report. The CAG selected three
studies on which to base their estimations. They were the studies
by Infante, et^ al^. ( 1977), Ott, et^ al^. ( 1978) and Aksoy, et: al.
(1976, 1974), which reported on benzene-induced leukemia in rubber
pliofilm plants in Ohio, Dow Chemical plants and shoe-making
establishments in Turkey, respectively. Taking advantage of the
levels of exposure reported by these investigators the CAG applied
a linear non-threshold model to estimate the leukemogenic risk to
the low average exposure populations cited in the exposure assess-
ment report. A slope for the linear dose-response curve was esti-
mated by mathematically combining the data from the three reports
and it was estimated that among the general population, 90 cases
of leukemia, with 95% confidence limits of 24-235, are on an annual
basis due to exposure to benzene in the 1 ppb range. This would
account for from 0.23%-1.62% of all leukemia deaths in this country.
An important problem with the CAG report is the criticism
of the estimates of exposure to benzene. In the Dow study (Ott, ert
al., 1978) the estimates were in all likelihood, the most accurate.
There is less confidence in the exposure levels reported by Infante,
et al. (1977) and Aksoy, et al^. (1976, 1974). The exposure levels

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IX-9
in the pliofilm plant reported by Infante, et_ al^. ( 1977) were
challenged at the benzene hearings where it was suggested that they
were in reality much higher than proposed in the report. They were,
in fact, not based on a carefully collected series of sampling data
since the exposures occurred a number of years ago and the study was
done retrospectively. The Aksoy, et^ a_l. (1976, 1974) sampling data,
although reported in their publications, was not sufficiently docu-
mented to allow for evaluation of its accuracy. Nevertheless, given
the non-threshold linear model for extrapolation adopted by CAG,
the exposures in the Infante, eit a_l. , and Aksoy, et^ al^., studies
might have been much higher, but might not have had much more impact
on the results of the CAG extrapolation.
The problems of benzene in drinking water are difficult
to assess because of the paucity of data of the effects of ingested
benzene in either humans or animals. From the point of view of
carcinogenic risk assessment, however, the recent report of Maltoni
and Scarnato (1979) will probably predominate in this field for
some time to come. These workers administered benzene by gavage
to Sprague-Dawley rats at doses of either 250 or 50 mg/kg, 4-5
days per week for 52 weeks. The authors report that, although the
animals did not demonstrate acute or subacute toxic effects of
benzene, there was a significant incidence of Zimbal gland tumors
as well as increases in leukemias, mammary carcinomas and some
other tumor types. Thus, they claim that benzene is a "general
carcinogen," i.e., the carcinogenic effects are not restricted to
leukemias.

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IX-10
The Ambient Water Quality Criteria Document (1980) from
EPA contains an extensive discussion of the methods used in achiev-
ing a criterion for water levels of benzene. It was assumed that
the major source of exposure was through inspired air. An adult
male living in an urban environment could expect that 80% of his
total exposure to benzene was via ambient air. A breakdown of
total exposure showed that drinking water might contain anywhere
from 0.1 to 10 ug/L of benzene, food contained 250 ug/L and ambi-
ent air 50 ug/m^. The total intake was estimated to be 1.128 mg/day
of which 1.4% came from water, 17.7% from food and 80.9% from air.
The slope of the dose-response curve for benzene-induced leukemia
in the CAG report was 0.024074 lifetime leukemia risks per ppm
exposure to benzene in air. Making use of the fact that 1 ppm
equals 3.25 mg/m^, the respiratory rate is about 24 m^/day and
about 50% of the inhaled benzene is absorbed, it can be calculated,
that the average daily intake of benzene at 1 ppm is 32.5 mg.
U.S.EPA (1980) calculated, from this number that the intake of
benzene which will increase the lifetime risk of benzene-induced
leukemia by a factor of one in 10^ is equal to 0.0135 mg/day.
Using an alternative approach to estimating benzene
exposure it was suggested that the total body exposure to benzene
may be as high as 1.1 mg/day, with air exposure the dominating
route in these calculations as well.
It is unlikely that it can be confirmed that any
specific case of environmental leukemia can be directly related

-------
». n-'o -5 ;»*««' >Kstl	ix-n
r (il'j oiU H place)
to ambient benzene, nor is it likely that an animal experiment can
be devised to demonstrate leukemia at low dose levels of benzene.
The limiting factor in the determination of expected risks due to
exposure to benzene is then the model that one uses for risk as-
sessment. Although models other than linear non-threshold and one
hit models have been proposed (Food Safety Council, The Scientific
Committee, 1978) they have not gained acceptance. This is because
they have not been validated and because they appear to be less
conservative than the approach taken by EPA. Therefore, it is
appropriate for the purposes of this document to make use of simi-
lar procedures in establishing a risk assessment for benzene in
drinking water.

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X-l
Chapter X Quantification of Toxicological Effects (QTE)
The quantification of toxicological effects of a chemical
consists of an assessment of the non-carcinogenic and carcino-
genic effects. In the quantification of non-carcinogenic
effects, an Adjusted Acceptable Daily Intake (AADI) for the
chemical is determined. For ingestion data, this approach is
illustrated as follows:
Adjusted ADI = 	(NOAEL or MEL in mg/kg) (70 kg)
(Uncertainty factor) (2 liters/day)
The 70 kg adult consuming 2 liters of water per day is used
as the basis for the calculations. A "no-observed-adverse-
effect-level" or a "minimal-effect-level" is determined from
animal toxicity data or human effects data. This level is
divided by an uncertainty factor because, for these numbers
which are derived from animal studies, there is no universally
acceptable quantitative method to extrapolate from animals to
humans, and the possibility must be considered that humans
are more sensitive to the toxic effects of chemicals than are
animals. For human toxicity data, an uncertainty factor is
used to account for the heterogeneity of the human population
in which persons exhibit differing sensitivity to toxins.
The guidelines set forth by the National Academy of Sciences
(Drinking Water and Health, Vol. 1 1977) are used in establishing
uncertainty factors. These guidelines are as follows: an
uncertainty factor of 10 is used if there exist valid
experimental results on ingestion by humans, an uncertainty
factor of 100 is used if there exist valid results on long-

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X-2
term feeding studies on experimental animals, and an uncertainty
factor of 1000 is used if only limited data are available.
In the quantification of carcinogenic effects, mathematical
models are used to calculate the estimated excess cancer
risks associated with the consumption of a chemical through
the drinking water. EPA's Carcinogen Assessment Group has
used the linear non-threshold model, which is linear and
does not exhibit a threshold, to extrapolate from high dose
animal studies to low doses of the chemicals expected in the
environment. This model estimates the upper bound (95%
confidence limit) of the incremental excess cancer rate that
would be projected at a specific exposure level for a 70 kg
adult, consuming 2 liters of water per day, over a 70 year
lifespan. Excess cancer risk rates also can be estimated
using other models such as the one-hit model, the Weibull
model, the logit model and the probit model. Current
understanding of the biological mechanisms involved in cancer
do not allow for choosing among the models. The estimates of
incremental risks associated with exposure to low doses of
potential carcinogens can differ by several orders of magnitude
when these models are applied. The linear, non-threshold
multi-stage model often gives one of the highest risk estimates
per dose and thus would usually be the one most consistent
with a regulatory philosophy which would avoid underestimating
potential risk.
The scientific data base, which is used to support the
estimating of risk rate levels as well as other scientific

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X- 3
endeavors, has an inherent uncertainty. In addition, in many
areas, there exists only limited knowledge concerning the
health effects of contaminants at levels found in drinking
water. Thus, the dose-response data gathered at high levels
of exposure are used for extrapolation to estimate responses
at levels of exposure nearer to the range in which a standard
might be set. In most cases, data exist only for animals;
thus, uncertainty exists when the data are extrapolated to
humans. When estimating risk rate levels, several other
areas of uncertainty exist such as the effect of age, sex,
species and target organ of the test animals used in the
experiment, as well as the exposure mode and dosing rates.
Additional uncertainty exists when there is exposure to more
than one contaminant due to the lack of information about
possible additive, synergistic or antagonistic interactions.

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XI-1
Chapter IX. Quantification of Toxicological Effects (QTE)
Non-Carcinogenic Effects
The toxic effects of benzene in human and other animals
include central nervous system effects, hematological effects
as well as immune system effects. Short-term exposure to
relatively high levels of benzene produces central nervous
system effects that include dizziness, giddiness, exhilaration,
nausea, vomiting, headache, drowsiness, staggering, loss of
balance, narcosis, coma and death. It has been known since
the 19th century that long term exposure to benzene produces
adverse hematological effects; Santesson (1897) described
cases of aplastic anemia in workers fabricating bicycle tires.
The original association of acute leukemia with benzene
exposure was made in 1928 (Delore and Bergomano, 1928) and it
has been postulated that benzene may be a cause of acute
myelogenous leukemia (Goldstein, 1981; OSHA, 1978b; NAS,
1980). Other hematological diseases also have been reported
to be associated with benzene exposure (Goldstein, 1977).
Gerarde (1960) provides a table summarizing acute effects
in which it is stated that 19,000-20,000 ppm for 5 to 10
minutes is a fatal benzene level; "7,500 ppm for 30 minutes is
dangerous to life; 1,500 ppm for 60 minutes produces serious
symptoms of illness; 50 to 150 ppm for five hours produces
headache, lassitude and weakness". Mild central nervous
system effects appear rapidly reversible following cessation
of exposure. There is no evidence that they result in chronic

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XI-2
brain damage. Also of importance is that these results appear
to be concentration-dependent. Lower levels do not appear to
illicit these responses no matter how long the exposure (at
480 mg/m^)(Goldstein, 1977).
The toxicity of benzene to the hematopoietic system of
humans experiencing chronic exposure to benzene is well
documented. Reported effects include myelocytic anemia,
thrombocytopenia (occurring separately or in cases of pancyto-
penia) and leukemia. In many of these studies, humans were
exposed to benzene along with other solvents at relatively
high concentrations. Data on the level and duration of
exposure are inadequate for deriving dose-response relation-
ships of chronic benzene toxicity (Vigliani and Formi, 1976).
While it is impossible to determine a no-effect-dose, it is
highly probable that continuous exposure to benzene at low
levels (see below) will result in the above noted effects.
Infante, et al. (1977), reported a retrospective cohort
study of two populations of workers who were involved in
the production of rubber sheeting (Pliofilm). In both plants
during 1940-1949, the occupational exposure of 561 workers
to benzene was apparently well within the maximum allowable
concentration of 100 ppm that was usually recommended.
Vital status to 1975, which was obtained for 75 percent of
the workers, showed a significant excess of leukemia in
those exposed to benzene, indicating a 10-fold increase in
risk of death from myeloid and mononcytic leukemia.

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XI-3
In 1981, Rinsky, et al., published a study that was a
follow-up using the same cohort as the Infante study. Rinsky's
study followed up more than 98 percent of the vital status
versus 75 percent for Infante's. Rinsky found that the leukemia
mortality for those workers exposed five or more years had an
Standard Mortality Ratio of 2,100. All leukemia deaths were
either myelocytic or monocytic cell types.
The onset of leukemia is usually preceded by many
observable effects on the hematopoietic system (Snyder and
Kocsis, 1975). It is not known whether benzene causes leukemia
as one aspect of its hematotoxic effects, whether the leukemia
is a consequence of benzene-induced damage to immunological
components of the bone marrow, or whether the leukemic effects
are unrelated to the other hematopoietic manifestations
(Laskin and Goldstein, 1977).
Benzene mixed with equal parts of olive oil was administered
to rats by subcutaneous injection (Latta and Davies, 1941;
Gerarde, 1956). Weight loss and leukopenia resulted from
doses of 880 mg benzene/kg body weight, which were given daily
for 14 days (Gerarde, 1956), and from doses of 1.32 g benzene/kg
body weight, which were given daily for 3 to 60 days (Latta
and Davies, 1941). In Latta and Davies' study, a rat that
died after 10 days had hyperplastic bone marrow, and one that
died at 21 days had acute leucopenia and hypoplastic bone
marrow. Oral administration of benzene to rats in daily
doses of 1, 10, 50 or 100 mg/kg weight during 132 days over

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XI-4
6	months resulted in leucopenia and erythrocytopenia at the
lowest minimal effect level of 10 mg/kg and above (Wolf, et
al., 1956).
Leucopenia is the most commonly observed effect of chronic
benzene intoxication in laboratory animals. Deichmann, et al.
(1963) exposed 40 male and 40 female Sprague-Dawley rats by
inhalation to six different levels of benzene for 5 hours to
7	hours per day four days a week for six to 31 weeks. Tail
blood was collected weekly or biweekly and analyzed for total
peripheral white blood cell count, red blood cell count and
benzene concentrations. All rats were examined for gross
pathologic tissue changes and, in a few instances, the
nucleated cell populations of femoral bone marrow were
determined. The dose levels were 0, 50, 96, 146 or 2760 mg/m^.
The most significant and constant pathological changes were
found in the lungs (chronic bronchopneumonia) and spleen
(hemosiderosis). The splenic hemosiderosis was more severe
and occurred more frequently in females when compared to
controls, but was not dose related. Leucopenia developed at
146 mg/m^ and above. This effect was dose related and occurred
with greater severity and at an earlier time in females. In
addition, there was some indication, also in females, that
the circulating white blood cell count was depressed at 103
mg/xn3. However, at lower exposures, a fall in leukocytes
causes cyclical fluctuations. Moreover, there is normally
wide variation among cell counts during diurnal cycles and
among individual animals.

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XI-5
Quantification of Non-carcinogenic Effects
OSHA noted that there was "no dispute" that certain non-
maligant blood disorders in humans evidenced by a reduction in
the level of red or white cells or platelets in the blood
could result from exposures of 25 to 40 ppm (Pagnotio, et
al., 1961, 43 Fed~ Reg. at 5921). Several studies indicate
that relatively slight changes in normal blood values could
result from exposure below 25 ppm and perhaps below 10 ppm
(Chang, 1972, Doskin, 1971).
Chang studied 119 workers exposed to benzene in an
industrial area. Hematological abnormalities were observed
in 28 percent including 21 with anemia, 2 with leukopenia,
and 5 with both. Chang plotted a graph in which each of
those affected individuals is characterized by duration of
work on the abscissa and the level of benzene exposure on the
ordinate. Based on this plot, Chang obtained an exponential
function that implied a "threshold" of 10 ppm benzene for
cytopenic effects (Chang, 1972). However, no hematological
toxicity was observed in the 18 workers exposed to 10 to 20 ppm
benzene. A major problem in interpreting this study is the
absence of information concerning the definition of work
exposure concentration for the individual employees.
Doskin (1971) in the Soviet Union evaluated 365 individuals
employed for three years in what was apparently a new chemical
factory. Serial hematological studies were performed on the

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XI-6
exposed workers as well as the control group. Benzene exposure
levels are given in terms of the maximum permissible concentra-
tion two- to eight-fold excess in 64 percent of the measure-
ments in the first year (37% in the second year and 3% in
the third year). This decrease in benzene levels paralleled
a decrease in the number of workers who had hematological
abnormalities. In the first year close to 40 percent of the
workers exhibited mild hematological abnormalities, the most
common being thrombocytopenia (95-155,OOO/mm^). In ^as much
as the maximal permissible concentration in the Soviet Union
at the time of the study was apparently 5 ppm, these findings
suggest that exposure of workers to concentrations of 10 to
40 ppm benzene for less than one year produces mild cytopenic
effects. Interpretation of this study would be furthered by
information concerning the benzene monitoring system and the
actual levels recorded. It is hard to identify a high risk
group per se. Since benzene bioaccumulates in the bone
marrow, it would be surmised that those people with rapidly
synthesizing marrows are at greatest risk. Those groups
would include:
1.	Fetuses, infants and children
2.	People with anemia (women)
a
3.	People with agranftlocytemia (drug or chemically induced)
It is almost certain that nearly all environmental
benzene exposure is a multiple chemical exposure. Gasoline,
fuel oil and leachate being the most common mixtures. No one
has determined if there is an additive or synergism of the

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XI-7
effects of multiple chemical exposure. Certainly the acute
effects will have combined greater effects if other volatile
organic chemicals are present.
An Average Daily Intake (ADI) may be calculated using
data from Wolfe, et al. (1976) who gavaged female rats of
1, 10, 50 or 100 mg/kg over a 187 day period. No effects
were seen at 1 mg/kg but a slight leucopenia was observed at
10 mg/kg given 132 times over the 187 days. The ADI may be
calculated using the 1 mg/kg level as a no-observed-adverse-
effect-level (NOAEL) and assuming 100 percent absorption
factor.
ADI = 1 mg/kg X (100%)(5) x 70 = 0.50 mg/day x 10~4 kg/day =
(100)(10)	(7)
50 ug/70 kg/day
Where: 1 mg/kg = assumed NOAEL
70 kg = 70 kg man
100% = absorption
100 = uncertainty factor appropriate for use with
NOAEL from animal data and no equivalent
human data
10 = uncertainty factor for less than lifetime exposure
An ADI based upon a NOAEL for human hematological abnormalities
might be developed as follows:
The NOAEL is between 10 ppm and 25 ppm.
10 ppm X 3.2 mg/m3/ppm X 8 m3 X 0.6 = 0.1530 mg/day
100 X 10
Where: 1 ppm = 3.2 mg/m3
8 m3 = The amount of air a 70 kg worker breaths in 8 hours/
per day

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XI-8
0.6 = 60% = percent absorbed and retained
100 = uncertainty factor appropriate for human exposure
with less than ideal experimental conditions
10 = uncertainty factor for less than a lifetime exposure
Adjusted ADI would be derived thusly:
(1 mg/kg)(70 kg ) (100%)(5) = 0.025 mg/1 or
(100) X (10) X 2 1 X (7)
ADI
2 1
Where: 1 mg/kg = assumed no-observed-adverse-effect-level
(NOAEL)
70 kg = 70 kilogram man
100% = absorption factor
2 1=2 liter of water consumed per day by the 70 kg
adult
100 = uncertainty factor appropriate for use with
NOAEL from animal data and no equivalent
human data
10 = factor for less than lifetime exposure
5/7 = factor to correct from 5 days/week to 7 days
An Adjusted ADI for non-carcinogenic effects based
upon a NOAEL for human hematological abnormalities might be
developed as follows:
The NOAEL is between 10 ppm and 25 ppm.
Adjusted = 10 ppm X 3.2 mq/m^/ppm X 8 m^/day X 0.6 = 0.078 mg/day
ADI	100 X 10
or 0.1536 mg/1 = 0.078 mg/1
2

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XI-9
Where: 1 ppm = 3.2 mg/m^
8 m^ = The amount of air a 70 kg person breaths per
active work day
0.6 = 60% = percent absorbed and retained
100 = uncertainty factor appropriate for human exposure
with less than ideal experimental conditions
10 = uncertainty factor for less than a lifetime exposure
Where: 21 = volume of drinking water imbbed a day by a 70 kg
adult
From the series of longer term experiments described
above, one would develop an Adjusted ADI protective against
non-carcinogenic effects in the range of 0.025 to 0.078 mg/day
for the 70 kg adult based on the human data. This assumes
that drinking water is the sole source of exposure to benzene.
The Adjusted ADI is derived to reflect allowable daily
exposure of a 70 kg adult drinking two liters of water per
day, and whose sole source of exposure to benzene is via that
drinking water. This calculation does not reflect the
associated carcinogenic risk.

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XI-10
Carcinogenic Effects
Maltoni and Scarnato (1979) administered by gavage
benzene dissolved in virgin olive oil to 13 week old Sprague-
Dawley rats. The material was administered at doses of 50
or 250 mg/kg for 4 to 5 days a week for 52 weeks. The
animals then were allowed to live until spontaneous death.
Each high dose group consisted of 35 male and 35 female rats;
the controls and low dose groups were composed of 30 male and
30 female rats each. After 20 weeks of exposure, Maltoni
and Scarnato corrected the denominators (numbers of animals
surviving) to reflect "nonexperimentally" caused deaths.
The 250 mg/kg dose level group then consisted of 33 male and
32 female rats; the 50 mg/kg and olive oil control group
then consisted of 28 male and 30 female rats. The authors
reported their results after 144 weeks. At the 250 mg/kg
dose level, 25 percent (8/32) of the female rats had Zymbal
gland tumors, 6.2 percent (2/32) had skin carcinomas, 21.9
percent (7/32) had mammary carcinomas, 3.1 percent (1/32)
had leukemias. The male rats in the 250 mg/kg dose group
had no Zymbal gland tumors, no skin carcinomas and no mammary
gland tumors; however, they had 12.1 percent leukemias (4/33),
one subcutaneous anigosarcoma (3.0%) and one hematoma (3.0%).
In the rats remaining after the 20 week adjustments, the

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XI-11
following carcinogenic effects were noted. At the 50 mg/kg
dose level, only female rats had tumors which were Zymbal
gland carcinoma, 6.7 percent (2/25) and mammary carcinoma,
13.3 percent (4/25). The control group had tumors only in
female rats, which were mammary carcinoma 10.0 percent (3/30),
and leukemias, 3.3 percent (1/30). The authors concluded
that benzene "appears to cause Zymbal gland carcinomas, at
the two studied dose levels with a dose response relationship.
Moreover, a dose correlated increase of hemato-lympho reticular
neoplasias (leukemias) and mammary carcinomas has also been
observed".
Ward, et al. (1975) subcutaneously injected male C57BL/
6N mice repeatedly with benzene dissolved in corn oil. Eighty
benzene treated mice, while initially divided into four groups
ranging from 0.1 to 2.0 mg/kg, were eventually combined and
reported as a single experimental group. Three control groups
were used with twenty male mice per group: a no treatment
control, a corn oil only control, and a positive control
using butylnitrosourea. The animals were injected twice weekly
for 44 weeks, then once weekly until 54 weeks. At 104 weeks
after the first injection, all surviving mice were sacrified
(108 weeks of age) and a complete necropsy was performed, as
had been done with all the mice that died. The toxic lesions
included bone marrow depleted of hematopoietic cells and
hepatonecrosis. A granulocytic leukemia was also noted.

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XI-12
After reviewing the data from that study, the National Academy
of Sciences Safe Drinking Water Committee concluded that the
increase in pathology was not statistically significant, even
when time to response was incorporated into the analysis
(National Academy of Sciences, 1977).
Benzene has been shown to be carcinogenic in Sprague-
Dawley rats. As noted above, tumors were found at both 50 mg/kg
and 250 mg/kg dose levels. It has been shown that humans are
at least two orders of magnitude more sensitive than animals.
Over the past several decades, scientists have conducted
a great deal of research in an effort to establish the mechanism(s)
by which chemical substances exert their carcinogenicity.
The somatic cell mutation theory of carcinogenicity suggests
that for a carcinogenic response to occur, an irreversible
change must occur in the cell which results in proliferation
of a neoplasm. This change reflects a mutational event in
the DNA of that cell, suggesting that the chemical carcinogen
must interact directly with or otherwise alter the DNA to
initiate the change. In recent years, however, some substances
have been shown to be carcinogenic, but by mechanisms in
which there apparently is no direct interaction with or
alteration of the DNA of the cell by the substance. Presumably,
these compounds are not capable of initiating the alteration
of a normal cell to a neoplastic response in latent cells.
On the basis of these purported differences in mechanisms,
carcinogens now are often classified into two broad categories:
genotoxic and epigenetic or nongenotoxic.

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XI-13
The mechanisms by which a compound exerts its carcino-
genicity rarely can be determined by the chronic testing of
whole animals such as is done in the NTP bioassay. Thus, a
Large number of short-term i_n vitro and _in vivo assay systems
have been developed for the purpose of elucidating mechanisms.
Since most of the jln vitro testing systems measure mutational
events, and many carcinogens are mutagens, it is suggested
that positive results in certain of these test systems may
indicate genotoxicity. The decision as to whether a substance
is genotoxic and be made qualitatively on the basis of
several criteria: 1) a reliable, positive demonstration of
genotoxicity in appropriate prokaryotic and eukaryotic systems
in vitro; 2) studies on binding to DNA and 3) evidence of
biochemical or biologic consequences of DNA damage (Weisburger
and Williams, 1981).
No single test system appears capable of detecting all
carcinogens that are genotoxic. Therefore, a number of
scientists have proposed testing batteries such that results
from each test within the battery, when evaluated as a whole,
will allow one to make a conclusion about the mechanism of
carcinogenicity of a particular compound.
Benzene has not been systematically studied in any
specific battery of tests, but has been evaluated in a number
of test systems that have been proposed for inclusion in one
or more batteries.
Toxic effects on bone marrow cells of rats and other

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XI-14
laboratory animals include changes in chromosome number and
chromosome breakage that resemble those in humans. There is
no clear evidence for dose-dependent response (Laskin and
Goldstein, 1977). Lyon (1975) used the Ames assay with
Salmonella typhimurium strains TA98 and TA100 to test benzene
for mutagenicity in doses ranging from 0.1 to 1.0 ul/plate,
both without and with microsomal fraction at concentrations
from 1 to 50 ul/plate. Postmitochondrial supernatant suspen-
sions of mircosomes were prepared from liver homogenates from
normal rats and from rats that had been treated with pheno-
barbital and 3-methylcholanthrene (MCA), and from the bone
marrow of normal and MCA-treated rats. Benzene was uniformly
negative in all of these assays and was inactive in the
dominant lethal assay in rats.
When considering the weight of evidence as a whole, it
becomes evident that benzene may exert its carcinogenic
effect via non-genotoxic mechanisms. Since all living
mammalian organisms have probably initiated cellular system
from the earliest time in life, one must now try to estimate
the risk to humans that exposure to this substance in drinking
water would pose. It is well known that both CAG (U.S. EPA,
1980) and OSHA (1978b) have determined benzene to be a human
carcinogen. Maltoni and Scartano (1979, 1980) have demonstrated
benzene to be an animal carcinogen. Benzene appears to have
a unique mechanism for producing cancer. Scientists have
not been able to demonstrate a threshold for benzene. Therefore,

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XI-15
exposure to any amount of this type of toxicant obligates
some measure of risk. Since we do not have experimental
results for effects seen at low doses of exposure, we may
mathematically extrapolate from the results obtained at
higher doses to project what would expected at the lower
doses.
Quantification of Carcinogenic Effects
Using methodology described in detail elsewhere, both
the National Academy of Sciences and the EPA's Carcinogen
Assessment Group(CAG) have calculated estimated incremental
excess cancer risks associated with the consumption of benzene.
Each group used the linearized, non-threshold multistage model.
The National Academy of Sciences, in Drinking Water and
Health, Volume 3 (1980), states:

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XI-16
There are no data from animal models for use
in extrapolation. Occupational studies on
human exposure (Aksoy, et al., 1972, 1974a,
b, 1976; Ishimaru, et al., 1971; Thorpe, 1974)
do not contain adequate information on degree
of exposure or size of population at risk.
In addition, the workers in benzene-related
occupations typically were exposed to other
chemicals, as in the study reported by Ott,
et al., 1978. Consequently, extrapolation
of benzene-induced cancer risk from such data
as these would be tenuous.
In a study by Infante, et al., 1977, workers
were exposed to benzene as the sole chemical
suspected of affecting the hematopoietic
system. In these cases, benzene concentrations
apparently were high during the first years of
exposure and were lower thereafter. There are
no data indicating how often short exposures
at elevated levels may have occurred. Esti-
mates of actual exposure are inadequate for
extrapolation for risk of benzene-induced
leukemia.
The EPA's Carcinogen Assessment Group (CAG) has determined
a carcinogenic risk estimate by using the following
considerations (see U.S. EPA Ambient Water Quality Documents
Benzene):
Three epidemiology studies of workers exposed
to benzene vapors on their jobs, performed by
Infante, Ott and Aksoy, were reviewed by the
CAG for the Office of Air Quality Planning and
Standards (U.S. EPA, 1979). Their result was
that the potency for humans breathing benzene
continuously is B = 0.02407. This means that
the lifetime risk of getting leukemia, R equals
0.02407 times the lifetime average continuous
exposure, X, measured as ppm of benzene by
volume in air, or R = B X. Therefore, the air
concentration, X, resulting in a risk of 10~5
is X = R/B = 10-5/0.02407 = 4.1539 X 10~4 ppm.
Since the air concentration corresponding to
1 ppm of benzene is 3.25 mg/m^ and assuming a
respiratory rate of 20 m-Vday and a respiratory
rate of 20 m^/day and a respiratory absorption
coefficient of 0.50, the daily intake that
would result in a risk of 10~5 is:

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XI-17
4.154 X 10~4 ppm X 3.25 X 10^ ug/m3 per ppm X 20m3/day X 0.5 =
13.5 ug/day
If it is assumed that the fraction of benzene absorbed
is the same between inhalation and ingestion of water and
fish, a daily benzene intake of 13.5 ug through drinking
water would cause a leukemia risk of 10~5. The water concen-
tration given this intake is:
C = (13.5 ug/day)/(2)
= 6.75 ug/1
= 6.8 ug/1
Table 1
Excess Lifetime	CAG (upper 95% CL)
Exposure Assumptions Cancer Risk	Corresponding Criteria
(per day)
2 liters of 10~®	0.68
drinking water 10"^	6.8
10~4	68.0
IARC reviewed Benzene in Vol. 29 and stated that benzene is a
human carcinogen. The IARC working group using the Rinskey
data developed minimum estimates of 140-170 excess leukemia
deaths per 1000 exposed workers over a working lifetime.
This calculation was based upon a 100 ppm exposure level in
air. They declined to give an upper bound figure for the 95%
confidence limit for excess leukemias following exposures
over a working lifetime, i.e. from 20 years to end of life,
taken at age 75.

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