EPA/600/R-01/013
        TOXICOLOGICAL REVIEW
                          OF
HEXACHLOROCYCLOPENTADIENE
                     (CAS No. 77-47-4)
          In Support of Summary Information on the
          Integrated Risk Information System (IRIS)
                        June 2001
                U.S. Environmental Protection Agency
                       Washington, DC

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                                    DISCLAIMER

       This document has been reviewed in accordance with U.S. Environmental Protection
Agency policy and approved for publication. Mention of trade names or commercial products
does not constitute endorsement or recommendation for use. This document may undergo
revisions in the future. The most up-to-date version will be available electronically via the IRIS
Home Page at http://www.epa.gov/iris.
                                           11

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                CONTENTS—TOXICOLOGICAL REVIEW FOR
                    HEXACHLOROCYCLOPENTADIENE
                             (CAS No. 77-47-4)
FOREWORD	v

AUTHORS, CONTRIBUTORS, AND REVIEWERS  	vi

1. INTRODUCTION	1

2. CHEMICAL AND PHYSICAL INFORMATION RELEVANT TO ASSESSMENTS 	2

3. TOXICOKINETICS RELEVANT TO ASSESSMENTS 	3
      3.1. ABSORPTION	3
      3.2. DISTRIBUTION AND METABOLISM	3
      3.3. EXCRETION	6

4.  HAZARD IDENTIFICATION 	9
      4.1. STUDIES IN HUMANS—EPIDEMIOLOGY, CASE REPORTS, AND CLINICAL
          CONTROL STUDIES  	9
      4.2. SUBCHRONIC/CHRONIC  STUDIES AND CANCER BIO AS SAYS IN
          ANIMALS-
          INHALATION AND ORAL	13
          4.2.1. Inhalation Studies	13
          4.2.2. Oral Studies	19
      4.3. REPRODUCTIVE/DEVELOPMENTAL STUDIES—ORAL AND INHALATIONS
      4.4. OTHER STUDIES	24
          4.4.1. Contact Dermatitis  	24
          4.4.2. Genotoxicity	25
          4.4.3. Acute Toxicity	26
      4.5. SYNTHESIS AND EVALUATION OF MAJOR NONCANCER EFFECTS AND
          MODE OF ACTION
          (IF KNOWN)—ORAL AND INHALATION 	27
          4.5.1. Inhalation Studies	29
          4.5.2. Oral Studies	29
          4.5.3. Mode of Action	30
      4.6. WEIGHT OF EVIDENCE EVALUATION AND CANCER
          CLASSIFICATION—SYNTHESIS OF HUMAN, ANIMAL, AND OTHER
          SUPPORTING EVIDENCE; CONCLUSIONS ABOUT HUMAN
          CARCINOGENICITY AND MODE OF ACTION	30
      4.7. SUSCEPTIBLE POPULATIONS	32
          4.7.1. Possible Childhood Susceptibility  	32
          4.7.2. Possible Sex Differences	32
                                   in

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                            CONTENTS (continued)

5. DOSE-RESPONSE ASSESSMENTS 	32
      5.1. ORAL REFERENCE DOSE	32
           5.1.1.  Choice of Principal Study and Critical Effect with
                 Rationale and Justification 	32
           5.1.2.  Methods of Analysis—NOAEL/Benchmark Dose Analysis 	33
           5.1.3.  RfD Derivation, Including Application of Uncertainty Factors (UFs)
                 and Modifying Factors (MFs)	35
      5.2. INHALATION REFERENCE CONCENTRATION 	36
           5.2.1.  Choice of Principal Study and Critical Effect with
                 Rationale and Justification 	36
           5.2.2.  Methods of Analysis—NOAEL/Benchmark Concentration Analysis .... 37
           5.2.3.  RfC Derivation Including Application of Uncertainty
                 Factors (UFs) and Modifying Factors (MFs) 	38
      5.3. CANCER ASSESSMENT	38

6. MAJOR CONCLUSIONS IN CHARACTERIZATION OF HAZARD IDENTIFICATION
      AND DOSE-RESPONSE ASSESSMENTS	39
      6.1. HAZARD IDENTIFICATION 	39
      6.2. DOSE RESPONSE 	40

7. REFERENCES	41

APPENDIX A
      External Peer Review—Summary of Comments and Disposition 	45

APPENDIX B
      Benchmark Dose Calculations for the RfD	47
                                      IV

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                                      FOREWORD

       The purpose of this Toxicological Review is to provide scientific support and rationale
for the hazard identification and dose-response assessment in IRIS pertaining to chronic exposure
to hexachlorocyclopentadiene. It is not intended to be a comprehensive treatise on the chemical
or toxicological nature of hexachlorocyclopentadiene.

       In Section 6, EPA has characterized its overall confidence in the quantitative and
qualitative aspects of hazard and dose-response. Matters considered in this characterization
include knowledge gaps, uncertainties, quality of data, and scientific controversies.  This
characterization is presented in an effort to make apparent the limitations of the assessment and
to aid and guide the risk assessor in the ensuing steps of the risk assessment process.

       For other general information about this assessment or other questions relating to IRIS,
the reader is referred to EPA's Risk Information Hotline at 202-566-1676.

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                  AUTHORS, CONTRIBUTORS, AND REVIEWERS
Chemical Manager

Judy Strickland, Ph.D.
National Center for Environmental Assessment
U.S. Environmental Protection Agency
Research Triangle Park, NC

Reviewers

       This document and summary information on IRIS have received peer review both by EPA
scientists and by independent scientists external to EPA.  Subsequent to external review and
incorporation of comments, this assessment has undergone an Agencywide review process
whereby the IRIS Program Manager has achieved a consensus approval among the Office of
Research and Development; Office of Air and Radiation; Office of Prevention, Pesticides, and
Toxic Substances; Office of Solid Waste and Emergency Response; Office of Water; Office of
Policy, Planning, and Evaluation; and the Regional Offices.
Internal EPA Reviewers

Michael DeVito, Ph.D.
Experimental Toxicology Division
National Health & Environmental Effects
Research Laboratory

Joyce Donohue, Ph.D.
Health and Ecological Criteria Division
Office of Science and Technology
Office of Water

E.M. Kenyon, Ph.D.
Experimental Toxicology Division
National Health & Environmental Effects
Research Laboratory

Deirdre L. Murphy, Ph.D.
Emission Standards Division
Office of Air Quality Planning and
Standards
External Reviewers

Peter J. Boogaard, Ph.D.
Molecular Toxicology
Shell International Chemicals, B.V.

Robert G. Tardiff, Ph.D., ATS
The Sapphire Group, Inc.
Ernest E. McConnell, D.V.M., M.S.
ToxPath, Inc.
                                          VI

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                                  1. INTRODUCTION

       This document presents background and justification for the hazard and dose-response
assessment summaries in EPA's Integrated Risk Information System (IRIS).  IRIS Summaries
may include an oral reference dose (RfD), inhalation reference concentration (RfC), and a
carcinogenicity assessment.

       The RfD and RfC provide quantitative information for noncancer dose-response
assessments.  The RfD is based on the assumption that thresholds exist for certain toxic effects
such as cellular necrosis, but may not exist for other toxic effects such as some carcinogenic
responses.  It  is expressed in units of mg/kg-day.  In general, the RfD is an estimate (with
uncertainty spanning perhaps an order of magnitude) of a daily exposure to the human population
(including sensitive subgroups) that is likely to be without an appreciable risk of deleterious
effects during a lifetime. The inhalation RfC is analogous to the oral RfD, but provides a
continuous inhalation exposure estimate.  The inhalation RfC considers toxic effects for both the
respiratory system (portal-of-entry) and for effects peripheral to the respiratory system
(extrarespiratory or systemic effects). It is generally expressed in units of mg/m3.

       The carcinogenicity assessment provides information on the carcinogenic hazard potential
of the substance in question and quantitative estimates of risk from oral exposure and inhalation
exposure. The information includes a weight-of-evidence judgment of the likelihood that the
agent is a human carcinogen and the conditions under which the carcinogenic effects may be
expressed.  Quantitative risk estimates are presented in three ways. The slope factor is the result
of application of a low-dose extrapolation procedure and is presented as the risk per mg/kg-day.
The unit risk is the quantitative estimate in terms of either risk per |_ig/L drinking water or risk
per |-ig/m3 air  breathed.  Another form in which risk is presented is a drinking water or air
concentration providing cancer risks of 1  in 10,000; 1 in  100,000; or 1 in 1,000,000.

       Development of these hazard identifications and dose-response assessments for
hexachlorocyclopentadiene has followed  the general guidelines for risk assessment as set forth by
the  National Research Council (1983).  EPA guidelines that were used in the development of this
assessment may include the following: Guidelines for Carcinogen Risk Assessment (U.S. EPA,
1986a), Guidelines for Mutagenicity Risk Assessment (U.S. EPA,  1986b), Guidelines for
Developmental Toxicity Risk Assessment  (U.S.  EPA, 1991), Proposed Guidelines for Carcinogen
Risk Assessment (U.S. EPA, 1996), Interim Policy for Particle Size and Limit Concentration
Issues and Inhalation Toxicity (U.S. EPA, 1994a), Methods for Derivation of Inhalation
Reference Concentrations and Application of Inhalation Dosimetry (U.S. EPA, 1994b), Peer
Review and Peer Involvement at the U.S.  Environmental Protection Agency (U.S. EPA, 1994c),
Use of the Benchmark Dose Approach in  Health Risk Assessment (U.S. EPA, 1995a), Science
Policy Council Handbook: Peer Review (U.S. EPA, 1998a), and a memorandum from EPA
Administrator, Carol Browner, dated March 21, 1995, Subject: Guidance on Risk
Characterization.

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      Literature search strategies employed for this compound were based on the CASRN and
at least one common name. At a minimum, the following databases were searched: RTECS,
HSDB, TSCATS, CCRIS, GENETOX, EMIC, EMICBACK, DART, ETICBACK, TOXLINE,
CANCERLINE, MEDLINE, and MEDLINE backfiles. Any pertinent scientific information
submitted by the public to the IRIS Submission Desk was also considered in the development of
this document.
  2.  CHEMICAL AND PHYSICAL INFORMATION RELEVANT TO ASSESSMENTS

      Other names for hexachlorocyclopentadiene include C-56, hexachloro-1,3-
cyclopentadiene, graphlox, HCCP, HCCPD, Hex, hexachloropentadiene, HRS 1655, NCI-
C55607, PCL, and perchlorocyclopentadiene.  It is predominantly used as an intermediate in the
production of many dyes, resins, pharmaceuticals, flame retardants, insecticides, and polyester
resins. Hexachlorocyclopentadiene (HCCPD) is also used to produce ketones, fluorocarbons,
acids, esters, and shockproof plastics.

      HCCPD exists as a dense oily liquid, pale yellow to amber in color, at room temperature
(melting point at -9°C, boiling point at 239°C). It has a pungent, unpleasant odor.  Vapors are
present at room temperature because of its high vapor pressure.  HCCPD is soluble in organic
nonpolar solvents but only slightly soluble in water. HCCPD degrades in the presence of light
and may decompose to produce toxic fumes upon heating (HSDB, 1999). See Table 1 for
selected  chemical and physical properties of HCCPD.

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         Table 1. Chemical and physical properties of hexachlorocyclopentadiene
Properties
Boiling point
Melting point
Molecular weight
Density
Koc
Log Kow
Solubility
Values
239°C
-9°C
272.77
1.7019 at 25°C
4,265
3.99
2 mg/L water at 25°C
Reference
HSDB, 1999
HSDB, 1999
HSDB, 1999
HSDB, 1999
U.S. EPA, 1999
U.S. EPA, 1999
U.S. EPA, 1995b
 Vapor pressure                 0.08 mm Hg at 25°C            U.S. EPA, 1999

 Henry's law coefficient          2.7 x 10'2 atm-cu m/mole        U.S. EPA, 1999
 Chemical structure
 (C5C16)
Conversion factor: 1 ppm = 11.3 mg/m3; 1 mg/m3 = 0.088 ppm (World Health Organization, 1991)

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               3. TOXICOKINETICS RELEVANT TO ASSESSMENTS

3.1.    ABSORPTION

       Yu and Atallah (1981) showed that HCCPD is poorly absorbed in rats following gavage
administration. They administered single doses of 99% pure 14C-HCCPD to 21 female and 6
male Sprague-Dawley rats (divided into groups of 1-3 per dose and time-point of analysis).
Approximately 25 mg/kg 14C-HCCPD dissolved in 0.5 mL corn oil was delivered via gavage
while 0.73 mg/kg HCCPD dissolved in 0.3 mL 20% Emulphor EL0620 saline solution was
administered IV.  Urine and fecal samples were obtained daily. Blood samples were obtained at
various postadministration durations, with the first sample taken at 0.5 hours and the last sample
taken at 24 hours.

       The concentration of 14C in blood following oral administration rose gradually to a
maximum of 2.25 ± 0.30 ppm HCCPD-equivalents at 4 hours postdosing, and then fell to 0.95 ±
0.16 ppm by 24 hours postdosing.  After IV administration, HCCPD equivalents reached a
maximum of 5.08 ± 1.02 ppm at 0.5  hours postexposure and dropped to 2.34 ± 0.75 ppm at 24
hours.  Despite the much lower dose given by IV, the area under the concentration-duration curve
for the  blood of IV-injected rats was 70 times that of gavaged rats. The body burden for IV-
injected rats was 10 times that of gavaged  rats.

       Lawrence and Dorough (1981) used one female Sprague-Dawley rat/dose to investigate
the retention of 1.4, 17.3, and 37.4 |_ig 14C-HCCPD /kg inhaled, via nose-only exposure, over a
1-hour  period.  Retention of the compound was 84% and independent of dose. Lawrence and
Dorough (1982) performed a similar experiment and reported 91% retention after 1.5 hours and
95% retention after 2 hours inhalation exposure to both low (1-5 pg/kg) and high (30-40 pg/kg)
doses of 14C-HCCPD. Lawrence and Dorough (1982) also measured the blood concentrations of
14C after administration of 10 |_ig 14C-HCCPD/kg via 0.5 mL corn oil gavage, nose only
inhalation (1 hour), and IV routes (in 0.2 mL dimethyl sulfoxide or 10:4:1 saline:propylene
glycol:ethanol) and confirmed the  results of Yu and Atallah (1981) which indicated poor
absorption for the oral route. Peak 14C blood concentrations for the oral route were
approximately  l/5th those of the inhalation route and approximately  l/50th those of the IV route.

3.2.    DISTRIBUTION AND METABOLISM

       Several studies were performed to  determine distribution and metabolism of HCCPD
after oral administration.  Mehendale (1977) administered 5 |_imole (~ 6 mg/kg in rats weighing
225-250 g) of 14C-HCCPD in 0.2 mL corn oil to male Sprague-Dawley rats via oral intubation.
Urine and fecal samples were collected daily for 7 days. The animals were then sacrificed for
collection of liver, kidneys, fat, lung, muscle, and blood tissues. After 7 days, the kidneys
retained 0.5% of the  administered  dose,  the liver retained less than 0.5%, and the remaining
tissues  contained only trace amounts. Thin-layer chromatography of organic urine extracts
revealed four metabolites of HCCPD, which were not chemically characterized.

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       Yu and Atallah (1981) also investigated the distribution of HCCPD in rats dosed with 25
mg/kg 14C-HCCPD by gavage or 0.73 mg/kg by IV injection. Brain, heart, lung, muscle, fat,
gonad, uterus, spleen, kidney, liver, blood, digestive system, skin, hair, and urinary bladder were
analyzed for retained radiolabel at 8,  24, 48, or 72 hours after oral administration. In gavaged
rats, the kidney contained 16.20 ppm HCCPD equivalents, whereas the liver retained 6.23  ppm,
and the gonad, fat, lung, and blood retained between 1.28 and 1.89 ppm equivalents at 8 hours
postdosing.  All other tissues had less than 1 ppm. At 24 and 48 hours postdosing, the kidney
and liver still had the highest concentrations of HCCPD equivalents.

       Tissue concentrations were measured at 24 and 48 hours after IV administration (Yu and
Atallah, 1981). Again, the kidney retained the highest concentration (2.64 ppm) of 14C-HCCPD
equivalents at 24 hours after administration.  The blood, spleen, and liver, in this order, contained
the next highest concentrations. At 48 hours after IV administration,  spleen and blood
concentrations were the highest (about 2.95 ppm), followed by the kidney at 2.02 ppm. All other
tissues contained less than 0.42 ppm.

       These data indicate that the tissue distribution of HCCPD and its metabolites was similar
from 8 to 72 hours after oral administration, with HCCPD primarily retained in the kidney and
liver.  After IV administration, HCCPD and its metabolites were distributed primarily in the
kidney, but the blood, spleen, and liver also had relatively high concentrations.  The study  shows
that although the distribution of HCCPD and its metabolites varies somewhat with route of
administration, the kidney and liver are the major organs of concentration for both oral and IV
routes. When the tissue concentrations are considered in proportion to the dose received, the
data also indicate that HCCPD and its metabolites are retained longer after IV administration
than after oral administration. The authors suggest that lower retention of orally dosed HCCPD
is due to its poor absorption in the gut.

       Based on blood data from IV  dosed rats, Yu and Atallah (1981) developed an open two-
compartment pharmacokinetic model. The model proposed that HCCPD was rapidly
metabolized and  distributed in the central compartment (blood, liver, kidney, and lung) and then
gradually redistributed to the peripheral compartment (fat tissues) after IV injection.  Comparison
of observed to expected values for radiolabel concentration in blood showed a good agreement.
Using the model, the authors predicted a biological  half-life of 32 hours for HCCPD in the rat
(Yu and Atallah, 1981). No modeling was performed for oral administration.

       Lawrence and Dorough (1981) investigated differences in distribution between corn oil
gavage and inhalation administration in female Sprague-Dawley rats. For inhalation studies, rats
inhaled, via nose-only exposure, 24 |_ig 14C-HCCPD/kg (exposure concentration not reported) for
single  1-hour periods.  For measurable tissue levels of 14C, the gavage dose had to be much
higher, 6 mg/kg 14C-HCCPD in 0.5 mL corn oil.  Tissue samples were taken at 72 hours
postdosing, combusted, and then 14CO2 was trapped and counted. Radioactivity was measured in
the trachea, lungs, liver, kidneys, and carcass. Levels were reported as a percentage of the
administered radioactivity. After inhalation exposure,  the carcass retained 7.8% ± 2.0% of the
dose, the lungs retained 2.0% ± 0.4%, the kidneys retained 0.8% ± 0.2%, and the liver retained

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0.4% ± 0.2%. After gavage, the carcass retained 1.87% ± 1.16% of the dose, the kidneys
retained 0.47% ± 0.06%, the liver retained 0.39% ± 0.06%, and other tissues retained less than
0.1% of the radiolabel.  For either route, only trace amounts of radiolabel were found in fat.

       In a similar study (Lawrence and Borough, 1982), distribution of 14C-HCCPD in female
Sprague-Dawley rats was studied following oral, inhalation, and IV administration.  Doses were
6 mg/kg via gavage, 24 pg/kg for the inhalation route (via nose cone), and 10 |_ig/kg for the IV
route. Trachea, lungs, liver, kidneys, fat, and remaining carcass were assayed for 14CO2 at 72
hours postexposure. After inhalation exposure, the highest concentration of HCCPD equivalents
was in the trachea (107 ± 65.0 ppb), followed by lungs (71.5 ± 55.2 ppb) and kidneys (29.5 ±
20.2 ppb). After oral exposure, the highest concentrations were in the kidneys (3,272 ± 84 ppb),
liver (539 ± 72 ppb), and lungs  (420 ± 250 ppb). Following IV exposure, the kidneys retained
the highest concentration, 22.3 ± 0.6 ppm, while the lungs retained 14.9 ±1.1 ppm and the liver
retained 9.6 ±1.1 ppm HPCCD equivalents.  The trachea retained only 3.3 ± 1.7 ppm following
IV administration.  These data are consistent with those from Lawrence and Borough (1981),
showing that distribution depends upon route of administration, with  oral and IV HCCPD
resulting in generally similar distribution patterns. Oral and IV administration resulted in the
highest concentrations of HCCPD equivalents in the kidneys and then in the liver and lungs,
whereas inhalation exposure resulted in the highest concentrations in  the trachea, followed by
lungs and then kidneys. The concentration of HCCPD equivalents in fat was only appreciable for
the oral route.

       Results from a study of distribution of radiolabeled HCCPD by Dorough and Ranieri
(1984) in rats and mice were consistent with those of Lawrence and Dorough (1982). Male and
female Sprague-Dawley rats and mice were gavaged with 2.5 mg/kg or 25 mg/kg 14C-HCCPD (in
0.9 mL corn oil for rats and 0.2-0.3 mL corn oil for mice). After both doses, the kidney
contained the highest concentration of radiolabel in the rat, but the  liver contained the highest
concentration in the mouse at 1  and 7 days after exposure. A study of the  distribution of dietary
HCCPD was performed using concentrations of 1, 5, and 25 ppm in food (Dorough and Ranieri,
1984).  After 15 days on the diet, radioassay of tissues collected from female rats showed the
highest concentration of HCCPD equivalents/dietary ppm in the kidneys, fat, then in the gonads
and liver at all dietary dose levels.  Male rats retained the compound in the same distribution
pattern as the female rats, but had higher concentrations of HCCPD equivalents/ppm diet in the
liver than in the gonads. Female and male mice retained the compound primarily in the fat, then
the liver, then the gonads and kidney.  Gonads  concentrated radioactive residues at a comparable,
but slightly lower, level to fat in both species, whereas muscle and  brain did not accumulate
appreciable amounts, even at the 25 mg/kg dose.

       Yu and Atallah (1981) also studied the  nature of the metabolites in the tissues by
extracting tissue homogenates with organic solvents.  The majority of degradation products were
polar and were organically extractable only after acidification.  Attempts to identify the
metabolites of HCCPD in rodents (Yu and Atallah, 1981; Mehendale, 1977; Logan and
Croucher, 1984) have been unsuccessful.

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       Yu and Atallah (1981) incubated fecal material from rats with aliquots of 315 |_ig of 14C-
labeled HCCPD to study the stability of HCCPD in this environment.  Samples of the mixture
were collected at 0, 1, 6, and 24 hours, homogenized, and organically extracted.  The remaining
solid was dried and radioassayed, while the organic extracts were partitioned using an
acetonitrile/water mixture, and the layers were radioassayed. The results indicated that the
HCCPD was rapidly degraded in the feces, with a half-life of 1.6 hours. The fact that
antimicrobial compounds slowed the degradation indicated that microbial action was responsible
for HCCPD breakdown in the fecal homogenate.

       Samples taken from the contents of the duodenum and small and large intestine from
selected rats were homogenized and added to radiolabeled HCCPD in the presence or absence of
antimicrobial agents (Yu and Attalah, 1981).  Sampling and extraction proceeded as described
for the fecal homogenates. The results of intestinal incubation indicated that HCCPD
degradation proceeded slowly in the gut in a microbe-dependent fashion with a half-life of 10.1
hours.  Degradation rates of HCCPD by liver homogenates were similar for active (t1/2 = 14.2
hours) and denatured (t1/2 = 12.4 hours) homogenates. Because of the similarity of degradation
rates between active and denatured extracts, the  authors proposed that the necessary cofactors for
proper liver enzyme activity to degrade HCCPD were likely not present in the prepared extracts,
or that most of the degradation of HCCPD takes place outside of the liver.

       El Dareer et al. (1983) performed in vitro binding experiments with HCCPD and varying
biological materials obtained from rats to study the interaction of the compound with biological
macromolecules. After an incubation of 14C-HCCPD with the material for 0, 5, or 60 minutes,  a
series of organic extractions was performed.  Liver homogenates, plasma, and whole blood
incubated with the HCCPD formed virtually inextractable mixtures even at 0 minutes. Feces and
intestinal contents, however, were easily extractable at 0 and 5 minutes, and extractability did not
decrease until the 60-minute incubation.  The results show the high chemical reactivity of
HCCPD toward biological materials.

3.3.    EXCRETION

       In the study by Mehendale (1977), which gavaged rats with ~ 6 mg/kg 14C-HCCPD, urine
and fecal samples were collected daily for 7 days.  After 7 days, approximately 33% of the total
radioactivity was excreted in the urine, with 87% of that eliminated within the first 24 hours.
Fecal excretion accounted for 10% of the administered dose, with 60% of fecal excretion
occurring during the first day. Only trace amounts of radioactivity were recovered in feces after
the third day.  Because individual tissues contained less than 0.5% of the radioactivity and only
43% had been excreted in feces and urine, Mehendale (1977) suggested that HCCPD may be
eliminated, to a large extent, in exhaled air.

       In another experiment, Mehendale (1977) injected ~ 6 mg/kg 14C-HCCPD into the
femoral veins of male rats and collected samples of blood and bile at 15, 30, 45, and 60 minutes.
The radioactivity in blood decayed biexponentially with a terminal half-life of 1 hour.
Approximately 9% of the radioactivity was excreted in bile over 1 hour. Predosing the rats with

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50 mg/kg/day HCCPD for 3 days by gavage had no effect on biliary excretion or on the decline
of radioactivity in blood.

       In the study by Yu and Atallah (1981) described in Section 3.1, urine and fecal samples
were analyzed for radioactivity at 8, 24, or 48 hours after a single oral or IV dose of radiolabeled
HCCPD. After gavage dosing, radiolabel was eliminated mainly in feces (70%) and urine (17%)
within 48 hours.  Fecal excretion after oral administration was much greater than that observed
by Mehendale (1977).  When administered intravenously, the radioactivity was eliminated
equally in feces (21%) and urine (18%) over the same time period.

       Lawrence and Borough (1981) administered 5 |_ig 14C-HCCPD/kg to female rats via 1-
hour inhalation or by gavage to compare excretion by the two exposure routes. Urine and fecal
samples were taken at 24, 48, and 72 hours postdosing.  Radioactivity in urine samples was
counted in a scintillation counter, while fecal samples were combusted and trapped 14CO2 was
assayed. At 24 hours after gavage, elimination was primarily in the feces (62.2% ± 8.0%) as
compared to the urine (22.8% ± 1.8%). Fecal and urinary excretion after oral  administration was
similar to that observed by Yu and Atallah (1981). After inhalation exposure, elimination was
higher in urine (29.7% ± 4.5%) than in feces (17.0% ± 7.5%).  The proportions of urine:fecal
excretion did not change at 48 or 72 hours. Another inhalation experiment (Lawrence and
Borough, 1981) in which rats were administered 1.4-37.4 |_ig 14C-HCCPD/kg showed that
excretion by exhalation was insignificant. Less than  1% of the radiolabel was eliminated as
14C-HCCPD in expired air in the 24 hours following exposure, and no 14CO2 was detected in
expired air.

       A follow-up study by Lawrence and Borough (1982) compared the fate of inhaled (24
pg/kg), oral (5 u.g/kg), and IV (10 u.g/kg) 14C-HCCPD in female Sprague-Dawley rats.
Radiolabeled residues were primarily excreted via the feces after oral and IV routes, and
primarily via the urine following inhalation exposure. After 3  days, the percentage of the dose
eliminated via the feces was significantly higher for oral administration (-70%) than it was for
IV (-30%) or inhalation (-27%). These results for percentage urinary excretion confirm those of
Yu and Atallah (1981) and Lawrence and Borough (1981). Lawrence and  Borough (1982) found
total body burden was much higher after IV  dosing (31.0% ± 7.8%), as compared to oral (2.8% ±
1.1%) or inhalation (12.9% ± 4.7%) exposure. Biliary excretion of label was found to be highest
following oral exposures, accounting for 18% of the dose in 28 hours. Biliary excretion of 14C-
HCCPB was 13% of the  IV dose and -9% of the inhaled dose.

       In the Borough and Ranieri (1984) study, female rats and mice intubated with a single
low (2.5 mg/kg) dose of radiolabeled HCCPB excreted the majority of the  label in feces as
compared to urine at both 1 and 7 days postdosing. After 1 day, rats excreted  65.2% of the dose
in feces and  12.4% in urine while mice excreted 42.1% of the dose in feces and 13.8% in urine.
The percentage excretion was higher at 7 days with a similar feces:urine ratio.  At 25 mg/kg,
there were no appreciable differences between rats and mice in the amount of radioactivity
excreted in feces vs. urine.  Results from male rats treated with 25 mg/kg 14C-HCCPB showed

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that excretion was similar to that in females.  Fecal excretion after 3 days was 73.6% of the
administered dose while urinary excretion was 13.4%.

       El Dareer et al. (1983) also investigated the disposition of 14C-HCCPD administered to
rats via a single oral gavage dose (4.1 mg/kg or 61 mg/kg 14C-HCCPD) in 1 mL corn oil/150 g
body weight, a single IV dose (0.59 mg/kg 14C-HCCPD) in 0.15 mL 1:1:4 Emulphor EL-
620:ethanol:water/150 g body weight, or a single inhaled dose (1.1 mg administered over 2 hours
via whole-body exposure).  Following oral doses, >90% of the radioactivity was excreted after 72
hours, with twice as much contained in the feces as in urine.  Only 34% of the IV dose was
excreted  in the feces  after 72 hours, with urinary excretion accounting for 15.8%, and 39.0%
remaining in the tissues. At 6 hours following the inhalation exposure, excretion was primarily
via the urine (41.0% of dose). The amount excreted via the feces (28.7%) was comparable to
that remaining in tissues (28.9%). At 72 hours after inhalation, excretion was roughly equal
between feces and urine (40%-50%), with only a small portion remaining in tissues (11%). El
Dareer et al. (1983) essentially confirm the results for urinary  and fecal excretion obtained by
Lawrence and Borough (1982) for oral, IV, and inhalation routes of exposure.

       Another study investigated the excretion of HCCPD in rats, rabbits, and  mice after the
administration of 20 mg/kg radiolabeled HCCPD (Logan and  Croucher, 1984).  Rats and mice
were dosed via gavage (2 mL corn oil/kg body weight), while rabbits were dosed via gelatin
capsule.  Consistent with the results of previous investigators (Yu and Atallah, 1981;  Lawrence
and Borough, 1982; Borough and Ranieri, 1984), fecal excretion of radiolabel was predominant,
with urinary excretion secondary. By the end of 3 days, 85%-92% of the entire dose was
eliminated. Urinary excretion was 20%, 23%, and 35% of the administered radiolabel for rats,
mice and rabbits, respectively. Fecal excretion over the same period was 68%, 69%, and 51% for
rats, mice, and rabbits, respectively.  As also shown by Lawrence and Borough (1981), little or
no 14CO2 was detected in expired air (measured for rats only).  After IV administration of 24
mg/kg radiolabeled HCCPB (200 mg/mL in 30 pL ethanol) to a separate group of rats, an equal
percentage of the dose administered was excreted in the feces (10%) and urine (9%), with much
less of the total dose excreted (19%) at the end of 3 days. The equal proportion  of fecal vs.
urinary excretion was similar to other studies using IV administration, but the percentage of the
total dose excreted was much less than that found in other studies (Yu and Atallah,  1981;
Lawrence and Borough, 1982; El Bareer, 1983).

       Most of these metabolism studies indicate that excretion of HCCPB metabolites varies
depending on exposure route. Fecal excretion predominates after oral exposure, but urinary
excretion predominates following inhalation exposure.  Microbial metabolism to polar
metabolites in the gut is likely to be responsible for the large proportion of fecal excretion after
oral administration. Fecal and urinary excretion are approximately equal after IV administration.
HCCPB metabolites produced following inhalation exposure are retained in the bodies of rodents
longer than those from ingested HCCPB, which may indicate  that the metabolism to polar
compounds occurs more slowly after inhalation exposure.

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                           4.  HAZARD IDENTIFICATION

4.1.    STUDIES IN HUMANS—EPIDEMIOLOGY, CASE REPORTS, CLINICAL
       CONTROLS

4.1.1.  Buncher, CR; Moomaw, C; Sirkoski, E. (1980) Mortality study of Montague plant.
       Unpublished report for Hooker Chemical Corporation. Doc. # 878212111.
       NTIS/OTS84003A.

       Buncher et al. (1980) conducted an occupational mortality study with 341 workers at the
Hooker Chemical Corporation plant in Montague, MI. The plant produced HCCPD and other
chlorinated hydrocarbons. Three hundred forty-one employees who had worked at least 90 days
between October 1, 1953, and December 31, 1974, were included in the cohort. Follow-up was
through December 31, 1978.  Expected deaths  were determined using sex-, age- and year-specific
U.S. mortality rates. The 24 deaths, grouped in such causal categories as all causes, all cancers,
diseases of the circulatory system, diseases of the digestive system, and external causes, were
fewer than expected.  The six observed cancer deaths included one cancer each in the esophagus,
large intestine, breast, and kidney, and two of the respiratory system. The authors indicate that
the ratios of observed to expected deaths for the respiratory cancers (0.87) and colon cancer
(1.75) are not statistically unusual.  The remaining cancers have ratios greater than or equal to 5;
however, the small numbers of deaths prevent  drawing a firm conclusion. The short follow-up
period in this study is also a limitation.

4.1.2.  Wang, HH; MacMahon, B. (1979) Mortality of workers employed in the
       manufacture of chlordane and heptachlor.  J Occup Med 21:745-748.

       This retrospective mortality study involved white male workers from the Velsicol
Chemical plants in Marshall, IL, and Memphis, TN. The population studied consisted of 1,403
white males currently or formerly employed for more than 3 months during the years 1946-1975
for the Illinois plant and 1952-1976 for the Tennessee plant. The plants manufactured heptachlor
and chlordane, for which HCCPD is an intermediate,  during those periods. Approximately 34%
of the subjects had less than 10 years follow-up and 36% had 20 or more years follow-up.
Expected deaths for these person-years were calculated from white male national mortality rates
through 1975. Observed deaths due to all causes were significantly lower than expected deaths.
Deaths due to cerebrovascular disease, however, were significantly elevated over those expected.
Because exposure to several organochlorines occurred, the increase in cerebrovascular disease
could not be attributed to HCCPD exposure. Deaths due to all cancers were less than expected,
but deaths due to lung cancer were greater than expected, although not significantly. Lung
cancer deaths were not associated with duration of employment or duration of follow-up, but the
numbers  available for such analysis were small. No data on individual cigarette smoking habits
were available.  There was one death each from cancer of the liver, bladder, prostate, and central
nervous system.
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4.1.3.  Shindell and Associates. (1980) Report of epidemiologic study of the employees of
       Velsicol Chemical Corporation plant, Marshall, Illinois, January 1946-December
       1979. Unpublished report for Velsicol Chemical Corporation, July 1980. Doc. # 40-
       8149074.

       Shindell and Associates (1980) conducted a mortality study of 783 workers employed at
least 3 months between January 1, 1946, and December 31, 1979, at the Velsicol Chemical
Corporation plant in Marshall, IL. The aim of the study was to evaluate the overall health status
of all former and  current employees with 3 months or longer employment during a time when the
Marshall plant was manufacturing chlordane. This  cohort is similar to that studied by Wang and
MacMahon (1979), but included nonwhite males and women. The cohort included 783
individuals comprising 689 white males, 10 nonwhite males, and 84 females.  The two studies
employed different follow-up techniques. The vital status of 97.4% of the cohort was known.
The causes of death examined included all deaths, malignant neoplasms, diseases of the heart and
circulatory system, cerebrovascular disease, trauma, and others.  The number of observed deaths
in each category was compared to the number of expected deaths calculated from race- and
sex-specific U.S.  mortality rates for appropriate 5-year periods.  No excess deaths  related to any
specific job class or product were seen. Except for  "other deaths" in females, the number of
deaths observed was lower than the number expected.  The 22 deaths from cancer included brain,
kidney, liver, lung, and digestive system cancers. Eight of the 22 cancer deaths were from lung
cancer. The number of expected deaths for each of these specific cancers was not  calculated.
This study reported no significant differences between mortality of plant employees and
individuals from the U.S. population matched for race, age, and sex during the time period the
cohort was studied. The authors noted the healthy worker effect in mortality data from the
Marshall plant.

4.1.4.  Shindell and Associates. (1981) Report of epidemiologic study of the employees of
       Velsicol Chemical Corporation plant, Memphis, Tennessee, January
       1952-December 1979. Unpublished report for Velsicol Chemical Corporation,
       March 1981.  Doc. # 40-8149074.

       The second mortality study performed by Shindell and Associates involved the Velsicol
plant in Memphis, TN. The cohort included 1,115 employees with a minimum of 3 months of
employment between  January 1952 and December 31,  1979. The purpose of the study was to
evaluate the overall health status of all former and current employees with 3 months or more
employment during a  time when the plant was manufacturing heptachlor.  The study design was
the same as Shindell and Associates (1980).  The vital status of 92.8% of the cohort was known.
Consistent with the earlier Shindell study, this investigation revealed no significant differences
between mortality of plant employees and the overall U.S. population. Deaths from strokes and
from trauma showed an insignificant increase over the number of expected deaths. The
distribution of the standard mortality ratio of deaths by site of cancer and job class showed a
nonsignificant excess  of lung cancer in maintenance workers.  The authors concluded that there
was no pattern of neoplasia suggestive of job-related risk. In addition, mortality by cause was
consistent regardless of tenure of employment at other plants.

                                          11

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4.1.5.  Brown, DP; Ditraglia, D; Namekata, T; et al. 1980. Mortality study of workers
       employed at organochlorine pesticide manufacturing plants. U.S. Dept of Health,
       Education and Welfare and University of Illinois. Unpublished report.  May 1980.
       Doc. # 40-8149074

       This mortality study involved cohorts from four different chemical plants that
manufactured organochlorine pesticides. The cohorts were defined as all workers at each plant
who had worked at least 6 months prior to December 31, 1964.  Causes of deaths that occurred
prior to December 31, 1976, were recorded.  The entire study included about 2,100 individuals,
but the cohorts at each plant were evaluated separately. These cohorts overlapped the one used
in the Wang and MacMahon study (1979) but extended the follow-up period. Observed deaths in
the cohorts were far fewer than expected, reflecting the healthy worker effect.  The expected
value was calculated using U.S. white-male cause-specific mortality rates, but the report did not
specify the sex or ethnicity of the employees. The increase in cerebrovascular disease observed
in the Wang and MacMahon study (1979) was not reported in this study. A decrease in expected
deaths from all malignant neoplasms in each plant was observed, but it was not statistically
significant. There were slight, but not statistically significant, increases in stomach cancer deaths
in one plant, and slight excesses of cancers of the esophagus, rectum, liver, and lymphatic and
hematopoietic systems in another plant. Exposure to multiple organochlorine compounds in each
of the plants precludes linking these cancer cases with  exposure to HCCPD or any other
individual compound.

4.1.6.  Kominsky, JR; Wisseman, CL, III; Morse, DL. (1980) Hexachlorocyclopentadiene
       contamination of a municipal wastewater treatment plant. Am Ind Hyg Assoc J
       41:552-556.

       This report documents an accidental acute occupational exposure to high concentrations
of HCCPD when an unidentified odoriferous and viscous substance accumulated on the bar
screens and grit  collection systems of a wastewater treatment plant. When employees used steam
to remove the substance, a blue haze was generated and permeated the primary water treatment
area, forcing approximately 20 workers to seek medical attention for tracheobronchial irritation.
On the following day, after a heavy rain, personnel noticed a similar blue haze over the grit
collection channels accompanied by an offensive odor throughout the primary treatment area.
The plant was closed 2 days later when HCCPD and octachlorocyclopentene (OCCP) were
detected in the wastewater. Airborne concentrations of HCCPD and OCCP during the exposure
period were not  known, but 4 days after the plant was closed for cleaning, concentrations in the
screen and grit chambers were 270-970 ppb, and HCCPD concentrations in the blue haze were as
high as 19,200 ppb (217 mg/m3)1.

       Of the 177 treatment plant employees (23 females, 154 males) who responded to a
medical questionnaire, 59% reported symptoms of eye irritation, 45% reported headaches, and
       Calculated using conversion of 1,000 ppb = 11.3 mg/m3.

                                          12

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27% reported throat irritation.  Six weeks after exposure to the organochlorines, many complaints
of persistent health effects were reported: headache (18%), persistent fatigue (15%), chest
discomfort (13%), skin irritation (10%), and cough (9%). A review of the medical records of 90
employees who were observed by the plant physician over a 2-month period starting with the first
reports of contamination revealed symptoms of headache as well as mucous membrane and
respiratory tract irritation. Unusual symptoms were reported by individuals with acute, high-
level exposure to the compounds, including one report of "burning feet" (the individual's boots
deteriorated in contaminated sludge), three incidences of "sunburn-like" facial irritation, seven
reports of rashes on exposed skin, and seven reports of transient confusion or memory loss. No
changes were observed for the 28 employees who received chest X-rays.  Arterial blood gas
analyses were performed for 16 of the 28 employees and pulmonary function tests were
performed for 22 people. Neither test revealed abnormalities.

       Laboratory tests from 97 cleanup crew members revealed no significant abnormalities in
renal function, complete blood counts, or urinalyses; however, 18 cleanup workers had mild liver
function abnormalities exhibited by abnormal serum values in glutamate-oxaloacetate
transaminase, alkaline phosphatase, total bilirubin, and/or lactate dehydrogenase. The proportion
of the 18 workers that underwent preexposure monitoring is uncertain because the authors
indicate only that 52 of the 97 cleanup workers were monitored prior to exposure.  Thus, the
relationship of the abnormal liver indices to exposure is uncertain. However, seven persons  did
have increased serum glutamate-oxaloacetate transaminase that seemed to be temporally related
to exposure to contaminated sewage.  The authors concluded that exposures to HCCPD and
associated compounds may produce liver damage.  The association of HCCPD exposure and
liver function abnormalities is confounded, however, by the lack of information on preexposure
monitoring and coexposure to OCCP.

4.1.7.  Boogaard, PJ; Rocchi, PSJ; van Sittert, NJ. (1993)  Effects of exposure to low
       concentrations of chlorinated hydrocarbons on the  kidney and liver of industrial
       workers. Br J Ind Med 50:331-339.

       In this study, 73  male operators in a chemical plant that produced several different
chlorinated hydrocarbons were evaluated for liver and kidney toxicity. The subjects were
employed for an average of 8.2 years (0.5-23 years). A control group consisted of 35 male
employees who were not occupationally  exposed to the chemicals. The control group was well
matched to the exposed  population in all selected parameters except age.  Age was a confounding
factor for several of the biochemical analyses performed.

       Exposure to HCCPD, allyl chloride, 1,3-dichloropropene, and epichlorohydrin was
measured by personal samplers on a few individuals. While mean concentrations of 1,3-
dichloropropene and epichlorohydrin were well below the applicable occupational exposure
standards (5 and 4 mg/m3, respectively),  exposures to allyl chloride and HCCPD occasionally
exceeded the maximum allowable concentrations of 3 and 0.11 mg/m3, respectively. Individual
exposures could not be estimated because personal samplers were used on few employees.
                                           13

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       Biochemical analyses indicated no differences between the control and exposed
populations on any of the liver function tests (serum alanine aminotransferase, alkaline
phosphatase, aspartate aminotransferase, total bilirubin, gamma-glutamyltranspeptidase, lactate
dehydrogenase, and total serum bile acids). Further, no statistically significant differences were
observed in kidney function tests measuring urinary levels of alanine aminopeptidase, N-acetyl-
p-D-glucosaminidase, retinol binding protein, and total protein. The exposed group had
significantly greater urinary albumin levels than did controls (8.09 mg/g vs. 4.68 mg/g), but the
levels were within normal limits. Boogaard and Caubo (1994) showed that shift workers have
increased albumin excretion compared with employees who work only during the day, and
suggested that this may be a circadian effect.  Thus, the results of Boogaard et al. (1993) indicate
that exposure to occupational concentrations of these chlorinated hydrocarbons does not cause
significant liver or kidney damage.

4.2.  SUBCHRONIC/CHRONIC STUDIES AND CANCER BIOASSAYS
     IN ANIMALS— INHALATION AND ORAL

4.2.1.  Inhalation  Studies

4.2.1.1.   NTP. (1994) Toxicology and carcinogenesis studies of hexachlorocyclopenta-
          diene in F344/Nrats andB6C3Fl mice (inhalation studies). National Toxicology
          Program Technical Report Series 437:318.

       In 13-week range-finding studies in F344/N rats and B6C3F1 mice, NTP exposed groups
of animals (10 per sex per species) for 5 days per week, 6 hours per day, to atmospheres
containing 0, 0.04,  0.15, 0.4, 1, or 2 ppm HCCPD (0, 0.45,  1.7, 4.5,  11, or 22 mg/m3,
respectively). Standard bioassay data including body weights, clinical chemistry, hematology,
urine analysis, organ weights, pathology, and histopathology were collected. All rats in the 11
and 22 mg/m3 groups died within 4 weeks.  Clinical effects in rats included listlessness in the 22
mg/m3 group from week 1, in the 11 mg/m3 group from week 2, and in the 4.5 mg/m3 group
during week 3.  Rats in the 11 and 22 mg/m3 groups also experienced respiratory distress (mouth
breathing and increased respiration rate).  Male rats in the 4.5 mg/m3 dose group exhibited a
statistically significant decrease in body weight compared with controls, but the decrease is not
considered to be lexicologically significant because it was less than 10%.  Body weights of
treated female rats were similar to  controls. No other treatment-related clinical findings of
toxicity were reported.

       Necropsy of rats in the 11 and 22 mg/m3 groups revealed extensive coagulation necrosis
in the respiratory epithelium of the nose, larynx, trachea, bronchi, and bronchioles. Necrosis was
accompanied by inflammatory signs  such as vascular congestion,  edema, fibrin accumulation,
and neutrophil and mononuclear cell infiltration.  Male rats in the 4.5 mg/m3 group exhibited
necrotizing and suppurative inflammation of the nose, bronchus, and bronchioles and squamous
metaplasia of the nose, as well as increased lung weights. The squamous  metaplasia was focal in
nature, generally observed on the tips of the turbinates, and characterized by stratification of the
epithelium to form  three to four poorly  defined layers of flattened, nonkeratinized polygonal

                                           14

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cells.  Female rats seemed to be less sensitive. At the 4.5 mg/m3 exposure, the only nose effect
was suppurative inflammation, and fewer females than males exhibited necrotizing and
suppurative inflammation of the bronchus and bronchioles. Because no respiratory lesions were
seen at exposures lower than 4.5 mg/m3 HCCPD, the NOAEL for rats was 1.7 mg/m3 and the
LOAELwas4.5mg/m3.

       All mice in the 11 and 22 mg/m3 groups died within 5 weeks. Before the end of the
study, seven deaths occurred in the 4.5 mg/m3 group, one death occurred in the 1.7 mg/m3 group,
and three deaths occurred in the 0.45 mg/m3 group.  Six deaths in the female control group were
attributed to a defective feeder.  Clinical effects included listlessness in the 4.5 mg/m3 and 11
mg/m3 groups. No chemical-related differences in hematology, clinical chemistry, or urinalysis
parameters were reported in exposed males or females.  Males in the 0.45 mg/m3 group exhibited
a statistically significant decrease in weight, which was not lexicologically significant (i.e.,
<10%). Body weights of exposed mice were similar to controls in all other groups.

       In both rats and mice some statistically significant hematological changes in red blood
cell parameters occurred. Although these changes were not dose-related, they are consistent with
an adaptive response to impairment of pulmonary gas exchange and add to the weight of
evidence that the respiratory system is the major target. Clark et al.  (1982) and Rand et al.
(1982a) also noted hematological effects in subchronic studies.

       As evidenced by a somewhat lower frequency of effects, mice were not as sensitive to the
respiratory toxicity of HCCPD as were rats. Male mice exhibited significant increases in
suppurative inflammation of the nose and squamous metaplasia of the trachea at 4.5 and 11
mg/m3, and acute necrosis and suppurative inflammation of the nose, acute necrosis of the
larynx, trachea, and lung, and congestion of the lung at 22 mg/m3. Female mice had serous
inflammation of the nose at 4.5 mg/m3, and suppurative inflammation of the nose,  squamous
metaplasia of the larynx and trachea, and necrotizing inflammation of the lung at 11 mg/m3.  At
the highest dose, female mice presented the same spectrum of effects as male mice. Because no
effects were observed in mice at 1.7 mg/m3, the NOAEL was 1.7 mg/m3 and the LOAEL was 4.5
mg/m3.

4.2.1.2.   Rand, GM; Nees, PO; Calo, CJ; et al. (1982a) Effects of inhalation exposure to
          hexachlorocyclopentadiene on rats and monkeys. J ToxicolEnviron Health 9:743-
          760.
          Rand, GM; Nees, PO; Calo, CJ; et al. (1982b) The Clara cell: an electron
          microscopy examination of the terminal bronchioles of rats and monkeys following
          inhalation of hexachlorocyclopentadiene. J Toxicol Environ Health 10:59-72.

       In these studies, Sprague-Dawley rats and cynomolgus monkeys inhaled, via whole-body
exposure, 97.7% pure HCCPD at 0, 0.01, 0.05, or 0.20 ppm (0, 0.11, 0.56, or 2.3 mg/m3,
                                          15

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respectively)2 for 6 hours/day, 5 days/week, for 14 weeks. Each exposure group contained 40
male and 40 female rats, or 6 male and 6 female monkeys.  To investigate the Clara cell of the
lung as a potential target for HCCPD toxicity, Rand et al. (1982b) performed electron
microscopy upon lung cell preparations from three rats of each sex and three monkeys of each
sex.

       Rand et al. (1982a) reported no mortalities or adverse clinical signs in monkeys at any
exposure level. Body weight gain and food consumption were not significantly different between
groups.  Pulmonary function tests (blood gas analysis, lung mechanics, lung ventilation) were
normal. No eye lesions were noted, and no exposure-related changes were noted in hematology,
clinical chemistry, urinalysis, organ weights, macroscopic pathology, or histopathology. One
male monkey from the 2.3 mg/m3 group exhibited occasional Clara cells containing "electron-
lucent inclusions in the apex and base of the cell, surrounded by a single limiting membrane."
The electron-lucent inclusions have no known relationship to pathology, so the existence of the
inclusions in the Clara cells was not considered to be adverse.  As no adverse effects were noted,
the NOAEL for monkeys was 2.3 mg/m3 HCCPD.

       Rand et al. (1982a) reported that four rats from three exposure groups, including the
control group, died or were killed because of severe illness, but illness was not attributed to
HCCPD exposure.  The only significant clinical sign reported in male rats was dark, red eyes
observed in the 0.56 and 2.3 mg/m3 dose groups. This effect, which was first noted after the 10th
exposure and disappeared after the 20th exposure, was also noted in a range-finding study
performed by the same authors, and was considered to be related to HCCPD exposure.
Ophthalmoscopic examination revealed no eye lesions.  There were no exposure-related changes
in body weight gain, food or water consumption, or urinalysis.  After 12 weeks of exposure, there
were slight, occasionally statistically significant increases in hemoglobin, red blood cell count,
and mean corpuscular hemoglobin concentration with a corresponding reduction in the mean cell
volume in males at 0.11 and 2.3 mg/m3 and in females at 0.56 and 2.3 mg/m3. The authors
observed similar effects in a range-finding study and considered them to be indicative of
impaired respiratory function. There were no other effects on hematology. Statistically
significant decreases in mean liver weight occurred in all treatment groups and in kidneys of all
treated males after  13 weeks of exposure.  The Clara cells of all treated rats contained a
statistically significant increase in the number of the electron-lucent inclusions as compared to
controls (Rand et al., 1982b). No treatment-related gross pathology or histopathology was
observed. Given that the changes in hematologic parameters were not dose-related, the kidney
and liver weight changes were not accompanied by pathology,  and the Clara cell inclusions were
not related to pathology, the NOAEL for rats was 2.3 mg/m3. There was no LOAEL.
       Calculated using conversion of 1 ppm =11.3 mg/m3.

                                           16

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4.2.1.3.   Clark, DG; Pitcher, A; Blair, D; et al  (1982) Thirty week chronic inhalation study
          of hexachlorocyclopentadiene (HEX) in rats. Group Research Report
          SBGR. 82.051. NTIS/OTIS43022.

       In a 30-week study, Wistar rats inhaled 0, 0.05, 0.1, or 0.5 ppm (0, 0.56, 1.1, or 5.6
mg/m3, respectively)3 HCCPD in inhalation chambers for 6 hours/day, 5 days/week, followed by
a recovery period of 14 weeks free from exposure.  Chemical purity of the compound decreased
from 96% to 90% during the course of the study because of oxidation.  Clinical signs included
sneezing and lethargy in animals exposed to 5.6 mg/m3 throughout the study. Four males and
two females from this group died during exposure. Pathological analyses revealed that the
animals that died prematurely had signs of bronchopneumonia. Two of the deceased rats had
enlarged adrenals and the thorax contained watery or bloodstained fluid. No deaths or clinical
signs of toxicity were reported in the other exposure groups.

       Males in the 1.1 mg/m3 and 5.6 mg/m3 groups had significantly higher mean erythrocyte
counts, hemoglobin concentrations, hematocrit and absolute numbers of neutrophils, and
significantly lower  lymphocyte counts than the controls. Mean absolute numbers of lymphocytes
were lower in females at the 5.6 mg/m3 dose.

       Body weights of males from the 5.6 mg/m3 dose group were significantly lower than
controls from the seventh week until the end of the study, but, at 6% less than controls, were not
lexicologically significant.  Several increases in body weights in females exposed to HCCPD,
compared to controls, were noted in the first half of exposure. At the end of the exposure period,
body weights of the 1.1 mg/m3 and 5.6 mg/m3 females were similar to controls; however, at the
end of the recovery period,  body weights of those groups were less than controls by 11% and 9%,
respectively. Kidney weights were significantly increased in females in the 5.6 mg/m3 group
after exposure for 30 weeks. Male heart weights were decreased at 30 weeks in the 5.6 mg/m3
group and male spleen weights were decreased at 44 weeks in the 0.56 and 1.1  mg/m3 groups.
Testes weights were significantly increased at 44 weeks in the 5.6 mg/m3 group. The organ
weight effects were not considered to be biologically significant by the study authors.

       Rats at the 5.6 mg/m3 dose showed pulmonary degenerative changes including epithelial
hyperplasia, edema, and sloughing of the bronchiolar epithelium in both sexes  and epithelial
ulceration and necrosis in the males. No degenerative changes in the lungs were observed in the
0.56 or 1.1 mg/m3 dose groups. Rats in the 5.6 mg/m3 group also had mild degenerative changes
in the liver and kidney.  The authors suggested that the toxic action of HCCPD involves an
extreme local irritation of the respiratory tract that causes death by respiratory failure following
bronchopneumonia. The authors considered that the mild degenerative changes in the livers and
kidneys of a few rats were unlikely to contribute significantly to HCCPD's toxicity in the rat.
The results  of this study indicate a NOAEL of 1.1 mg/m3 and a LOAEL of 5.6  mg/m3 for the
       3Calculated using conversion of 1 ppm =11.3 mg/m3.

                                           17

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critical effect of respiratory tract histopathology. Correction for the HCCPD content of the
administered compound (90%) gives a NOAEL of 1 mg/m3 and a LOAEL of 5 mg/m3.

4.2.1.4.   NTP. (1994) Toxicology and carcinogenesis studies of hexachlorocyclopentadiene
          in F344/N rats andB6C3Fl mice (inhalation studies). National Toxicology
          Program Technical Report Series 437:318.

       The National Toxicology Program conducted 2-year inhalation exposure studies in
F344/N rats and B6C3F1 mice.  Groups of 60 animals per sex per species were exposed for 5
days per week, 6 hours per day, to atmospheres containing 0, 0.01, 0.05, or 0.2 ppm (0, 0.11,
0.56, or 2.23 mg/m3, respectively) HCCPD. Ten male and 10 female rats and mice from each
exposure group were evaluated at 15 months.  Standard bioassay data including body weights,
urinalysis, organ weights, pathology, and histopathology were collected. Monitoring of the
stability of the compound throughout the study showed that no degradation took place for up to 2
years.

       Exposure to HCCPD did not significantly affect survival of rats or mice, but the decrease
in survival of female mice approached statistical significance in the 2.23 mg/m3 group owing to
suppurative inflammation of the ovary.  Body weights of rats were unchanged by HCCPD
exposure, but body weights of male and female mice were reduced in the 2.23 mg/m3 group.

       Neoplastic lesions:  No exposure-related increases in neoplasms were seen in male or
female rats or mice.  Male rats in the 2.23 mg/m3 group, however, exhibited a significant increase
in the incidence of pars distalis adenoma of the pituitary (66%). Because the historical control
incidence of pars distalis adenoma in male F344/N rats from other NTP inhalation studies was
60%, NTP considered this tumor to be unrelated to HCCPD exposure.  NTP  concluded that
HCCPD exhibited "no evidence of carcinogenic activity" (NTP, 1994).

       Nonneoplastic lesions: In female rats, significant increases in incidence of squamous
metaplasia of the larynx were seen in the 0.11 and 2.23 mg/m3 groups, but not in the 0.56 mg/m3
group (see Table 2 for incidence). The lesion, described as  stratified squamous epithelium
several cell layers thick in areas usually lined by columnar epithelium, was considered to be of
minimal severity in all groups. Because there is individual variation in the location of the
transition between squamous and columnar epithelium and in obtaining consistent tissue  sections
in the treated rats, NTP indicated that the significance of this metaplasia is unknown.  In
addition, a dose-response relationship was not evident. Exposure-related increases in yellow-
brown granular pigmentation within the cytoplasm of epithelial cells of the nose, trachea, and
lung were also observed in both sexes of rats.

       Exposure-related increases in pigmentation of the respiratory epithelium of the nose,
trachea, and lung were also seen in male and female mice (see Table 3 for incidence). Female
mice also exhibited a dose-related increase in the incidence of suppurative ovarian inflammation
that was significantly different from controls  at 0.56 and 2.23 mg/m3 HCCPD. At 2.23 mg/m3
HCCPD, increases in suppurative inflammation of the nose were noted in both male and female

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      Table 2. Incidence3 of selected respiratory tract lesions in rats from NTP (1994)

Lesion
Nose pigmentation
Trachea
pigmentation
Lung pigmentation
Bronchiole
Peribronchiole
Squamous
metaplasia of larynx
Males
0
mg/m3
1/48
0/48
0/50
0/50
NR
0.11
mg/m3
46/50
0/50
0/50
0/50
NR
0.56
mg/m3
48/49
0/48
0/50
2/50
NR
2.23
mg/m3
48/50
5/50
49/50
16/50
NR
Females
0
mg/m3
0/50
0/50
0/50
3/50
9/50
0.11
mg/m3
34/50
0/50
25/50
1/50
20/50
0.56
mg/m3
47/49
0/49
42/49
4/50
15/48
2.23
mg/m3
48/50
1/50
50/50
27/50
24/50
a Compared with number examined.
NR-not reported.
      Table 3.  Incidence" of selected respiratory tract lesions in mice from NTP (1994)

Lesion
Nose
pigmentation
Suppurative
inflammation
Trachea
pigmentation
Lung pigmentation
Suppurative ovarian
inflammation
Males
0
mg/m3
0/50
0/50
0/50
0/49
NA
0.11
mg/m3
45/50
0/50
29/50
2/50
NA
0.56
mg/m3
50/50
1/50
48/50
42/50
NA
2.23
mg/m3
44/50
36/50
48/50
45/50
NA
Females
0
mg/m3
0/49
4/49
0/49
0/48
0/49
0.11
mg/m3
40/50
0/50
6/50
0/50
3/50
0.56
mg/m3
48/50
3/50
43/48
27/50
6/50
2.23
mg/m3
41/48
40/48
42/47
44/49
17/50
a Compared to number examined.
NA-not applicable.
                                            19

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mice during the interim evaluation at 15 months and at study termination.  In the 13-week study,
this effect was noted in males at 4.5 mg/m3 and in females at 11 mg/m3 HCCPD.

 Necrotizing inflammation of the bronchus/bronchioles, a response observed in NTP's
subchronic  study, was not reported in the 2-year study in rats or mice. Because rats exhibited no
exposure-related pathology or histopathology, the NOAEL for rats was 2.23 mg/m3 HCCPD, the
maximum exposure concentration. The NOAEL for mice was 0.56 mg/m3 and the LOAEL was
2.23 mg/m3, based on increased incidence of suppurative inflammation of the nose of both sexes.

 Although  the suppurative ovarian inflammation is clearly an adverse effect, it is not considered
to be the critical effect because its causation by HCCPD exposure is suspect.  These lesions were
common in NTP studies at the time of the HCCPD study (1984),  and have since been reduced
through better laboratory practice (Rao  et al.  1987). The NTP Pathology Working Group on the
HCCPD study did not consider these lesions to be a direct effect of the chemical, but felt they
were most likely secondary to stress resulting from exposure.  Ovarian abscesses in B6C3F1
mice resulted from bacterial infection, with the bacterium Klebsiella oxytoca being isolated most
commonly.  Dose related increases in ovarian abscesses have been seen in other NTP chronic
studies and  the reason for this apparent  treatment-related effect has been unclear. It has been
suggested that stress related to exposure may depress the immune system allowing infection by
opportunistic bacteria. The ovarian inflammation is unlikely to have been mouse grouping
related,  as the mice were housed separately in this inhalation study.

 The yellow-brown pigmentation of the respiratory epithelium was considered to be a marker of
exposure rather than a toxic effect because it was not associated with any discernible lesion even
after prolonged exposure. It was found in both sexes of both species.  The pigmentation occurred
in all areas  of the respiratory tract at the highest exposure, and as  the exposure was reduced,  only
in the proximal portion of the respiratory tract.  NTP (1994) suggested that lipid peroxidation
may have produced the pigmentation. Although the designation of this pigmentation as
nonadverse conflicts with ATSDR's treatment (ATSDR, 1999), it is entirely consistent with the
guidance in the RfC methodology (U.S. EPA, 1994b) which indicates that "enzyme induction
and subcellular proliferation or other changes in organelles, consistent with possible mechanism
of action, but no other apparent effects" should be ranked low in severity. Furthermore, the
guidance states that "effects that may be considered marginal are  designated as adverse only to
the extent that they are consistent with other structural and functional data suggesting the same
toxicity," indicating pigmentation does  not qualify as an adverse effect in this situation.

4.2.2. Oral Studies

4.2.2.1.   Abdo, KM; Montgomery, CA; Kluwe, WM; et al  (1984) Toxicity of
          hexachlorocyclopentadiene: Subchronic (13-week) administration by gavage to
          F344 rats andB6C3F1 mice. JAppl Toxicol 4:75-81.

       This subchronic study investigated the systemic toxicity of HCCPD given by gavage to
weanling F344 rats and B6C3F1 mice.  HCCPD (97.4% pure) was dissolved in corn oil and

                                           20

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administered daily, 5 days per week for 13 weeks. Ten rats/sex/dose received 0, 10, 19, 38, 75,
or 150 mg/kg HCCPD. Ten mice/sex/dose received 0, 19, 38, 75, 150, or 300 mg/kg HCCPD.
Stability of the gavage mixture, or the frequency of preparation, was not reported.  Although data
on clinical signs, body weights, organ weights, gross pathology, and histopathology were
collected, no clinical chemistry, hematology, or urine analysis was performed as required by
current test guidelines (U.S. EPA, 1998b).

       Table 4 shows the mortality rates for rats and mice. The deaths of six male rats in the 150
mg/kg group, and one in the 75 mg/kg group, were attributed to HCCPD. All male mice and
three females in the 300 mg/kg group died before the end of the study.  Other premature deaths in
treated rodents were attributed to gavage error.  Clinical signs of ruffled fur and slight inactivity
were noted in both rats and mice in the two highest dose groups.  Significant body weight
decreases (i.e., >10% less than controls) were noted in male rats in the 38, 75, and 150 mg/kg
groups and in female rats in the 75 and 150 mg/kg groups. In mice, significant decreases in body
weight were noted in males in the 150 mg/kg group  and in females in the 300 mg/kg group.  Data
from organ weight ratios were significantly greater than controls for female rats at 75 and 150
mg/kg for right kidney:brain and at 38, 75, and 150 mg/kg for liverbrain. Liverbrain and right
kidney:brain weight ratios were significantly increased compared to controls at all doses in
female mice. In addition, the lungs:brain ratio was significantly elevated over controls at the
highest dose in female mice.  Organ weight ratios were unaffected in male mice.

       Necropsy revealed grossly observed lesions detected in the gastric mucosa in both rats
and mice.  These lesions consisted of black discolored foci, red cysts, and ulceration in rats
gavaged with 75  and 150 mg/kg HCCPD.  Thickening of the mucosa was also observed in mice
in the 150 and 300 mg/kg groups. Histopathological analyses noted forestomach lesions that
ranged from minimal to marked in severity and were focal to diffuse in distribution.  Notable
features were hyperplasia, acanthosis, and hyperkeratosis of the epithelial surface of the
forestomach and increased mitotic activity in the basal layer of the epithelium.  Forestomach
lesions were only discernible at and above the 38 mg/kg dose in male rats, but were seen
(identified as epithelial hyperplasia and focal inflammation) in female rats at the 19 mg/kg dose
(see Table 5). Forestomach lesions were noted in male and female mice at the 38 mg/kg dose
                 Table 4. Mortality for mice and rats (Abdo et al., 1984)
Dose
(mg/kg)
0
10
19
38
Male rats
3/10
1/10
1/10
1/10
Female rats
1/10
2/10
2/10
1/10
Male mice
1/10
-
0/10
0/10
Female mice
0/10
-
0/10
0/10
                                           21

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75
150
300
3/10
7/10
-
3/10
5/10
-
0/10
0/10
10/10
0/10
0/10
3/10
     Table 5.  Incidence" of stomach and kidney lesions in rats from Abdo et al.  (1984)

Dose (mg/kg)
Lesion
Stomach lesions
Toxic nephrosis
Males
0
0/10
0/10
10
0/10
0/10
19
0/10
0/10
38
5/10
10/10
75
9/10
9/10
150
8/9
8/10
Females
0
0/10
0/10
10
0/10
0/10
19
2/10
0/10
38
5/10
10/10
75
9/10
10/10
150
9/10
10/10
1 Compared to total number of animals examined.
(see Table 6). The forestomach lesions are believed to be a manifestation of irritation which is
consistent with the observation of dermal irritation, (Treon et al., 1955; Industrial Bio-test
Laboratories, 1975a; HEW, 1978) and other portal-of-entry effects from HCCPD exposure
(Clark et al., 1982; NTP, 1994).  No forestomach lesions were observed in control rodents of
either species.

       Toxic nephrosis of the kidney was observed in male and female rats in the 38, 75, and
150 mg/kg groups, and in female mice in the 75, 150, and 300 mg/kg groups (see Tables 5 and 6,
respectively). The tables show that the incidence of this response was zero at the two lower
doses and approximately maximal at the higher doses. This dose-response pattern may reflect
the steepness of the dose-response curve. The kidney lesions were predominantly limited to the
terminal portion of the proximal convoluted tubules in the inner cortex and were characterized by
dilated tubules and epithelial changes consisting of cytomegaly, karyomegaly, and anisokaryosis
with nuclear and cytoplasmic vacuolization.  Acute tubular necrosis, which was morphologically
distinct from the toxic nephrosis, was observed in 7 of the 10 male mice in the 300 mg/kg group
and may have caused the early mortality in this group. Although histopathologic changes in mice
did not occur at doses below 38 mg/kg HCCPD, liver weights increased in a dose-dependent
fashion starting at 19 mg/kg HCCPD. Because organ weight changes occurred only in females of
both rodent species, and toxic nephrosis was not observed in male mice, this report indicates that
female rodents may be generally more susceptible to the adverse effects of ingested HCCPD to
the kidney and liver.
                                           22

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    Table 6. Incidence3 of stomach and kidney lesions in mice from Abdo et al.  (1984)

Dose (mg/kg)
Lesion
Stomach lesions
Toxic nephrosis
Males
0
0/10
0/10
19
0/10
0/10
38
2/10
0/10
75
8/10
0/10
150
9/10
0/10
300
10/10
0/10
Females
0
0/10
0/10
19
0/10
0/10
38
2/9
0/10
75
9/10
9/10
150
10/10
10/10
300
9/9
7/10
1 Compared to total number of animals examined.
                                          23

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       Based on the irritant effect manifested by the incidence of forestomach lesions, the
NOAEL for both sexes of mice was 19 mg/kg. The LOAEL was 38 mg/kg HCCPD.  For rats,
the NOAEL was 10 mg/kg based on the incidence of forestomach lesions in female rats.  The
LOAEL for rats was 19 mg/kg.

4.2.2.2.   Industrial Bio-test Laboratories.  (1975b)  90-Day subacute oral toxicity study with
          C-56 in albino rats.  Unpublished report to Hooker Chemical Corporation.  Doc #
          878212102. NTIS/OTS84003A.

       In this study, 0, 30,  100, and 300 ppm HCCPD of unknown purity was fed to 15 weanling
male and 15 female Charles River rats per group.  The diet was prepared by preblending the
required amount of HCCPD with the chow in a high-speed blender. Fresh diets were prepared on
a weekly basis.  No precautions to prevent degradation of the test compound during diet
preparation or throughout the study were reported. During the 90-day study, animal weights,
food consumption, and clinical signs were recorded.  Blood chemistry, hematology, and
urinalyses were analyzed at 45 and 84 days.  Animals were sacrificed after 90 days, at which time
gross examinations, organ weight comparisons, and microscopic examinations were performed.

       The authors reported no  statistically significant differences between exposed and control
populations that were related to  HCCPD exposure. On day 45 total leukocyte counts  in males
and females at 300 ppm were statistically lower than controls (rats at the lower doses  were not
tested).  On day 84, however, male rats at 30 and 100 ppm, and female rats at 100 ppm had
statistically higher total leukocyte counts than controls, whereas total leukocyte counts in both
sexes at 300 ppm were not different from controls. Thus, the response did not follow a
consistent dose-response pattern and may be unassociated with HCCPD exposure.  Statistical
differences in hemoglobin concentration followed the same pattern of dose and duration as those
for total leukocyte count. The authors indicated that even though some of the hematologic
changes in treated animals were statistically different from controls, the values were still within
the limits of normal variation. All other measured parameters, including food consumption, body
weight gain, organ weights, hematology, clinical blood chemistry, and urinalyses revealed no
exposure-related differences between control and exposed populations.

       The results of this study  identify a NOAEL of 300 ppm HCCPD in food for male and
female rats. Multiplying the total food consumed by the amount of HCCPD in food (i.e., 300
mg HCCPD/kg) and dividing by the number of days on the study (i.e., 90 days) yielded an
average daily  consumption  of 6.9 mg HCCPD/day for males and 5.0 mg HCCPD/day for
females. Dividing the average daily consumption of HCCPD by the average weight of the
animals yielded NOAEL doses of 21.4 mg/kg/day for males and 25 mg/kg/day for females.
However, as the HCCPD was not tested for degradation throughout the study and the
HCCPD/food mixture was prepared only on a weekly basis, the stability of the test compound is
in question. The absence of observable effects in this study could be a direct result of the
degradation of the compound from exposure to light after diet preparation.  Additional
misgivings  about this study are due to the fact that it was performed during a time when critical
                                          24

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errors were committed at Industrial Bio-test Laboratories. Although they may not have occurred
in this particular study, any data from this period are suspect.

4.3. REPRODUCTIVE/DEVELOPMENTAL STUDIES—ORAL AND INHALATION

       There are no animal studies available on developmental or reproductive effects of
HCCPD after inhalation exposure.  The following studies suggest a lack of developmental effects
following oral exposure, although degradation of the highly photoreactive HCCPD may have
occurred in some studies.

4.3.1.  Murray, FJ; Schwetz, BA; Balmer, MF; et al. (1980)  Teratogenic potential of
       hexachlorocyclopentadiene in mice and rabbits. Toxicol Appl Pharmacol 53:
       497-500.

       HCCPD was tested for teratogenicity by administration to an unspecified number of
pregnant CF-1 mice and New Zealand white rabbits via oral gavage in cottonseed  oil on gestation
days 6-15 for mice or 6-18 for rabbits. The test doses were 0, 5, 25, or 75 mg/kg. Mice were
sacrificed at gestation day 18 and rabbits were sacrificed at gestation day 29. Gas
chromatography indicated the HCCPD preparation was stable for at least 7 days.

       No significant effects were seen for number of implantations, fetus viability, resorptions,
or mean fetal body measurements.  Maternal toxicity in the form of severe diarrhea and
subsequent death in an unspecified number of rabbits was seen at 75 mg/kg.  A dose-related
increase in the proportion of rabbit fetuses with 13  ribs was seen and was statistically significant
in the 75 mg/kg group. Given the authors' statement that 12 or 13 ribs in this species is normal,
this increase is not considered to be a significant effect. No other dose-related effects on
incidence of fetal malformations in mice or rabbits were seen. The authors concluded that
HCCPD was not teratogenic in mice or rabbits at the doses given.

4.3.2.  Chernoff, N; Kavlock,  RJ. (1983) A teratology test system which  utilizes postnatal
       growth and viability in the mouse.  Environ Sci Res 27:417-427.

       The teratogenicity of HCCPD was tested in mice using a simple screening  procedure
based on the assumption that prenatal effects would be manifested as changes in two easily
measured postnatal parameters (pup viability and growth). This assay was performed with a
number of chemicals and found to predict the results of standard, more labor-intensive
teratogenicity tests with sufficient accuracy. Twenty-five pregnant CD-I mice were gavaged
with 45 mg/kg HCCPD on gestation days 8-12, the period of major organogenesis. Gestation
was allowed to continue until delivery at day 19.

       No significant differences in maternal weight change, pup survivorship, or average pup
weight were seen between treated animals and untreated controls. The authors'  conclusion that
HCCPD was not a teratogen under the conditions of this assay agrees with the results of the
standard mouse  assay in Murray et al.  (1980).

                                           25

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4.3.3.  Goldenthal, El; Jessup, DC; Rodwell, DE. (1978) Teratology study in rats.
       Unpublished report by International Research and Development Corporation for
       Velsicol Chemical Corporation. Report No. 163-573. Doc #40-8249076,
       NTIS/OTS0512884.

       The Velsicol Chemical Corporation performed teratogenicity studies with HCCPD in CD
rats (Goldenthal et al.,  1978). Groups of 25 pregnant rats were administered doses of 0, 3, 10, or
30 mg/kg HCCPD via corn oil gavage on gestation days 6-15 and were sacrificed on day 20. No
significant maternal effects were seen, and no significant fetal effects were seen as measured by
mean number of implantations, corpora lutea, live fetuses, postimplantation losses, mean fetal
body weights, fetal sex ratios, or incidence of soft-tissue or skeletal malformations. No details
were provided on  possible precautions taken to prevent compound degradation during the
experiment.

4.4.    OTHER STUDIES

4.4.1.  Contact Dermatitis

       Several studies have evaluated the dermal toxicity of HCCPD in rabbits and guinea pigs.
A preliminary study involved painting 300 mg/kg HCCPD on the skin (location unspecified) and
sacrificing the animal after 24 hours (HEW, 1978).  Gross pathology revealed subcutaneous
edema from the inguinal region to the mediastinal area.  Rib impressions on the parietal surface
were apparent from expanded lungs.  Histopathology of the lungs revealed atelectasis with
thickened alveolar walls containing moderate numbers of macrophages and neutrophils.
Histopathology of the skin revealed that the squamous epithelium was one cell thick. No
hyperkeratosis or mitotic activity or necrosis  of epithelial cells was apparent. Collagen bundles
were disrupted by moderate edema and  focal  pockets of neutrophils were seen in the dermis.
Both the dermis and the adipose tissue layer were edematous.

       A second preliminary study using doses of 0, 300, 600, and 1,200 mg/kg painted on the
skin (location unreported) of one guinea pig/dose resulted in adverse effects  similar to those
observed in acute  oral studies in which rats had been administered up to 300 mg/kg HCCPD in
corn oil via gavage.  These effects included sneezing, erythema of the eyelids and ears, rhinitis,
cyanosis of the lips and feet, retraction of the head, and labored breathing. In addition, the guinea
pigs had black, crusty lesions at the point of HCCPD application (HEW, 1978).  The animal
dosed with 1,200 mg/kg died 6 hours after treatment.

       Treon et al. (1955) applied various solutions of 93.3% HCCPD in Ultrasene to the intact
skin of a monkey and two guinea pigs to determine the concentration that produced dermal
irritation. When applied to the back of the monkey, 0.05 mL of the 20% solution discolored the
skin immediately.  After five days, the skin was slightly swollen and after 12 days the skin was
scaly.  The 10% solution applied to the  abdomen produced no signs of irritation.  Thus,  the
threshold concentration for producing dermal irritation in monkeys is between 10% and 20%
HCCPD. When applied to the back of a guinea pig, solutions of HCCPD up to 1% produced no

                                          26

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effects.  On another guinea pig, the lowest concentration tested that produced an effect was 40%.
The skin became hard, encrusted, and necrotic. Thus, the threshold concentration for irritating
the skin of guinea pigs is between 1% and 40% HPCCD.

       A 28-day dermal toxicity test was performed using 0.1% and 0.5% HCCPD (w/v)
dissolved in denatured ethyl alcohol (Industrial Bio-test Laboratories,  1975a). The solutions
were applied 5 days/week for 4 weeks to the shaved skin of five female and five male rabbits.
These doses were equivalent to 1 mg/kg and 5 mg/kg, respectively. The skin of two males and
two females in each group was abraded. After the first application, a slight red erythema was
noticeable. After the seventh application, focal necrosis, escharosis, hemorrhaged fissures, and
pustules with odorous exudate were reported in both dose groups.  Slight-to-moderate (1 mg/kg)
or moderate-to-severe (5 mg/kg) desquamation was observed after 20  applications. No deaths
occurred, and although a few of the animals in the high-dose group lost weight at 14 days
(corresponding to the severity of the skin reactions), the animals regained the weight as the
lesions healed and formed scabs and scars.  No treatment-related effects were reported on
hematology, blood chemistry, urinalyses, or gross or microscopic pathology tests.

4.4.2.  Genotoxicity

       A battery of in vitro and in vivo genotoxicity studies performed by the National
Toxicology Program yielded generally negative results for HCCPD (NTP, 1994). Absence of
mutagenicity observed in Ames reversion assays using Salmonella typhimurium (S. typhimurium)
strains TA98, TA100, TA1535, and TA1537, with or without S9 fraction confirmed earlier
results by Industrial Bio-test Laboratories (1977) and Brooks et al. (1984). NTP (1994) also
obtained negative results for micronucleated erythrocyte frequency in the B6C3F1 mice exposed
to HCCPD for 13 weeks by inhalation, and for induction of sex-linked recessive lethal mutations
in male Drosophila melanogaster.  The negative results in Drosophila melanogaster essentially
duplicated earlier analyses (Zimmering et al., 1985; Mason et al., 1992). When administered to
male flies at 10-40 mg/kg in feeding solutions, or at 900-2,000 mg/kg by injection, HCCPD did
not increase the number of lethal mutations in male Drosophila when  compared to controls.
However, cytogenetic effects manifested as sister chromatid exchanges and chromosomal
aberrations were observed in Chinese hamster ovary cells exposed to HCCPD, with and without
S9 (NTP, 1994).

       Brooks et al. (1984) used a preincubation protocol suitable for volatile chemicals to
incubate five strains ofS.  typhimurium (TA1535, TA1537 TA1538, TA98, and TA100) with
HCCPD at concentrations up to 10 |_ig/mL (37 |_iM) in the absence of S9 fractions, or 500 |_ig/mL
(1.8 mM) in the presence of S9 fractions. There was no evidence of mutagenesis.  Similar results
were obtained when S.  typhimurium strain TA100 was incubated for 30, 60, or 120 minutes in
the presence of HCCPD as a volatilate at 500-2,500 pg/mL (183 mM-917 mM; Industrial Bio-
test Laboratories, 1977). As the exposure duration was increased over 120 minutes, cell survival
decreased at each concentration tested, indicating that HCCPD is cytotoxic in this concentration
range. HCCPD did not induce chromosome damage in metaphase stage rat liver (RL4) cells after
a 24-hour incubation at 0.2 |_ig/mL (0.8  |_iM), the highest nontoxic concentration tested (Brooks et

                                           27

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al., 1984). HCCPD did not induce a significant increase in morphological transformation in
BALB/3T3 cells (at concentrations up to 0.000156 |_iL technical grade HCCPD/mL incubation
medium, or 1.6  x 10"5%) and did not induce forward mutations in mouse lymphoma cells at non-
cytotoxic concentrations (up to 0.00125 |_iL technical grade HCCPD/mL incubation medium, or
1.3 x 10"4%) (Litton, 1978).  HCCPD at subtoxic concentrations also did not induce DNA repair
when incubated with rat hepatocytes in vitro (Brat, 1983).

4.4.3.  Acute Toxicity

       The acute toxicity of HCCPD via inhalation and oral exposure is well established.  Treon
et al. (1955) performed the only published study for these exposure routes in several different
animal species.  The lethal dose of a 93.3% pure solution of HCCPD (5% V/V in peanut oil)
administered via gavage to female rabbits ranged between 420 and 620 mg/kg. The authors also
administered the same solution of HCCPD at doses of 180 to 2,100 mg/kg to groups of 10 six-
month-old rats per dose. The numbers of deaths and adverse effects were recorded for 10 days.
The LD50 for male rats was 505 mg/kg.  Rats and rabbits that died exhibited diffuse degenerative
changes in the brain, heart, liver, and adrenal glands;  degeneration of the liver, and kidney
tubules, and pulmonary hyperemia and edema.  An earlier study using Spartan albino rats
administered HCCPD in corn oil at 10 mL/kg body weight (Wazeter and Geil, 1972).  The results
yielded a LD50 of 630 mg/kg for males and 530 mg/kg for females, with a combined LD50 for
both sexes of 584 mg/kg. The purity of the HCCPD was not reported for this  study.

       Industrial Bio-test Laboratories (1975c) investigated the acute inhalation toxicity for
HCCPD (unreported purity) using groups of five male and five female Charles River rats
exposed to 2.5 to 21  ppm (28.2-237 mg/m3)4 HCCPD for 4 hours. The LC50 was estimated as
38.4 mg/m3. Necropsies performed on animals that died revealed acute pneumonia, with the
lungs showing varying degrees of hepatization (i.e., gorged with effused matter so that they are
no longer pervious to air). Surviving rats were emaciated and often the lungs  did not collapse
when the thorax was opened. This phenomenon suggests a chronic proliferative inflammatory
response in the lungs.

       Wazeter and Geil (1972)  also studied acute inhalation toxicity of HCCPD (purity
unreported) using two sets of 10  male Carworth CFE rats. The rats inhaled either 2 or 200 mg/L
(2,000  or 200,000 mg/m3, respectively) HCCPD for 4 hours.  All  died within 48 hours of
exposure. Clinical signs included eye squint, dyspnea, cyanosis, salivation, lacrimation, ocular
and nasal porphyrin discharge, and erythema followed by blanching and hypoactivity. Necropsy
revealed congestion of the lungs  in all rats at the low dose, while rats at the high dose had gray
coloring of the skin and severe hemorrhage of the lung and hydrothorax.

       Treon et al. (1955) performed acute and subacute inhalation toxicity studies on guinea
pigs, rats, mice,  and rabbits. The concentrations ranged from 1.7  mg/m3 (89.5% HCCPD) to 804
       4Calculated using conversion of 1 ppm =11.3 mg/m3.

                                          28

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mg/m3.  The duration of exposure was increased in some experiments with lower doses (e.g., 3.6
mg/m3 was administered five times with each exposure lasting 7 hours). Clinical signs and
fatalities were recorded. LC50s were not estimated. A concentration of 143 mg/m3 for 3 hours
resulted in fatalities among rabbits, rats, and mice, but not among guinea pigs.  The authors noted
that rabbits appeared to be the most susceptible species, with mice, rats, and guinea pigs
exhibiting decreasing susceptibility, in that order.  Exposure to concentrations as low as 3.6
mg/m3 irritated the eyelids and increased respiratory rate after 2 or 3 days (species not indicated).
Prolonged intermittent exposure (150 exposures of 7 hours each) to 1.7 mg/m3 HCCPD, the
lowest concentration administered, resulted in slight degenerative changes in the livers  and
kidneys of all species observed. Mice exhibited pulmonary edema and bronchitis, and some of
the guinea pigs and rats developed pneumonia (incidence not specified). Rabbits did not appear
to manifest an inflammatory response at 1.7 mg/m3.

       Ulrich and Hagan (1978) administered HCCPD (unknown purity) at 8 different
concentrations from 0.28 to 5.8 ppm (3.2 to 66 mg/m3)5 to groups of 10 male and 10 female
Sprague-Dawley rats.  The experiment consisted of inhalation exposure to HCCPD  for  4 hours,
followed by a 14-day observation period.  The 4-hour LC50 was 18 mg/m3 for male rats  and 41.3
mg/m3 for females, which indicated that males are more sensitive to the compound.  The LC50
for females was similar to the 38.4 mg/m3 LC50 calculated by Industrial Bio-test Laboratories
(1975c) using both sexes.  Ulrich and Hagan (1978) observed some degree of sedation in all rats
exposed to 16 mg/m3 or greater, and dyspnea in all animals at 40 mg/m3 or greater.  Tearing,
salivation, and ataxia were  observed in most animals exposed to 66 mg/m3. All animals in the
3.2 mg/m3 group gained weight normally over the 14-day observation period while animals in all
other exposure groups (16-66 mg/m3) lost weight. Necropsies indicated that animals exposed to
16 mg/m3 or greater had red focal or diffuse consolidation of the lungs progressing to severe
generalized hemorrhage and hepatization that was dose-dependent.  Some animals in the 66
mg/m3 group also had rhinorrhea and mottling of the liver.  The authors noted that despite  the
biphasic mortality curve (indicating potentially two toxic responses), only pulmonary
abnormalities were found.

       These studies indicate that HCCPD vapors are very toxic and cause respiratory effects
during repeated  exposures to low concentrations such as 1.7 mg/m3.  Treon et al. (1955)
indicated that the acute inhalation toxicity of HCCPD was greater than that of phosgene.

4.5.    SYNTHESIS AND EVALUATION OF  MAJOR NONCANCER EFFECTS AND
       MODE OF ACTION (IF KNOWN)—ORAL AND INHALATION

       There are no epidemiologic data concerning the chronic health effects of HCCPD alone in
humans. Mortality studies  from several plants at which HCCPD was used cannot distinguish
between effects  from exposure to HCCPD and effects from exposure to other chlorinated
compounds present.  The presence of other chemicals, however, is not a confounder because the
       Calculated using conversion of 1 ppm =11.3 mg/m3

                                          29

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studies reported no significant increases in death from any causes, including cancer, for
employees exposed to HCCPD and other chlorinated chemicals compared with matched
populations from the United States (Brown et al., 1980; Buncher et al., 1980; Shindell, 1980;
Shindell, 1981; Wang and MacMahon, 1979).

       An occupational study (Boogaard et al., 1993) of the chronic effects of HCCPD, which
followed more sensitive health measures than the mortality studies, also found no significant
health effects.  Male chemical plant operators exposed to HCCPD (0.11 mg/m3), allyl chloride (3
mg/m3), 1,3-dichloropropene (<5 mg/m3), and epichlorohydrin (< 4 mg/m3) for an average of 8.2
years did not show any differences in liver and kidney function tests as compared to controls.
The data indicate that chronic exposure to this mixture of chlorinated  solvents did not cause
significant liver or kidney damage under these occupational exposure  conditions.

       An acute occupational exposure to HCCPD at concentrations that may have been as high
as 211 mg/m3 produced eye irritation, headache, persistent fatigue, chest discomfort, skin
irritation, and cough that persisted for up to 6 weeks following exposure (Kominsky et al., 1980).
Liver function studies on workers detected slight increases in serum glutamate-oxaloacetate
transaminase, alkaline phosphatase, total bilirubin, and lactate dehydrogenase.  These changes
suggest that acute exposure to high concentrations of HCCPD may result in liver damage, but the
relationship of HCCPD exposure to hepatotoxicity is confounded by inadequate preexposure
monitoring, the presence of OCCP, and the lack of definitive exposure data.

       Three developmental toxicity studies showed that oral HCCPD did not induce adverse
developmental effects in  mice, rats, or rabbits, even at doses that induced severe maternal
toxicity such as diarrhea and subsequent death in rabbits (Murray et al., 1980; Chernoff and
Kavlock, 1983; Goldenthal et al., 1975).  Oral doses as high as 75 mg HCCPD/kg were tested.

       The metabolic pathways of HCCPD are not well known.  Pharmacokinetic studies in
mice, rats, and rabbits indicate that absorption, distribution, and excretion of HCCPD depend on
exposure route.  Orally administered HCCPD is poorly absorbed (Mehendale, 1977; Yu and
Atallah, 1981; Lawrence and Dorough, 1981, 1982).  Although the relative concentration varies
with route, the kidneys, liver, and lungs are the predominant sites for HCCPD distribution.  Oral
HCCPD concentrates mainly in the kidneys, followed by the liver and then the lung (Lawrence
and Dorough, 1981, 1982). Distribution studies involving both rats (Lawrence and Dorough,
1981, 1982) and mice (Dorough and Ranieri, 1984) indicate that inhaled HCCPD deposits
primarily in the trachea, followed by the lungs and the kidneys. IV HCCPD deposits in the
kidneys, followed by the lungs and then the liver. The exposure route also influences the
excretion of HCCPD. Inhaled HCCPD is excreted primarily in the urine, whereas oral HCCPD
is excreted mainly via the feces.  The larger proportion of excretion via feces after oral
administration is due, at least partly, to the larger proportion of biliary excretion.  Approximately
equal proportions of an IV dose end up in urine and feces. Metabolism of radiolabeled HCCPD
in rodents is rapid, with the majority of the radiolabel excreted within 24 hours of administration
(Yu and Atallah, 1981; Lawrence and Dorough, 1981, 1982; Dorough and Ranieri, 1984).
                                          30

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Attempts to characterize the polar metabolites from tissue homogenates or urine or fecal samples
have been unsuccessful (Mehendale, 1977; Yu and Atallah, 1981; Logan and Croucher, 1984).

4.5.1.  Inhalation Studies

       There are several subchronic inhalation toxicity studies available as well as one study of
chronic duration.  Although no adverse effects were noted in monkeys or rats exposed to up to
2.23 mg/m3 HCCPD in a subchronic regimen, rats exhibited minor changes in hematologic
parameters, which were not dose-related, after 12 weeks of exposures as low as 0.11 mg/m3
(Rand et al., 1982a). In another subchronic study, Clark et al. (1982) identified the lungs as a
target organ for HCCPD toxicity. Four of 20 rats exposed to 5.5 mg/m3 HCCPD died from
bronchopneumonia.  That exposure also produced epithelial hyperplasia, edema,  sloughing of
bronchiolar epithelium, and epithelial ulceration and necrosis.  Decreases in body weight were
noted at 1.1 mg/m3.  Changes in hematologic parameters with no consistent dose or duration
relationship were also noted. A later subchronic study using rats and mice also found
hematologic changes in no dose-related pattern and confirmed the respiratory tract pathology
(NTP, 1994). Necrotic and suppurative inflammation of the lung occurred in male rats exposed
to 4.5 mg/m3 HCCPD. Higher exposures, 11 and 22 mg/m3, produced more severe lesions such
as extensive coagulation necrosis in the epithelium of the respiratory tract, inflammatory signs,
and 100% mortality. Mortality (3/20) was observed in mice exposed to doses as  low as 0.45
mg/m3 in the absence of respiratory tract histopathology (NTP, 1994). The 2-year NTP (1994)
study found no respiratory tract pathology in rats exposed to up to 2.3 mg/m3 HCCPD  or in male
or female mice exposed to up to 0.56 mg/m3.  At 2.3 mg/m3, mice exhibited suppurative
inflammation of the nose. A dose-related increase in the incidence of suppurative ovarian
inflammation was seen in female mice, but it was not considered to be the critical effect because
it was a common occurrence attributed to laboratory management procedures (Rao et al., 1987).
Neither rats nor mice showed any evidence of exposure-related carcinogenicity.

4.5.2.  Oral Studies

       Only subchronic studies are available for the oral route of exposure.  HCCPD
administered via gavage for 13 weeks was responsible for rat mortality at doses as low as 75
mg/kg and mouse mortality at 300 mg/kg (Abdo et al., 1984). Forestomach lesions were
observed at 19 mg/kg in female rats and at 38  mg/kg in male rats and both sexes of mice (Abdo
et al., 1984).  Toxic nephrosis was seen at 38 mg/kg in both sexes of rats and at 75 mg/kg in
female mice.  Although they did  not develop toxic nephrosis at any dose, male mice  developed
acute tubular necrosis at 300 mg/kg. The other major toxic effect in this study was significantly
reduced body weight beginning at 38 mg/kg in rats and 150 mg/kg in mice. No adverse effects
were noted at 19 mg/kg in mice or at 10 mg/kg in rats. HCCPD administered in feed for 90 days
produced no effects in rats at doses of up to 21-25 mg/kg/day (Industrial Bio-test Laboratories,
1975). The actual delivered dose in this study is questionable, however, because the stability of
HCCPD in the weekly prepared diet was not verified.
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4.5.3.  Mode of Action

       HCCPD is a highly reactive chemical as evidenced by its portal-of-entry effects. With
two double bonds, it is very reactive with mucous membranes and thus highly irritating to the
eyes, respiratory system, and stomach. The biological reactivity of HCCPD, a conjugated diene,
may be a result of its high reactivity in Diels-Alder reactions, in which it combines with an
alkene (a dienophile) in a cycloaddition reaction (ATSDR, 1999).  Spontaneous reactions of this
type may explain the fecal elimination as well as the portal-of-entry effects.  Potential biological
reactants with HCCPD include quinones, sterols, 2-alkenoic acids, unsaturated fatty acids, and
unsaturated fatty acid derivatives.

       An alternative explanation for irritation of mucous membranes is cleavage of the -C-C1
bond by mixed-function oxidases, which yields free radicals (C1-) that readily attack unsaturated
fatty acids in cell membrane lipids and produce lipid peroxidation. The yellow-brown
pigmentation in the respiratory epithelium of rodents chronically exposed to HCCPD by
inhalation is thought to be a result of lipid peroxidation (NTP, 1994).  The kidney and liver are
also target organs because of the high activity of biotransformation enzymes such as the mixed
function oxidase types.  The kidney nephrosis in the subchronic oral study (Abdo, 1984) in rats
and mice is localized in the proximal tubule, which has a high activity of enzymes associated
with biotransformation of HCCPD and a high capacity to concentrate chemicals intracellularly.

4.6.    WEIGHT OF EVIDENCE EVALUATION AND CANCER CLASSIFICATION-
       SYNTHESIS OF HUMAN, ANIMAL, AND OTHER SUPPORTING EVIDENCE;
       CONCLUSIONS ABOUT HUMAN CARCINOGENICITY AND MODE OF
       ACTION

 The apparent inability of HCCPD to cause genotoxic effects, and the lack of evidence for both
human and animal carcinogenicity, justify the conclusion that HCCPD is not likely to present a
human cancer risk by the inhalation route of exposure. According to the existing Guidelines for
Carcinogen Risk Assessment (U.S. EPA, 1986a), the evaluation of the overall weight of evidence
for carcinogenicity to humans indicates that HCCPD is most appropriately characterized as
Group E —Evidence of Noncarcinogenicity to Humans by the inhalation route.  In accordance
with U.S. EPA's Proposed Guidelines for Carcinogen Risk Assessment (U.S. EPA, 1996),
HCCPD is not likely to be a human carcinogen by the inhalation route based on current data
indicating no evidence of cancer in well-conducted bioassays in two species of rodents; the
absence of increased deaths from cancer in the limited human occupational studies available;  and
lack of mutagenicity in a variety of test systems. In a well conducted 2-year inhalation bioassay,
no increased incidence of tumors was reported in male or female rats and mice up to 2.2 mg/m3
(NTP,  1994).  Several occupational epidemiological studies reported no increase in cancer
mortality associated with HCCPD exposure, in the presence of other chlorinated production
compounds. Mutagenicity studies were negative in five strains of S. typhimurium; negative in
mouse micronucleus assays; showed no evidence of transformation of BALB/3T3 cells or
forward mutations in mouse lymphoma cells; did not induce DNA repair when incubated with rat
hepatocytes; and failed to induce lethal mutations in the offspring of male Drosophila. The only

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positive result for mutagenicity was an isolated statistically significant increase in sister
chromatid exchanges and chromosomal aberrations in Chinese hamster ovary cells, but
chromosome damage did not occur in metaphase stage rat liver cells.

 Because the existing chronic health effect data in both humans and animals covers only the
inhalation route of exposure, the potential for carcinogenicity by the oral route is indeterminate.
Additionally, there are no data on the carcinogenic potential of HCCPD in developing organisms.
4.7.    SUSCEPTIBLE POPULATIONS

4.7.1.  Possible Childhood Susceptibility

       There are no human studies that indicate the relative sensitivity of children and adults to
the toxic effects of HCCPD.  There are no animal inhalation studies for developmental effects,
but oral studies that administered HCCPD during organogenesis showed no significant fetal
effects (Chernoff and Kavlock, 1983; Goldenthal et al., 1978) even at doses that cause severe
maternal effects (Murray et al., 1980). On the basis of these results, it is unlikely that HCCPD
causes developmental effects in humans.  In the absence of data on the effects of HCCPD in
juvenile animals, its effects in children cannot be predicted.

4.7.2.  Possible Sex Differences

       Epidemiology studies have not provided adequate information on sex differences in
susceptibility to HCCPD toxicity. The mortality studies (Buncher et al., 1980; Wang and
MacMahon, 1979; Shindell and Associates, 1980, 1981; Brown et al., 1980) and single
occupational cohort (Boogaard et al., 1993) were predominantly limited to men and did not
report significant health effects. Subchronic inhalation studies in cynomolgous monkeys
reported no sex differences. Several subchronic studies in rodents, however, suggested that
female rodents are more sensitive to sublethal effects whereas males are more sensitive to the
lethal effects. Abdo et al. (1984) found more male rodents than female rodents died at the higher
doses during a subchronic gavage study, but female rats were more sensitive to forestomach
lesions than male rats, and female mice were more sensitive to toxic nephrosis than male mice.
A subchronic inhalation study generally reported that more male mice than females died at doses
producing mortality (NTP, 1994). For both rats and mice, males were more sensitive than
females to respiratory tract inflammation (NTP, 1994). In the chronic inhalation study, however,
there were no clear differences in the sensitivity of male and female rodents. There are no
mechanistic data available to support or refute male-female differences in sensitivity in animals,
and thus no way to predict those susceptibilities in humans.
                         5.  DOSE-RESPONSE ASSESSMENTS

5.1.    ORAL REFERENCE DOSE

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5.1.1.  Choice of Principal Study and Critical Effect with Rationale and Justification

       No chronic oral studies for HCCPD were identified.  There were two subchronic oral
studies in rodents. One is a gavage study in rats and mice by Abdo et al. (1984) and the other is a
dietary study by Industrial Bio-test Laboratories (1975b).  Athough gavage administration is not
ideal for extrapolation to human exposure, there are two main reasons for choosing Abdo et al.
(1984) as the principal study: (1) no effects were observed in the Industrial Bio-test Studies, and
(2) effects were noted at lower doses than those given in the Industrial Bio-test Laboratories
(1975b) study. Although dietary administration is more relevant to human exposure, there are
three main reasons not to choose Industrial Bio-test Laboratories (1975b) as the principal study:
(1) the quality of the data is suspect because the study was performed during a time when critical
errors were committed at Industrial Bio-test Laboratories, and (2) it was not published in the
peer-reviewed literature. Neither study reported sufficient information on the degradation of the
dosage preparation.  Although Industrial Bio-test Laboratories (1975b) prepared the HCCPD-
food mixture weekly, stability information was not reported. Because HCCPD degrades when
exposed to light (HSDB, 1999),  the HCCPD may have degraded while exposed to light in the
animal food bins.  Abdo et al.  (1984) did  not report the frequency of dosage preparation or
storage conditions. The results of Abdo et al. (1984), however, do confirm that adequate
chemical was delivered to produce effects at 14 mg/kg/day (duration-adjusted), whereas
Industrial Bio-test Laboratories (1975b) observed no effects at the highest doses tested:  21.4
mg/kg/day in male rats and 25 mg/kg/day in female rats.

       Abdo et al. (1984) administered 0, 10, 19, 38, 75, or  150 mg HCCPD/kg in corn oil  by
gavage 5 days per week for 13 weeks to 10  F344 rats/sex. Ten B6C3F1 mice/sex were
administered 0, 19, 38, 75, 150 or 300 mg HCCPD/kg on the same schedule. Mortality,
significant decreases in body weight, and forestomach lesions were observed in all rodents at the
higher doses. Toxic nephrosis was also reported in male and female rats and in female mice.
The toxic nephrosis was characterized by proximal tubular dilation, cytomegaly, karyomegaly,
and anisokaryosis with nuclear and cytoplasmic vacuolization and occurred at doses higher than
those producing forestomach lesions.  The forestomach lesions were characterized in rats by a
varying degree of inflammation  associated with hyperplasia  in the surface epithelium with the
formation of vesicles or bullae and ulceration and erosion of the mucosa.  Lesions in mice
consisted mainly of inflammation and proliferation, with ulceration restricted to the highest dose
in both sexes. The forestomach  lesions are  believed to be a manifestation of chronic irritation,
which is consistent with the observation of dermal irritation  (Treon et al., 1955; Industrial Bio-
test Laboratories, 1975a; HEW,  1978) and other portal-of-entry effects from HCCPD  exposure
(Clark et al., 1982; Rand et al., 1982a; NTP, 1994).

       Because chronic irritation manifested by forestomach pathology was the most  sensitive
treatment-related adverse effect, it was identified as the critical effect. Rats were more sensitive
than mice. Forestomach lesions were observed in  female rats beginning at 19 mg/kg and in both
sexes of mice beginning at 38  mg/kg. The NOAEL for this lesion in  female rats was identified as
10 mg/kg and the LOAEL was 19 mg/kg  (see Table 7).

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5.1.2.  Methods of Analysis—Benchmark Dose Analysis

       The incidence of treated animals with stomach lesions is a quantitative measure of
toxicity that allows benchmark dose analysis. Benchmark dose modeling was applied to these
data because there was a clear increase in response with dose and there were at least two doses
that produced more than minimal but less than maximal effects.  Only data from female rats were
used because this sex was more sensitive to HCCPD toxicity based on the presence of a response
in females at 19 mg/kg, which did not produce a response in males (Abdo et al.,  1984). The
dose-response data and the conversion to continuous dosing are shown in Table 7. Because
Abdo et al. (1984) provided gavage administration 5 days per week, the doses were adjusted to
daily doses by multiplying by 5  days/week and dividing by 7 days/week.  Thus, the duration-
adjusted NOAEL and LOAEL are 7 and 14 mg/kg/day, respectively.

       Benchmark dose (BMD) analysis was chosen for dose-response analysis because it uses
the entire doseresponse curve to identify the point of departure, it does not depend upon dose
spacing, and it is sensitive to the number of animals used in the study. The data available met the
suggested criteria (U.S. EPA, 1995) of at least three dose levels with two doses eliciting a greater
than minimum and less than maximum response. Nine statistical models from U.S. EPA's
Benchmark Dose Software (vl.2) were applied to the data to identify the model that best fit the
dose-response curve (see Appendix B).  The models with good statistical fit, as evidenced by
goodness-of-fit p-values >0.05,  were retained for evaluation of the Akaike Information Criterion
(AIC), a measure of the deviance of the model fit adjusted for the degrees of freedom, and
evaluated for visual fit in the low dose region, which approximates 10% response. The model
with the lowest AIC and best visual  fit is used to estimate the BMD10 (dose predicted to cause a
10% increase in the incidence of the effect) and the BMDL10 (the 95% lower confidence limit on
the BMD10). Visual ranking is important to assess whether the calculated curve fits well in the
10% response range.

       Six of the nine statistical models met the statistical requirements for goodness of fit:
gamma (p = 0.4333), quantal-linear model  (p = 0.5784),  Weibull model (p = 0.4312), multistage
(p = 0.4055), log-logistic (p = 0.7766), and log-probit (p = 0.7368).  The log-logistic model was
chosen to estimate the BMD10 and BMDL10 because it had the lowest AIC and best visual fit at
the control and two lowest doses, which encompassed the 10% response. The BMD10 and
BMDL10 for the log-logistic model were 10.57 and 5.6 mg/kg/day, respectively (see
Appendix B).
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Table 7.  Incidence of forestomach lesions in female F344 rats
Administered
dose
(mg/kg/day)
0
10
19
38
75
150
Duration-
adjusted dose
(mg/kg/day)1
0
7
14
27
54
107
Incidence of
forestomach
lesions
0/10
0/10
2/10
5/10
9/10
9/10
     Conversion 10 aujusi lor exposure uurauon
   e.g., 150 mg/kg/day x 5/7 = 107 mg/kg/day.
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5.1.3.  RfD Derivation, Including Application of Uncertainty Factors (UFs) and Modifying
       Factors (MFs)

       Uncertainty factors (UFs) are applied to the BMD10 and BMDL10 to account for
uncertainties in extrapolation from rodent bioassay data to human exposure conditions, for
unknown variability in human sensitivities, for data deficiencies, and for other factors.
Historically, UFs were applied as values of 10 in a multiplicative fashion (Dourson and Stara,
1983). Recent EPA practice, however, also includes use of a partial UF such as 101/2, or 3 (U.S.
EPA, 1994b), under conditions where toxicokinetics  and mechanistic information are available
and/or data are available on the nature and extent of human variability.

       Chronic studies are preferred for RfD development.  To account for the uncertainty in
using a subchronic study for RfD derivation,  the default UF of 10 is usually applied; however, for
HCCPD, the ratio of subchronic  to chronic NOAELs for the inhalation studies is used to
determine the subchronic-to-chronic UF for oral exposure. This approach is justified by the fact
that the most sensitive effect is a portal-of-entry effect for both routes of exposure. Respiratory
effects and forestomach lesions are seen following inhalation and oral exposure, respectively.
Thus, the differences in subchronic versus chronic dose-metrics are considered similar between
the two routes of exposure. The subchronic inhalation study of NTP (1994) observed a NOAEL
of 1.7 mg/m3for respiratory effects in rats while the chronic study observed a NOAEL of 2.23
mg/m3. Because comparing the subchronic NOAEL  for inhalation exposure in rats to the chronic
NOAEL yielded counterintuitive results, i.e., the subchronic NOAEL was less than the chronic
NOAEL, the mouse results were examined.  The subchronic mouse bioassay (NTP, 1994)
yielded a NOAEL of 1.7 mg/m3 whereas the NOAEL in the chronic assay was 0.56 mg/m3
HCCPD. Thus, the subchronic:chronic ratio  for NOAELs in mice is 3.  It is more typical for the
subchronic NOAEL to be larger than the chronic NOAEL, so 3, or 101/2,  was chosen as the
subchronic-to-chronic UF for the RfD.

       The toxicokinetics of HCCPD are not well understood, and  it is not known if the toxicity
is due to the parent compound or to metabolites. However, it is known that HCCPD does not
bioaccumulate,  and tissue concentrations and excretion of the compound depend somewhat on
the exposure route. Rodent and rabbit studies show that oral HCCPD is absorbed rather poorly
and excreted largely in the feces  (about 70%  of a single dose), but because there is no
information on which to base a pharmacokinetic or pharmacodynamic comparison of animals to
humans, the default UF  of 10 is used for interspecies extrapolation. There are no data
documenting the nature and extent of variability in human susceptibilities to HCCPD, so the
default UF of 10 is used to protect  sensitive human subpopulations.

       The database for HCCPD includes studies of genotoxicity, developmental toxicity,
systemic toxicity, and cancer.  Although the three developmental studies (Murray et al., 1980;
Chernoff and Kavlock, 1983; Goldenthal et al., 1978) were negative for structural defects and the
histopathological observations for reproductive organs in the primary study (Abdo et al., 1984)
were negative, functional information that would be provided by a reproductive toxicity or two-
generation reproductive toxicity  study is lacking.  Absence of pathology does not necessarily

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imply proper function. An additional UF of 101/2 is added for these database deficiencies.
Additional data that would increase confidence in the assessment include immunotoxicity, acute
and subchronic neurotoxicity, and developmental neurotoxicity.

       The total UF is 1,000 (101/2 for subchronic to chronic NOAEL, 10 for interspecies
variability,  10 for intraspecies variability, and 101/2 for database deficiency). The BMD10 and
BMDL10 are divided by 1,000 to derive the RfD.

                    BMD10= 10.6 -H 1,000 = 0.011 mg/kg/day
                    BMDL10= 6 -H 1,000 = 0.006 mg/kg/day

       Thus, the RfD, as derived from the BMDL10, is 0.006 mg/kg/day.

5.2.    INHALATION REFERENCE CONCENTRATION

5.2.1.  Choice of Principal Study and Critical Effect with Rationale and Justification

      Only one chronic inhalation study for HCCPD was identified. NTP (1994) exposed rats
and mice to 0, 0.11, 0.56, and 2.23 mg/m3 for 5 days/week for 2 years. Exposure to HCCPD did
not affect survival in rats or in male mice. The survival of female mice in the 2.23 mg/m3 group
was marginally lower than controls. Squamous metaplasia of the larynx was noted in female rats
at 0.11 and 2.23 mg/m3 HCCPD, but it was not dose-related. No adverse effects were noted in
male rats.  Exposure-related effects in mice included suppurative inflammation of the nose in
both sexes at 2.23 mg/m3.

      Female mice exhibited suppurative inflammation of the ovaries that increased in a dose-
dependent fashion. The effect was observed at 0.11 mg/m3 HCCPD, but began to be statistically
significant at 0.56 mg/m3.  The slightly lower survival rate for female mice in the 2.23 mg/m3
group was attributed to the ovarian inflammation.  It was not considered to be the critical effect
because it was a common occurrence thought to be due to pathogens thriving under inadequate
sanitation procedures (Rao et al., 1987) and because several subchronic inhalation studies (NTP,
1994; Clark et al., 1982; Rand et al., 1982a) had identified the respiratory system as the major
target of HCCPD toxicity.

      The yellow-brown pigmentation of the  respiratory  epithelium was considered to be a
marker of exposure rather than a toxic effect because it was not associated with any discernible
lesion even after prolonged exposure.  Although the designation of this pigmentation as
nonadverse conflicts with ATSDR's treatment (ATSDR,  1999), it is consistent with the guidance
in the RfC methodology (U.S.  EPA, 1994b), which indicates that "enzyme  induction and
subcellular proliferation or other changes in organelles, consistent with possible mechanism of
action, but no other apparent effects" should be ranked low in severity. Furthermore, the
guidance states that "effects that may be considered marginal are designated as adverse only to
the extent that they are consistent with other structural and functional data suggesting the same
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toxicity," indicating pigmentation does not qualify as an adverse effect in this situation. NTP
(1994) suggested that lipid peroxidation may have produced the pigmentation.

      Suppurative inflammation of the nose in mice was used as the critical endpoint for
calculation of the RfC. The dose-response data for male and female mice from NTP (1994) and
the duration adjustment to continuous exposure are shown in Table 8.  The NOAEL for
suppurative inflammation of the nose was 0.56 mg/m3 and the LOAEL was 2.23 mg/m3.

           Table 8. Incidence of suppurative inflammation of the nose in mice
Exposure
concentration
(mg/m3)
0
0.1
0.56
2.23
Duration-adj usted
exposure
(mg/m3)1
0
0.02
0.10
0.40
Nasal
inflammation
incidence
4/99
0/100
4/100
76/98
                1 Conversion from intermittent exposure to continuous exposure:
                0.56 mg/m3 x 6/24 hrs x 5/7 days = 0.10 mg/m3.
Adjusting from intermittent to continuous exposure results in a duration-adjusted NOAEL of 0.1
mg/m3 and a LOAEL of 0.4 mg/m3.

5.2.2. Methods of Analysis—NOAEL/Benchmark Concentration Analysis

      Benchmark concentration (BMC) analysis is preferred for dose-response analysis because
it uses the entire dose-response curve to identify the point of departure, it does not depend upon
dose spacing, and it is sensitive to the number of animals used in the study.  The available data,
however, did not meet the suggested criteria (U.S. EPA, 1995) of at least three dose levels with
two doses eliciting a greater than minimum and less than maximum response. Thus, the
duration-adjusted NOAEL of 0.10 mg/m3 is used to derive the RfC.

      HCCPD is a Category 1 gas (U.S. EPA, 1994b) because its inhalation effects target the
respiratory tract.  The human equivalent concentration (HEC) for HCCPD is derived by
multiplying the duration-adjusted NOAEL for rodents by an interspecies dosimetric
adjustment factor for gas respiratory effects in the region of critical effect. Because the critical
effect is in the nose, the dosimetric adjustment factor was calculated for the extrathoracic (ET)
region.

      For HCCPD, the  dosimetric adjustment factor is the regional gas dose ratio (RGDR) for
HCCPD in the ET region. The RGDR was calculated as the ratio of mouse to human ventilation
rate/ET surface area.  The ventilation rate (VE) was calculated for mice using the average body
weight of males and females in the NOAEL exposure group (41.4 g).  The ventilation rate for
                                          39

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mice was calculated as 0.049 L/minute using the allometric relationships contained on page 4-27
of U.S. EPA (1994b). The default human ventilation rate is 13.8 L/minute (U.S. EPA, 1994b).
The default ET surface areas (SAET) for the mouse and for the human are shown in Table 4-4 of
U.S. EPA (1994b) as 3.0 and 200 cm2, respectively. The RGDR was calculated as follows:

      RGDRET = (VE / SAET)animal / (VE / SAET)human = (0.049/3.0) / (13.8/200) = 0.237

      The duration-adjusted NOAEL was then multiplied by the RGDRET to yield the
                  = NOAEL^j x RGDRET = 0.1 mg/m3 x 0.237 = 0.024 mg/m3

5.2.3.  RfC Derivation Including Application of Uncertainty Factors (UFs) and Modifying
       Factors (MFs)
       Uncertainty factors (UFs) are applied to the NOAELjjgc to account for uncertainties in
extrapolation from rodent bioassay data to human exposure conditions, for unknown variability
in human sensitivities, for data deficiencies, and for other factors.  Historically, UFs were applied
as values of 10 in a multiplicative fashion (Dourson and Stara, 1983). Recent EPA practice,
however, also includes use of a partial UF such as 101/2 (U.S. EPA, 1994b) under conditions
where toxicokinetics and mechanistic information are available and/or data are available on the
nature and extent of human variability.

        For long-term rodent bioassays, the default UFs for interspecies extrapolation and
within-species variability are each 10. Half of that factor, 101/2, or 3, reflects the pharmacokinetic
component of uncertainty and half represents the pharmacodynamic component of uncertainty.
The calculation of an HEC adjustment to the NOAEL reduces the uncertainty associated with
interspecies variation. Therefore, the use of UF = 101/2, instead of the default UF = 10, is
justified for interspecies extrapolation. There are no data documenting the nature and extent of
variability in human susceptibility; therefore, the default UF of 10 is used for within-species
variation.

       Although the available  chronic and  subchronic inhalation studies survey portal-of-entry
and many systemic effects, the inhalation database is limited by the lack of information for
developmental and reproductive toxicity. Thus, an additional uncertainty of 101/2 for database
deficiencies is used in the calculation of the RfC.  Additional data that would increase confidence
in the assessment include immunotoxicity,  acute and subchronic neurotoxicity, and
developmental neurotoxicity.

       A total uncertainty factor of 100 (101/2 for interspecies variability, 10 for intraspecies
variability,  and 101/2 for a limited database) is applied to the NOAELjj^ of 0.024 mg/m3, yielding
an RfC of 0.0002 mg/m3.

5.3.   CANCER ASSESSMENT

                                            40

-------
       Human occupational studies and animal studies have failed to demonstrate an association
between exposure to HCCPD and cancer.  The NTP conducted a 2-year inhalation study with rats
and mice and concluded that HCCPD exhibited no evidence of carcinogenic activity (NTP,
1994). HCCPD is not likely to be a human carcinogen because of the absence of increased
deaths from cancer in limited human studies, no evidence of cancer in rodents, and lack of
mutagenicity. Therefore, a quantitative dose-response assessment for carcinogenicity has not
been conducted for HCCPD.
        6.  MAJOR CONCLUSIONS IN CHARACTERIZATION OF HAZARD
             IDENTIFICATION AND DOSE-RESPONSE ASSESSMENTS

6.1.  HAZARD IDENTIFICATION

      HCCPD is a dense oily liquid, pale yellow to amber in color.  It has a pungent, unpleasant
odor.  It is predominantly used as an intermediate in production of many dyes, resins,
Pharmaceuticals,  flame retardants, insecticides, and polyester resins. HCCPD is also used to
produce ketones,  fluorocarbons, acids, esters, and shockproof plastics.

      In animals, HCCPD is absorbed poorly after oral exposures, but is absorbed readily
following inhalation exposures. Oral HCCPD is excreted mainly in the feces whereas inhaled
HCCPD is excreted primarily in the urine. Metabolism is poorly characterized. The distribution
of the compound  and metabolites depends somewhat upon exposure route, but the kidneys, liver,
and lungs are the  major tissues of concentration regardless of route of exposure. HCCPD and
metabolites are typically excreted within a few days of dosing and do not accumulate in tissues.

      Although the data are limited, the repeated-exposure human toxicity data for HCCPD
show no significant health effects. In animals, the compound adversely affects the
histopathology of the tissues along the portal of entry.  Inhalation exposure produces
inflammation and hyperplasia in the nose, larynx, trachea, and lung of treated rodents exposed
for 13 weeks at doses as low as 4.5 mg/m3 (NTP, 1994). A longer term study using  lower doses
found only suppurative inflammation of the nose at doses as low as 2.3 mg/m3.  Gavage
administration for 13 weeks induced mild to moderate forestomach lesions and toxic nephrosis in
rats and mice (Abdo et al., 1984).  The lowest dose producing these effects was 19 mg/kg. No
significant developmental effects were observed via oral exposure in three studies using mice,
rats, or rabbits at  doses as high as 75 mg/kg during organogenesis
(Goldenthal  et al., 1978; Murray et al., 1980; Chernoff and Kavlock, 1983).

      The potential carcinogenic effects of HCCPD have been studied in rodents  (NTP,  1994).
In a 2-year study  that exposed rats and mice via inhalation, no treatment-related neoplastic
lesions were observed. Generally, in vitro and in vivo mutagenicity tests have produced negative
results.  According to the existing Guidelines for Carcinogen Risk Assessment (U.S. EPA,
1986a), HCCPD is most appropriately characterized as a Group E, Evidence of
Noncarcinogenicity to Humans, carcinogen when exposure occurs by inhalation. This

                                          41

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characterization is based on inadequate data for cancer in humans and evidence of
noncarcinogenicity in animals.  In accordance with U.S. EPA's Proposed Guidelines for
Carcinogen Risk Assessment (U.S. EPA, 1996), HCCPD is not likely to be a human carcinogen
via inhalation because of the absence of increased deaths from cancer in limited human studies,
no evidence of noncarcinogenicity in rodents, and lack of mutagenicity. Because the existing
chronic health effect data in both humans and animals do not include the inhalation route of
exposure, the potential for carcinogenicity by the oral route is indeterminate.

6.2.   DOSE RESPONSE

      The RfD of 0.006 mg HCCPD/kg/day was derived from a 13-week subchronic bioassay
(Abdo et al., 1984), in which rats and mice exhibited forestomach histopathology at the highest
three doses tested. Forestomach lesions in female mice were identified as the critical effect. An
overall uncertainty factor of 1,000 was applied to the BMDL10 to account for the subchronic
exposure, extrapolation from rat to human, intrahuman variability, and a limited database.

      The overall confidence in the oral RfD is low; however, the confidence in the principal
study is medium. Although the study was well conducted, an adequate number of doses were
examined, and corroborative results in two species were obtained, no data on hematology,
clinical chemistry, or urine analyses were collected. In addition, there are no supporting
subchronic or chronic oral studies with which to compare the effects noted. Developmental
studies are available for three species, but confidence in the database is low because of the lack
of a chronic study and a two-generation reproductive study.

      The developmental studies using oral administration of HCCPD during organogenesis
reported no occurrence of adverse effects in mice, rats, or rabbits. Although these studies may
suggest that HCCPD does not produce developmental effects, no multigenerational reproductive
studies have been performed to examine effects on stages of development other than
organogenesis.

      The daily inhalation exposure to the human population that is likely to be without an
appreciable risk of deleterious effects during a lifetime (RfC) is  0.0002 mg/m3.  This value was
derived from a 2-year inhalation assay by NTP (1994). Dose-related suppurative inflammation of
the nose was observed in mice. An overall uncertainty factor of 100 was used to account for the
limited database, extrapolation from mouse to human, and intrahuman variability.

      The overall confidence in the RfC assessment is medium.  The confidence in the principal
study is high because it was well designed and well conducted and followed standard guidelines
for inhalation toxicity studies of chronic duration. The overall confidence in the database is
medium.  Although there are two subchronic studies that verify that the respiratory tract is the
major target organ, the database lacks reproductive/developmental studies in rodents following
inhalation exposure to HCCPD. Oral developmental studies in three species, however, indicate
that HCCPD is not a developmental toxin at doses (i.e., 75 mg/kg) higher than those that cause
                                           42

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portal-of-entry irritation (i.e., 19 mg/kg). This suggests that the possible developmental effects
of inhaled HCCPD may be less sensitive than respiratory tract effects.
                                            43

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                                         7. REFERENCES

Abdo, KM; Montgomery, CA; Kluwe, WM; et al.  (1984)  Toxicity of hexachlorocyclopentadiene: Subchronic (13-
week) administration by gavage to F344 rats and B6C3F1 mice. J Appl Toxicol 4:75-81.

Agency for Toxic Substances and Disease Registry. (1999) lexicological profile for hexachlorocyclopenta-diene.
U.S. Department of Health & Human Services.

Boogaard, PJ; Caubo, MEJ. (1994) Increased albumin excretion in industrial workers due to shift work rather than to
prolonged exposure to low concentrations of chlorinated hydrocarbons. Occup Environ Med 51:638-641.

Boogaard, PJ; Rocchi, PSJ; van Sittert, NJ.  (1993) Effects of exposure to low concentrations of chlorinated
hydrocarbons on the kidney and liver of industrial workers. Bri J Ind Med 50:331-339.

Brat, SV.  (1983) The hepatocyte primary culture/DNA repair assay on compound hexachlorocyclopentadiene using
rat hepatocytes in culture. Unpublished report prepared by Naylor Dana Institute for Disease Prevention for Velsicol
Chemical Corporation. Doc #878213752. NTIS/OTS84003A.

Brooks, TM; Hodson-Walker, G; Wiggins, DE.  (1984) Genotoxicity studies with hexachlorocyclopentadiene.
Shell Oil Company Report No. 184.  Doc # 878214192. NTIS/OTS0206492.

Brown, DP; Ditraglia, D; Namekata, T; et al.  (1980) Mortality study of workers employed at organochlorine
pesticide manufacturing plants.  U.S. Dept. of Health, Education and Welfare and University of Illinois. Unpublished
report. May, 1980. Doc. # 40-8149074

Buncher, CR; Moomaw, C; Sirkoski, E. (1980)  Mortality study of Montague plant.  Unpublished report for Hooker
Chemical Corporation. Doc. # 878212111. NTIS/OTS84003A.

Chernoff, N; Kavlock, RJ. (1983)  A teratology  test system which utilizes postnatal growth and viability in the
mouse. Environ Sci Res 27:417-427.

Clark, DG; Pilcher, A; Blair, D; et al. (1982)  Thirty week chronic inhalation study of hexachlorocyclopentadiene (HEX)
in rats. Group Research Report SBGR.82.051. NTIS/OTIS43022.

Dorough, HW; Ranieri, TA.  (1984)  Distribution and elimination of hexachlorocyclopentadiene in rats and mice. Drug
Chem Toxicol 7:73-89.

Dourson, ML, Stara, JF. (1983) Regulatory history and experimental support of uncertainty (safety) factors. Reg
Toxicol Pharmacol 3:224-238.

El Dareer, SM; Noker, PE; Tillery, KF; et al.  (1983) Investigations on the basis for the differential toxicity of
hexachlorocyclopentadiene administered to rats by various routes. J Toxicol Environ Health 12:203-211.

Goldenthal, El; Jessup, DC; Rodwell, DE. (1978)  Teratology study in rats. Unpublished report by International
Research and Development Corporation for Velsicol Chemical Corporation. Report No.  163-573.  Doc #40-8249076,
NTIS/OTS0512884.

Haworth, S; Lawlor, T; Mortelmans, K; et al. (1983) Salmonella mutagenicity test results for 250 chemicals. Environ
MutagenSuppl 1:3-142.
                                                    44

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HEW.  (1978)  Pathology reports of studies on rats & guinea pigs treated w/HCCP & an ecotoxicological evaluation of
environmental chemicals. Unpublished internal document from the U.S. Department of Health, Education and Welfare.
February 1978.  Doc. # 40-7849029.

HSDB.  (1999)  Hazardous Substances Data Bank. National Library of Medicine, National Toxicology Program (via
TOXNET), Bethesda, MD.  April 1999.

Industrial Bio-test Laboratories. (1975a) 28-day subacute dermal toxicity study with C-56 in albino rabbits.
Unpublished report to Hooker Chemical Corporation. Doc. # 878212101. NTIS/OTS84003A.

Industrial Bio-test Laboratories. (1975b) 90-day subacute oral toxicity study with C-56 in albino rats. Unpublished
report to Hooker Chemical Corporation. Doc # 878212102. NTIS/OTS84003A.

Industrial Bio-test Laboratories. (1977) Mutagenicity of PCL-HEX incorporated in the test medium tested against five
strains of Salmonella typhimurium and as a volatilate against tester strain TA-100. Unpublished report to Velsicol
Chemical Corporation, August 1977.  NTIS/OTS0512876.

Kominsky, JR; Wisseman, CL, III; Morse, DL. (1980) Hexachlorocyclopentadiene contamination of a municipal
wastewater treatment plant. Am Ind Hyg Assoc J 41:552-556.

Lawrence, LJ; Dorough, HW. (1981) Retention and fate of inhaled hexachlorocyclopentadiene in the rat. Bull Environ
Contam Toxicol 26:663-668.

Lawrence, LJ; Dorough, HW. (1982) Fate of inhaled hexachlorocyclopentadiene in albino rats and comparison to the
oral and IV routes of administration. Fundam Appl Toxicol 2:235-240.

Litton Bionetics, Inc. (1978) Evaluation of hexachlorocyclopentadiene in vitro malignant transformation in Balb/3T3
cells.  Unpublished report submitted to Velsicol Chemical  Company. Doc #40-8049068. NTIS/OTS0512876.

Logan, CJ; Croucher, A. (1984) Hexachlorocyclopentadiene: metabolism of a single oral dose by rat, rabbit and mouse.
Shell Oil Company. Doc # 878214191 NTIS/OTS84003A. Shell Research Ltd., Group Research Report SBGR.83.200.

Mason, JM; Valenci, R; Zimmering, S. (1992) Chemical mutagenesis testing in Drosophila: VIII. Reexamination of
equivocal results. Environ Mol Mutagen 19:227-234.

Mehendale, HM. (1977)  Chemical reactivity-absorption, retention, metabolism, and elimination of
hexachlorocyclopentadiene. Environ Health Perspect 21:275-278.

Murray, FJ; Schwetz, BA; Balmer, MF; et al.  (1980) Teratogenic potential of hexachlorocyclopentadiene in mice and
rabbits.  Toxicol Appl Pharmacol 53:497-500.

NTP.  (1994)  Toxicology and carcinogenesis studies of hexachlorocyclopentadiene in F344/N rats and B6C3F1 mice
(inhalation studies). National Toxicology Program Technical Report Series 437: 318.

Rand, GM; Nees, PO; Calo, CJ; et al.  (1982a) Effects of inhalation exposure to hexachlorocyclopentadiene on rats and
monkeys.  J Toxicol Environ Health 9:743-760.

Rand, GM; Nees, PO; Calo, CJ; et al.  (1982b) The Clara cell: an electron microscopy examination of the terminal
bronchioles of rats and monkeys following inhalation of hexachlorocyclopentadiene. J Toxicol Environ Health 10:59-72.

Rao, GN; Hickman, RL; Seilkop, SK; et al. (1987) Utero-ovarian infection in aged B6C3F1 mice. Lab. Animal Sci.
2:153-158.
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Shindell and Associates. (1980) Report of epidemiologic study of the employees of Velsicol Chemical Corporation
plant, Marshall, Illinois, January 1946-December 1979. Unpublished report for Velsicol Chemical Corporation, July
1980. Doc. #40-8149074

Shindell and Associates. (1981) Report of epidemiologic study of the employees of Velsicol Chemical Corporation
plant, Memphis, Tennessee, January 1952-December 1979. Unpublished report for Velsicol Chemical Corporation,
March 1981. Doc. # 40-8149074

Treon, JF; Cleveland, FP; Cappel, J. (1955)  The toxicity of hexachlorocyclopentadiene. AMA Arch. Ind. Health Ind
Health 11:459-472.

Ulrich, CE; Hagan, JV (1978) Determination of the four hour LC50 for hexachlorocyclopentadiene. Final Report.
Project Number 783-189. Unpublished report by Huntingdon Research Center for Velsicol Chemical Corporation,
September, 1978.  Doc. #88-920002098. NTIS/OTS0536262.

U.S. EPA. (1986a) Guidelines for carcinogen risk assessment. FedReg51(185):33992-34003.

U.S. EPA. (1986b) Guidelines for mutagenicity risk assessment. FedReg51(185):34006-34012.

U.S. EPA. (1991) Guidelines for developmental toxicity risk assessment. Fed Reg 56:63798-63826.

U.S. EPA. (1994a) Interim policy for particle size and limit concentration issues in inhalation toxicity: notice of
availability. Fed Reg 59:53799.

U.S. EPA. (1994b) Methods for derivation of inhalation reference concentrations and application of inhalation
dosimetry. EPA/600/8-90/066F.

U.S. EPA. (1994c) Peer review and peer involvement at the U.S. Environmental Protection Agency. Signed by the U.S.
EPA Administrator, Carol A. Browner, June 7.

U.S. EPA. (1995a) Use of the benchmark dose approach in health risk assessment.  EPA/630/R-94/007.

U.S. EPA. (1995b) National Primary Drinking Water Regulations: Contaminant Fact Sheets.  EPA/811-F-95-003-T.

U.S. EPA. (1996) Proposed guidelines for carcinogen risk assessment. Washington, DC: National Center for
Environmental Assessment. EPA/600/P-92/003C.

U.S. EPA. (1998a) Science Policy Council handbook: peer review. Prepared by the Office of Science Policy,  Office of
Research and Development, Washington, DC. EPA/100/B-98/001.

U.S. EPA. (1998b) Health Effects Test Guidelines. OPPTS 870.3100 90-day oral toxicity in rodents.  EPA 712-C-199.

U.S. EPA. (1999) Technical factsheet on hexachlorocyclopentadiene (HEX). National Primary Drinking Water
Regulations. U.S. Environmental Protection Agency. EPA 600/4-88-039.

Wang, HH; MacMahon, B.  (1979) Mortality of workers employed in the manufacture of chlordane and heptachlor. J
OccupMed 21:745-748.

Wazeter, FX; Geil, RG.  (1972)  Acute toxicity studies in rats and rabbits. Unpublished report  from International
Research and Development Corporation for Velsicol Chemical Corporation. September 1972.  Doc # 88-920001138.
NTIS/OTS0537036.
                                                   46

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World Health Organization. (1991) Environmental health criteria 120, hexachlorocyclopentadiene. Geneva:
International Programme on Chemical Safety.

Yu, CC; Atallah, YH. (1981) Pharmacokinetics and metabolism of hexachlorocyclopentadiene in rats. Unpublished
report to Velsicol Chemical Corporation. NTIS/OTS0512880.

Zimmering, S; Mason, JM; Valencia, R; et al. (1985) Chemical mutagenesis testing inDmsophila. II. Results of 20
coded compounds tested for the National Toxicology Program. Environ Mutagen 7:87-100.
                                                    47

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                      APPENDIX A.  EXTERNAL PEER REVIEW-
                    SUMMARY OF COMMENTS AND DISPOSITION

       The support document and IRIS summary for HCCPD have undergone both internal peer
review performed by scientists within EPA and a more formal external peer review performed by
scientists outside EPA in accordance with EPA guidance on peer review (U.S. EPA, 1994).
Comments made by the internal reviewers were addressed prior to submitting the documents for
external peer review and are not part of this appendix.  The external peer reviewers were tasked with
providing written answers to general questions on the overall assessment and on chemical-specific
questions in areas of scientific controversy or uncertainty. A summary of significant comments
made by the external reviewers and EPA's response to these comments follows.

A.     Appropriateness of the critical studies and critical effects for the RfD and RfC

       All three reviewers agreed with the critical study (NTP, 1994) and the critical effect,
suppurative inflammation of the nose, for RfC derivation. All reviewers agreed with the selection of
Abdo et al. (1984) as the critical study for the RfD; however, one reviewer questioned the use of
forestomach lesions as the critical effect.  The reviewer suggested that the forestomach lesions were
inappropriate because they resulted from acute irritation by the high concentration of the test
compound in a corn oil vehicle. The reviewer suggested that the kidney toxicity seen in this study
was a better critical effect because kidney toxicity is an expression of systemic injury from repeated
and prolonged exposure and because it was consistent with the toxicokinetic data suggesting that the
kidney is a major target organ.

       Response to Comment: The forestomach lesions are believed to be a manifestation of
chronic irritation, which is consistent with the observation of dermal irritation (Treon et al., 1955;
Industrial Bio-test Laboratories, 1975a; HEW, 1978) and other portal-of-entry effects from HCCPD
exposure (Clark et al., 1982; Rand et al., 1982a; NTP, 1994).  Thus, Section 5.1.1 has been altered to
characterize forestomach hyperplasia as a manifestation of chronic irritation. Another reviewer
indicated that the observation of chronic irritation was supported by the fact that epithelial
hyperplasia was found in association with inflammation.

B.     Appropriateness of the uncertainty and modifying factors applied to the RfD and RfC

       One reviewer agreed with all the uncertainty and modifying factors applied to the RfD and
RfC. Another reviewer thought that a UF of 3 for database deficiency was unwarranted. The
deficiency noted for the RfD was  the absence of a two-generation reproductive study while those
noted for the RfC were the absence of inhalation studies for both reproductive and developmental
effects.  The reviewer indicated that, for the RfD, there were three oral developmental toxicity
studies that showed no reproductive effects and only maternal effects, so it was doubtful that a two-
generation reproductive study would elicit any decrement of reproductive performance. For the RfC,
this reviewer noted that the absorption data from inhalation studies indicated that blood levels were
much less than those after developmental studies using oral administration, and that it was unlikely
that a inhalation two-generation toxicity study could achieve blood and tissue levels capable of

                                            48

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producing reproductive studies when higher systemic doses did not do so in one-generation
reproductive studies. The third reviewer suggested using 3 rather than 10 for the interspecies UF for
the RfD because sensitivity to local chemical irritation is not likely to vary largely between species.

       Response to Comment: The UF of 3 for database deficiency was originally added to the
RfD to account for the lack of a two-generation reproductive study.  Three developmental studies by
the oral route (Murray et al.,  1980; Chernoff and Kavlock, 1983; Goldenthal et al., 1978) and
histopathological observations  for reproductive organs in the primary study  (Abdo et al.,  1984) do
provide information on pathology and histopathology of the reproductive organs, but the functional
information that would be provided by a reproductive toxicity or two-generation reproductive
toxicity study is lacking.  Absence of pathology does not necessarily imply proper function.  Other
database deficiencies, including immunotoxicity, acute and subchronic neurotoxicity, and
developmental neurotoxicity also provoke the application of the UF  of 3. This rationale has  been
added to Section 5.1.3 to provide further support for the UF of 3 for database deficiencies.

       It is acknowledged that the inhalation of 2.23 mg/m3 for 6 hours/day will deliver a much
smaller dose of HCCPD/body weight than the oral developmental studies. Nevertheless, as noted
above, no functional reproductive information is available even for the oral route.  Other database
deficiencies, including immunotoxicity, acute and subchronic neurotoxicity, and developmental
neurotoxicity, also support the  application of the UF of 3.  This rationale has been added to Section
5.2.3 to provide further support for the UF of 3 for database deficiencies.

       Even though it may be intuitively apparent that the sensitivity to local irritation would not
vary greatly between species, there are no data that support this assumption. Thus, the interspecies
UF for the RfD remains at 10.

C.     Cancer Classification

       All reviewers agreed  with the group E carcinogen classification.
                                             49

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          APPENDIX B. BENCHMARK DOSE CALCULATIONS FOR THE RfD

The RfD is based on forestomach lesions in the female rat, as reported in Abdo et al. (1984). The
dose-response data and the conversion to continuous dosing are shown below in Table B-l.

               Table B-l.  Incidence of forestomach lesions in female F344 rats
Administered dose
(mg/kg/day)
0
10
19
38
75
150
Continuous dose
(mg/kg/day)
0
7
14
27
54
107
Incidence of
forestomach lesions
0/10
0/10
2/10
5/10
9/10
9/10
              1 Conversion to adjust for exposure duration (5 days to 7 days),
              e.g., 150 mg/kg/day x 5/7 = 107 mg/kg/day

                                  NOAEL = 7 mg/kg/day
                                  LOAEL = 14 mg/kg/day

     The BMDL10 (95% lowest confidence limit of the dose predicted to cause a 10% increase in the
incidence of the effect) was estimated using U.S. EPA's Benchmark Dose Software (Version 1.2).
The results of applying nine statistical models for dichotomous data from BMDS to the data for mild
to moderate forestomach lesions are shown in Table B-2. Models with statistical goodness-of-fit/>-
value > 0.05 were ranked based on the values of the Akaike Information Criterion (AIC), a measure
of the deviance of the model fit adjusted for the degrees of freedom, and evaluated for visual fit in
the low-dose region, that approximates 10% response.  The model with the lowest AIC and best
visual fit is used to calculate the BMDL.  The gamma,  quantal-linear, Weibull, multistage, log-
logistic, and log-probit models had adequate statistical  goodness-of-fit. The log-logistic model
results were used to derive the RfD because this model had the lowest AIC and the best visual fit at
the control and two lowest doses, which encompassed the 10% response.
                                            50

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      Table B-2. Benchmark dose results for forestomach lesions
Model
Gamma
Logistic
Log-logistic
Multistage
Probit
Log-probit
Quantal-linear
Quantal-
quadratic
Weibull
Chi-square
goodness-of-fit
p-value
0.4333
0.0
0.7766
0.4055
0.0108
0.7368
0.5784
0.0000
0.4312
AIC
44.6988
NE
42.8097
46.2565
52.0664
42.9691
44.5543
NE
45.3437
Visual
Rank
2
NE
1
4
NE
1
4
NE
3
BMD10
(mg/kg/day
)
8.97
24.8
10.56
5.41
12.95
10.57
4.37
14.44
7.39
BMDL10
(mg/kg/day)
3.57
24.3
5.6
3.13
9.13
5.98
3.07
11.82
3.35
NE - Not evaluated because statistical goodness of fit^-value was < 0.05.
AIC - Akaike Information Criterion

The BMD10 of 10.6 mg/kg/day and the BMDL10 of 6 mg/kg/day were divided by the UF of 1000 to
derive the RfD.
              BMD10= 10.6 -H 1000 = 0.011 mg/kg/day
              BMDL10= 6 - 1000 = 0.006 mg/kg/day

     Graphical results from the BMD models that were visually ranked follow.
                                           51

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Log Probit-Visual rank=l
                         Probit Model with 0.95 Confidence Level
           0.6
        ••§ 0.4
        03
           0.2
                Probit
               : BMDL   BMP
                   0
          10:1703/132000
          20
40       60
     dose
80
100
Log-logistic-Visual rank=l
                     Log-Logistic Model with 0.95 Confidence Level
           1
           BMD Lower Bound
      3
      I 0.6
      •-g 0.4
       03
      LL
         0.2
           0
Log-Logistic
               BMDL   BMP
                 0        20

         12:5703/132000
                  40       60
                       dose
                  80
         100
                                        52

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Gamma Multi-hit Visual rank=2
                   Gamma Multi-Hit Model with 0.95 Confidence Level
            1 Gamma Multi-Hit
            BMD Lower Bound
       I 0.6
       ••g 0.4
       2
       LJ_
          0.2


            0
              BMD.L  BMP
                 0       20


         10:2303/132000
                  40      60

                       dose
                                         80
100
Weibull Visual rank=2
                       Weibull Model with 0.95 Confidence Level
  1
  B


0.8
           BMD
       CD
       •5
         r\ r-
         0.6
       C

       % 0.4
       CO
         0.2


           0
     Weibull
Lower Bound
              BMDL  BMP
                 0       20


         13:0003/132000
                  40       60

                       dose
                                         80
 100
                                       53

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Multistage Visual rank=4
                         Multistage Model with 0.95 Confidence Level
               1  Multistage
             0.6
          I 0.4
          ro
             0.2
               0
                BMDLBMD
                    0
            10:2703/132000
             20
40      60
     dose
80
100
Quantal linear Visual rank=4
                      Quantal Linear Model with 0.95 Confidence Level
                Quantal Linear
             BMD Lower Bound
           0.8
           0.6
           0.4
           0.2

             0
L     /
i.BMDLBMD. ..
                   0       20

           10:3203/132000
                     40       60
                          dose
                  80
         100
                                        54

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