UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C, 20460

                           April 11, 1984
                                                               OF
                                                       THE ADMINISTRATOR
Honorable William D. Ruckelshaus
Administrator
U. S, Environmental  Protection Agency
401 M Street SW
Washington, n. C,  20460

Hear Mr, Ruckelshaus:

     The Environmental  Health Committee of the Science Advisory
Board has completed its review of a revised Draft Cancer Risk
Assessment Document for Coke Oven Emissions prepared by the
Agency's Office of Research and Development (ORD).  The major
conclusion of the document was that coke oven emissions are
carcinogenic to humans.  This conclusion is based on a number
of scientific studies including an extensive series of
occupational epidemiology studies of coke oven workers and
evaluation of individual  coke oven constituent responses in
experimental animals.  The Committee unanimously concurs with
this conclusion.

     Several risk models  were evaluated by ORD's Cancer
Assessment Group (CAG)  staff to develop a quantitative risk
assessment for this pollutant.  The dose-response relationship
in the epidemiological  studies is non-linear in the range of
past occupational exposure.  At the much lower levels that
characterize ambient exposures, the dose-response relationship
is highly uncertain and several forms of the dose-response
relationship can be validly hypothesized and defended.  Because
the available scientific  evidence does not permit rejection
of the hypothesis that  the dose-response relations-hip is
dominated at low doses  by a linear term, a linear nonthreshold
approach has therefore  been used to estimate an upper bound
for the incremental  cancer risk from unit exposure.  Non-linear
weibull and multi-stage models have been used to calculate
both maximum likelihood estimates- and ranges' for the  -•.'.'
un.it/ risk (one rticrogram  of- pollutant per cubic meter of
air).  Results from the two models were in the expected
directions and did not  differ greatly.  The Committee -was briefed
by CAR on its plans to  carry out additional calculations on

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the modified linear non-threshold approach;  it is the Committee's
expectation that it will  receive the final  results  of such
analysis when they are completed.   The Committee anticipates
that the modified linear  nonthreshold approach will  continue
to be the most protective to public health,  and it  is assumed
to be applicable in this  report.

     The revised Draft Cancer Risk Assessment for Coke Oven
Emissions has been reviewed by the Committee following exten-
sive briefings by Agency  staff and participation by  the public*
CAfi staff have proven responsive to previous Committee requests
for revisions, particularly in the development of a  quantitative
risk assessment.  The result has been beneficial in  at least
three important respects:  1) the Committee  is satisfied that
the September 1983 draft  document  presents  a thorough and
balanced treatment of the available scientific evidence
associated with coke oven emissions; 2}  the  process  of communi-
cation between Agency staff and the Committee has produced
cons itferah 1 e clarification regarding the development and use
of quantitative risk assessment by ORO;  and  3} several recent
heilth assessment documents developed by ORD and reviewed  by
the Committee, including  those for acrylonitrile, carbon
tetrachloride and inorganic arsenic* have incorporated the
discussions regarding the use of mathematical models and
                          evolved  from the  review of the coke
                          These documents were of high scientific
                          the overall review process has been
quantitative methods that
oven emissions document.
quality and, as a result,
considerably shortened.
     Additional  Committee comments and recommendations  for
the Draft Cancer Risk Assessment for Cok» Oven  Emissions  are
summarized in the attached report.  The Committee recommends
that CAS provide a formal response to the recommendations
included in the  attachment*  The Environmental  Health Committee
appreciates the  opportunity to provide its scientific advice
on this important issue.
                              Hersehel
                              Chairman, £nvi r
                                Committee
                                                ental  Health
                              Norto   eson
                              Chairman,  Science Advisory Board
cc;   Mr,  Alvin Aim
     Dr.  Elizabeth Anderson
     Mr,  Joseph Cannon
     Dr.  Bernard Goldstein
     Or,  Terry Yosie

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         Environmental  Health Committee Key Findings,
            Conclusions and Recommendations on the
             Revised Draft Cancer Risk Assessment
             for Coke Oven Emissions (September 1983)


I.  Qualitative Assessment

     Based upon an extensive review of epidemic!ogical  studies

of coke oven workers in America,  Britain,  and Japan*  as well

as tests in experimental  animals  and bacteria, the following

conclusions were drawn  in the document?

     " 1) coke oven workers have  been found to be at  an
       excess risk of mortality from cancer at all sites,
       lung cancer, prostate cancer, and kidney cancer  as  a
       result of exposure to coke oven emissions.  These
       risks may possibly have been enhanced by smoking but
       are not believed to have been confounded by smoking.
       2) Sample extract  from a coke oven  main and coal tar,
       a condensate of  coke oven  emissions, were  found  to  be
       carcinogenic in  animal skin painting studies.   Animals
       exposed to coal  tar aerosol developed lung tumors.
       3) Simple extracts from coke oven topside  and  a  coke
       oven main initiated tumor  formation in initiation-
       promotion studies  in mice.  4) Coke oven door  emissions
       were found to be mutagenic in bacteria.  5) Numerous
       constituents of  coke oven  emissions are known  or
       suspected carcinogens.  The Cancer  Assessment  Group
       concluded that coke oven emissions  are carcinogenic,"

     The Committee unanimously agrees with these  conclusions.

II.  Quantitative Assessment

     The Committee reviewed at length the  quantitative

assessment section of the document and is  pleased to  report

that numerous changes, and improvements have been  incorporated

as the result of the Committee's  advice.  The body ,of this

section of our report will address these changes.

     1.  Understanding  of the significance of coke oven

emissions as i public health issue is enhanced by the

presentation of alternative quantitative estimates and  the

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comparison of risk estimates against  other known  or  suspected
carcinogens.  This is a particularly  useful  means  of communi-
cating to both the scientific community as well  as  the  general
public the significance of the risk  of this  pollutant.
     2.   The Committee suggests  an alternative definition  of
unit risk which it believes will  more thoroughly  explain  its
use in risk assessment when the  linear nonthreshold  model  is
utilized.  The alternative definition should read;   unit
risk is  defined as the maximum,  lifetime incremental lung
cancer risk theoretically estimated  to occur in  a  population
in which all individuals are assumed  to be continuously exposed
from birth to death to i one microgram per cubic  meter  increase
of the agent in the air they breathe.
     3.   The discussion of the use of mathematical  models  in
risk assessment has been considerably clarified  by  placing
confidence limits on the estimates calculated  through the  use
of the Weibull model and the multistage model.  Hore caution
should be exercised, however, in  presenting  a  risk  estimate to
two significant figures past the  decimal point.   This practice
implies  a degree of certainty or  precision which  does not
exist.  It is also desirable to  present in tabular  form the
results  of all the models» giving at - least the most  likely
estimator and upper confidence limits.
     4*   The issue of linearity  vs.  non-linearity  in the  dose
response relationship is a constant  subject  of discussion  in
evaluating risk assessments.  In  the  case of coke  oven

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emissions there Is relatively clear evidence of rton-1 inearity
in cases of occupational  exposure.  This issue should  be
stated more forcefully 1n the Summary of the document.   A
proposed insert might read as follows:
     At the much lower levels that characterize ambient
     exposures, the dose-response relationship is  highly
     uncertain:  the available scientific data do  not
     permit rejection of  the hypothesis  that the dose-
     response relationship will  be dominated by a  linear
     term.  EPA therefore makes  upper bound  calculations
     of risk using the conservative assumption that  an
     essentially linear nonthreshold dose-response relation-
     ship function exists at low doses.   The multistage  model
     is used to estimate, with an upper  bound 95%  confidence
     limit, the largest linear term consistent with  the
     occupational  data.  Such estimates  for  different  lag
     times have been used in developing  a plausible  upper
     bound estimate of the unit  risk for coke oven emissions.
     5,  A more careful statement is needed  in the document
to clarify that the cancer risk  assessment for coke  oven
emissions uses the benzene soluble organic (BSD) portion of
coke oven emissions as an indicator of  the risk due  to the
entire complex mixture.  There is discussion of other  car-
cinogenic agents in the coke oven emissions  mixture, and
BSD serves as an indicator for estimating the cancer risk
of the entire mixture* including these  other compounds.
     6.  The Office of Research  and Development and  the
Office of Air Quality Planning and Standards shoul d  'joi ntly
work to develop exposure  assessment information for  hazardous
air pollutants.  The Committee recommends that data  bases
related to exposure assessment be included in the  risk
assessments submitted for the Committee's review.

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     7,  A statement is needed in the document with respect
to the radioisotope portion in coke oven emissions that would
                  *
theoretically contribute to lung cancer.  This radiation
component from radon or other radioisotopes that have alpha
emissions has a linear term throughout the dose response
curve.  There are numerous studies, among uranium miners for
example, for which a lung cancer incidence rate has been
calculated.  There is also information available on alpha
emitted particles in coke oven emissions.
Ad d i t_i o n a 1 Re commendations
     1.  The ultimate credibility of  the Cancer Assessment
Group's (CAS's) procedures in developing risk assessments
will  rest upon their publication in the scientific, peer
reviewed literature.  wany of the difficulties and confusions
that  arise from the application of  CAG's methods are the
result of not having this peer review.  The Committee strongly
recommends that CAG submit its risk assessment procedures,
and the assumptions contained therein, for publication in
applied statistics and other journals.
     2.  CAG has undertaken a project to establish correlations
between quantitative responses in humans and in experimental
animals from selected pollutants, including coke oven emissions,
believed to cause cancer.  The Committee has discussed this
project with Agency staff and strongly recommends that the
Office of Research and Development  provide support to see
this  work through to its completion.

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     3.   The Committee supports the CAG effort to extend the
coke oven worker study through 1984.  CAG Intends to use data
on individual  coke oven workers to improve the current risk
assessment model  which is  based on aggregate data from groups
of workers.

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