UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C. 20460
EPA-SAB-EHC-,9t-QQ8                                     OFFICE OF
^jr«. O«.D i^rn_  *«                                       THE ADMINISTRATOR
April 2.9, 1991

Honorable William K. Reilly
Administrator
U.S. Environmental Protection Agency
401 M Street, S.W,
Washington, D.C. 20460

Subject: Science Advisory Board's review of the office of Research and
Development document Interim Methods  forDevelopment of  Inhalation
Reference Concentrations  (EPA/600/8-90/066,  August 1990}

Dear Mr. Reilly:

     Inhalation Reference Concentrations (RfC) were developed to serve
as a basis for health risk estimates for non-cancer effects (analogous
to the Agency's  Reference Dose (RfD)  for orally  ingested  toxicants)
resulting  from  exposure to airborne  pollutants.   It  is  anticipated
that RfCs will be used for Clean Air Act regulatory activities  as a
part of  the determination of negligible and residual risk  for  non-
cancer health effects of air toxics.

      The methodology  to  calculate inhalation RfCs follows  the  oral
Reference  Dose  paradigm,  with  an added emphasis  on portal-of-entry
considerations of  comparative  toxicity and  inhalation dosimetry for
particles and gases.  A draft of the interim methodology was reviewed
at a public peer-review workshop in October, 1987 and the methodology
has since been reviewed and implemented by  the Agency's  RfD/RfC work
group.   It  was  intended to review and update the methodology as the
state-of-the-art  progressed.    Now that  RfC values  are  being  made
available  to  the public  on the  Integrated Risk  Information System
(IRIS), and in anticipation of their aforementioned role in regulatory
support, the EPA Office of Research and Development requested an SAB
review in  order  to incorporate further expert opinion and recommen-
dations on  improving the  interim methodology.

     In  response  to  this   request,  the  SAB Environmental Health
Committee  (EHC)  met on October 26,  1990  in Arlington, Virginia to
receive briefings on the RfC methodology from Agency staff.
                                                            Printed on Recycled Paper

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     The following  issues,  comprising the Charge to  the Committee,
were discussed and are dealt with fully in the accompanying report:

     1.  Does the  methodology  utilize appropriate dosimetric ex-
         trapolations for particles and gases, respectively?

     The Committee found the extrapolations and other factors used
to be reasonable and well founded.  Some specific suggestions for
improvement are provided in the report.

     2.  Should  the same uncertainty factors  be used when dosi-
         roetric adjustments are incorporated?

     Current methods for assessing  the  Reference Dose (RfD) call
for applying an uncertainty factor of  10 to compensate for extrap-
olation  from animal data to human data.   The proposed inhalation
Reference Concentration methods are far more detailed in estimating
respiratory exposure and, in fact, adjust for  differences  in inter-
species dosimetry.  The importance and accuracy of that adjustment
is highly variable among compounds and among biological endpoints.
Clearly the use of more precise methods should not be discouraged
by applying the same uncertainty  factors that would be applied to
more general methods, but a general statement  about the appropriate
uncertainty factor is riot possible,  other than to state that this
factor should be smaller with  improved data and understanding.

     Dealing with this  issue could also be aided by a more detailed
articulation of the intent of the various  uncertainty  factors.  An
understanding of  the various  uncertainties  for  which a specific
factor is designed to compensate would allow a better evaluation of
the influence of increased information on  an  uncertainty  factor.

     3.  Are the  concepts  and applications  of the  methodology
         clearly articulated in its documentation?

     The Committee believes that 1PA Staff did an excellent job in
defining and explaining a sophisticated approach to a complex prob-
lem.   Specific  observations for improving or clarifying the text
have been forwarded to the  appropriate EPA staff.

       4.  Is the research intended to support the methods appro-
          priate for improving risk extrapolation procedures?

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     Suggestions  for  further research  are  given throughout  the
document.  In some cases these are explicitly mentioned; in others
they are inferred.   It would be preferable to provide a special
section outlining research needs and suggestions.

     Overall, the  Committee  finds the referenced document  to be
useful and comprehensive.  It advances  considerably the previous
approaches for calculating reference doses for inhaled toxicants.
The Committee is  concerned,  however,  about  the  emphasis given to
the "No  Observed  Adverse  Effects Level  (NQAEL)  plus uncertainty
factor" approach,  especially  in  view of the SAB's past urging that
alternative methods, such  as  the benchmark approach  (A statistical
approach for deriving RfC or RfD, based on the entire set of rel-
evant dose-response data,not  only the NGAEL/LQAEL points.  The low-
er ten percent  confidence limit sets the RfC or RfD value,), be
applied to the raw data.  The draft document discusses the bench-
mark approach in Appendix  A,  but refers to this and other methods
as "Novel."  We  consider these approaches to  be alternative, and in
some cases, more desirable, methods.

     Also,  the  Committee  wishes to  stress that  there can be con-
siderable differences in the extent of information available,  and
in toxicity mechanisms for various toxicant-endpoint combinations.
This situation gives rise to two additional suggestions:

     (1) When the subject interim document is revised, we propose
         that its title be changed to identify the approaches set
         forth as guidelinesf not fixed "cookbook formulas," thus
         retaining  flexibility needed  to deal with varying toxi-
         cants and conditions,

     (2) Given the need to accommodate knowledge for specific toxi-
         cants,  the Committee believes that  it would be useful for
         the SAB to  review some toxicant-specific derivations of
         the RfC.   This would increase  our understanding  of the
         overall methodology and  its data base requirements,  and
         enhance our ability  to  review the dosimetric adjustments.

     Finally, the  Committee would  appreciate  learning of  the
Agency's plans and schedule to revise the current  interim document.
We stand ready to  review the  specific applications noted above, as
well as a future revision of the document itself.

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     The  Science Advisory  Board  is  pleased  to  have  had  the
opportunity to review the draft document and to offer its advice.
We would  appreciate your response  to the  major points we  have
raised.
                                   Dr. Raymond Loehr, Chairman
                                   Science Advisory Board
                                   Dr. Arthur Upton, chairman
                                   Environmental Health Committee
ENCLOSURE

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  SEPA
US, Snviromwnttl            Washington, DC
protection Agtiwy
    REPORT OF THE ENVIRONMENTAL
          HEALTH COMMITTEE
   REVIEW OF THE OFFICE OF RESEARCH
 AND DEVELOPMENT'S DRAFT DOCUMENT
  "INTERIM METHODS FOR DEVELOPMENT
       OF INHALATION REFERENCE
           CONCENTRATIONS"
   (EPA/600/8-90/066, AUGUST, 1990)
A SCIENCE ADVISOW BOARD R6PCW                         Apra- '"1

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                              ABSTRACT

     Inhalation  Reference  Concentrations  (RfCs)  were developed  to
serve as  a basis for  health risk estimates for  non-cancer effects
(analogous to the oral Reference Dose (RfD))  resulting from exposure
to airborne pollutants.   On October 26,  1990,  the  Science Advisory
Board (SAB) reviewed the methodology for development  of inhalation Rfc
values (as described in the document  "Interim Methods for Development
of Inhalation  Reference Concentrations,"  (EPA/6QQ/8-90/Q66,  August
1990), as requested by  EPA's Office of Research and Development.

     The Committee found the proposed methods for deriving RfCs to be
reasonable, although some  specific improvements,  such  as the use of
the benchmark dose  in  place of  the No  Observed Adverse Effects Lev-
el/Lowest Observed Adverse  Effects Level (KOAEL/LOAEL), were proposed.
Methods to determine RfCs should retain flexibility to accommodate the
specific information and characteristics of various toxic substances,
and could incorporate a tiered approach in which simpler methods are
applied before the more sophisticated methods defined in the documents
reviewed are used.

Keywords:  RfC;  Inhalation  Reference Concentration;  Benchmark dose;
Dosimetry? Methodology.

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               0. S. ENVIRONMENTAL PROTECTION AGENCY

                               NOTICE

     This report has been written as a part of the activities of the
Science Advisory Board, a public advisory group providing extramural
scientific  information and  advice  to the  Administrator and  other
officials  of  the  Environmental  Protection  Agency.    The Board  is
structured  to provide balanced,  expert assessment  of  scientific
matters related to problems  facing  the Agency.   This  report  has not
been reviewed for approval by the Agency and, hence,  the contents of
this report do not necessarily represent the views and policies of the
Environmental  Protection  Agency,   nor   of   other agencies  in  the
Executive Branch, of the Federal government,  nor does mention of trade
names or commercial products constitute a recommendation for use.

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                     U.S* ENVIRONMENTAL PROTECTION AGENCY
                            SCIENCE ADVISORY BOARD
                    ENVIRONMENTAL HEALTH COMMITTEE MEETING

                               October 26, 1990
ACTING CHAIRMAN
or. Ronald Wyzga
    Electric Power Research
     Institute

MEMBERS, & CONSULTANTS

Dr. Mel Anderson
    Chemical Industry Institute of
     Toxicology

Dr. David Gaylor
    Department of Health & Human
     Services
    Food and Drug Administration,
    National Center for
     lexicological Research

Dr. Marshall Johnson
    Professor, Department of Anatomy
    Jefferson Medical College

Dr. Fred Miller
    Duke University Medical Center

Dr.  Richard Monson
     Harvard School of Public
      Health
Dr. D, Warner North
    Principal, Decision Focus
     Inc.

Dr. Guenter Oberdoerster
    Radiation Biology and
     Biophysics Division
     University of Rochester
    School of Medicine
Dr. Martha Radike
    Department of Environmental
     Health
    Medical Center, University
     of Cincinnati

Dr. Bernard Weiss
    Professor, Division of
     Toxicology
     P.O. Box RBB
    University of Rochester,
     School of Medicine
Mr. Samuel Rondberg
    Science Advisory Board
     (A101F)
    U.S. Environmental
      Protection Agency
    Washington, D. G.   20460
    (202) 382-2552}
    FAX-(202) 382-9693

STAFF SECRETARY
Ms. Mary L. Winston
    Environmental Protection
     Agency
    Science Advisory Board
     (A101F)
    Washington, D,C»  20460
    (202) 382-2552
     FAX-(202) 382-9693

STAFF PIRECTOR
Dr. Donald G, Barnes
    Environmental Protection
     Agency
    Science Advisory Board
    401 M Street S.W.,  (AlOl)
    Washington, D.c.   20460
                                      111

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                                 TABLE OF CONTENTS


L.0    Executive  Summary   .,»,,....  	  ......     1
l.Q    Introduction   ................  	  .  .     3
J, 0    Detailed Charge    ...,»,	     5
1.0    Findings   ......  	  ....  	  ........     6
            4.1  Overall  Findings   	  .............     6
            4.2  Appropriateness of dosimetric extrapolations   ....     7
            4.3  Appropriate uncertainty  factors  .....  	  .     8
            4.4  Is the document clearly  articulated?   ...  	     9
            4,5  Appropriateness of suggested research  ...  	     9
5.0   Conclusions and Recommendations	    10

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                       1*0    Executive summary

     Inhalation Reference Concentrations (RfCs)  were developed to
serve as health risk estimates for non-cancer effects  (analogous to
the  oral Reference Dose (RfD)) resulting from exposure to airborne
pollutants.   The RfC  is  an estimate (with uncertainty spanning
perhaps an order of magnitude)  of a  daily  inhalation exposure to
the human population (including sensitive subgroups) that is lively
to be without an appreciable risk of deleterious non-cancer effects
daring a lifetime,

     SAB review of the methodology for  development of inhalation
RfC  values,  as described  in the document "Interim  Methods  for
Development  of Inhalation  Reference  Concentrations," (EPA/600/8-
90/066, August 1989) was requested by  EPA's Office of Research and
Development in order to incorporate further expert opinion and rec-
ommendations  on  the methodology,  as well  as suggestions  for its
improvement.

     The Committee finds the proposed methods for deriving RfCs to
be reasonable, although some specific improvements,  such  as the use
of the benchmark dose  in place of the No Observed Adverse Effects
Level/Lowest Observed  Adverse Effects Level (NOAIL/LOHEL) , are pro-
posed*   Methods  to determine  RfCs should  retain  flexibility to
accommodate the specific information and characteristics  of various
toxic substances, and  could incorporate  a tiered  approach in which
simpler methods are applied before the more sophisticated methods
defined in the documents reviewed are employed.

     The Committee recommends review of RfC derivations for several
specific chemicals that illustrate each of the dosimetric adjust-
ments, demonstrate inadequate data bases for derivation ("not veri-
fiable"  status)  or represent difficult  scientific  issues (e.g.,
sensitizing  agents like toluene diisocyanate)."

     The Committee also notes that:

           l.  The magnitude of uncertainty  factors used  for a spe-
              cific agent should   decrease  as more data are incor-
              porated  into a given RfC assessment.

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2. A clear articulation of the definition and intent of
   the various uncertainty factors is needed.

3. Research needs are not clearly described.   A special
   section or report should be drafted to detail these
   needs.

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                           2.0
     The Clean Air  Act Amendments (CAAA) recently passed  by the
Congress identifies  189 substances and classes of chemicals, which,
if emitted at specified quantities (10 or more tons of a specific
substance, or 25 or more tons  of  of  several chemicals) ,  are sub-
jected to Maximum Achievable Control Technology  (MACT) *  Additional
chemicals may be listed, and  listed chemicals may be delisted, de-
pending on health risks.   In addition,  the CAAA require emitting
sources to demonstrate that,  based on health  risk estimates, only
negligible risks (and no residual  risk) exist after implementation
of control technology. Inhalation Reference Concentrations (RfCs)
have been developed to serve as   base-line health risk estimates
for non-cancer effects (analogous to the Agency's Reference Dose
(RfO) for  orally  ingested  toxicants) resulting  from exposure to
airborne pollutants.   The RfC is an estimate  (with uncertainty
spanning  perhaps  an  order of  magnitude) of  a  daily inhalation
exposure in the human population  (including  sensitive subgroups)
that is  likely  to be without  an  appreciable risk of deleterious
non-cancer effects during a lifetime.  It is anticipated that RfCs
will be  used for CAAA regulatory activities  as  a  part  of the
determination  of list ing/del ist ing   decisions,  lesser  quantity
cutoffs, and  residual risk for non-cancer health  effects  of air
toxics.   Additionally, regional,  state  and  local air  pollution
control offices have begun  to utilize RfC values in risk management
programs .

      The  inhalation  RfC  methodology follows the  oral  Reference
Dose  (RfD)  paradigm  with  an  added  emphasis on portal-of-entry
considerations of comparative toxicity and inhalation  dosimetry for
particles  and gases.    Extrapolation modeling  has been used to
derive factors that have been  incorporated in  the methodology to
adjust exposure concentrations for dosimetric differences between
experimental  animal species  and humans.   A draft  of the interim
methodology  was reviewed  at  a   public  peer-review   workshop  in
October, 198? and has since  been  reviewed and  implemented by the
Agency's  RfD/RfC  work group.   The  methodology was  interim and
intended  to  be  reviewed  and  updated  as  the  state-of-the-art
progressed.  Since the RfC values are now being made available to
the public on the Integrated Risk Information  System (IRIS) , and
anticipating their aforementioned role in regulatory support, the
EPA Office of Research and Development requested an SAB review to

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receive further expert opinion and recommendations on improving the
methodology.

     In response  to  this  request,  the SAB  Environmental Health
Committee (EHC) met on  October  26,  1990 in Arlington Virginia to
receive briefings on the RfC methodology from Agency staff, discuss
the issues devolving from the Charge to the Committee  (see follow-
ing) , and to initiate development of a report responding to these
issues.  Dr. Ronald Wyzga  served  as Chair,  in the absence of Dr,
Arthur Upton,

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                      3.0
     The SAB was requested to review the methodology for develop-
ment of  inhalation Rfc estimates,  as described in  the document
"Interim  Methods  for  Development of  Inhalation Reference  Con-
centrations,"  (EPA/6QQ/8-90/Q66,  August  1990)  and  its associated
documentation, Appendix B to the IRIS  (essentially  an executive
summary to the methodology which also serves as a quick reference
for the calculations) .  Key issues for the review were:

     1*  Does the methodology utilize appropriate dosimetric ex-
         trapolations for particles and gases, respectively?

     2.  Should  the same  uncertainty factors be used when dosi-
         metric adjustments are incorporated?

     3.  Are  the concepts  and  applications  of the methodology
          clearly articulated in its documentation?

     4,  Is the intended research  to support the methods appropri-
         ate to improving risk extrapolation procedures?

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                            4.0   Findings

4.1  Overall Findings  The  document  is useful and comprehensive,
and it advances considerably the previous approaches for deriving
reference  concentrations for  inhaled toxicants.   The  proposed
dosimetric adjustment  factors  are  relatively sophisticated,  how-
ever, and require the development and consideration of significant
quantities of detailed  information; often information at this level
of detail may be  incongruent with some of the cruder aspects of the
methodology, e.g., the application of roughly defined uncertainty
factors  to  numbers of several  significant  digits.     The Agency
should give consideration to the development of an iterative ap-
proach, in which  simpler methods are first applied? only when human
exposures appear  to  be significant,  given these initial results,
would more detailed methods then be considered.  The Committee is
also concerned about the emphasis given to the  "NOAEL  plus un-
certainty  factor"  technique,  despite the SAB's  past  urging  that
alternative approaches, such as the benchmark method1, be applied
to the  raw data2.   The  draft  Document  discusses  the bench-mark
method in Appendix A,  but refers to  this and other approaches as
"Novel,"   We believe these approaches to be alternative,  and in
some cases, more desirable,  methods.

     The proposed methods emphasize the importance of the effect of
cumulative dose (concentration x time)  on response.  Although this
emphasis may be reasonable for many toxicant-endpoint combinations,
the Committee cautions that there  are many  known examples in the
literature when  this assumption is not  correct  and urges flexi-
bility in utilizing alternatives to the cumulative dose concept.

     The methods  should  recognize  that there can be considerable
differences in  the extent of information available, and in toxicity
mechanisms for various toxicant-endpoint combinations.   This re-
quires flexibility in  the methods.  Given the need to accommodate
knowledge for specific toxicants,  the Committee believes it would
     1 A statistical approach for deriving Rfc or RfD, based on the
entire set of relevant dose-response data,not only the NQAEL/LQAEL
points.   The lower ten percent confidence limit sets  the RfC or RfD
value.

     2 SAB Report  "Comments on The Use  of Uncertainty and Modifying
Factors in  Establishing Reference  Dose Levels," EPA-SAB-EC-005,
January 17, 1990

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be useful for the SAB to review some toxicant-specific derivations
of the RfC.  This would increase our understanding of the overall
methodology and its data base retirements and enhance our ability
to review the dosimetric adjustments.

     The methods should also more explicitly communicate the degree
of uncertainty associated with the derivations of the various RfCs.
Factors which could  be so  addressed  might include issues such as
the validity of the RfG to particles of different sizes, changes in
assumptions  about breathing mode,  applicability  of  results  for
children, differences in alternative lung deposition models,  and
whether deposited  dose should be normalized  on the basis of lung
surface area or per graw of lung  tissue.  It would be desirable to
use 95% confidence intervals for  deposition of particles to derive
a similar 95% confidence interval for RfCs.   In addition, several
sizes  of  particles could  be grouped together rather  than being
detailed so  specifically as in the draft document*  For example,
particle  sizes  could be categorized in a number  of appropriate
ranges, based on their aerodynamic size.  Finally,  the role of, and
assumptions  about, clearance should also be discussed  in more
detail.

4«2  appropriateness of dosimetric extrapolations   Overall, we find
the methodology to be reasonable.  There are some areas, however,
where  improvements can be  made.   For example,  it  is assumed that
there are linear relationships between breathing parameters used to
derive the Regional Retained Dose Ratios (RDDR) and other sets of
breathing parameters. The  proposed method also assumes that  all of
a gas inspired goes to the  region of  concern.  This simplification
could  be  improved by having available two uptake values for the
gas, one  where only physical absorption is  assumed,  and another
where  instantaneous  chemical  reactions  are  assumed.   These two
values would then  define bounds  for  the deposition of the gas.

     The methodology might also take  note of the fact that there is
a close  continuum between ultrafine particles and gases.  This
"continuity" may suggest ways to  modify the gas approaches in order
to address ultrafine particles.

     In the case of the many inhaled chemicals which  impact  organs
other than the  lung, toxicity is sometimes related to metabolites
of the chemicals, rather  than the inhaled  chemicals themselves.
Application of physiological-biological and pharamacokinetic models

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in these cases will require detailed information on the nature of
the mechanisms  of action  for  the specific chemical  of concern.
Methods should be  sufficiently flexible to allow more sophisticated
pharmacokinetic modeling to be incorporated when required.

     The Committee  also notes  that a  new set of  physiological
parameters  (e.g., lung  volumes and  breathing  rates)  is to  be
published  in   the   International  Committee   for   Radiological
Protection   Reference Manual.   These up-dated values  should  be
incorporated into the methodology.

<«3  Appropriate uncertainty factors  The oral Reference Dose (RfD)
paradigm, on which this proposed methodology is based,  applies
(generally)  ten-fold uncertainty factors to account for uncertain-
ties engendered by the various extrapolations performed to arrive
at daily human exposure estimates from the available experimental
data.  The proposed  Inhalation Reference Concentration methods are
far more detailed in estimating respiratory exposure and, in fact,
adjust for differences  in  inter-species dosimetry as far as dep-
osition  is concerned.   The  importance and accuracy  of  that  ad-
justment is  highly variable  among compounds  and among biological
endpoints.   Clearly the use of more precise methods should not be
penalized by applying the  same  uncertainty factors  that would be
applied to more general  methods,  but a  general statement about the
appropriate  uncertainty factor  is not  possible,  other  than  to
expect that  improved data and understanding of uptake, as opposed
to intake, should lead to smaller uncertainty factors.  In general,
there will be less uncertainty  associated with the  dose  to  the
respiratory  region than to organs outside  the respiratory tract;
for that reason,  the uncertainty factors associated with respira-
tory effects would in general be smaller than those associated with
effects in the more distal organs.

     Dealing with this issue could also be aided  by a more detailed
articulation of the intent of the various uncertainty  factors.  An
understanding of  the various uncertainties for which a specific
factor is designed to compensate would allow a better evaluation of
the influence of  increased information on  an uncertainty factor.
An alternative  scheme that does  not  require  uncertainty factors
might  use   the  benchmark   dose  variant  to  calculate  risk
specifically.
                                8

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4.4  Is the damim^ttt; clearly articulated?  The Committee believes
that EPA Staff did an  excellent  job  in defining and explaining a
sophisticated approach to  a coaplex problem.   Many specific de~
tailed observations for improving or  clarifying  the text were made
by Committee members; these have  been forwarded  to the appropriate
EPA Staff.  Other considerations are addressed above.

4*5  Appropriateness  of suggested research  Suggestions for further
research are given throughout the document.   In some cases these
are explicitly mentioned; in others they are inferred. It would be
preferable to provide  a special  section outlining research needs
and  suggestions.   The research suggested  should  include  ways to
address many of  the  uncertainties raised  by  the  Committee,   The
Committee does, however, wish to indicate  that  in some cases re-
quired research will be compound-specific; the report should ack-
nowledge  the need for this research  as  well  for  more  generic
methods research.

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     The  proposed methods  to derive  Inhalation Reference  Con-
centrations are reasonable,  although  some specific improvements,
such as the use  of the benchmark dose  (or  other alternative ap-
proach) in place  of  the NQAEL/LOA1L,  have been  proposed.   It is
important that the methods to determine RfCs retain flexibility to
accommodate the specific information and characteristics of various
toxic substances  (in  light of this, future iterations of the inter-
im methods document could be entitled as "Guidelines" to reinforce
the idea that  the methods are not  "cookbook formulas").  The meth-
ods could also incorporate a tiered approach in which simpler meth-
ods are applied before  the  more  sophisticated methods  defined in
the documents  reviewed are utilized.  Also, a  review of the appli-
cations of the proposed RfC methods for several specific chemicals
would facilitate  the  evaluation of these methods,  and the Committee
would be pleased to assist in such reviews.

     The Committee also notes that?

       1. In general, as the amount of scientific information in-
          corporated into RfC determination increases,  the magni-
          tude  of the overall uncertainty factor, applied in the
          RfC derivation, should decrease.

       2. A clear articulation of  the definition  and intent of the
          various uncertainty factors is needed.   This would help
          define  the correct  uncertainty factors to be used for
          RfCs.  A review of RfC estimates that illustrate the dif-
          ferent dosimetric adjustments and that illustrate the use
          of different uncertainty factors (e.g.,  laboratory animal
          to  human,  subchronic  to chronic,  LQAEL to NOAEL, etc.)
          would aid in the formulation of  any  recommendations con-
          cerning the uncertainty factors.

       3. The methodology  is reasonably well described.  The in-
          clusion of case studies  for specific toxicants, as noted
          above,  would  improve this description.

       4. Research  needs are  not clearly described.  A special
          section  or report  should  be drafted to detail these
          needs.
                                   10

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The detailed RDDR tables in Appendix M of the draft doc-
ument provide an inappropriate sense of precision by dis-
playing four significant figures after the decimal point.
The tables should be revised to display less detailed da-
ta,  perhaps giving ranges of particle  sizes and RDDRs
generated with other deposition models.
                         11

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