EPA/600/D-90/006

                                                 March,1990
        ANALYSIS OF 2,3,7,8-TCDD TUMOR PROMOTION ACTIVITY
                  AND ITS RELATIONSHIP TO CANCER
                      James W.  Holder,  Ph.D.
              Human Health Assessment Group (RD-689)
          Office of Health and Environmental Assessment
               U.S. Environmental Protection Agency
                       Washington,  DC 20460

                         Heinrich Menzel
                Hessische Landesanstalt fur Umwelt
                   Federal Republic of Germany
                          Presented at
             The International Conference on Dioxins
                           Umea,  Sweden
                           August 1988

                     Proceedings  Published in
                   Chemosphere 19(1-6),  861-868
The views expressed in this paper are those of the authors and do
not necessarily represent the views or policies of the U.S.
Environmental Protection Agency or Hessische Landesanstalt fur
Umwelt.

-------
                      NOTICE

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 endorse-
ment or recommendation for use.

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                                                                                     EPA/600/D-90/006
                                                                                     March  1990
       ANALYSIS  OF  2.3.7.8-TCDD TUMOR PROMOTION  ACTIVITY

                       AND  ITS  RELATIONSHIP TO  CANCER


                        JAMES W. HOLDER " and  HEINRICH M, MENZEL b

                  Genetic Toxicology Assessment Branch,  Office  of Health ind
                Environmental  Assessment, Office  of  Research and Development,
                     United States  Environmental  Protection Agency, USA;
                Hessische I. andesans ta 11 fur Unuelt,  Federal Republic of Germany,


         ABSTRACT

2,3,7,8-tetrachlorodibenzo-p-diojun (hereifter referred to as TCDD) has a high estimated cancer potency in
animals which has been reasoned to imply that TCDD might be carcinogenic to man. The animal cancer data show
that TCDD can act in a solitary  manner causing tumors without the participation of other  known factors.
However, there exists animal cancer data indicating that TCDD can act as a tumor promoting compound. This
analysis examines which  type of carcinogen and which mechanism best characterizes TCDD cancer activiiy. It
is suggested that TCDD acts by a hormonal mechanism to cause cancer in a solitary manner, at low doses, in two
species, and in a number of different organs, including rare sites. These observations in iota characterize TCDD
as a complete carcinogen,  which by definition encompasses both initiation and promotion carcinogenic activities.


         KEYWORDS

Total carcinogen; tumor  promoter; tumor initiator; hormonal carcinogen.


         INTRODUCTION

In order to best assess the hazards to human life from chemical carcinogens, it is necessary to incorporate as much
understanding of the mechanism of action of animal and human carcinogens into the hazard assessment process
as possible. The carcinogenic response to TCDD in mice and rats seems to indicate adichotomous mechanism: one
mechanism proceeding by complete  carcinogenesis and the other by tumor promotion. The first mechanism
indicates that TCDD can act as a solitary carcinogen needing no other factors to cause cancer. The second
mechanism  refers  to a  type  of incomplete carcinogenesis where  the  compound  completes  the  initial,
subcarcinogenic insult of a total carcinogen, e.g. from  another source, so as to cause tumorigenesis.

We consider, in the delineation of the cancer mechanism, that it is important to qualitatively model what type
of mechanism is likely to be operative in TCDD-exposed man. Quantitative models used to explain cancer
dosimetry must of necessity  be based on  the best available realistic  qualitative mechanistic model.

This analysis shall proceed in  turn through the extant TCDD tumor promotion data, complete carcinogenesis
data, hormonal-related mechanisms to TCDD, and finally through a summary analysis of the mechanism which
best characterizes TCDD carcinogenicity.


         EVIDENCE FOR THE TUMOR PROMOTION EFFECTS  OF TCDD

a. in vivo Support for TCDD-Related Tumor Promotion (Dirgct BioassaM)

Pilot et al, (1980) have presented data on the promotion characteristics of TCDD in female Charles River rats
(Fig. 1). The primary purpose  of this study was to demonstrate tumor promoter-related quantitative liver enzyme
focus formation. Positively  staining foci for  7 -glutamyl transpeptidase (GGT) was used as a liver tumor-
promotion marker for liver cells disposed to preneoplasia by TCDD. These foci were markedly  increased
compared to  controls (see protocol, Fig. 1).

The Pitot study also enumerated the number of female rats with hepatocellular carcinoma among the dose groups
(4-7 rats/TCDD group, FIg.l), No  liver cancers were found in any control group, none in the low-dose TCDD
group (10 ng/kg/day given s.c,  in corn oil), but 5/7 rats had liver cancers  at the high-dose TCDD group (100 ng
The views .expressed in  this presentation *re those of the authors and not necessarily those of our respective
countries or

-------
 TCDD/kg b.w./day). A positive control group was tested also with phenobarbital (0,05% in diet) which showed
 8/10 rats had liver cancers. Although few animals were tested giving a lowered statistical inference of the tumor
 results (compared to a standard bioassay with SO animals/scx/dose group), it is clear that sufficient fields of cells
 were scanned to determine the TCDD-related histochemical effects of TCDD and phenobarbital in the rat liver.
 Pitot et fl/.(198Q) have suggested that, because of the positive tumor promotion results, which are associated with
 particular enzyme foci formation in the liver, it is reasonable to hypothesize that all the tumors associated with
 persistent TCDD exposure arise from the tumor promoting effects of TCDD on "already initiated* cells in the
 test animal. This further implies that there is no primary initiating effect of TCDD on these female rat cells
 (cf. DISCUSSION section).

 A study in HRS/J mouse skin is presented in Fig. 2 (Poland et a/,,1982). When hairless  mice (hr/hr)  were first
 exposed to 0.2 nmol of DMBA (initiation) and then exposed to repetitive exposures of either SO ng TCDD/mouse
 or 2000 ng TPA/mouse (a known skin tumor promoter), papillomas of the epithelium were formed in both cases.
 It is notable that TCDD alone in this experiment caused no increases in skin papillomas. But when a subthreshold
 dose of a complete  carcinogen was applied to skin, then subsequent  TCDD or TPA exposure caused tumor
 promotion in hairless mice. TCDD is about 40 times more potent as a tumor promoter in this system than is TPA.
 In congeneic mice which are genetically (hr/+), no tumors can be promoted by repetitive exposures  to TCDD,
 thereby suggesting that a single recessive trait (hr) may be involved in the TCDD-mediated tumor promotion in
 HRS/J mice. However, the possibility of other genetic loci involvement is not ruled out.

 A tumor promotion bioassay was done for the U.S. National Toxicology Program (U.S.NTP,  19S2i) in mice.
 TCDD was applied dermally onto the dorsal region of skin (Fig. 3). Swiss-Webster mice showed marginal increases
 in fibrosircomas upon TCDD exposure in either the male TCDD or DMBA/TCDD dose groups which are not
 viewed as statistically increased cancer responses; however, definite increases in fibrosarcomas were observed
 in the female TCDD and DMBA/TCDD dose groups. These increases, which were about  the same (30% and 28%,
 Fig. 3), showed  that TCDD alone  increased the fibrosarcomas, but prior initiation with DMBA  was not further
 enhanced by repetitive  exposure to TCDD. This suggests that TCDD is acting as a  total carcinogen. It  is
 interesting that fibrosarcomas were caused by TCDD and not cancers of the mouse epithelium, onto  which the
 three times/week  applications in  0.1 ml. acetone were applied.  It  is known, for instance, that TPA and certain
other phorbol esters do promote tumors in that same epithelium (Felling and Slaga, 1985, and references therein).

Other results (Fig. 4) found in "normal" wild-type mice (presumably +/+ at the hr locus) are also negative for
TCDD skin tumor promotion (Berry el a/,, 1978). The results in all of the mice strains tested for tumor promotion
 taken together suggest that HRS/J hairless mice may be unique in showing skin tumor promotion  responses as
a result of repetitive TCDD  exposures to  the shaved and depilatated mouse dorsal skin epithelium.

b.in vitro  Support for TCDD-Related Tumor Promotion Effects

TCDD has little transforming ability in 10 T 1/2 cells alone, but was a promoter of transformation  following
MNNG((N-MethyI-N*-nitro-N-nitrosoguanidine), a known tumor initiator (Abernethy et at., 1985; Abernethy and
Boreiko, 1987). Following initiating (low) levels of MNNG in this assay, TCDD was a very potent transforming
agent, since it has a high transformation efficiency: 29%-39%  @ 4 picomolar.
          Tumor Promotion In Charles River Bats.
   Top Panel.  Protocol is presented as a time line.
   Initiation is by intragastric intubation (IX) of
   diethylnitrosamine; subcarcinogenic dose of
   DEN * 10 mg/kg. After a rest period, tumor
   promotion was effected by persistent subcutaneous
   injections of TCDD 8t either 140 ng or 1400 ng
   TCDD per kg body weight per dose. A promotion
   dose was given twice/week. Dosing periods; DEN,
   TCDD, or phenobarbital alone, 28 wks; as tumor
   promoters, TCDD for 14 wks or phenobarbital
   for 28 wks.

   Bottom Panel. Indicates the incidence of cancer
   in the rat liver identified as hepatocellular
   carcinomas. Note the short period of TCDD
   treatment for TCDD as a promoter while causing
   about the same incidence as for phenobarbital
   as a promoter at twice the treatment TCDD
   period (14 versus 28 wks). Hence, at doses
   given by Pitot and his collaborators, TCDD
   tumors in the liver develop faster.
      ran i MM HIM n ewuus inn HATS •»
imnummMm mrunoi • i,!.7,i-rca> nm
             ut» i> PITOT. H. , IT «i. <19«0>
             CMC*> glaum* *4 !Uf - Ilia
               IRC  LIKE
       mill:   i  • IBITIATM, DirrnTMiirmiiuniii IBIIO
             »  « TO** »mniiii, 'Z,3,?,J.TCM
             FH • rURTlAL MIMrKTQMY (HI^LtCArieMt
  icon rm u»««
  GTT CILL fOCI

TUC TQ
1400 M
""«»

111
10 TIUTMIHTI/llfH
•UlCMTAlllOVkir /K&. «,H.
cs fluUTiOH or TCOO fip«$
•^^B jcom ro* fi«a
I


,»«
• I ••
TtMTHMT

CM • DEN


PN • TOO

 PH *
mENOUUMITU.
           BATS   No. fOCl/enl
                                                          Vie*
                                                         Kt -  SEN     10
                                                         • PHENOeAfttlTM. •
                 }«

                 25

                 5«

                 171

                 ill
                           LWKUJSCIiilKE
0/« « 0%


»f! * 0*
                           »//  » 71%


                           1/19  > SOt

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                                                                                                   Fig. 3
                             Fig.  2
I
TWO* PROMOTION BY 2,3,7,4-TOO U HAIRLESS MICE
       I
INITIATOR
QMBA
(0,2 NMOL
ON84-
(Q.2)
OMB 4
10.2)
MNNG
15 HOL
MNNG
' MNNC
HMNS
ACETONE
BEFEBIKCE
PROMOTES TUMOR INCICEUCE TUMOB MULTIPLICITY
ACETONE i \ o.i
i
TPA
(2000 NG/MSI.) 56 \ 1.9
TCDD • 98 % 2.0
(50 io/Mst.)
TCDD (3.8 MQ/HSE.) 5 % 0.05
)
TCDO (7.5 NG/MS£.) 55 % 0.7
TCDO (IS NO/ME.) 77 1 1.5
TCDD (30 NS/MSE.) 100 * 4.0
TCCD '(30 NC/Mit.) 0 % 0
POLAND, PALIN, 1 GLOVIS (1982) 3JO. (Nev.) 271 - 273
                               Fig.  4
       TUWfi PROHOTIN6 AJILITY IN CD-I NICE 1Y 2,3,7.8-TCOO
       PROTOCOL
                    IN CO-1 MOUSE SKIN   IOORJ»L)

                    TREATED TWICE/MEEK   ro«  30 UIIKS

                    100 S4/«BPL!C*TION IN 0.2 ML.
                                      ACITONE
         INITIATOR   PROMOTER    QflS£   IMCIPIMCI  TUMORS/HOUSE

         OMBA                                0           0
          (200NHOI.)
          OMIA
          OHBA
                       TPA      2,000 N&


                       TPA     10.000 HC
                                      I


                                    92
0 .03


 8.1
                        TCOD
                        TCDO
                                  100 NG
                                  100 NG
       REFERENCE:

         BERRY, DZ£JOV»MNI,  JUCHAU,  IHACKEN,  GLCASOH, SI.»G«
           RESE40CM COMMUNICATICNS IN CMEHIC«L P*THCLOGV
              «NB  PHAHMACOLOST  2J}- (1>  101 - 108  (19781.
                                                                  NATIMtti. TOIICauXY ftOfUH  -  198J DERHAL aWSURE TO TCOO
                                                                                   (JWIJI - MMTtl MICK)
TREATMENT
SO uc.
OMBA
TCDD
DOSE
RATE
TOTAL
DOSE
DURATION
S
I
1
T
MALE DOSE
one TINE SKIN
• tMTITXVI SKIN
THIiTHtNTS (O.lKL)
1 NC' 025 KC I.W.
3K/UECK
17.1 M/«/«Y
2 ve»BS

TREATMENT
CONTROL
TCDD
DHBA/TCDO
CONTROL
- TCDO
OMBA/TCDD
FIBROSARCOMA
INCIDENCE
MALES
3/42
6/28
S/30
F E N A L £ S
2/41
8/27
8/29
FEMALE DOSE *
ONI TINE SKIN
APPLICATION (0 IML!
KEPITXTIVt *KIN
T«f ATWftlTS (O.lm.)
• 5 us/. 025 KG t.u.
3X/MEEH
85.7 KG/KG/OAT
2 »f*BS

PERCENT
7
21
17
5
30
28
P-VALUE
0.08
0.18
0.007
0,01
rATISTICAL
HFERENCE: ITCWJ INCIDENCE! »eK*us tDMBA/TCOO INCIDENCE]
1ALES, P e 0.50, FEMALES, P = 0.55 -— MO DIFFEflENCES
««ro«E, TCCD TREATMENT APPARENTLY NOT DIFFERENT FROM
TMI OMBA/TCDD TREAMENT,
                                                                                             Fig. S
                                                                                                                     -
                                                                  -ss-S^itjiial^'S^fe::* f: :^                '              ^ -
                                                                                  KOCI1A 119781 SAVA6E STUDY  *--^   - -
                                                                         -&••'**H»
                                                                                  CANCER  INCIDENCE  IN SHUSUE-DAMUY  RATS
                    Jf|  [EVIDENCE FOR INDUCED CAKEK FROM  2.3,7,8-TCDO]

                  .; *j|i.: i-j-i-; ^^^^•ff^g^^r^^^^gg^^^y^.-^-,!:jft»;iy>--
CANCER
TYPE/SEX

M
HARD
PALATE
F

M
2,
0
(PER
0/85
(0)

0/86
(0)
0/85
' TONGUE (0)
F 1/86

M-

LIVER
F

M

LUNG
F

(1.1)
2/85
(2.3)

1/86
(1.1)
5/65
(5.8)

0/86
(0)
3,7,8-TCDD
1.0
e • * T
0/50
(OS

0/10
(0)
1/50
(2!
0/50
(Q!
0/50
(0)

0/50
(0)
0/50
(0)

0/50
(0)
DOSE-RATE
10
I N C I D f
'O/SQ
(0)

1/50

1/50
(2)
0/50
(0!
0/50
(0)

2 '50
(ii
• 0/50
(0)

0/50
(0!
(NG/KG/OAY)
100
NCI)
4/50«
(8)

4/49*
(8)
3/SO«
(6)
2/49
(41
1/50
(2)

11/49.
(22)
1/50
' (21

7/49.
114)
RESULT
* INCREASE


«• INCREASE
(P =0.016>
* INCREASE
(P s .048)
NO EFFECT

NO EFFECT


. INCREASE


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 The degree of cellular malignancy associated with the in vitro focus formation was likely significant because type
 III cells [defined originally by Reznikoff et a/.,  1973] were scored. Since transformation is viewed to be an
 essential series of cellular conversions in the development of cancer, these observations in 10 T 1/2 cells indicate
 this subset of cellular transformations is caused by TCDD. The connection between in vitro transformation to
 tumor promotion is not well understood as of yet, however, and can only be surmised as being part of the process.

 Although  TCDD facilitates cell transformation like a tumor promoter, TCDD does not  inhibit  intercellular
 communication - as many tumor promoters have been observed to do (Williams, 1980;Troskoe/a/., 1981) measured
 by the 3H-Uridine cellular exchange, or by movement of Lucifer yellow dye among cells in intercellular transfer
 assays (Boreikoe/a/,, 1986). This lack of interference in cell-to-cell communication suggests that TCDD is either
 not a lumor promoter, or that TCDD is a tumor promoter acting by a different mechanism than a classic promoter
 such as TPA.

 Two of  the major re-programming cellular effects caused by tumor promoters are increased mitosis in some cell
 subpopulationsand increased terminal cellular differentiation in other cell populations (Willey J.C., et al., 1984).
 For example, TCDD has been found to increase keratinizadon in skin (Knutspn and Poland, 1980). Hyperplasia
 from TCDD exposure is seen in vitro in cultured human keratinocytes, in exposures to human epidermis, and in
 animal  systems (Milstone and LaVigne, 1984; Gianotti, 1977; Poland and Knutson, 1982). Both properties of
 increased  cellularity and maturation are descriptive of tumor promotion activity but are  also  manifest by
 complete carcinogens, which possess both  initiation and promotion activities.


          EVIDENCE OF TCDD ACTING  ALONE AS A TOTAL CARCINOGEN

 Sprague-Dawley rats were gavgged with average daily TCDD doses of 0,1,10, and lOOng/kg/day (Kocibi.ef a/.,
 1978). The summary of the Kociba study is presented in Fig. 5. Increases in malignant tumors were observed in
 four different organs: hard palate (including nasal turbina te cancers), tongue, liver, and lung. This tumor activity
 is carcinogenic activity since TCDD caused malignant tumors in these organs (Kociba, 1984).  Mechanistic
 activities  of tumor initiation, promotion, and progression are all indicated by these rat  malignant responses to
 TCDD oral exposure.

 It is interesting to note that the cancer responses were positive at the 100 ng/kg/day dose and not at 10 ng/kg/day
 (Fig.5). The same pattern of response was seen (100 + and 10 •) in the Pilot tumor promotion experiment where
 TCDD was administered to rats subcutaneously (Pilot et a/., 1980). The observations that different routes of
 TCDD exposure show the same break in the cancer response curve (at the same dose level shows a null response),
 in radically different protocols, and in different rat strains, all suggest that this dose region may be one that
 observationally defines (not proves) an apparent cancer threshold for TCDD in the rat.

 It is also interesting  to note (in the same experiment): not only were tumors increased but also  tumors were
 decreased  by TCDD. These tumor decreases are shown in Fig. 6 and Fig. 7. We note one exception to tumor
 incidence  decreases,  i.e. an increase in benign  tumors of the adrenal gland cortex. However, decreases were
 observed at the same time in adrenal pheochromocytomas (Fig, 7), The tissues affected by TCDD-related cancer
 decreases  are all  endocrine organs, thereby strongly suggesting the mechanism  of action of  2,3,7,8-
 tetrachlorodibenzo-p-dioxin is linked to these hormonal systems. This "protection effect" of TCDD has not been
 adequately discussed  or factored into any complete hazard evaluation or risk assessment of TCDD as of yet. This
 dichotomous tumor pattern imposes an additional complexity when ascribing the "estimated" carcinogenicity
 hazard from TCDD exposure and how this relates to human  carcinogenicity risk.

 Later  work on TCDD carcinogenicity has been reported by the NTP in Osborrie-Mendel rats and B6C3F1 mice
(U.S.NTP,  1982b). Hepatocellular carcinomas are the dominant cancer response in the Osborne-Mendel rats with
 females and males demonstrating carcinogenicity increases only at  the highest dose tested (Fig,  8). A mostly
 benign response to TCDD was also observed in the follicular thyroid at the highest dose and in both sexes. It is
 notable  that tongue, hard palate, and lung tumors did not appear increased in the Osborne-Mendel rat in this NTP
 study  as in the above Kociba study in Sprague-Dawley rats (cf, Fl|. 5). However, the liver repeated as being a
 cancerous  site between the two studies as well as increases in an endocrine organ (thyroid), whereas decreases
 were observed in Sprague-Dawley  rat endocrine organs (pituitary, pancreas, thyroid, uterus, mammae,  and
adrenals) with only benign  tumors increased in the adrenal cortex Sprague-Dawley rat.

 A similar carcinogenicity response in the NTP study was observed inB6C3Fl  mice(Fl§, 9).  That is, in the mouse
just as in the rat, liver and  thyroid tumors were also increased by TCDD exposure.
         DISCUSSION

It is clear that repetitive TCDD exposure, after a subcircinogenic initial exposure of a carcinogen, can bring
about or promote tumors. This activity of tumor promotion seems to be manifest in Charles River rats and HRS/J

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                            Fig. 6
KOCISA [1978! GAVA6E CANCER IHCIDDCC IN SPiASUE-OAMLElf  RATS

 [EVIDENCE FOR DECREASED TIMOR RESPONSE FROM 2. 3, 7.8-TCDO]
                                                                                                Fig. 7

                                                                     KDCIBA [1978]  SAVAGE CANCER INCIDENCE IN SPRA&UE-OAKLEY RATS

                                                                      IEVIDEKCE  FOR OECtEASED TUMOR RESPONSE FSOK 2.3,7,8-TCDO
ORGAN SITE /
MALIGNANCY
STATUS
S = SCN1CN
PITUITARY M
In » B)
F
PANCREAS
Ac I MB N
(M * 8>
' ISLIT F
(M • B)
THYROID K
Iw * B)
f
0
 E
26/85
(30)
49/86
(17)
28/85
(33»
5/86
(5.81
11/85
(13)
18/66
(21)
NOTE:' • INDICATES
8-TCOD* DOSE-RATE
1.0 10.0
BCtuT INC
6/50*
(12)
18/50
(3$)
6/10.
112)
3/50
16)
0/50.
(0)
3/50.
P-VALUE
(NS/KG/DAY
100
I 9 I N C
11/30 13/50
(221 (26)
13/50 14/49.
(36) (28)
12/50
1/50
(2)
1/50»
(2)
2/SO.
(4>
LESS THAN
9/50-
(18)
0/49
(0)
7/50
(14)
6/49
(12)
O.US
RESULT
I)
LOU DOSE I
DECREASE ¥
ONLY  HID
OOSE I
DECREASE V
LOU 1 HID
DOS! !
DECREASE V

ORGAN SITE/
MALIGNANCY
STATUS
M - MALIGNANT
S = ICKlGN

UTIRUS F
(B ONLY.)
MAMMAE F
(I 9NIY)
ADRENAL
IB OKLY)
F
ADRENAL
M
(B ONLY)
F
2,3,7,8-TCDO DOSE-
0 1-0 10

C 0 N T I N
28/86 12/50
(331 (241
73/86 35/50
(85) (70)

U * T I
11/50
(22)
36/59
(72)
RATE IN;
100

0 N OF
7/49-
(14)
24/49.
(49)
ADBINAL FHIOCHMMOCYYOMAS
28/85 6/50. 10/50 4/50.
(33) (12) (20) <8>
7/86 2/50 1/50 3/49
(8) (4) 12) 16)
U»1CM*L
0/85 0/50
(01 (0)
9/86 6/50
110! (12)
C01TII
2/SO
(4)
2/50
(4)
5/SO*
(10)
5/49
(10)
K5/OAY )

KOCIIA STUOY
HIGH
OOSE !
DECREASE V

HIGH
DOSE I
DECREASE V
LQM i HIGH
OOSE
DECREASE \
NO EFFECT
(EXCEPT
HIGH
DOSE
INCREASE
NO EFFECT
ON)
                                                                        NOTE:   •  INDICATES   F-VALUE  LISS  THAN 0.05.
                            Fig. 8

::?~: i'.'•"?. f '-Kit •&&%'*. i-3'ffiiElRSIfjJJH'lBBS

.  :           U.S.  NATIONAL TOXICOUWY

I!',!             C19821 6AVAiE STUDY m THE RAT

'•'•  RESULTS r» OS«O««E-HiKOEL R*TJ (DutcmoiMS * AotMM*$>

                                                 SSSiHEIj S!
                                                                                               Fig. 9
                                                                             U.S. KATIONAL TOXICOLD6T PRD6RAM

                                                                                [19821 SAVAGE STUDY (N THE HOUSE

                                                                       RESULTS  m B6C3F1 Mice   (CARCINOMAS * ABENOWAS!
ORSAN
SITE
0
LIVER
« 0/124
(0!
F 5/124
(4)
2,3,7,8-TCDD DOSE-RATE
3,0 7.0
S * C C N T INCIB

0/50
(0)
1/49
(2
THi'RQ'f.O' - FOUICULAH,
M 6/118 »/4«'
(5) (10)
' F 5/122
(4)
2/45
(4)

0/50
(0)
3/50
MOSTLY ADENOMAS
8/50*
(16)
f * .02
1/49
(2)
(N6/K6/B«Y)
70 RESULT
C N C t)

4/50*
(8)
15/49.
(31)
P • 5
11/SO.
(22)
P •
6/47.
(13)
P s

INCREASE
006
INCREASE
x 10-*
INCREASE
.002
INCREASE
.05
                                                                     ORGAN
                                                                     SITE
                                                                                   2,3.7,8-TCDO DOSE-RATE  (NO/W/DAY)

                                                                                   0         3.0       7.0        70
                                                                                   (PERCENT   INCIBtN'CE)
                                                                     LIVER

                                                                       H
                                                                                31/123
                                                                                 (25)
                                                                                          12/49
                                                                                           (24)
                                                                                4/123     8/SO.
                                                                                  (3)       (12)
                                                                                        P =  .03
13/49     27/50.   INCREASE
 (27)      (44)
          P = 3  x 10'4

 5/48.    11/47.   INCREASE
  (13)     (23)
f s  ,03   f = 2  » 10"*
THYROID -
M

F


FQLLICULAD
0/114
(0)
0/136
(0)
P
BENISN,
3/48
(6)
3/50.
(6)
« ,02
ONLY
0/48
(0)
1/47
(2)


0/49 NO EFFECT
(0)
5/46- INCREASE
(11) ,
P * 8 x 1C'4

-------
 hairless mice (hr/hr), but not in some "normal" mice strains (Swiss-Webster or CD-I) which are presumed to be
 wild type at the hr locus. ID the hairless mouse cross experiments mice which were heterozygous (hr/+) at the hr
 locus also did not show tumor promotion activity with TCDD suggesting the hr trait may be a accessary element
 for mouse skin tumorigenicity .

 It appears, then, that tumor promotion can be observed in some test strains, and not in others. Furthermore, it
 is noted (Fig. 3) in Swiss-Webster mice that, although TCDD skin tumor promotion is not observed in DMBA
 treated mice, TCDD by itself caused significant increases in fibrosarcomas in females (p=0.007) and a borderline
 response in males (p-0,08). These results suggest that although TCDD did not promote or enhance tumors in this
 test system it can cause carcinogenesis. This points to a total carcinogen mechanism in this system for TCDD. In
 a single report TCDD showed tumor initiation activity in the mouse (Digiovanni, 1977), Consequently, we surmise
 from all the TCDD tumor promotion data that TCDD has tumor promotion characteristics only in certain strains
 tested  in the two-stage carcinogenesis system.

 The cancers observed by Kociba and his collaborators in Sprague-Dawley rats were tumors in liver and squamous-
 cell carcinomas of the lung, the later being an uncommon tumor type occurring spontaneously in the iung. Also,
 the tongue and hard palate responded with carcinomas both of which are direct-route sites and are rare tumors.
 The occurrence of tumors is revealing as to the carcinogenicity of TCDD: (1) it strengthens the causal relationship
 between chemical exposure and cancerous outcome because the outcome is improbable due to random chance, and,
 (2) it indicates the probable effect of TCDD is'likely direct on  these tissues to cause cancer rather than
 "promoting" cryptic  initiation lesions Jhypothetieally caused  by prior events] in these normally cancer-free
 tissues. Were this latter point not true, then it would be expected that the theoretical initiation lesions,  if really
 present, might nonspecif ically interact with other promotion agents, such as exist in the diet, to cause cancer. But,
 cancer is only rarely observed in the hard palate and tongue of  the rat.

 So it is reasoned that analogous to a complete cancer-causing agent in  man, such as tobacco smoke which contains
 known initiation and promotion agents and is carcinogenic to the human tongue, hard palate, and lung, TCDD
 can also be carcinogenic to these same tissues in the Sprague Dawley rtt thereby indicating that TCDD is a
 complete carcinogenic agent, at least in the rat. It remains to be proven whether TCDD is also carcinogenic to
 these tissues in TCDD-exposed humans. Since no other known agent participated in the rare cancer formation
 in the Kociba TCDD rat study, then it is reasoned that TCDD is a complete carcinogen possessing both initiation
 and promotion properties, although the proportional degree of each is not yet known; The relative proportion of
 the initiation/promotion mechanisms need not be the same among compounds testing positive for cancer in test
 species and may not  necessarily correlate with the same proportion  of these mechanism types in man.

 Tumor promotion is not a new concept. Inception of this etiology took place in the 1920's by investigators who
 suggested  a noncarcinogenic effect such as  wound healing could evoke cancer in some cases, called traumatic
 cancer (Deelman, 1924, 1927). Later, the seminal work of Peyton Rous showed that certain chemical treatments
 could "seed* apparently normal tissue with persistent cells, in which later in time could be stimulated or enhanced
 by other noncarcinnogenic chemicals (or even by mechanical stimulus) to form tumors in the seeded tissues (Rous
 and Kidd, 1939; MacKensie and Rous,  1941). These authors referred to the  latter stimulus which caused cell
 growth leading  to tumors as "extraneous encouragement agents", and it was later defined as promoting agents
 (Fried wald and Rous, 1944). In this work the term initiating agents was also given to the irreversible carcinogenic
 action of chemicals which would start the process. With such concepts of stages of effects in sequence started the
 conceptualization of the commonly accepted initiation/promotion hypothesis of carcinogenesis which still is
 considered a valuable  working model today.

Other  investigators  pursued  the initiation/promotion  concept  referring  to it  as "specific  cellular
reaction'/developing factor (Mottram, 1945), and initiation process/promotion process (Berenblum and Shubik,
 1949). These studies, and other genetic studies, provided support for the two stage hypothesis (Olinos, et aL, 1951).
The operative concept was also supported by the evolving somatic mutation hypothesis (Berenblum and Shubik,
 1949): cancer was determined to arise from a somatic mutation of a few cells [there being variation among these
 few mutated cells as  to the type of lesion (Shubik, 1950)]. Some of these cells, in time, could be developed by a
 number of diverse agents to unscheduled cellular growth which  proceeded in greater abundance [presumably]
 from mutated cells to hyperplastic regions, tumors, and finally in  some cases to cancers which disseminated
 throughout the body. These developing agents, which by all authors were referred to as noncarcinogens, enhance
 the chances of cancer in initiated tissues and were  referred to as tumor promoters.

This concept of tumor promotion has been studied by a number of investigators (Boutwell, 1964; Van  Duuren,
 1969; Berenblum, 1969; Shubik, 1984; Felling and Slaga, l985;Schulte-Herman, 1985) since the foundation works
discussed above. The concept of tumor promotion in our opinion may be generally defined as:

   Promotion is a reversible set of cellular processes which can cause unscheduled and/or mis-controlled cellular
   growth allowing for relative enrichment of initiated cells compared to the normal field of cells in which these
   initiated cells reside. Promotion leads to expanded clones, as well as.  allows for reversible qualitative changes
   in the normal cellular differentiation process. Cancer can result from  this promotion process if further changes
   in genetic expression {progression} are imposed on the exposed field of cells,

                                                                                                  (

-------
 For other discussion of tumor promotion definition refer to U.S. EPA, 1987.

 It is instructive to note that (1) tumor promotion does not take place in the absence of initiation, i.e. initiation
 precedes promotion which  in turn precedes progression into malignancy, and (2) tumor promoters are not
 carcinogens. We reason that TCDD produces cancers (malignancy) alone without any known prior tissue .initiation
 which indicates TCDD is a complete carcinogen needing no assistance in causing cancer. If TCDD were iust a
 tumor promoter as has been  suggested (Shu et al.,  1987), then all the responding tissues (liver, lung, hard palate,
 tongue, skin, and thyroid) would of necessity have already been initiated at the time of TCDD exposure. We view
 this alternative as unlikely since the responses occur in a number of species/strains, and in a number of organs,
 including palate and tongue which are rare sites, These occurrences are not indicative of promoters studied to
 date which usually  affect one organ, and only if that  tissue has been initiated previously. We know of no
 published example where just a promoter exposure alone caused a dose-response of malignant tumors at a  rare
 site. Lastly, even though it may be argued that the tongue and hard palate may have extraordinarily high TCDD
 exposures, this does not necessarily account for the rare carcinogenic response of these tissues any more than
 other carcinogens which are similarly administered by gavage. We conclude there must have been some specificity
 for the tongue and hard palate in the Sprague Dawley rat in the Kociba study. However, since this response was
 from  a single study, it will be necessary to replicate these results in these tissues in order to increase certainty
 of the hard palate, tongue, squamous lung cancer responses.

 A control often done in earlier work was to test whether a chemical could promote itself (e.g. Boutwell, 1964),
 This control started  the process by a subcarcinogenic dose of the suspected carcinogen. If no other treatment is
 given, no tumors result; but if repetitive isoquantal doses of the same test chemical are applied, tumors dj. result
 if the chemical is a carcinogen. This is interpreted to mean that processes of initiation and promotion occur, i.e.
 a total carcinogen can promote itself. We view TCDD as having promotion activity, but this does not preclude
 that TCDD is a total  carcinogen capable of promoting it's own initiation process. It should not be a surprise, then,
 that at the right dose-rate total carcinogens wilt act as tumor prompters in tumor promoter assays. We view TCDD
 acting this way in the tumor promotion assays reviewed here (Pilot el at.,  1980; Poland and Glover, 1982).

 It remains then to address what kind of carcinogen is TCDD. The present genotoxicity information on TCDD is
 mostly negative although positives do occur (U.S. EPA,  1985). The mostly negative genotoxicity results suggest
 that TCDD is not generally positive by current methodology, and the true genotoxicity may not be known since
 the appropriate end-point may not have tested yet. Some authors have taken the position that TCDD must act
 upon  the genetic material [but by an  unknown  mechanism] (Giri, 1986). The classical  mutation mechanism
 whereby covalent-binding mutagens alter the DNA content may not be operating in the case of TCDD. TCDD
 may alter the genetic informational flow  by a here-to-fore undescribed carcinogenic mechanism.

 Due to the extended residence times of TCDD in the body {(t1/2), «• 1-4 mo. in rodents and 6-10  yrs.in man],
TCDD could interact with  functional chromatin, cell generation  after cell generation, so as to alter genetic
expression by persistent phenotypic changes. TCDD likely interacts by noncovalent binding in the rat since DNA
 measured covaknt binding s 1 TCDD molecule/1011 nucleotides (Poland and Glover, 1979). However, assuming
 2 x 109 base pairs/cell, the  estimated number (maximum) of hits in the rat are:

      1 molecule TCDD     x     4»10g    nuclootides      ss       j molecule of fGDP
      10"  nucleotid«B          on«  «ukaryotic call                   25 calls

This hit frequency of TCDD covalent linkage to DNA  is very low in rats  being less than one hit per cell and
4-6 orders of magnitude less than most chemical rat carcinogens (Poland and Knutson, 1982a). However, in long
term human TCDD exposure over 50% of fecal label has been reported to be TCDD-metabolites (Wendling et.al,,
 1988), thereby not ruling  out the possibility of tumor initiators being generated [over  long periods] in man.

The relationship of  TCDD cellular  actions is known to be related to a specific  cytosolic receptor protein Ah,
which binds tightly to TCDD, Kd » 0,3 * 10"f M~l. The receptor-ligand  complex is thought to initiate and
promulgate many of the pleiotropic cellular effects of TCDD including wasting of some tissues and hyperplasia
 in others (Poland and  Knutson, 1982). One of the most characteristic TCDD-induced  biochemical events is a
 rapid  increase in P-450 enzymes. This event leads to an important observation: pretreatment of animals  with
TCDD can abrogate subsequent cancer responses from known carcinogens (DiGiovanni et al,, 1980).  Also
interesting, and perhaps related, is the TCDD-related suppression of tumors in the pituitary, pancreas, thyroid,
uterus, mammae, and adrenals. Such tumor incidence suppressions are likely to be related to TCDD ** hormonal
influences in these tissues. Neither of these negative carcinogenic influences caused by TCDD have been factored
into the hazard evaluation of TCDD in any risk assessment to date.

Evidence is continuing to build from  a number of laboratories that TCDD affects the adrenals and thymus
(Greenlee et at., 1985), thyroid (Rozman et a/., 1984; Henry arid Gasiewicz, 1987; Romkes, et al., 1987), estradiol-
(Umbriet et al., 1988)  glucocorticoid  and cholesterol-producing systems, as well as epidermal growth factor
cellular  activity (cf. Greenlee ei  at.,  1987, and references therein). It has been suggested that (1) there is a

-------
 relationship of the TCDD Ah receptor protein function to the steroid and thyroid receptor protein functions, and
 (2) the relationship may be due (in part) to sequence homology among these receptors (Evans, 1988). There are
 no cross-bindings of these ligands among the other systems'reccptors. The sharing of a common motif among the
 essential receptor proteins indicates a superfamily of receptors which coordinate major cellular systems (Green
 and Chambon, 1986). TCDD may cause its pleiotropic effects by perturbing the superfamily gene expression by
 interaction with each of the various hormone-receptor reaction sequelae at their respective functional sites in
 chromatin.

 Given the hormonal relationships of TCDD to cancer (at least in animal test systems), we postulate that TCDD
 is a hormonal carcinogen. TCDD may be unique in its close association with so many essential organismic control
 systems, and might  be expected to act in a hormonal-like fashion. Moreover, the tight hormone-like binding to
 the Ah receptor may relate to the supreme cancer potency estimate for TCDD. As a comparative example,
 estimated cancer potency [to humans, units are in  (mg/kg/day)"1] based on rodent positive tests are: TCDD
 (156,000), aflatoxia BI (2,900), ethylene dibromide (41), benz[a]pyrene (11.5), bis-(2-chloroethyl)-ether (1.1),
 DDT/DDE (0.34), vinyl chloride (0.017), and methylene chloride (0.008). Part of this extreme potency is no doubt
 due to the accumulation of this mctabolically stable compound. Lastly, the carcinogcnicity effects of TCDD in
 hormonal organs are also expected to be influenced by the interplay hormonally among the  interactive target
 systems, i.e. direct TCDD effects in one target affect a second target [in  part] by disturbance of homeostasis
 between the targets.

 We conclude: the bioassay data designate TCDD as a  total carcinogen, which can participate in tumor promotion
 assays so as to  complete the carcinogcnicity action started by other carcinogens. TCDD is unique  in its  supreme
 cancer potency and  close functional relationships with a number of key hormonal regulation systems. Inference
 to other hormonal actions suggests that TCDD may also mechanistically show a threshold, which  would suggest
 that the traditional  assumption made with all carcinogens that there is a finite positive chance of cancer from
 even at one molecule of exposure (some 15 orders of magnitude lower than total body burden of TCDD) may not
 be  the correct assumption to make in the case of TCDD. The  existence of a  threshold  has  not yet  been
 demonstrated and further work on TCDD dosimetry  needs to be done to properly assess the carcinogenic hazard.

 We think the uniqueness of this compound offers an excellent investigative tool for hormonal carcioogenicity
 mechanisms. The derivation of risk from human exposure, using quantitative modeling should take into account
 the qualitative biological concepts discussed here: complete carcinogenicity, presumptive nongenotoxicity or
 mutation, probable  dose-rate limitation at low doses, and hormonal systems interactions.
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                                    TECHNICAL REPORT DATA
                             (Please read Instructions ,6'n Mf reverse before completing}
1. REPORT NO.
 EPA/600/D-90/Q06
4. T.ITJLE AND SUBTITLE
                               2,
  Analysis of 2,3,7,8-TCDD Tumor  Promotion Activity
  and  its Relationship to Cancer
              6, ee«FgR(YHNG ORGANIZATION (ODDE

                 E'PA/bod/021"
              3,
                        J
              §, .B.E.P.QPT'PATE
                    March:. 1990
7. A,yT,HQR.
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