Response to Peer Review Comments on the Draft Human
Health Toxicity Values for
Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its
Ammonium Salt (CASRN 13252-13-6 and CASRN 62037-
80-3)
Also Known as "GenX Chemicals"
EPA Document Number: 823-R-18-003
November 2018
Prepared by:
U.S. Environmental Protection Agency
Office of Water (4304T)
Health and Ecological Criteria Division
Washington, DC 20460

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Response to Peer Review Comments-GenX Chemicals
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CONTENTS
ACRONYMS	3
INTRODUCTION	5
SECTION I: TECHNICAL CHARGE TO EXTERNAL REVIEWERS	7
BACKGROUND	8
REVIEW MATERIALS PROVIDED BY THE EPA	9
CHARGE QUESTIONS	9
REFERENCES	10
SECTION II: REVIEWER COMMENTS ORGANIZED BY CHARGE QUESTION	12
CHARGE QUESTION 1	13
CHARGE QUESTION 2	17
CHARGE QUESTION 3	21
CHARGE QUESTION 4	22
CHARGE QUESTION 5	25
CHARGE QUESTION 6	28
CHARGE QUESTION 7	31
SECTION III: RE VIEWER ADDITIONAL AND EDITORIAL COMMENTS	34
APPENDIX A: INDIVIDUAL REVIEWER COMMENTS	A-l
Karen Chou, PhD	A-2
Lisa M. Kamendulis, PhD	A-6
Angela M. Leung, MD	A-l 1
Angela L. Slitt, PhD	A-16
David Alan Warren, MPH, PhD	A-21
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ACRONYMS
Please note that acronyms are not consistently defined throughout this document, as much of the text
was extracted in its original format from charge questions and reviewer comments. Please refer to
the table below for acronym meanings, when needed.
BMD	Benchmark dose
BMDL	Benchmark dose lower limit
BMR	Benchmark response
CASRN	Chemical Abstracts Service Registry Number
DAF	Dosimetric adjustment factor
EPA/USEPA U.S. Environmental Protection Agency
FIFRA	Federal Insecticide, Fungicide, and Rodenticide Act
GLP	Good Laboratory Practices
HED	Human equivalent dose
HERO	Health & Environmental Research Online
HFPO	Hexafluoropropylene oxide
hL-FABP	Human liver fatty acid-binding protein
ICR	Institute of Cancer Research
LOAEL	Lowest-observed-adverse-effect level
mg/kg/day	Milligrams per kilogram per day
MO A	Mode of action
NOAEL	No-observed-adverse-effect level
OECD	Organization for Economic Cooperation and Development
OPPT	Office of Pollution Prevention and Toxics
PFAS	Per- and polyfluoroalkyl substances
PFOA	Perfluorooctanoic acid
POD	Point of departure
PODhed	Point of departure human equivalent dose
PPARa	Peroxisome proliferator-activated receptor alpha
RfD	Reference dose
T1/2	Half-life
TG	Test guideline
TSCA	Toxic Substances Control Act
TSCATS1	Toxic Substances Control Act Test Submissions 1
UF	Uncertainty factor(s)
UFa	Interspecies uncertainty factor
UFd	Database uncertainty factor
UFh	Intraspecies uncertainty factor
UFl	LOAEL to NOAEL extrapolation uncertainty factor
UFs	Extrapolation from subchronic to a chronic exposure duration uncertainty factor
WOE	Weight of evidence
WOS	Web of Science
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INTRODUCTION
This document was prepared under the EPA Contract No. EP-C-17-017, Task Order 0008 with
Eastern Research Group, Inc. Five independent external peer reviewers reviewed the draft
assessment, and their comments are presented with the EPA's responses. Appendix A includes the
full comments from the reviewers.
The EPA is issuing draft subchronic and chronic oral toxicity values (i.e., RfDs) for HFPO dimer
acid and its ammonium salt (CASRN 13252-13-6 and CASRN 62037-80-3)—or "GenX chemicals'
for public comment. The EPA is publishing these toxicity values to facilitate future decision-making
by the Agency's Programmatic, Regional, and/or State partners associated with contamination
concerns in a variety of exposure scenarios when they are finalized. The EPA developed this toxicity
assessment to provide the health effects information used as the basis for derivation of these RfDs
for GenX chemicals.
The database used to derive these RfDs for HFPO dimer acid and its ammonium salt includes oral
animal toxicity studies of acute, short-term, subchronic, and chronic duration in rats and mice.
Available information identifying health effects from inhalation or dermal exposures to GenX
chemicals in animals is limited. Repeated-dose toxicity data are available for oral exposure, but not
for the other exposure routes (inhalation and dermal exposures). Thus, this assessment applies only
to the oral route of exposure. Two studies were available: one oral reproductive and developmental
toxicity study in mice and one prenatal developmental toxicity study in rats. These studies report
liver toxicity (increased relative liver weight, hepatocellular hypertrophy, and single-cell necrosis),
kidney toxicity (increased relative kidney weight), immune effects (antibody suppression),
developmental effects (an increased number of early deliveries and delays in genital development),
and cancer (liver and pancreatic tumors). Overall, the available toxicity studies demonstrate that the
liver is particularly sensitive to toxicity induced by HFPO dimer acid and its ammonium salt.
The critical study the EPA chose for determining the subchronic and chronic RfDs for HFPO dimer
acid and/or its ammonium salt is the oral reproductive/developmental toxicity study in mice, with a
NOAEL of 0.1 mg/kg/day based on liver effects (single-cell necrosis in males) (DuPont-18405-
1037, 2010). Following EPA guidance, the resulting PODhed is 0.023 mg/kg/day. UF applied
include a 10 for intraspecies variability, 3 for interspecies differences, and 3 for database
deficiencies, including immune effects and additional developmental studies, to yield a subchronic
RfD of 0.0002 mg/kg/day. In addition to those UF, a UF of 3 was also applied for extrapolation from
a subchronic to a chronic duration in the derivation of the chronic RfD of 0.00008 mg/kg/day.
Overall, the peer reviewers agreed with the EPA's decisions regarding the:
•	Choice of critical study
•	Choice of critical effect
•	BMD modeling
•	Determination of a HED dose using body weight scaling
•	UF application
•	Cancer classification
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The peer reviewers made several clarifying comments. Specifically, they asked for additional
clarification on the:
•	Justification of the UFa
•	Selection of studies for dose-response modeling
•	Blood effects as a potential critical adverse endpoint
•	Kidney hazard identification and additional clinically relevant endpoints
•	Chronic study reanalysis and female liver tumors
•	Systematic review procedures
Minor comments and editorial suggestions were reviewed and are addressed directly in this
document. Specific responses to major comments are provided under each respective
section/question.
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SECTION I: TECHNICAL CHARGE
TO EXTERNAL REVIEWERS
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Technical Charge to External Peer Reviewers
Contract No. EP-C-17-017
Task Order 0008
June 2018
External Peer Review of EPA's Draft Human Health Toxicity Assessment
for GenX Chemicals
BACKGROUND
The EPA is issuing subchronic and chronic toxicity values (i.e., RfDs) for 2,3,3,3-tetrafluoro-2-
(l,l,2,2,3,3,3-heptafluoropropoxy)propanoic acid (CASRN 13252-13-6)—or HFPO dimer acid—
and 2,3,3,3-tetrafluoro-2-(l,l,2,2,3,3,3-heptafluoropropoxy)propanoate (CASRN 62037-80-3)—or
HFPO dimer acid ammonium salt. HFPO dimer acid and its ammonium salt are collectively referred
to as "GenX chemicals" because they are the two major chemicals associated with the GenX
processing aid technology.
The EPA developed toxicity assessment of GenX chemicals to provide the health effects information
used as the basis for derivation of RfDs. The toxicity assessment identifies and characterizes the
health hazards of these chemicals and includes information to address the first two steps of the
human health risk assessment paradigm: hazard identification and dose-response assessment. The
EPA is publishing these toxicity values to facilitate decision-making by the Agency's Programmatic,
Regional, and/or State partners associated with contamination concerns in a variety of exposure
scenarios.
This document was developed by building on previously completed assessments. Specifically, the
EPA assessed the toxicity of HFPO dimer acid and its ammonium salt in 2008 under the TSCA.
Most of the available data were submitted to the EPA by DuPont/Chemours, the manufacturer of
these chemicals, under TSCA, as required pursuant to a consent order (USEPA, 2009) or as required
under TSCA reporting requirements (e.g., section 8(e)). The EPA evaluated all toxicokinetic and
repeat-dose toxicity studies of 28 days and longer against the EPA OPPT's Application of Systematic
Review in TSCA Risk Evaluations processes.
The submitted studies and literature identified by the search of publicly available sources are
available through the EPA's HERO website1:
https://hero.epa.gov/hero/index.cfm/proiect/page/proiect id/2627. Please see the instructions for
requesting access to HERO if you do not have an active account.
1 Access to full-text references was provided to external peer-reviewers through the HERONet website, an internal
database of bibliographic information and scientific studies. Due to copyright laws/regulations, access to the copyright
protected materials that are stored in the HERONet database are prohibited from public dissemination. However, a list of
all citations and access to publicly available references is provided via the public HERO website
(https ://hero. epa. gov/hero/index. cfm/proi ect/page/proi ect 1(1/26271.
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REVIEW MATERIALS PROVIDED BY THE EPA
•	Draft Human Health Toxicity Values for Hexajluoropropylene Oxide (HFPO) Dimer Acid
and Its Ammonium Salt (CASRN13252-13-6 and CASRN 62037-80-3) Also Known as
"GenXChemicals" (USEPA, 2018)
•	References and supporting documentation (also see appendix A)
o Benchmark Dose Technical Guidance (USEPA, 2012).
o Background references are available on the EPA's HERONet. If you do not have an
active account for HERO, please see the attached instructions for access. Once your
account is active, the URL above will take you directly to the references needed.
CHARGE QUESTIONS
HFPO dimer acid and its ammonium salt or GenX Chemicals
1.	The document describes the process for identifying and selecting pertinent studies. Please
comment on whether the literature search strategy, study selection considerations, and study
evaluation considerations are appropriate and clearly described. Please identify additional
peer-reviewed studies that the assessment should consider.
2.	For GenX chemicals the critical study chosen for determining the subchronic and chronic
RfDs is the oral reproductive/developmental toxicity screening study in adult mice (DuPont
18405-1037, 2010) and the critical effect is liver effects (single cell necrosis) in adult males.
Is the selection of the critical study and critical effect for the derivation of the subchronic and
chronic RfDs for GenX chemicals scientifically justified and defensible?
a.	If so, please explain your justification.
b.	If not, please provide your rationale and detail an alternative critical study and/or
critical effect you would select to support the derivation of the subchronic and
chronic RfDs.
3.	EPA employed benchmark dose modeling in the identification of a point-of-departure (POD)
for GenX chemicals (USEPA 2012). Is the modeling approach, selection of benchmark
response level, and the selected model used to identify the POD for derivation of the RfD
scientifically justified and defensible?
4.	Given what is known and not known about the interspecies differences in toxicokinetics of
GenX chemicals, EPA applied body weight to the 3/4 allometric scaling to adjust the POD to
estimate a human equivalent dose (HED) in the derivation of the respective RfDs (USEPA
2011).
a.	Is applying the body weight to the 3/4 for GenX chemicals scientifically justified and
defensible? If not, please provide your rationale and detail the alternative approach
you would use.
b.	Do the methods used to derive the RfDs for GenX chemicals appropriately account
for uncertainties in evaluating the toxicokinetic differences between the experimental
animal data and humans?
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5.	EPA has evaluated and applied where appropriate uncertainty factors to account for
intraspecies variability (UFh), interspecies differences (UFa), database limitations (UFd),
duration (UFs), and LOAEL-to-NOAEL extrapolation (UFl) for GenX chemicals.
a.	Has uncertainty been adequately accounted for in the derivation of the RfDs? Please
describe and provide suggestions, if needed.
b.	Does the provided scientific rationale support the application of the selected
uncertainty factors? Please explain.
6.	The draft assessment for GenX chemicals identifies liver effects as a potential human hazard.
EPA evaluated the available evidence for liver effects, including the potential role of PPARa,
using Hall et al. (2012) criteria for adversity.
a.	Please comment on whether the available data have been clearly and appropriately
synthesized for these toxicological effects.
b.	Please comment on whether the weight of evidence for hazard identification has been
clearly described and scientifically justified.
c.	Please comment on whether the conclusions regarding adversity are scientifically
supported and clearly described.
7.	The draft assessment concludes that there is suggestive evidence of carcinogenic potential for
GenX chemicals and that this descriptor applies to oral routes of human exposure (USEPA
2005). Please comment on whether the available animal and mechanistic studies support this
conclusion.
8.	Editorial or Additional Comments: Please provide any editorial or additional comments
you would like to make here. These should be any comments that are not in direct response
to the technical charge questions above.
REFERENCES
DuPont-18405-1037: E.I. du Pont de Nemours and Company. 2010. An Oral (Gavage)
Reproduction/Developmental Toxicity Screening Study ofH-28548 in Mice. USEPA OPPTS
870.3550; OECD Test Guideline 421. Study conducted by WIL Research Laboratories, LLC
(Study Completion Date: December 29, 2010), Ashland, OH.
Hall, A.P., C.R. Elcombe, J.R. Foster, T. Harada, W. Kaufmann, A. Knippel, K. Kiittler, D.E.
Malarkey, R.R. Maronpot, A. Nishikawa, T. Nolte, A. Schulte, V. Strauss, and M.J. York.
2012. Liver hypertrophy: A review of adaptive (adverse and non-adverse) changes—
Conclusions from the 3rd International ESTP Expert Workshop. Toxicologic Pathology
40(7):971-994.
USEPA (U.S. Environmental Protection Agency). 2005. Guidelines for Carcinogen Risk
Assessment. EPA/630/P-03/001B. USEPA, Risk Assessment Forum, Washington, DC.
Accessed May 2018. https://www.epa.gov/risk/guidelines-carcinogen-risk-assessment.
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USEPA (U.S. Environmental Protection Agency). 2009. Consent Order and Determinations
Supporting Consent Order for Premanufacture Notice Numbers: P-08-508 and P-08-509.
USEPA, Office of Pollution Prevention and Toxics, Washington, DC. Accessed May 2018.
https://chemview.epa.gov/chemview/proxy?filename=sanitized consent order p 08 0508c.
Edf.
USEPA (U.S. Environmental Protection Agency). 2011. Recommended Use of Body Weight3/4 as the
Default Method in Derivation of the Oral Reference Dose. EPA/100/R11/0001. USEPA, Office
of the Science Advisor, Risk Assessment Forum, Washington, DC. Accessed May 2018.
https://www.epa.gov/sites/production/files/2013-09/documents/recommended-use-of-
bw34.pdf.
USEPA (U.S. Environmental Protection Agency). 2012. Benchmark Dose Technical Guidance.
EPA/100/R-12/ 001. USEPA, Risk Assessment Forum, Washington, DC. Accessed May
2018. https://www.epa.gov/risk/benchmark-dose-technical-guidance.
USEPA (U.S. Environmental Protection Agency). 2018. Draft Human Health Toxicity Values for
Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its Ammonium Salt (CASRN13252-13-
6 and CASRN 62037-80-3) Also Known as "GenX Chemicals. " USEPA, Office of Water,
Washington, DC.
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SECTION II: REVIEWER COMMENTS
ORGANIZED BY CHARGE QUESTION
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CHARGE QUESTION 1
The document describes the process for identifying and selecting pertinent studies. Please
comment on whether the literature search strategy, study selection considerations, and study
evaluation considerations are appropriate and clearly described. Please identify additional
peer-reviewed studies that the assessment should consider.
Chou
The literature search strategy and study evaluation considerations are clearly described and appear to
be appropriate.
The reviewer suggests an additional article by Rakhshandehroo. M.. Knoch. B.. Mullen M.. and
K erst en, S. (2010). Peroxisome Proliferator-Activated Receptor Alpha Target Genes. PPAR
Research. 2010. 1-20.
Using primary hepatocytes culture from mice and human, this study demonstrated that human
hepatocytes are sensitive to enzymatic induction by PPARalpha agonists. Of the 208 PPARa
targeted genes in mouse hepatocytes, 85 (41%) are also targeted in human hepatocytes. In addition,
12 genes targeted by PPARa in human hepatocytes are not in mouse hepatocytes. Six of the human-
specific genes are in the biotransformation pathways and the other six are in the lipid metabolism
pathways, including the pathways of peroxisomal P-oxidation, microsomal co-hydroxylation,
lipogenesis, plasma triglyceride metabolism, and cholesterol/bile transport & metabolism. The
potential manifestation of the effects on these human-specific target genes should be considered
when determining UFa.
EPA Response: Thank you for providing the reference to the review paper by
Rakhshandehroo et al. (2010). This review paper provides an overview of PPARa target
genes involved in different biological processes in the liver and the literature evaluating
differences and similarities between the genes impacted in mice and humans. The authors
conclude that based on their review of the literature, the function and specific target genes of
PPARa are generally well conserved between mouse and human specifically for lipid
metabolism. Only a subset of those genes impacted in mice and humans, however, are linked
to the PPARa response element, and none of those identified as human fell only in that
category. In addition, the review paper does not specifically address GenX chemicals or other
perfluorinated compounds (Rakhshandehroo et al., 2010).
As described in section 4.7, findings consistent with PPARa agonists were observed (e.g.,
increases in liver weight, hepatocellular hypertrophy, and increased P-oxidation activity) for
GenX chemicals; however, data gaps exist for key events and other MOAs might be involved
(Rakhshandehroo et al., 2010). Therefore, the EPA concluded that the MOA for GenX
chemicals is not clearly understood and cannot be solely attributed to PPARa.
The commenter noted that several genes involved in biotransformation and lipid metabolism
are human-specific and recommended the potential effects resulting from regulation of these
human-specific PPARa target genes should be considered when determining UFa. As
pointed out above, none of those human genes were directly linked to the PPARa response
element by the authors (Rakhshandehroo et al., 2010). The UFa is applied to account for the
extrapolation of laboratory animal data to humans, and it generally is presumed to include
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both toxicokinetic (i.e., absorption, distribution, metabolism, and elimination) and
toxicodynamic (i.e., MO A) aspects. The toxicokinetic portion of the UFa was accounted for
by application of the EPA's Recommended Use of Body Weight4 as the Default Method in
Derivation of the Oral Reference Dose in the determination of the POD for derivation of the
RfD (USEPA, 2011). Uncertainty related to toxicodynamic processes (i.e., MOA), however,
still exists; thus, the EPA applied a UFa of 3 along with a UFd of 3 for data gaps. Given the
lack of specificity of the review paper to GenX chemicals, this publication was not added to
the document (Rakhshandehroo et al., 2010). The EPA updated the UFa discussion, however,
to highlight that this addresses uncertainty related to toxicodynamic processes such as MOA.
Kamendulis
Yes, the literature search strategy, study selection and evaluation considerations were very well
presented and sufficiently clear. The process used was described well and was a very thorough and
transparent approach to systematically evaluate each of the available scientific studies that described
the health effects of GenX chemicals.
I am unaware of other peer-reviewed studies that should be included in this assessment.
EPA Response: Thank you for your response.
Leung
The draft report describes the systematic approach taken toward the identification and selection of
pertinent studies on this topic. The search strategy is overall easy to understand and transparent,
although there are some concerns and several areas which could be better addressed:
a. The most important issue is that the search results highlight the overall relative scarcity of
available data regarding the potential risks of Gex chemicals. Almost all of the literature used to
base the current assessments are animal studies conducted by Dupont submitted as part of the
TSCA. The HERO database shows 119 included references, from which only 29 are from non-
Dupont sources (and not all, albeit most, are necessarily from peer-reviewed journals.) The lack
of rigorous studies published in well-regarded journals spanning the animal, human, and
epidemiologic literature is a substantial limitation to interpreting the health impacts of exposure
to these chemicals.
EPA Response: In section 3.3.1, the EPA describes the limited number of publicly available
studies. Section 1.1 (History of Assessment of GenX Chemicals at EPA) is included in the
assessment to provide the reader with the background information necessary to understand
the origin of the data used for this assessment. Additionally, throughout the document, the
data have been well characterized as either published, peer-reviewed studies or studies
submitted by DuPont/Chemours. All of the available DuPont/Chemours studies considered in
the assessment have also been made publicly available through HERO at
https://hero.epa.gov/hero/index.cfm/proiect/page/proiect id/2627. Despite the limited
number of publicly available and peer-reviewed studies, the studies that are available for
assessing GenX chemicals toxicity are robust (i.e., full study reports containing individual
animal data) and adhere to good laboratory practices and EPA and international (i.e., OECD)
TGs.
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Specifically, and as noted in section 3.3.2 of the assessment, all of the TSCA-submitted
studies considered for derivation of the RfDs were conducted according to OECD TGs
and/or EPA health effects TGs for pesticides and toxic substances, which "are generally
intended to meet testing requirements for human health impacts of chemical substances under
the FIFRA and TSCA." All available studies were considered for inclusion (see appendices
A and B), and most of the studies selected for inclusion in this assessment adhered to the
Principles of Good Laboratory Practice, and full study reports, including individual animal
data, were submitted for Agency review (see section 3.3.2). It should also be noted that two
of the DuPont studies used in this assessment were published in peer-review journals:
•	Hoke, R.A., B.D. Ferrell, T.L. Sloman, R.C. Buck, and L.W. Buxton. 2016. Aquatic
hazard, bioaccumulation and screening risk assessment for ammonium 2,3,3,3-
tetrafluoro-2-(heptafluoropropoxy)-propanoate. Chemosphere 149:33 6-342.
•	Rae, J.M., L. Craig, T.W. Slone, S.R. Frame, L.W. Buxton, and G.L. Kennedy. 2015.
Evaluation of chronic toxicity and carcinogenicity of ammonium 2,3,3,3-tetrafluoro-
2-(heptafluoropropoxy)-/propanoate in Sprague-Dawley rats. Toxicology Reports
2:939-949.
b.	One concern regarding the search strategy, as shown in Appendix A (Table A-5), is that studies
for which only an abstract was available were excluded. What does this signify, and were there
any further attempts done to assess the relevance of these excluded studies (which are not
shown)?
EPA Response: The GenX chemicals literature search resulted in just one study for which
only an abstract was available within the cited journal.1 This study was related to
immunotoxicity of HFPO dimer acid and its ammonium salt. The reference lacked
information with which to evaluate it using the EPA's criteria. In fact, only the title was
available online when conducting the literature search. The literature search and systematic
review process did not include contacting authors to obtain more details for abstract-only
references. The EPA, however, did not deem this a critical limitation as a more recent report
describing an immunotoxicity in mice (Rushing et al., 2017), by the same authors as the
abstract, was also identified and is summarized in the draft document.
c.	The draft report demonstrates the approach used to rank the relevance and usefulness of included
studies. Studies were then scored by various EPA OPPT criteria quite rigorously (Appendix B)
in an objective a manner as possible by several reviewers. It would be relevant to state the
number of reviewers, whose aggregate assessment was reported as weighted scores, involved in
this process, as well as their professional areas of expertise.
EPA Response: The study reviews were conducted using established EPA OPPT protocols.
Specifically, the GenX chemicals study reviews were conducted by EPA staff with expertise
in toxicology, biology, pharmacokinetics/modeling, and related fields with understanding of
OECD TGs and risk assessment. Each expert reviewed 1-2 studies. Following individual
'Rushing, B.R., and J. Dewitt. 2013. Immunotoxic effects of undecafluoro-2-methyl-3-oxahexanoic acid in mouse models. Abstracts
of Papers - American Chemical Society Vol 245.
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study reviews, a separate staff scientist performed a final review of all reviewers' evaluations
to provide a level of consistency across the evaluations.
d. One additional comment regarding the scoring system is regarding Metric #22, which assessed
"Health outcomes thought to be unrelated to exposure". It does not appear that are any further
details regarding what these outcomes may have been, although there are occasional comments
when such health outcomes were not reported in the study. Further detail regarding these health
outcomes would provide greater context to the conclusions posed by this draft report.
EPA Response: Thank you for the comment. All health effects that demonstrated a dose
response and were significantly different from the control are reported in the assessment; this
includes effects that were categorized as "outcomes unrelated to exposure" by study authors.
Therefore, these details are already covered in the body of the assessment and will not be
added to the systematic review sheet tables. The EPA will consider this input, however, as
EPA OPPT implements its systematic review procedures and in any updates in the future.
Slitt
The literature search strategy was appropriate and thorough. It was well described and included clear
criteria for the inclusion and exclusion of studies. The databases utilized (i.e. PubMed, WOS,
Toxline, and TSCATS1) are appropriate and the search terms were comprehensive in nature. The
methods in section B used to evaluate study quality were systematic and thorough. The metrics and
criteria applied for Animal and in vitro toxicity studies were exceedingly thorough and well defined.
The weighting and relative important used for weighting the criteria was appropriate. Overall, this
semi-quantitative approach in evaluating the data/studies to be included is considered to be is
appropriate and thorough.
A minor comment is that exposure for in vitro studies on page A-9, Table A-5 should be described.
It is assumed that it is via addition of chemical to media, however it should be described for what
criteria would be constitute inclusion/exclusion for in vitro studies. For example, solubility and
vehicle could be mentioned.
EPA Response: The EPA will add the following bullet in under exposure in Table A-5:
• Exposure is via cells in culture or subcellular matrices.
Warren
Sections 3.3.1 (Literature Search Strategy and Results) and 3.3.2 (Study Screening Process and
Study Evaluation) succinctly describe a laborious task that requires considerable skill if done well. I
have refrained from using the phrase "done correctly" in recognition of the subjective judgments
inherent to the process. The search of public literature is clearly comprehensive, as I was able to
locate only one additional study that might be worthy of inclusion in the toxicity assessment (see
below). Admittedly, I am unsure as to whether it meets the inclusion-exclusion criteria in Table A-5.
Based on its title and abstract, it might be appropriate to include in Section 1.3 (Occurrence). As for
the screening process and evaluation of manufacturer-submitted studies, like the toxicity assessment,
I too acknowledge the importance of adherence to OECD/EPA TGs and GLP. And while I find the
scoring system and qualitative rating process a bit arbitrary, the evaluation domains and metrics
within them make for a transparent means in the pursuit of consistency and ultimately, validity in
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toxicity values. Therefore, I support the study evaluation process while encouraging its refinement
over time.
Additional Peer-Reviewed Study
1. WA Gebbink. L van Asseldonk. and SPJ van Leeuwen. Presence of Emerging Per- and
Polyfluoroalkyl Substances (PFASs) in River and Drinking Water near a Fluorochemical
Production Plant in the Netherlands. Environ. Sci. Technol.. 51(19): 1 1057-1 1065. October 3.
2017.
The above study investigated the presence of legacy and emerging PFAS (including GenX) in river
water collected in 2016 up- and downstream from a fluorochemical production plant in The
Netherlands. Additionally, drinking water samples were collected from municipalities in the vicinity
of the production plant, and like the river water, were positive for GenX.
EPA Response: Thank you for the suggested reference. EPA has added a more inclusive list
of international occurrence references to section 1.3 (Occurrence), including this reference.
CHARGE QUESTION 2
For GenX chemicals the critical study chosen for determining the subchronic and chronic
RfDs is the oral reproductive/developmental toxicity screening study in adult mice (DuPont
18405-1037, 2010) and the critical effect is liver effects (single cell necrosis) in adult males. Is
the selection of the critical study and critical effect for the derivation of the subchronic and
chronic RfDs for GenX chemicals scientifically justified and defensible?
a.	If so, please explain your justification.
b.	If not, please provide your rationale and detail an alternative critical study and/or
critical effect you would select to support the derivation of the subchronic and chronic
RfDs.
Chou
The selection of liver effects as the critical effect for derivation of oral subchronic and chronic RfDs,
using the oral reproductive/developmental toxicity screening study in adult mice, is well justified. It
is justified based on increases in liver weight, relatively high number of animals (22-25) per
treatment group for liver endpoints, and consistent adverse effects corroborated in other studies
presented in the Draft. The weaknesses of other studies are well described in the draft on p. 51-52.
EPA Response: Thank you for your response.
Kamendulis
a. If so, please explain your justification.
I agree with the selection of the critical study selected for deriving RfD's for GenX chemicals
(DuPont-18405-1037 2010). This oral reproductive/developmental toxicity study in mice identified
liver effects, specifically single-cell necrosis in males, as the critical effect and was used to derive
the subchronic and chronic RfDs for GenX chemicals. As noted, this study utilized a larger sample
size (n=24 / dose) and provided the most health protective PODhed. Further, this study was an 84-85
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Response to Peer Review Comments-GenX Chemicals
November 2018
day study compared to the other mouse study (28 days). In addition, several other studies provide
support for the selection of liver necrosis as the critical effect following oral exposure to GenX
chemicals (DuPont-24459 2008; DuPont-24447 2008; DuPont-18405-1307 2010; DuPont-18405-
1238 2013; DuPont-18405-841 2010). Liver effects (changes in liver enzyme levels,
histopathological lesions, and tumors) were observed in both male and female mice and rats at
varying durations of exposures and doses of GenX chemicals.
EPA Response: Thank you for your response.
b. If not, please provide your rationale and detail an alternative critical study and/or
critical effect you would select to support the derivation of the subchronic and chronic
RfDs.
N/A
EPA Response: No response required.
Leung
This study in which the subchronic and chronic RfDs is based upon consisted of 150 mice, in which
histopathologic changes and increased liver weights were seen in all three dose groups. However, as
summarized in the draft report, these findings have also largely been supported by at least seven
other studies, including one from the peer-reviewed published literature, although only one was
considered chronic (i.e., >90 days duration). Evidence of hepatic damage is also supported by the
very significant increases in serum transaminase levels among mice exposed to the higher doses.
Overall, availability of more than one study assessing chronic exposure would be relevant toward
the hepatic and other potential clinical endpoints.
The draft report describes that the other organ systems and endpoints in which adverse effects have
been found were hematology, renal, development/reproduction, immunology, and carcinogenesis
(Section 5). No differences in survival at a planned 12-month necropsy timepoint were found in the
one available chronic study. Regarding these other organ systems:
a. It is described that the maximum decrement of hemoglobin/hematocrit levels in male mice and in
rats was 12% from several studies assessing doses up to 100 mg/kg/day lasting up to 180 days.
This may be clinical significant, and consideration of this endpoint in greater detail may be
relevant. Additionally, in the one chronic study, female mice and rats had up to a 24% decrease
in hemoglobin/hematocrit levels, further supporting this as a possible critical effect.
EPA Response: We agree with the commenter regarding the potential clinical significance of
the decreased hemoglobin/hematocrit endpoint as described in section 6.1. As outlined in the
document, however, the hematological effects were inconsistently observed in both mice and
rats, especially as study duration increased. The limitations in the database related to blood
effects could be addressed with additional studies. The EPA has added the need for
additional research to the UFd discussion. Additionally, the EPA highlighted these
inconsistencies in the observed hematological endpoints to the uncertainty discussion
(section 7.0).
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Response to Peer Review Comments-GenX Chemicals
November 2018
b.	Regarding renal effects, the primary endpoints that have been assessed are weight of the kidneys,
microscopic changes of the kidney, and blood urea nitrogen concentrations. The draft report
states that given the limited changes in these parameters, renal toxicity is unlikely a critical
effect. Animal physiology is not my area of expertise, but there certainly other factors important
in the assessment of human renal function like serum creatinine concentrations and filtration rate
that are also clinically important.
EPA Response: As discussed in section 3.3.4, the EPA reported potential adverse effects that
were statistically significantly different from the control and/or had a dose-response.
Therefore, the EPA did not report every endpoint that was measured in each individual
DuPont/Chemours report. The increases in kidney weight and blood urea nitrogen
concentrations as well as the microscopic changes of the kidney were statistically
significantly changed from the control group. Serum creatinine levels were measured in
many of the toxicity studies (DuPont-24447, 2008; DuPont-24459, 2008; DuPont-17751-
1026, 2009; DuPont-18405-1307, 2010; DuPont-18405-1238; 2013), but none of the treated
groups in these studies had creatinine levels that were statistically significantly different from
the control. Filtration rate was not measured in any of the studies.
c.	It is unfortunate that the potential developmental/reproductive toxicities are based only on two
animal studies. From the description of these, these toxicities are rare and may not be clinically
significant. However, only F1 mice were studied and there are no data on potential effects
spanning more than two generations.
EPA Response: The developmental effects observed as a result of in utero exposure to GenX
chemicals (e.g., decreased birth weight and altered puberty as evidence by vaginal patency
and balanopreputial separation) are considered adverse effects (USEPA, 1991, 1996). These
are common developmental endpoints measured in developmental toxicity studies. The lack
of a full two-generation reproductive toxicity study evaluating exposures during early
organogenesis (i.e., gestation day 0 to gestation day 6) and studies evaluating additional
developmental endpoints observed following exposure to other PFAS (i.e., skeletal
development in mice and altered puberty in mice (USEPA, 2016a, 2016b)) is identified as a
database deficiency. Please see the discussion in section 6.4.2 for more information.
d.	The data for immunotoxicity are even more limited, but suggest some adverse effects among
female mice. In the absence of more data, it is difficult to ascertain whether these preliminary
findings should be considered critical effects.
EPA Response: Data on the potential for GenX chemicals to impact aspects of immune
function beyond immunosuppression are lacking. Additional studies would be useful to
support a more conclusive determination of immunotoxic potential. Please see the UFd
discussion in section 6.4.2 for more information.
e.	I agree with the summary in Section 5.6, which describes the inability to determine overall
carcinogenicity based on the substantially limited available data. However, the observation of
increased hepatocellular carcinomas in female dosed rats should not be discounted.
EPA Response: In section 4.4, the EPA concluded that the increased incidence of liver
tumors in females at 500 mg/kg/day is treatment-related. The EPA does not discount these
data but found the existing evidence from this single chronic study inadequate to justify a
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Response to Peer Review Comments-GenX Chemicals
November 2018
quantitative assessment for either males or females. The EPA has added the lack of
additional chronic studies in the most sensitive species to the UFd discussion in section 6.4.2.
Slitt
Yes, a survey of the data included in the report points to liver effects in adult male is appropriate and
defensible. The study meets the criteria listed in almost all elements for being considered of high
quality. It meets every metric as high or medium, such as test substance, test setup, exposure
characterization, etc. The critical effect of single cell necrosis in male mice is based on n=24-25 FO
males, which a large "n". The selection of this study is scientifically justifiable based on it
sufficiently meeting the review criteria. The selection of single-cell necrosis is a reasonable measure
to use as a critical effect. This measure has been used previously for PFOA and PFOS, in which
rodent studies that have demonstrated hepatotoxicity demonstrate concordance with studies in
human populations illustrating slight elevation serum in liver enzymes.
It should be noted that there was PFOA contamination for the test substance for DuPont 18405-1037,
2010 lists that purity of the test article at 84%. Another study listed in the document that meets the
evaluation criteria with high confidence (DuPont -24459, 2008) lists a slightly higher purity of the
test article (88% purity). This 28-day oral dosing study that evaluated 0.1, 3 and 30 mg/kg/day did
not observe any statistically significant increases in liver single cell necrosis at 0.1 mg/kg, but did
observe significant elevation of serum liver enzymes, liver weight, and single cell necrosis in males
at 3 mg/kg. Given that the purity of the test article was slightly higher, this study should also be
considered along with DuPont 18405-1037, 2010 for considering 0.1 mg/kg in male mice for the
RfD.
EPA Response: The EPA agrees with the reviewer that the 28-day oral dosing study in mice
(DuPont-24459, 2008) is an important study, which is why it was considered as a candidate
POD and selected for BMD modeling alongside the oral reproductive/developmental toxicity
screening study (DuPont-18405-1037, 2010). As described in section 6.2 and appendix E of
the assessment, the results of the BMD modeling (presented in Table 8) demonstrate that
DuPont-18405-1037 (2010) yielded the most health protective PODhed. Moreover, this study
used a larger sample size (n=24 / dose versus n=10 / dose). Finally, DuPont-18405-1037
(2010) was of a longer duration (84/85 days) than DuPont-24459 (28 days). For these
reasons, the EPA selected DuPont-18405-1037 (2010) as the critical study for the derivation
of RfDs for GenX chemicals.
Additionally, section 7.2 (Effects Characterization) further describes purity as a consideration
in study selection.
Warren
Selection of the gavage study of reproduction/developmental toxicity in mice (DuPont 18405-1037,
2010) and single cell necrosis for toxicity value derivation are scientifically justified and well
defended in the toxicity assessment. However, the dismissal of studies from further consideration as
the critical study on the basis of NOAEL alone (i.e., having aNOAEL >0.1 mg/kg/day) is a
questionable practice. This is especially true when a dismissed study's NOAEL is but an order of
magnitude greater than that of the critical study (i.e., 1 mg/kg/day), a difference dwarfed by the total
UF applied to toxicity value derivation. Nonetheless, Section 6.1 makes a convincing case for
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Response to Peer Review Comments-GenX Chemicals
November 2018
selection of critical study and effect, especially with regard to preference for liver necrosis over a
hematological or immunological effect and use of a subchronic study for chronic RfD derivation in
lieu of a chronic toxicity/oncogenicity study reporting the same critical effect, albeit at a
considerably higher dose in a less sensitive species.
EPA Response: Section 6.1 has been revised to further discuss selection of critical studies and
effects, specifically addressing why those with NOAELs higher than 0.1 mg/kg/day were
considered no further for modeling.
CHARGE QUESTION 3
EPA employed benchmark dose modeling in the identification of a point-of-departure (POD)
for GenX chemicals (USEPA 2012). Is the modeling approach, selection of benchmark
response level, and the selected model used to identify the POD for derivation of the RfD
scientifically justified and defensible?
Chou
The reviewer agrees with the selection of BMDL10 from Table E-2 and Table E-4. The modeling
approach, selection of benchmark response level, and the selected model used to identify the PODs
are well justified and defensible.
EPA Response: Thank you for your response.
Kamendulis
Yes, I agree with the approach used. As there are no biologically based dose-response models
available for GenX chemicals, benchmark dose modeling was used, and was consistent with EPA's
guidance document (USEPA 2012). The BMD and the BMDL were estimated using a BMR of 10%
extra risk for dichotomous data, and candidate PODs were estimated from all 3 doses (plus control)
for the critical study.
EPA Response: Thank you for your response.
Leung
BMD modeling is not within my area of expertise. However, it appears that the draft report makes a
reasonable effort to identify clinically-relevant endpoints required for the modeling from the
available limited data. I defer to the other reviewers regarding whether the translation of a POD to a
human dose equivalent, the determination of uncertainty factors (UFs), and the mathematical
calculations of the corresponding subchronic and chronic RfDs, are appropriate.
EPA Response: Thank you for your response.
Slitt
This is out of my area of expertise, so I decline responding to this question.
EPA Response: No response required.
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Response to Peer Review Comments-GenX Chemicals
November 2018
Warren
Application of BMD modeling to data from two of three studies having NOAELs of 0.1 mg/kg/day
was appropriate for POD identification, as neither sex of rats in the third study (DuPont-17751-1026
2009) exhibited liver necrosis. The modeling approach appears consistent with USEPA's Benchmark
Dose Technical Guidance document, including use of dichotomous models, selection of BMR, and
inclusion of data from all dose groups given an adequate model fit when none are omitted. Criteria
for model selection appears to be largely consistent with Agency guidance, as well. For example,
model selection considerations included those with goodness of fit p-values > 0.1, lowest Akaike's
Information Criterion (provided BMDLs are "sufficiently" close), sufficiently small BMD:BMDL
ratios, and lowest scaled residuals for doses near the BMD/BMDL. In addition, fitted curves of
incidence rate as a function of dose allowed for an assessment of visual fit. Finally, selection was
made of the lowest BMDL (0.15 mg/kg/day), which was one-half that of the alternative derived from
the 28-day gavage study in mice. As such, the toxicity assessment's BMD modeling results were
obtained using time-tested and widely-accepted methods and model choice decision logic, making it
scientifically justified and defensible. It is noteworthy that such methods stand in stark contrast to
the means by which North Carolina derived a drinking water equivalent level on the basis of an RfD
derived by application of a total UF of 1,000 to the NOAEL of 0.1 mg/kg/day for single cell necrosis
in the liver.
EPA Response: Thank you for your response.
CHARGE QUESTION 4
Given what is known and not known about the interspecies differences in toxicokinetics of
GenX chemicals, EPA applied body weight to the % allometric scaling to adjust the POD to
estimate a human equivalent dose (HED) in the derivation of the respective RfDs (USEPA
2011).
a.	Is applying the body weight to the % for GenX chemicals scientifically justified and
defensible? If not, please provide your rationale and detail the alternative approach you
would use.
b.	Do the methods used to derive the RfDs for GenX chemicals appropriately account for
uncertainties in evaluating the toxicokinetic differences between the experimental
animal data and humans?
Chou
a. Is applying the body weight to the % for GenX chemicals scientifically justified and
defensible? If not, please provide your rationale and detail the alternative approach you
would use.
The reviewer agrees to the use of 3/4 allometric scaling to adjust the POD to estimate a human
equivalent dose (HED) in the derivation of the respective RfDs in the draft assessments.
EPA Response: Thank you for your response.
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Response to Peer Review Comments-GenX Chemicals	November 2018
b. Do the methods used to derive the RfDs for GenX chemicals appropriately account for
uncertainties in evaluating the toxicokinetic differences between the experimental
animal data and humans?
Considering the differences of enzymes targeted by PPARa activation between the mouse and the
human (see comments for Item 1), the UFh and UFd values used in this draft are appropriate; any
values less than 3 would not be acceptable.
EPA Response: Please see response to Charge Question 1:
Thank you for providing the reference to the review paper by Rakhshandehroo et al. (2010).
This review paper provides an overview of PPARa target genes involved in different
biological processes in the liver and the literature evaluating differences and similarities
between the genes impacted in mice and humans. The authors conclude that based on their
review of the literature, the function and specific target genes of PPARa are generally well
conserved between mouse and human specifically for lipid metabolism. Only a subset of
those genes impacted in mice and humans, however, are linked to the PPARa response
element and none of those identified as human fell only in that category. In addition, the
review paper does not specifically address GenX chemicals or other perfluorinated
compounds (Rakhshandehroo et al. 2010).
As described in section 4.7, findings consistent with PPARa agonists were observed (e.g.,
increases in liver weight, hepatocellular hypertrophy, and increased P-oxidation activity) for
GenX chemicals; however, data gaps exist for key events and other MOAs might be involved
(Rakhshandehroo et al., 2010). Therefore, the EPA concluded that the MOA for GenX
chemicals is not clearly understood and cannot be solely attributed to PPAR.
The commenter noted that several genes involved in biotransformation and lipid metabolism
are human specific and recommended the potential effects resulting from regulation of these
human-specific PPARa target genes should be considered when determining UFa. As
pointed out above, none of those human genes were directly linked to the PPARa response
element by the authors. The UFa is applied to account for the extrapolation of laboratory
animal data to humans, and it generally is presumed to include both toxicokinetic (i.e.,
absorption, distribution, metabolism, and elimination) and toxicodynamic (i.e., MOA)
aspects. The toxicokinetic portion of the UFa was accounted for by application of the EPA's
Recommended Use of Body Weight4 as the Default Method in Derivation of the Oral
Reference Dose in the determination of the POD for derivation of the RfD (USEPA, 2011).
Uncertainty related to toxicodynamic processes (i.e., MOA), however, still exists; thus, the
EPA applied a UFa of 3 along with a UFd of 3 for data gaps. Given the lack of specificity of
the review paper to GenX chemicals, this publication was not added to the document
(Rakhshandehroo et al., 2010).
Kamendulis
a. Is applying the body weight to the % for GenX chemicals scientifically justified and
defensible? If not, please provide your rationale and detail the alternative approach you
would use.
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Response to Peer Review Comments-GenX Chemicals
November 2018
Yes, the application of3A allometric scaling was justified and adequately presented. Any uncertainty
in using this approach is accounted for by application of uncertainty factors (see answers to question
5 below).
EPA Response: Thank you for your response.
b. Do the methods used to derive the RfDs for GenX chemicals appropriately account for
uncertainties in evaluating the toxicokinetic differences between the experimental
animal data and humans?
Yes, the methods that were used to derive the RfD's for GenX chemicals took into consideration
toxicokinetic differences between animals and humans. Further, any uncertainties are accounted for
by the application of uncertainty factors (see question 5 below).
EPA Response: Thank you for your response.
Leung
This is not my area of expertise, thus I defer to the other reviewers.
EPA Response: No response required.
Slitt
a.	Is applying the body weight to the % for GenX chemicals scientifically justified and
defensible? If not, please provide your rationale and detail the alternative approach you
would use.
This is not within my expertise to respond.
EPA Response: No response required.
b.	Do the methods used to derive the RfDs for GenX chemicals appropriately account for
uncertainties in evaluating the toxicokinetic differences between the experimental
animal data and humans?
Yes, the methods used do account for the appropriate uncertainties.
EPA Response: Thank you for your response.
Warren
Yes, use of the default dosimetric adjustment factor (DAF) of bw to the 3/4 is scientifically justified
and defensible given the lack of a PBPK model for GenX (possibly excluding that of Gomis et al.,
2018), paucity of toxicokinetic data in experimental animals and their absence in humans, and little
mechanistic information to inform the issue of how internal dose relates to the nature, magnitude,
and time-course of biological effects. As noted in the toxicity assessment, its use is also justified
given GenX's lack of metabolism, relatively short clearance time compared to longer-chain PFAS,
and application to adult mice as opposed to those in earlier life stages. Furthermore, the default
approach is consistent with the hierarchy of approaches for interspecies extrapolation clearly
expressed by USEPA in multiple documents, including Recommended Use of Body Weight3/4 as the
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Response to Peer Review Comments-GenX Chemicals
November 2018
Default Method in Derivation of the Oral Reference Dose and Harmonization in Interspecies
Extrapolation: Use ofBW3/4 as Default Method in Derivation of the Oral RfD. The toxicity
assessment's use of a UF of 3 for interspecies differences is also consistent with Agency guidance,
as the default DAF appropriately addresses some, but not all, of the considerable cross-species
uncertainties in both GenX toxicokinetics and toxicodynamics. Lastly, it is encouraging to see the
use of an updated body weight for adult humans in the DAF equation (i.e., 80 kg), a minor change,
but one that increases confidence that the toxicity assessment reflects the state-of-the-science.
EPA Response: Thank you for your response.
CHARGE QUESTION 5
EPA has evaluated and applied where appropriate uncertainty factors to account for
intraspecies variability (UFh), interspecies differences (UFa), database limitations (UFd),
duration (UFs), and LOAEL-to-NOAEL extrapolation (UFl) for GenX chemicals.
a.	Has uncertainty been adequately accounted for in the derivation of the RfDs? Please
describe and provide suggestions, if needed.
b.	Does the provided scientific rationale support the application of the selected uncertainty
factors? Please explain.
Chou
a.	Has uncertainty been adequately accounted for in the derivation of the RfDs? Please
describe and provide suggestions, if needed.
Please see response to Question 4b.
EPA Response: No response required.
b.	Does the provided scientific rationale support the application of the selected uncertainty
factors? Please explain.
The draft provided appropriate scientific rationale for the selection of the UF values. Additional
justification for UFa may be used. See comments for Question 1.
EPA Response: Please see response to Charge Question 1:
Thank you for providing the reference to the review paper by Rakhshandehroo et al. (2010).
This review paper provides an overview of PPARa target genes involved in different
biological processes in the liver and the literature evaluating differences and similarities
between the genes impacted in mice and humans. The authors conclude that based on their
review of the literature, the function and specific target genes of PPARa are generally well
conserved between mouse and human specifically for lipid metabolism. Only a subset of
those genes impacted in mice and humans, however, are linked to the PPARa response
element and none of those identified as human only fell in that category. In addition, the
review paper does not specifically address GenX chemicals or other perfluorinated
compounds (Rakhshandehroo et al., 2010).
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Response to Peer Review Comments-GenX Chemicals
November 2018
As described in section 4.7, findings consistent with PPARa agonists were observed (e.g.,
increases in liver weight, hepatocellular hypertrophy, and increased beta-oxidation activity)
for GenX chemicals; however, data gaps exist for key events and other MO As may be
involved (Rakhshandehroo et al., 2010). Therefore, the EPA concluded that the MO A for
GenX chemicals is not clearly understood and cannot be solely attributed to PPARa.
The commenter noted that several genes involved in biotransformation and lipid metabolism
are human specific and recommended the potential effects resulting from regulation of these
human-specific PPARa target genes should be considered when determining UFa. As
pointed out above, none of those human genes were directly linked to the PPARa response
element by the authors (Rakhshandehroo et al., 2010). The UFa is applied to account for the
extrapolation of laboratory animal data to humans, and it generally is presumed to include
both toxicokinetic (i.e., absorption, distribution, metabolism, and elimination) and
toxicodynamic (i.e., MO A) aspects. The toxicokinetic portion of the UFa was accounted for
by application of EPA's Recommended Use of Body Weight3/4 as the Default Method in
Derivation of the Oral Reference Dose in the determination of the POD for derivation of the
RfD (USEPA, 2011). However, uncertainty related to toxicodynamic processes (i.e., MOA),
however, still exists; thus, the EPA applied a UFa of 3 along with a UFd of 3 for data gaps.
Given the lack of specificity of the review paper to GenX chemicals, this publication was not
added to the document (Rakhshandehroo et al., 2010).
Kamendulis
a. Has uncertainty been adequately accounted for in the derivation of the RfDs? Please
describe and provide suggestions, if needed.
Yes, uncertainty has been adequately accounted for in the derivation of RfDs for GenX chemicals.
An interspecies uncertainty factor of 3 was applied to account for uncertainty in extrapolating from
laboratory animals to humans. A factor of 3 was used in lieu of a 10 since a PODhed was derived
from the BMDL as specified in EPA's guidance document (USEPA 201 lb). As the allometric
scaling accounts for some aspects of species extrapolation, some uncertainty remains. Thus, the
application of an UF of 3 appears appropriate.
An intraspecies uncertainty factor (UFh) of 10 is assigned to account for variability in the responses
within the human populations. This is also appropriate.
The BMD approach was utilized, therefore application of a UF for using a LOAEL to NOAEL is not
needed.
For the chronic RfD, although a chronic bioassay is available (in rats), a UF of 3 was applied for
extrapolation from a subchronic to a chronic exposure duration (UFs) of 3. The 2-year study
identified a NOAEL of 1 mg/kg-day for liver effects (increased liver enzyme levels and centrilobular
hepatocellular hypertrophy and cystic focal degeneration in males and centrilobular necrosis in both
sexes), consistent with the effects observed in the oral reproductive/developmental study in mice,
however, at a much higher NOAEL. As data suggests that rats appear to be less sensitive than mice,
a UF of 3 was used to account for extrapolation from subchronic to chronic exposure duration for the
chronic RfD. This appears appropriate.
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Response to Peer Review Comments-GenX Chemicals
November 2018
While only a limited number of studies have been conducted for GenX chemicals, a database
uncertainty factor (UFd) of 3 was applied. This is due to the quality of the available studies - which
include acute toxicity, metabolism and toxicokinetics, genotoxicity, and systemic toxicity studies in
mice and rats with dosing durations of up to 2 years, and one reproductive and developmental
toxicity study in mice and one prenatal and developmental toxicity study in rats. Many of these
studies were conducted under GLP conditions, with full study reports available and reviewed. Thus,
the application of a UFd of 3 appears appropriate.
EPA Response: Thank you for your response.
b. Does the provided scientific rationale support the application of the selected uncertainty
factors? Please explain.
I have addressed this comment in my responses to 5a above - the application of the UF's used to
derive RfD's for GenX chemicals was scientifically based and well described.
EPA Response: Thank you for your response.
Leung
This is not my area of expertise, thus I defer to the other reviewers.
EPA Response: No response required.
Slitt
a.	Has uncertainty been adequately accounted for in the derivation of the RfDs? Please
describe and provide suggestions, if needed.
Yes. The use of uncertainty factors was used according to EPA guidance (USEPA, 201 lb). The
authors were unable to find any human epidemiological studies, so an UF of 10 was used
appropriately. The application of a UF of 3 for interspecies differences is appropriate as well because
the chronic cancer bioassays were performed in rat and not mouse, with the several studies herein
demonstrating that rats appear to be a less sensitive species than mouse. Lastly, a UFD of 3 is in
agreement with the guidance, as there are many knowledge gaps for GenX. Lastly, uncertainty for
intraspecies variability and database limitations must be included. Currently there are no studies to
address whether developmental or immunotoxicity is observed at exposures lower than the 0.1
mg/kg RfD that was observed for liver effects in male mice.
EPA Response: Thank you for your response.
b.	Does the provided scientific rationale support the application of the selected uncertainty
factors? Please explain.
Yes, Section 7 did outline and provide sufficient rationales for the application of the selected
uncertainty factors. See response in part a.
EPA Response: Thank you for your response.
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Response to Peer Review Comments-GenX Chemicals
November 2018
Warren
Yes, the considerable uncertainty surrounding the risk of GenX exposure has been adequately
accounted for in the toxicity assessment. Section 6.4.2 does a good job of explaining the rationale
behind each individual UF value and I agree with the total UFs of 100 and 300 used for RfD
derivation.
EPA Response: Thank you for your response.
CHARGE QUESTION 6
The draft assessment for GenX chemicals identifies liver effects as a potential human hazard.
EPA evaluated the available evidence for liver effects, including the potential role of PPARa,
using Hall et al. (2012) criteria for adversity.
a.	Please comment on whether the available data have been clearly and appropriately
synthesized for these toxicological effects.
b.	Please comment on whether the weight of evidence for hazard identification has been
clearly described and scientifically justified.
c.	Please comment on whether the conclusions regarding adversity are scientifically
supported and clearly described.
Chou
a.	Please comment on whether the available data have been clearly and appropriately
synthesized for these toxicological effects.
Yes, the draft clearly synthesized the toxicological effects.
EPA Response: Thank you for your response.
b.	Please comment on whether the weight of evidence for hazard identification has been
clearly described and scientifically justified.
Yes, the weight of evidence for hazard identification has been clearly described, and scientifically
justified to meet the definition of "adverse".
EPA Response: Thank you for your response.
c.	Please comment on whether the conclusions regarding adversity are scientifically
supported and clearly described.
Yes, the conclusions are supported by scientific evidences. Please also see comments above.
EPA Response: Thank you for your response.
Kamendulis
a. Please comment on whether the available data have been clearly and appropriately
synthesized for these toxicological effects.
I agree that the available data were adequately and clearly described.
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Response to Peer Review Comments-GenX Chemicals
November 2018
EPA Response: Thank you for your response.
b.	Please comment on whether the weight of evidence for hazard identification has been
clearly described and scientifically justified.
Yes, I feel that the weight of evidence for effects on the liver, as well as other endpoints
(hematological and immune systems, and reproductive and developmental) was scientifically
evaluated and justified.
EPA Response: Thank you for your response.
c.	Please comment on whether the conclusions regarding adversity are scientifically
supported and clearly described.
The liver effects observed following exposure to GenX chemicals were consistently seen across
several studies including both male and female rats and mice, for short-term and chronic exposures.
Thus, the conclusions drawn are scientifically supported and adequately described in the document.
EPA Response: Thank you for your response.
Leung
The Hall 2012 reference helps delineates the differences between physiologic adaptive responses vs
pathologic toxic effects resulting in hepatocellular hypertrophy. Using this framework, the draft
report summarizes the available studies with hepatic endpoints, which did show increased
proportions of dosed animals with increased liver weights, abnormal serum liver function tests,
hepatocellular hypertrophy, and hepatocellular necrosis. These studies were also the basis for the
observation that mice may be more sensitive to toxic hepatic effects than rats, given the development
of the adverse findings at comparably higher doses in rats. The report does not comment on whether
steatosis was assessed and/or observed in these studies.
The hepatic toxicologic effects are consistent and reproducible, as seen from the eight studies of
either mice or rats and in both genders. Altogether, the conclusions regarding adversity in the draft
report are appropriately summarized.
EPA Response: Thank you for your response. Additional text has been added to section 4.7
(Mode of Action) that characterizes the steatosis data. Steatosis is not assessed in any of the
DuPont/Chemours studies. Wang et al. (2016) is the only available study to qualitatively
mention observing steatosis in mouse liver samples but does not provide quantitative
measurements.
Slitt
a. Please comment on whether the available data have been clearly and appropriately
synthesized for these toxicological effects.
Yes, the review agrees with the overall conclusion of the authors in section 4.7 for the mode of
action. The conclusion from the document is that the findings are not adequate to definitely conclude
that a PPARa mechanism of action (MOA) exists for HFPO dimeric acid and/or ammonium salt.
There is a lack of publications that have evaluated the mechanisms of action for GenX and the
authors cannot draw firm conclusions regarding PPARa involvement with limited findings. This is
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Response to Peer Review Comments-GenX Chemicals
November 2018
based on a study by Wang et al., 2016 that administered 1 mg/kg/day via oral gavage for 28 days to
male ICR mice that was not considered to be of high qualitative determination because it lacked
sufficient quality in multiple elements. The finding from this study, point to treatment with the
HFPO dimeric acid ammonium salt impacting pathways in liver for PPARa signaling, retinol
catabolism, and fatty acid degradation, however the lack of rigor in the experimental design limits
the interpretation. The authors do cite Dupont-24459 2008 and Dupont-24447 2008 with some
potential endpoints that are consistent with peroxisome proliferation (i.e. hepatic (3-oxidation),
however they do not identify PPARa as the cause for the observed effects. Thus, the conclusion that
the findings are not adequate to definitely that a PPARa mechanism of action (MOA) exists for
HFPO dimeric acid and/or ammonium salt is appropriate.
EPA Response: Thank you for your response.
b.	Please comment on whether the weight of evidence for hazard identification has been
clearly described and scientifically justified.
Yes. The weight of evidence (WOE) for hazard identification has been clearly described and
scientifically justified in this document. The WOE is based on the liver being a target organ for
toxicity from the oral exposure to HFPO dimeric acid. The document cites liver effects for both male
and female mice and rats, with male mice being the most sensitive species. This conclusion is based
on several studies carried out in which the test methods and study design meet criteria as being
"high" in quality. These studies assessed the impact of GenX in numerous endpoints (i.e. gross
measures such as food consumption, appearance, serum clinical markers of injury, gross organ
changes, and tissue pathology). These studies did evaluate relative liver weight and hepatocellular
hypertrophy in the context of evidence of hepatic necrosis, as measured by serum enzyme levels and
evidence of cellular necrosis.
EPA Response: Thank you for your response.
c.	Please comment on whether the conclusions regarding adversity are scientifically
supported and clearly described.
Yes, the conclusions regarding adversity are scientifically supported and clearly described. There
were no human epidemiology studies for GenX to base adversity, so rodent studies were used as a
basis for the RfD. The conclusion is that 0.1 mg/kg/day causes liver effects that are observed as
single cell necrosis in males (DuPont-18405-1037 2010). Other studies presented in the document
(refer to Table 7) also support liver effects being considered the adverse effect for GenX at similar
NOAELS (Dupont-24459, DuPont-18405-1238). Because these studies evaluated necrosis and liver
weight and found evidence for cytotoxicity, they meet the concern for adversity as outlined by Hall
et al. 2012). In addition, because there is a lack of substantive information regarding the mechanism
of action for GenX in rodent and cell-based studies, the role of PPARa as being the cause for the
observed liver effects, such as liver weight and single-cell necrosis, cannot be concluded.
EPA Response: Thank you for your response.
Warren
The toxicity assessment, particularly Section 5.1, does an admirable job of synthesizing the available
data on liver effects and making the case (using a weight-of-evidence approach) for GenX exposure
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November 2018
as a potential hazard to the human liver provided a threshold dose is met. Concern that the liver may
not be the most appropriate target organ for RfD derivation is minimal at best, as four manufacturer-
submitted studies reported liver effects at the LOAEL. In these studies, effects were seen in both
sexes of mice and rats under conditions of varying exposure magnitude and duration. Furthermore,
the critical effect of single-cell necrosis typically co-occurred with liver hypertrophy, increased
relative liver weight, and/or elevated liver enzymes, not to mention liver tumors in chronically-
treated, high dose, female rats. As for the issue of whether hepatic hypertrophy and increased
relative liver weight are "adverse", the toxicity assessment clearly warns against the use of such an
unqualified label in the event such effects are PPARa-mediated. This is consistent with the
consensus opinion of Hall and colleagues (an expert panel of workshop attendees) that hepatic
hypertrophy, in the absence of histologic or clinical pathology, should be considered adaptive or
non-adverse. Given the weight ascribed to the Hall et al. (2012) publication by the toxicology
community, and deservedly so, it is appropriate that USEPA share the same opinion in the absence
of evidence to the contrary.
EPA Response: Thank you for your response.
CHARGE QUESTION 7
The draft assessment concludes that there is suggestive evidence of carcinogenic potential for
GenX chemicals and that this descriptor applies to oral routes of human exposure (USEPA
2005). Please comment on whether the available animal and mechanistic studies support this
conclusion.
Chou
Currently, there is no sufficient evidence to determined that the adenomas and adenocarcinoma
observed in rodent liver are not relevant in humans. Nonetheless, the evidence in rodent
adenocarcinoma present in the existing studies is not very strong. The reviewer agrees to the
descriptor "there is suggestive evidence of carcinogenic potential for GenX chemicals."
EPA Response: Thank you for your response.
Kamendulis
There are no dermal or inhalation studies available that evaluated evaluating cancer, however, one
oral exposure bioassay for HFPO dimer acid ammonium salt in rats showed an increase in liver
tumors (females) and pancreatic acinar adenomas and carcinomas (combined, males). While there
were increases in tumors at the high dose, a dose-response pattern was not observed. Further, data
suggests that mice may be more sensitive to GenX chemicals compared to rats. As such, based on
the available data, I agree with EPA's Guidelines for Carcinogen Assessment that classifies GenX
chemicals as Suggestive Evidence of Carcinogenic Potential following oral exposure only.
EPA Response: Thank you for your response.
Leung
From my understanding of Section 4.4, the EPA had requested that studies be repeated to exclude
both control and dosed animals when it was observed that early deaths were found in both groups
that were not necessarily associated with incident tumors (thus presuming that the deaths may have
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November 2018
been unrelated to the intervention). The reanalysis was performed, but only in male rats and only to
assess for testicular hyperplasia/tumors. Thus, it is unclear why the reanalyses were not
comprehensively performed for both male and female rats, and also systematically for other potential
tumors.
From the available information that did not reflect this exclusion, there were statistically
significantly increased proportions of hepatocellular carcinomas in female dosed rats and a trend
toward increased pancreatic carcinomas in male dosed rats, although both occurred only at single
high doses; a typical dose-response pattern was not observed. I agree with the report that mice
should also be studied, as it was reported that mice may be more susceptible toward GenX
carcinogenicity. Altogether, given these points, I agree with the summary in Section 5.6, which
describes the inability to determine overall carcinogenicity based on the substantially limited
available data. However, the observation of increased hepatocellular carcinomas in female dosed rats
should not be discounted.
EPA Response: The EPA does not discount the increased hepatocellular carcinomas in
female dosed rats and classifies this effect as adverse and related to HFPO dimer acid
ammonium salt exposure in sections 4.4 and 5.6. Review of the initial results indicated the
increased incidences of liver tumors and pancreatic acinar tumors were significant despite the
inclusion of early deaths, thus the EPA agreed to limit the reanalysis to testicular hyperplasia
and tumors in male rats only.
Sections 4.4 and 5.6 have been edited to provide additional details regarding the reanalysis.
The EPA has identified the lack of a chronic study in the most sensitive species as an
uncertainty.
Slitt
The conclusion is based on evidence that the liver is the target organ for toxicity and primary organ
for tumor development. The lack of cancer bioassay data using mice, which are the more sensitive
species, limits the conclusion. The conclusion is based on findings from a study that meets the
review criteria as being of high consideration and is in line with the EPA's Guidelines for
Carcinogenic Potential for Carcinogen Risk Assessment (USEPA, 2005). Based on this document, is
appropriate to make this conclusion based on the literature collected and studies that met criteria for
consideration. Moreover, the lack of substantive information regarding PPARa activation does not
allow one to rule out the potential for PPARa-independent activation contributing to the observed
liver effects.
EPA Response: The EPA has identified the lack of a chronic study in the most sensitive
species as an uncertainty.
Warren
I agree that the one chronic toxicity/oncogenicity study is suggestive of carcinogenic potential for
GenX, and in the absence of information that the observed tumors were rat-specific, believe the
weight-of-evidence descriptor should apply to humans exposed via the oral route. Sections 4.4 and to
a greater extent, 5.6, speak to the considerable weaknesses in the cancer bioassay data. Nonetheless,
liver and pancreatic tumors in GenX-exposed female and male rats, respectively, were significantly
elevated over controls. As rats have been shown to be considerably less sensitive than mice to many
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November 2018
non-cancer effects of GenX, a chronic bioassay in the more sensitive species would be a logical next
step. While the toxicity assessment provides an informative overview of mode of action possibilities
(e.g., cytotoxicity followed by reparative proliferation, genotoxicity though the data are mixed, and
promotion mediated by PPARa), data are insufficient to select one over the others. Obviously, if the
observed liver tumors in rats were PPARa-mediated, humans would be resistant to tumor induction
via this mechanism.
EPA Response: The EPA has identified the lack of a chronic study in the most sensitive
species as an uncertainty.
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Response to Peer Review Comments-GenX Chemicals
November 2018
SECTION III: REVIEWER ADDITIONAL AND
EDITORIAL COMMENTS
**A11 comments/suggestions/edits offered by reviewers in this section have been carefully
considered and addressed appropriately in the revised draft assessment**
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Response to Peer Review Comments-GenX Chemicals
November 2018
Chou
P. 5, Line 8: Please clarify. In this paragraph the first sentence states that the salt form of HEPO
dimer acid is solid. Then, on Line 8: "Both compounds are liquids at room temperature, ..Do you
mean "When in water, both compounds are ..."?
EPA Response: Thank you for your comment. The following revision was made in section
2.1:
"Both compounds can volatilize from water to air, where they will dissolve in aerosolized
water droplets or bind to suspended particulate matter."
P. 6: Melting point of -21.0 C must be a mistake if it is solid at room temperature. Please make
correction. The reviewer now notices that DuPont's 24637 (2008) study was conducted with 86% of
the substance, which is in a liquid form. The physical and chemical property values and descriptions
of the substance were based on a mixture of impurities. These values need to be either corrected to
be CAS no. specific or the purity of the test substance needs to be specified.
Response: Values have been corrected in the table and text in section 2.0.
P. 16, Line 10 (excluding lines in table): should the Table 2 Table "3"?
EPA Response: Yes. Change made. Thank you.
P. 16, Line 26 (excluding lines in table): should the Table 2 Table "3"?
EPA Response: Yes. Change made. Thank you.
P. 30, Line 26: This is a recovery study (DuPont-24459). Please modify the study description.
EPA Response: DuPont-24459 (2008) included an assessment of endpoints at both the 28-
day completion of dosing and after a 28-day recovery period. Because the derived reference
values assume that exposure is continuous, the assessment of endpoints after the 28-day
recovery period were not considered. Only endpoints assessed after the completion of the 28-
day continuous dosing period were considered for RfD derivation.
References used by the reviewer:
Rakhshandehroo, M., Knoch, B., Miiller, M., & Kersten, S. (2010). Peroxisome Proliferator-
Activated Receptor Alpha Target Genes. PPAR Research, 2010, 1-20.
https://doi.org/10.1155/2010/612089
EPA Response: Please see response to Charge Question 1:
Thank you for providing the reference to the review paper by Rakhshandehroo et al. (2010).
This review paper provides an overview of PPARa target genes involved in different
biological processes in the liver and the literature evaluating differences and similarities
between the genes impacted in mice and humans. The authors conclude that based on their
review of the literature, the function and specific target genes of PPARa are generally well
conserved between mouse and human specifically for lipid metabolism. However, only a
subset of those genes impacted in mice and humans are linked to the PPARa response
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Response to Peer Review Comments-GenX Chemicals
November 2018
element and none of those identified as human only fell in that category. In addition, the
review paper does not specifically address GenX chemicals or other perfluorinated
compounds (Rakhshandehroo et al., 2010).
As described in section 4.7, findings consistent with PPARa agonists were observed (e.g.,
increases in liver weight, hepatocellular hypertrophy, and increased beta-oxidation activity)
for GenX chemicals; however, data gaps exist for key events and other MO As may be
involved (Rakhshandehroo et al., 2010). Therefore, the EPA concluded that the MO A for
GenX chemicals is not clearly understood and cannot be solely attributed to PPARa.
The commenter noted that several genes involved in biotransformation and lipid metabolism
are human specific and recommended the potential effects resulting from regulation of these
human-specific PPARa target genes should be considered when determining UFa. As
pointed out above, none of those human genes were directly linked to the PPARa response
element by the authors (Rakhshandehroo et al., 2010). The UFa is applied to account for the
extrapolation of laboratory animal data to humans, and it generally is presumed to include
both toxicokinetic (i.e, absorption, distribution, metabolism, and elimination) and
toxicodynamic (i.e., MO A) aspects. The toxicokinetic portion of the UFa was accounted for
by application of EPA's Recommended Use of Body Weight4 as the Default Method in
Derivation of the Oral Reference Dose in the determination of the POD for derivation of the
RfD (USEPA, 2011). However, uncertainty related to toxicodynamic processes (i.e., MOA)
still exists; thus, EPA applied a UFa of 3 along with a UFd of 3 for data gaps. Given the lack
of specificity of the review paper to GenX chemicals, this publication was not added to the
document (Rakhshandehroo et al., 2010).
Kamendulis
In general, the document was very thorough and well written. However, in many places, particularly
in section 2, the document was very redundant, and the sentence structure was a bit cumbersome in
places. Section 5 was a summary of 4 and was also a bit redundant.
EPA Response: Section 2 has been revised to reduce redundancy.
Section 4 provides a study-by-study summary of the available data for GenX chemicals.
Given the extensive nature of the reporting in the DuPont/Chemours studies, this section
serves as a more succinct presentation of the relevant data. Section 5 is an organ system-
specific synthesis of the weight of the evidence to determine potential hazards of GenX
chemicals exposure.
P7 - section 2.2 the second sentence does not appear complete "The degradation data suggest that
the substances will be very (i.e., half-life [T1/2] > 6 months) in air, water, soil, and sediments".
EPA Response: Thank you for the comment. The following revision was made in section
2.2:
"The degradation data suggest that the substances will be very persistent (i.e., half-life [T1/2]
> 6 months) in air, water, soil, and sediments."
P16 - in 2 instances, references to table 2 are made in the text, however, I believe they are referring
to table 3.
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November 2018
EPA Response: Yes. Change made. Thank you.
P40 - second paragraph - the study data in discussed in relation to PFOA effects. Up to this point,
no other study descriptions contained references to PFOA effects. Should this information be
included in the study description?
EPA Response: Thank you for the comment. The text was edited to remove PFOA from
section 4.6.1.
P51 - last sentence of the first paragraph does not appear complete "While considered adverse, the
hematological effects are inconsistently observed, especially as study duration increases, thus EPA
did not hematotoxicity as the critical effect".
EPA Response: Thank you for the comment. The following revision was made 6.1:
"Furthermore, while considered adverse, the hematological effects were inconsistently
observed, especially as study duration increased."
P61 - second to last paragraph, last sentence - "Differences in toxicokinetics in rodents could result
in sex-specific differences in the toxicity studies of them." - it is unclear what is meant by this
statement.
EPA Response: Thank you for the comment. The following revision was made in section
7.6:
"The observed sex-specific toxicokinetic differences in rodents likely contribute to the
observed sex-specific differences in toxic response."
Leung
The draft report is well-written and provides a clear summary on what is currently known regarding
the potential adverse health effects of GenX chemicals.
a. However, I would suggest a more comprehensive "summary of health hazards" in Section 5, by
better utilizing the information presented in the toxicity studies of Section 4 and perhaps the
inclusion of a corresponding table. There are multiple organ systems and health effects which are
not summarized (e.g., abnormalities in endocrine systems [glucose and triglycerides
concentrations, adrenal cortex hypertrophy], abnormalities in serum clinical chemistries),
differences in weight, differences in hair growth, non-neoplastic effects, etc.). These may have
not been statistically significant, but it would still be helpful to place in context with the other
organ systems mentioned in Section 5.
EPA Response: As described in section 3.3.4, the EPA focused its review primarily on
statistically significant adverse effects (see section 5). Section 4 provides a study-by-study
summary of the available data for GenX chemicals. Given the extensive nature of the
reporting in the DuPont/Chemours studies, this section serves as a more succinct presentation
of the relevant data. Section 5 is an organ system-specific synthesis of the weight of the
evidence to determine potential hazards of GenX chemicals exposure. Additionally, the EPA
has made all the DuPont/Chemours study data (including individual animal data) available on
its HERO website at https://hero.epa.gov/hero/index.cfm/proiect/page/proiect id/2627.
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Response to Peer Review Comments-GenX Chemicals
November 2018
b. As such, the studies presented in Section 4 are important but could be better and more
systematically organized. Suggest the use of additional subheadings in Sections 4.2 to 4.5 to
guide this long narrative text.
EPA Response: Subheadings denoting study author and date have been added in sections 4.2
to 4.5.
Slitt
The document reads well and summarizes the findings appropriately.
EPA Response: Thank you for your response.
Warren
The toxicity assessment is well written, though there are numerous minor errors in syntax, subject-
verb agreement, and punctuation, none of which detract significantly from the effort. Overall, the
toxicity assessment should be characterized as a high-quality work product typical of USEPA. See
several recommendations for minor editorial changes below.
1)	The toxicity assessment might want to note that Pan et al. (2017) not only examined blood, liver
and muscle of common carp, but also found detectable levels in the sera of Chinese residents
residing near the fluoropolymer production plant
EPA Response: The EPA acknowledges this information is provided in the reference cited
and has cited this reference in the updated occurrence section (1.3).
2)	On p. 13, "fetus mice" might be better expressed as "fetal mice"
EPA Response: Edit accepted. Thank you.
3)	Table 2 at the end of the 1st two paragraphs on p. 16 should be Table 3
EPA Response: Edit accepted. Thank you.
4)	the last sentence on p. 19 should read 28 and 95, not 28 and 90
EPA Response: Edit accepted. Thank you.
5)	change lines 6 and 7 on p. 20 to read .. .(e.g., effects such as liver toxicity), and populations at
risk of exposure to HFPO....;
EPA Response: Edit accepted. Thank you.
6)	change "undermined" to "undetermined" toward the bottom of p. 31
EPA Response: Edit accepted. Thank you.
7)	place a period after (0%-8.3%) on p. 36 and begin a new sentence
EPA Response: Edit accepted. Thank you.
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Response to Peer Review Comments-GenX Chemicals
November 2018
8)	insert the word "study" after toxicity in the 1st line of the last paragraph on p. 38
EPA Response: Edit accepted. Thank you.
9)	consider rewriting the paragraph immediately before section 4.6 to read as follows: The NOAEL
for this prenatal and developmental toxicity study is 10 mg/kg-day based on an increase in early
deliveries, decreases in gravid uterine weight, and decreased fetal weights for both sexes, all
having a LOAEL of 100 mg/kg-day
EPA Response: Edit accepted. Thank you.
10)	should the "to" in the fourth sentence on p. 41 be changed to "did"
EPA Response: Thank you for your comment. The following edit was made in section 4.6.1:
Ultimately, this study found that HFPO dimer acid ammonium salt exhibited a weaker
binding affinity and bound differently to hL-FABP than PFOA and PFOS (Sheng et al.,
2018).
11)	delete the word "increasing" from the 8th line of paragraph 2 on p. 43
EPA Response: Edit accepted. Thank you.
12)	consider an alternative to the phrase "suggestive of hazard" on p. 45
EPA Response: Edit accepted. Thank you.
13)	delete the word "female" in the 2nd line of the 2nd paragraph of Section 5.5 on p. 46
EPA Response: Edit accepted. Thank you.
14)	insert the word "consider" or "select" after the word "not" in line 7 of p. 51
EPA Response: Edit accepted. Thank you.
15)	consider changing the first sentence on p. 52 to read as follows: Additionally, there were
increases in serum liver proteins at 0.5 mg/kg-day in males, though they did not statistically
significantly differ from control
EPA Response: Clarifying edit added to text.
16)	delete "by" or "via" from the last sentence of the 1st paragraph on p. 53
EPA Response: Edit accepted. Thank you.
17)	consider changing the phrase "liver as a hazard" at the end of the 1st paragraph on p. 58
EPA Response: Edit accepted. Thank you.
18)	insert the word "studies" after "other" in line 4 of the 2nd paragraph on p. B-l
EPA Response: Edit accepted. Thank you.
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Response to Peer Review Comments-GenX Chemicals	November 2018
19) change nominator to numerator on p. B-l 1
EPA Response: Edit accepted. Thank you.
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Response to Peer Review Comments-GenX Chemicals
November 2018
APPENDIX A: INDIVIDUAL REVIEWER
COMMENTS
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Response to Peer Review Comments-GenX Chemicals
November 2018
COMMENTS SUBMITTED BY
Karen Chou, PhD
Associate Professor, Department of Animal Science
Michigan State University
East Lansing, Michigan
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Response to Peer Review Comments-GenX Chemicals
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External Peer Review of EPA's Draft Human Health Toxicity Values
for Hexafluoropropylene Oxide (HFPO) Dimer Acid
and its Ammonium Salt (GenX Chemicals)
1.	The document describes the process for identifying and selecting pertinent studies. Please
comment on whether the literature search strategy, study selection considerations, and
study evaluation considerations are appropriate and clearly described. Please identify
additional peer-reviewed studies that the assessment should consider.
The literature search strategy and study evaluation considerations are clearly described and
appear to be appropriate.
The reviewer suggests an additional article by Rakhshandehroo. M.. Knoch. B.. Mullen M.. and
K erst en. S. (2010). Peroxisome Proliferator-Activated Receptor Alpha Target Genes. PPAR
Research. 2010. 1-20.
Using primary hepatocytes culture from mice and human, this study demonstrated that human
hepatocytes are sensitive to enzymatic induction by PPARalpha agonists. Of the 208 PPARa
targeted genes in mouse hepatocytes, 85 (41%) are also targeted in human hepatocytes. In
addition, 12 genes targeted by PPARa in human hepatocytes are not in mouse hepatocytes. Six
of the human- specific genes are in the biotransformation pathways and the other six are in the
lipid metabolism pathways, including the pathways of peroxisomal P-oxidation, microsomal co-
hydroxylation, lipogenesis, plasma triglyceride metabolism, and cholesterol/bile transport &
metabolism. The potential manifestation of the effects on these human-specific target genes
should be considered when determining UFh.
2.	For GenX chemicals the critical study chosen for determining the subchronic and chronic
RfDs is the oral reproductive/developmental toxicity screening study in adult mice (DuPont
18405-1037, 2010) and the critical effect is liver effects (single cell necrosis) in adult males.
Is the selection of the critical study and critical effect for the derivation of the subchronic
and chronic RfDs for GenX chemicals scientifically justified and defensible?
a.	If so, please explain your justification.
b.	If not, please provide your rationale and detail an alternative critical study and/or
critical effect you would select to support the derivation of the subchronic and
chronic RfDs.
The selection of liver effects as the critical effect for derivation of oral subchronic and chronic
RfDs, using the oral reproductive/developmental toxicity screening study in adult mice, is well
justified. It is justified based on increases in liver weight, relatively high number of animals (22-
25) per treatment group for liver endpoints, and consistent adverse effects corroborated in other
studies presented in the Draft. The weaknesses of other studies are well described in the draft on
p. 51-52.
3.	EPA employed benchmark dose modeling in the identification of a point-of-departure
(POD) for GenX chemicals (USEPA 2012). Is the modeling approach, selection of
benchmark response level, and the selected model used to identify the POD for derivation
of the RfD scientifically justified and defensible?
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Response to Peer Review Comments-GenX Chemicals
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The reviewer agrees with the selection of BMDL10 from Table E-2 and Table E-4. The
modeling approach, selection of benchmark response level, and the selected model used to
identify the PODs are well justified and defensible.
4.	Given what is known and not known about the interspecies differences in toxicokinetics of
GenX chemicals, EPA applied body weight to the % allometric scaling to adjust the POD to
estimate a human equivalent dose (HED) in the derivation of the respective RfDs (USEPA
2011).
a.	Is applying the body weight to the % for GenX chemicals scientifically justified and
defensible? If not, please provide your rationale and detail the alternative approach
you would use.
The reviewer agrees to the use of3A allometric scaling to adjust the POD to estimate a human
equivalent dose (HED) in the derivation of the respective RfDs in the draft assessments.
b.	Do the methods used to derive the RfDs for GenX chemicals appropriately account
for uncertainties in evaluating the toxicokinetic differences between the
experimental animal data and humans?
Considering the differences of enzymes targeted by PPARa activation between the mouse and
the human (see comments for Item 1), the UFh and UFd values used in this draft are appropriate;
any values less than 3 would not be acceptable.
5.	EPA has evaluated and applied where appropriate uncertainty factors to account for
intraspecies variability (UFH), interspecies differences (UFA), database limitations (UFD),
duration (UFS), and LOAEL-to-NOAEL extrapolation (UFL) for GenX chemicals.
a.	Has uncertainty been adequately accounted for in the derivation of the RfDs? Please
describe and provide suggestions, if needed.
Please see response to Question 4b.
b.	Does the provided scientific rationale support the application of the selected
uncertainty factors? Please explain.
The draft provided appropriate scientific rationale for the selection of the UF values. Additional
justification for UFAmay be used. See comments for Question 1.
6.	The draft assessment for GenX chemicals identifies liver effects as a potential human
hazard. EPA evaluated the available evidence for liver effects, including the potential role
of PPARa, using Hall et al. (2012) criteria for adversity.
a.	Please comment on whether the available data have been clearly and appropriately
synthesized for these toxicological effects.
Yes, the draft clearly synthesized the toxicological effects.
b.	Please comment on whether the weight of evidence for hazard identification has
been clearly described and scientifically justified.
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Response to Peer Review Comments-GenX Chemicals
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Yes, the weight of evidence for hazard identification has been clearly described, and
scientifically justified to meet the definition of "adverse".
c. Please comment on whether the conclusions regarding adversity are scientifically
supported and clearly described.
Yes, the conclusions are supported by scientific evidences. Please also see comments above.
7.	The draft assessment concludes that there is suggestive evidence of carcinogenic potential
for GenX chemicals and that this descriptor applies to oral routes of human exposure
(USEPA 2005). Please comment on whether the available animal and mechanistic studies
support this conclusion.
Currently, there is no sufficient evidence to determined that the adenomas and adenocarcinoma
observed in rodent liver are not relevant in humans. Nonetheless, the evidence in rodent
adenocarcinoma present in the existing studies is not very strong. The reviewer agrees to the
descriptor "there is suggestive evidence of carcinogenic potential for GenX chemicals."
8.	Editorial or Additional Comments: Please provide any editorial or additional comments
you would like to make here. These should be any comments that are not in direct response
to the technical charge questions above.
P. 5, Line 8: Please clarify. In this paragraph the first sentence states that the salt form of HEPO
dimer acid is solid. Then, on Line 8: "Both compounds are liquids at room temperature, ...". Do
you mean "When in water, both compounds are ..."?
p. 6: Melting point of -21.0 C must be a mistake if it is solid at room temperature. Please make
correction. The reviewer now notices that DuPont's 24637 (2008) study was conducted with
86% of the substance, which is in a liquid form. The physical and chemical property values and
descriptions of the substance were based on a mixture of impurities. These values need to be
either corrected to be CAS no. specific or the purity of the test substance needs to be specified.
p. 16, Line 10 (excluding lines in table): should the Table 2 Table "3"?
p. 16, Line 26 (excluding lines in table): should the Table 2 Table "3"?
p. 30, Line 26: This is a recovery study (DuPont-24459). Please modify the study description.
References used by the reviewer:
Rakhshandehroo, M., Knoch, B., Miiller, M., & Kersten, S. (2010). Peroxisome Proliferator-
Activated Receptor Alpha Target Genes. PPAR Research, 2010, 1-20.
https://doi.org/10.1155/2010/612Q89
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Response to Peer Review Comments-GenX Chemicals
November 2018
COMMENTS SUBMITTED BY
Lisa M. Kamendulis, PhD
Associate Professor
and
Core Director, Oxidative Stress and Environmental Analysis Core
Department of Environmental Health
School of Public Health
Indiana University
Bloomington, Indiana
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Response to Peer Review Comments-GenX Chemicals
November 2018
External Peer Review of EPA's Draft Human Health Toxicity Values
for Hexafluoropropylene Oxide (HFPO) Dimer Acid
and its Ammonium Salt (GenX Chemicals)
1.	The document describes the process for identifying and selecting pertinent studies. Please
comment on whether the literature search strategy, study selection considerations, and
study evaluation considerations are appropriate and clearly described. Please identify
additional peer-reviewed studies that the assessment should consider.
Yes, the literature search strategy, study selection and evaluation considerations were very well
presented and sufficiently clear. The process used was described well and was a very thorough
and transparent approach to systematically evaluate each of the available scientific studies that
described the health effects of GenX chemicals.
I am unaware of other peer-reviewed studies that should be included in this assessment.
2.	For GenX chemicals the critical study chosen for determining the subchronic and chronic
RfDs is the oral reproductive/developmental toxicity screening study in adult mice (DuPont
18405-1037, 2010) and the critical effect is liver effects (single cell necrosis) in adult males.
Is the selection of the critical study and critical effect for the derivation of the subchronic
and chronic RfDs for GenX chemicals scientifically justified and defensible?
a.	If so, please explain your justification.
I agree with the selection of the critical study selected for deriving RfD's for GenX chemicals
(DuPont-18405-1037 2010). This oral reproductive/developmental toxicity study in mice
identified liver effects, specifically single-cell necrosis in males, as the critical effect and was
used to derive the subchronic and chronic RfDs for GenX chemicals. As noted, this study
utilized a larger sample size (n=24 / dose) and provided the most health protective PODhed.
Further, this study was an 84/85 day study compared to the other mouse study (28 days). In
addition, several other studies provide support for the selection of liver necrosis as the critical
effect following oral exposure to GenX chemicals (DuPont-24459 2008; DuPont-24447 2008;
DuPont-18405-1307 2010; DuPont-18405-1238 2013; DuPont-18405-841 2010). Liver effects
(changes in liver enzyme levels, histopathological lesions, and tumors) were observed in both
male and female mice and rats at varying durations of exposures and doses of GenX chemicals.
b.	If not, please provide your rationale and detail an alternative critical study and/or
critical effect you would select to support the derivation of the subchronic and
chronic RfDs.
N/A
3.	EPA employed benchmark dose modeling in the identification of a point-of-departure
(POD) for GenX chemicals (USEPA 2012). Is the modeling approach, selection of
benchmark response level, and the selected model used to identify the POD for derivation
of the RfD scientifically justified and defensible?
Yes, I agree with the approach used. As there are no biologically based dose-response models
available for GenX chemicals, benchmark dose modeling was used, and was consistent with
EPA's guidance document (USEPA 2012). The BMD and the BMDL were estimated using a
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Response to Peer Review Comments-GenX Chemicals
November 2018
BMR of 10% extra risk for dichotomous data, and candidate PODs were estimated from all 3
doses (plus control) for the critical study.
4.	Given what is known and not known about the interspecies differences in toxicokinetics of
GenX chemicals, EPA applied body weight to the % allometric scaling to adjust the POD to
estimate a human equivalent dose (HED) in the derivation of the respective RfDs (USEPA
2011).
a.	Is applying the body weight to the % for GenX chemicals scientifically justified and
defensible? If not, please provide your rationale and detail the alternative approach
you would use.
Yes, the application of3A allometric scaling was justified and adequately presented. Any
uncertainty in using this approach is accounted for by application of uncertainty factors (see
answers to question 5 below).
b.	Do the methods used to derive the RfDs for GenX chemicals appropriately account
for uncertainties in evaluating the toxicokinetic differences between the
experimental animal data and humans?
Yes, the methods that were used to derive the RfD's for GenX chemicals took into consideration
toxicokinetic differences between animals and humans. Further, any uncertainties are accounted
for by the application of uncertainty factors (see question 5 below).
5.	EPA has evaluated and applied where appropriate uncertainty factors to account for
intraspecies variability (UFH), interspecies differences (UFA), database limitations (UFD),
duration (UFS), and LOAEL-to-NOAEL extrapolation (UFL) for GenX chemicals.
a. Has uncertainty been adequately accounted for in the derivation of the RfDs? Please
describe and provide suggestions, if needed.
Yes, uncertainty has been adequately accounted for in the derivation of RfDs for GenX
chemicals. An interspecies uncertainty factor of 3 was applied to account for uncertainty in
extrapolating from laboratory animals to humans. A factor of 3 was used in lieu of a 10 since a
PODhed was derived from the BMDL as specified in EPA's guidance document (USEPA
201 lb). As the allometric scaling accounts for some aspects of species extrapolation, some
uncertainty remains. Thus, the application of an UF of 3 appears appropriate.
An intraspecies uncertainty factor (UFh) of 10 is assigned to account for variability in the
responses within the human populations. This is also appropriate.
The BMD approach was utilized, therefore application of a UF for using a LOAEL to NOAEL is
not needed.
For the chronic RfD, although a chronic bioassay is available (in rats), a UF of 3 was applied for
extrapolation from a subchronic to a chronic exposure duration (UFs) of 3. The 2-year study
identified a NOAEL of 1 mg/kg-day for liver effects (increased liver enzyme levels and
centrilobular hepatocellular hypertrophy and cystic focal degeneration in males and centrilobular
necrosis in both sexes), consistent with the effects observed in the oral
reproductive/developmental study in mice, however, at a much higher NOAEL. As data suggests
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Response to Peer Review Comments-GenX Chemicals
November 2018
that rats appear to be less sensitive than mice, a UF of 3 was used to account for extrapolation
from subchronic to chronic exposure duration for the chronic RfD. This appears appropriate.
While only a limited number of studies have been conducted for GenX chemicals, a database
uncertainty factor (UFd) of 3 was applied. This is due to the quality of the available studies -
which include acute toxicity, metabolism and toxicokinetics, genotoxicity, and systemic toxicity
studies in mice and rats with dosing durations of up to 2 years, and one reproductive and
developmental toxicity study in mice and one prenatal and developmental toxicity study in rats.
Many of these studies were conducted under GLP conditions, with full study reports available
and reviewed. Thus, the application of a UFd of 3 appears appropriate.
b. Does the provided scientific rationale support the application of the selected
uncertainty factors? Please explain.
I have addressed this comment in my responses to 5a above - the application of the UF's used to
derive RfD's for GenX chemicals was scientifically based and well described.
6.	The draft assessment for GenX chemicals identifies liver effects as a potential human
hazard. EPA evaluated the available evidence for liver effects, including the potential role
of PPARa, using Hall et al. (2012) criteria for adversity.
a.	Please comment on whether the available data have been clearly and appropriately
synthesized for these toxicological effects.
I agree that the available data were adequately and clearly described.
b.	Please comment on whether the weight of evidence for hazard identification has
been clearly described and scientifically justified.
Yes, I feel that the weight of evidence for effects on the liver, as well as other endpoints
(hematological and immune systems, and reproductive and developmental) was scientifically
evaluated and justified.
c.	Please comment on whether the conclusions regarding adversity are scientifically
supported and clearly described.
The liver effects observed following exposure to GenX chemicals were consistently seen across
several studies including both male and female rats and mice, for short-term and chronic
exposures. Thus, the conclusions drawn are scientifically supported and adequately described in
the document.
7.	The draft assessment concludes that there is suggestive evidence of carcinogenic potential
for GenX chemicals and that this descriptor applies to oral routes of human exposure
(USEPA 2005). Please comment on whether the available animal and mechanistic studies
support this conclusion.
There are no dermal or inhalation studies available that evaluated evaluating cancer, however,
one oral exposure bioassay for HFPO dimer acid ammonium salt in rats showed an increase in
liver tumors (females) and pancreatic acinar adenomas and carcinomas (combined, males).
While there were increases in tumors at the high dose, a dose-response pattern was not observed.
Further, data suggests that mice may be more sensitive to GenX chemicals compared to rats. As
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Response to Peer Review Comments-GenX Chemicals
November 2018
such, based on the available data, I agree with EPA's Guidelines for Carcinogen Assessment that
classifies GenX chemicals as Suggestive Evidence of Carcinogenic Potential following oral
exposure only.
8. Editorial or Additional Comments: Please provide any editorial or additional comments
you would like to make here. These should be any comments that are not in direct response
to the technical charge questions above.
In general, the document was very thorough and well written. However, in many places,
particularly in section 2, the document was very redundant, and the sentence structure was a bit
cumbersome in places. Section 5 was a summary of 4 and was also a bit redundant.
P7 - section 2.2 the second sentence does not appear complete "The degradation data suggest
that the substances will be very (i.e., half-life [T1/2] > 6 months) in air, water, soil, and
sediments".
P16 - in 2 instances, references to table 2 are made in the text, however, I believe they are
referring to table 3.
P40 - second paragraph - the study data in discussed in relation to PFOA effects. Up to this
point, no other study descriptions contained references to PFOA effects. Should this information
be included in the study description?
P51 - last sentence of the first paragraph does not appear complete "While considered adverse,
the hematological effects are inconsistently observed, especially as study duration increases, thus
EPA did not hematotoxicitv as the critical effect".
P61 - second to last paragraph, last sentence - "Differences in toxicokinetics in rodents could
result in sex-specific differences in the toxicity studies of them." - it is unclear what is meant by
this statement.
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Response to Peer Review Comments-GenX Chemicals
November 2018
COMMENTS SUBMITTED BY
Angela M. Leung, MD
Health Sciences Clinical Assistant Professor of Medicine
David Geffen School of Medicine
University of California Los Angeles
and
Division of Endocrinology, Diabetes, and Metabolism
Department of Medicine
VA Greater Los Angeles Healthcare System
Los Angeles, California
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Response to Peer Review Comments-GenX Chemicals
November 2018
External Peer Review of EPA's Draft Human Health Toxicity Values
for Hexafluoropropylene Oxide (HFPO) Dimer Acid
and its Ammonium Salt (GenX Chemicals)
1.	The document describes the process for identifying and selecting pertinent studies. Please
comment on whether the literature search strategy, study selection considerations, and
study evaluation considerations are appropriate and clearly described. Please identify
additional peer-reviewed studies that the assessment should consider.
The draft report describes the systematic approach taken toward the identification and selection
of pertinent studies on this topic. The search strategy is overall easy to understand and
transparent, although there are some concerns and several areas which could be better addressed:
a.	The most important issue is that the search results highlight the overall relative scarcity of
available data regarding the potential risks of Gex chemicals. Almost all of the literature used
to base the current assessments are animal studies conducted by Dupont submitted as part of
the TSCA. The HERO database shows 119 included references, from which only 29 are from
non-Dupont sources (and not all, albeit most, are necessarily from peer-reviewed journals.)
The lack of rigorous studies published in well-regarded journals spanning the animal, human,
and epidemiologic literature is a substantial limitation to interpreting the health impacts of
exposure to these chemicals.
b.	One concern regarding the search strategy, as shown in Appendix A (Table A-5), is that
studies for which only an abstract was available were excluded. What does this signify, and
were there any further attempts done to assess the relevance of these excluded studies (which
are not shown)?
c.	The draft report demonstrates the approach used to rank the relevance and usefulness of
included studies. Studies were then scored by various EPA OPPT criteria quite rigorously
(Appendix B) in an objective a manner as possible by several reviewers. It would be relevant
to state the number of reviewers, whose aggregate assessment was reported as weighted
scores, involved in this process, as well as their professional areas of expertise.
d.	One additional comment regarding the scoring system is regarding Metric #22, which
assessed "Health outcomes thought to be unrelated to exposure". It does not appear that are
any further details regarding what these outcomes may have been, although there are
occasional comments when such health outcomes were not reported in the study. Further
detail regarding these health outcomes would provide greater context to the conclusions
posed by this draft report.
2.	For GenX chemicals the critical study chosen for determining the subchronic and chronic
RfDs is the oral reproductive/developmental toxicity screening study in adult mice (DuPont
18405-1037, 2010) and the critical effect is liver effects (single cell necrosis) in adult males.
Is the selection of the critical study and critical effect for the derivation of the subchronic
and chronic RfDs for GenX chemicals scientifically justified and defensible?
a. If so, please explain your justification.
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Response to Peer Review Comments-GenX Chemicals
November 2018
b. If not, please provide your rationale and detail an alternative critical study and/or
critical effect you would select to support the derivation of the subchronic and
chronic RfDs.
This study in which the subchronic and chronic RfDs is based upon consisted of 150 mice, in
which histopathologic changes and increased liver weights were seen in all three dose groups.
However, as summarized in the draft report, these findings have also largely been supported by
at least seven other studies, including one from the peer-reviewed published literature, although
only one was considered chronic (i.e. >90 days duration). Evidence of hepatic damage is also
supported by the very significant increases in serum transaminase levels among mice exposed to
the higher doses. Overall, availability of more than one study assessing chronic exposure would
be relevant toward the hepatic and other potential clinical endpoints.
The draft report describes that the other organ systems and endpoints in which adverse effects
have been found were hematology, renal, development/reproduction, immunology, and
carcinogenesis (Section 5). No differences in survival at a planned 12-month necropsy timepoint
were found in the one available chronic study. Regarding these other organ systems:
a.	It is described that the maximum decrement of hemoglobin/hematocrit levels in male mice
and in rats was 12% from several studies assessing doses up to 100 mg/kg/day lasting up to
180 days. This may be clinical significant, and consideration of this endpoint in greater detail
may be relevant. Additionally, in the one chronic study, female mice and rats had up to a
24% decrease in hemoglobin/hematocrit levels, further supporting this as a possible critical
effect.
b.	Regarding renal effects, the primary endpoints that have been assessed are weight of the
kidneys, microscopic changes of the kidney, and blood urea nitrogen concentrations. The
draft report states that given the limited changes in these parameters, renal toxicity is unlikely
a critical effect. Animal physiology is not my area of expertise, but there certainly other
factors important in the assessment of human renal function like serum creatinine
concentrations and filtration rate that are also clinically important.
c.	It is unfortunate that the potential developmental/reproductive toxicities are based only on
two animal studies. From the description of these, these toxicities are rare and may not be
clinically significant. However, only F1 mice were studied and there are no data on potential
effects spanning more than two generations.
d.	The data for immunotoxicity are even more limited, but suggest some adverse effects among
female mice. In the absence of more data, it is difficult to ascertain whether these preliminary
findings should be considered critical effects.
e.	I agree with the summary in Section 5.6, which describes the inability to determine overall
carcinogenicity based on the substantially limited available data. However, the observation of
increased hepatocellular carcinomas in female dosed rats should not be discounted.
3. EPA employed benchmark dose modeling in the identification of a point-of-departure
(POD) for GenX chemicals (USEPA 2012). Is the modeling approach, selection of
benchmark response level, and the selected model used to identify the POD for derivation
of the RfD scientifically justified and defensible?
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Response to Peer Review Comments-GenX Chemicals
November 2018
BMD modeling is not within my area of expertise. However, it appears that the draft report
makes a reasonable effort to identify clinically-relevant endpoints required for the modeling from
the available limited data. I defer to the other reviewers regarding whether the translation of a
POD to a human dose equivalent, the determination of uncertainty factors (UFs), and the
mathematical calculations of the corresponding subchronic and chronic RfDs, are appropriate.
4.	Given what is known and not known about the interspecies differences in toxicokinetics of
GenX chemicals, EPA applied body weight to the % allometric scaling to adjust the POD to
estimate a human equivalent dose (HED) in the derivation of the respective RfDs (USEPA
2011).
a.	Is applying the body weight to the 3A for GenX chemicals scientifically justified and
defensible? If not, please provide your rationale and detail the alternative approach
you would use.
b.	Do the methods used to derive the RfDs for GenX chemicals appropriately account
for uncertainties in evaluating the toxicokinetic differences between the
experimental animal data and humans?
This is not my area of expertise, thus I defer to the other reviewers.
5.	EPA has evaluated and applied where appropriate uncertainty factors to account for
intraspecies variability (UFH), interspecies differences (UFA), database limitations (UFD),
duration (UFS), and LOAEL-to-NOAEL extrapolation (UFL) for GenX chemicals.
a.	Has uncertainty been adequately accounted for in the derivation of the RfDs? Please
describe and provide suggestions, if needed.
b.	Does the provided scientific rationale support the application of the selected
uncertainty factors? Please explain.
This is not my area of expertise, thus I defer to the other reviewers.
6.	The draft assessment for GenX chemicals identifies liver effects as a potential human
hazard. EPA evaluated the available evidence for liver effects, including the potential role
of PPARa, using Hall et al. (2012) criteria for adversity.
a.	Please comment on whether the available data have been clearly and appropriately
synthesized for these toxicological effects.
b.	Please comment on whether the weight of evidence for hazard identification has
been clearly described and scientifically justified.
c.	Please comment on whether the conclusions regarding adversity are scientifically
supported and clearly described.
The Hall 2012 reference helps delineates the differences between physiologic adaptive responses
vs pathologic toxic effects resulting in hepatocellular hypertrophy. Using this framework, the
draft report summarizes the available studies with hepatic endpoints, which did show increased
proportions of dosed animals with increased liver weights, abnormal serum liver function tests,
hepatocellular hypertrophy, and hepatocellular necrosis. These studies were also the basis for the
observation that mice may be more sensitive to toxic hepatic effects than rats, given the
development of the adverse findings at comparably higher doses in rats. The report does not
comment on whether steatosis was assessed and/or observed in these studies.
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Response to Peer Review Comments-GenX Chemicals
November 2018
The hepatic toxicologic effects are consistent and reproducible, as seen from the eight studies of
either mice or rats and in both genders. Altogether, the conclusions regarding adversity in the
draft report are appropriately summarized.
7.	The draft assessment concludes that there is suggestive evidence of carcinogenic potential
for GenX chemicals and that this descriptor applies to oral routes of human exposure
(USEPA 2005). Please comment on whether the available animal and mechanistic studies
support this conclusion.
From my understanding of Section 4.4, the EPA had requested that studies be repeated to
exclude both control and dosed animals when it was observed that early deaths were found in
both groups that were not necessarily associated with incident tumors (thus presuming that the
deaths may have been unrelated to the intervention). The reanalysis was performed, but only in
male rats and only to assess for testicular hyperplasia/tumors. Thus, it is unclear why the
reanalyses were not comprehensively performed for both male and female rats, and also
systematically for other potential tumors.
From the available information that did not reflect this exclusion, there were statistically
significantly increased proportions of hepatocellular carcinomas in female dosed rats and a trend
toward increased pancreatic carcinomas in male dosed rats, although both occurred only at single
high doses; a typical dose-response pattern was not observed. I agree with the report that mice
should also be studied, as it was reported that mice may be more susceptible toward GenX
carcinogenicity. Altogether, given these points, I agree with the summary in Section 5.6, which
describes the inability to determine overall carcinogenicity based on the substantially limited
available data. However, the observation of increased hepatocellular carcinomas in female dosed
rats should not be discounted.
8.	Editorial or Additional Comments: Please provide any editorial or additional comments
you would like to make here. These should be any comments that are not in direct response
to the technical charge questions above.
The draft report is well-written and provides a clear summary on what is currently known
regarding the potential adverse health effects of GenX chemicals.
a.	However, I would suggest a more comprehensive "summary of health hazards" in Section 5,
by better utilizing the information presented in the toxicity studies of Section 4 and perhaps
the inclusion of a corresponding table. There are multiple organ systems and health effects
which are not summarized (e.g., abnormalities in endocrine systems [glucose and
triglycerides concentrations, adrenal cortex hypertrophy], abnormalities in serum clinical
chemistries), differences in weight, differences in hair growth, non-neoplastic effects, etc.).
These may have not been statistically significant, but it would still be helpful to place in
context with the other organ systems mentioned in Section 5.
b.	As such, the studies presented in Section 4 are important but could be better and more
systematically organized. Suggest the use of additional subheadings in Sections 4.2 to 4.5 to
guide this long narrative text.
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Response to Peer Review Comments-GenX Chemicals
November 2018
COMMENTS SUBMITTED BY
Angela L. Slitt, PhD
Associate Professor
Department of Biomedical and Pharmaceutical Sciences
and
Director, Graduate Programs, College of Pharmacy
University of Rhode Island
Kingston, Rhode Island
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Response to Peer Review Comments-GenX Chemicals
November 2018
External Peer Review of EPA's Draft Human Health Toxicity Values
for Hexafluoropropylene Oxide (HFPO) Dimer Acid
and its Ammonium Salt (GenX Chemicals)
1.	The document describes the process for identifying and selecting pertinent studies. Please
comment on whether the literature search strategy, study selection considerations, and
study evaluation considerations are appropriate and clearly described. Please identify
additional peer-reviewed studies that the assessment should consider.
The literature search strategy was appropriate and thorough. It was well described and included clear
criteria for the inclusion and exclusion of studies. The databases utilized (i.e. PubMed, WOS,
Toxline, and TSCATS1) are appropriate and the search terms were comprehensive in nature. The
methods in section B used to evaluate study quality were systematic and thorough. The metrics and
criteria applied for Animal and in vitro toxicity studies were exceedingly thorough and well defined.
The weighting and relative important used for weighting the criteria was appropriate. Overall, this
semi-quantitative approach in evaluating the data/studies to be included is considered to be is
appropriate and thorough.
A minor comment is that exposure for in vitro studies on page A-9, Table A-5 should be described.
It is assumed that it is via addition of chemical to media, however it should be described for what
criteria would be constitute inclusion/exclusion for in vitro studies. For example, solubility and
vehicle could be mentioned.
2.	For GenX chemicals the critical study chosen for determining the subchronic and chronic
RfDs is the oral reproductive/developmental toxicity screening study in adult mice (DuPont
18405-1037, 2010) and the critical effect is liver effects (single cell necrosis) in adult males.
Is the selection of the critical study and critical effect for the derivation of the subchronic
and chronic RfDs for GenX chemicals scientifically justified and defensible?
a. If so, please explain your justification.
Yes, a survey of the data included in the report points to liver effects in adult male is appropriate and
defensible. The study meets the criteria listed in almost all elements for being considered of high
quality. It meets every metric as high or medium, such as test substance, test setup, exposure
characterization, etc. The critical effect of single cell necrosis in male mice is based on n=24-25 F0
males, which a large "n". The selection of this study is scientifically justifiable based on it
sufficiently meeting the review criteria. The selection of single-cell necrosis is a reasonable measure
to use as a critical effect. This measure has been used previously for PFOA and PFOS, in which
rodent studies that have demonstrated hepatotoxicity demonstrate concordance with studies in
human populations illustrating slight elevation serum in liver enzymes.
It should be noted that there was PFOA contamination for the test substance for DuPont 18405-1037,
2010 lists that purity of the test article at 84%. Another study listed in the document that meets the
evaluation criteria with high confidence (DuPont -24459, 2008) lists a slightly higher purity of the
test article (88% purity). This 28-day oral dosing study that evaluated 0.1, 3 and 30 mg/kg/day did
not observe any statistically significant increases in liver single cell necrosis at 0.1 mg/kg, but did
observe significant elevation of serum liver enzymes, liver weight, and single cell necrosis in males
at 3 mg/kg. Given that the purity of the test article was slightly higher, this study should also be
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Response to Peer Review Comments-GenX Chemicals
November 2018
considered along with DuPont 18405-1037, 2010 for considering 0.1 mg/kg in male mice for the
RfD.
3.	EPA employed benchmark dose modeling in the identification of a point-of-departure
(POD) for GenX chemicals (USEPA 2012). Is the modeling approach, selection of
benchmark response level, and the selected model used to identify the POD for derivation
of the RfD scientifically justified and defensible?
This is out of my area of expertise, so I decline responding to this question.
4.	Given what is known and not known about the interspecie differences in toxicokinetics of
GenX chemicals, EPA applied body weight to the % allometric scaling to adjust the POD to
estimate a human equivalent dose (HED) in the derivation of the respective RfDs (USEPA
2011).
a.	Is applying the body weight to the % for GenX chemicals scientifically justified and
defensible? If not, please provide your rationale and detail the alternative approach
you would use.
This is not within my expertise to respond.
b.	Do the methods used to derive the RfDs for GenX chemicals appropriately account
for uncertainties in evaluating the toxicokinetic differences between the
experimental animal data and humans?
Yes, the methods used do account for the appropriate uncertainties.
5.	EPA has evaluated and applied where appropriate uncertainty factors to account for
intraspecies variability (UFH), interspecies differences (UFA), database limitations (UFD),
duration (UFS), and LOAEL-to-NOAEL extrapolation (UFL) for GenX chemicals.
a.	Has uncertainty been adequately accounted for in the derivation of the RfDs? Please
describe and provide suggestions, if needed.
Yes. The use of uncertainty factors was used according to EPA guidance (USEPA, 201 lb). The
authors were unable to find any human epidemiological studies, so an UF of 10 was used
appropriately. The application of a UF of 3 for interspecies differences is appropriate as well because
the chronic cancer bioassays were performed in rat and not mouse, with the several studies herein
demonstrating that rats appear to be a less sensitive species than mouse. Lastly, a UFD of 3 is in
agreement with the guidance, as there are many knowledge gaps for GenX. Lastly, uncertainty for
intraspecies variability and database limitations must be included. Currently there are no studies to
address whether developmental or immunotoxicity is observed at exposures lower than the 0.1
mg/kg RfD that was observed for liver effects in male mice.
b.	Does the provided scientific rationale support the application of the selected
uncertainty factors? Please explain.
Yes, Section 7 did outline and provide sufficient rationales for the application of the selected
uncertainty factors. See response in part a.
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Response to Peer Review Comments-GenX Chemicals
November 2018
6. The draft assessment for GenX chemicals identifies liver effects as a potential human
hazard. EPA evaluated the available evidence for liver effects, including the potential role
of PPARa, using Hall et al. (2012) criteria for adversity.
a.	Please comment on whether the available data have been clearly and appropriately
synthesized for these toxicological effects.
Yes, the review agrees with the overall conclusion of the authors in section 4.7 for the mode of
action. The conclusion from the document is that the findings are not adequate to definitely conclude
that a PPARa mechanism of action (MOA) exists for HFPO dimeric acid and/or ammonium salt.
There is a lack of publications that have evaluated the mechanisms of action for GenX and the
authors cannot draw firm conclusions regarding PPARa involvement with limited findings. This is
based on a study by Wang et al., 2016 that administered 1 mg/kg/day via oral gavage for 28 days to
male ICR mice that was not considered to be of high qualitative determination because it lacked
sufficient quality in multiple elements. The finding from this study, point to treatment with the
HFPO dimeric acid ammonium salt impacting pathways in liver for PPARa signaling, retinol
catabolism, and fatty acid degradation, however the lack of rigor in the experimental design limits
the interpretation. The authors do cite Dupont-24459 2008 and Dupont-24447 2008 with some
potential endpoints that are consistent with peroxisome proliferation (i.e. hepatic (3-oxidation),
however they do not identify PPARa as the cause for the observed effects. Thus, the conclusion that
the findings are not adequate to definitely that a PPARa mechanism of action (MOA) exists for
HFPO dimeric acid and/or ammonium salt is appropriate.
b.	Please comment on whether the weight of evidence for hazard identification has
been clearly described and scientifically justified.
Yes. The weight of evidence (WOE) for hazard identification has been clearly described and
scientifically justified in this document. The WOE is based on the liver being a target organ for
toxicity from the oral exposure to HFPO dimeric acid. The document cites liver effects for both male
and female mice and rats, with male mice being the most sensitive species. This conclusion is based
on several studies carried out in which the test methods and study design meet criteria as being
"high" in quality. These studies assessed the impact of GenX in numerous endpoints (i.e. gross
measures such as food consumption, appearance, serum clinical markers of injury, gross organ
changes, and tissue pathology). These studies did evaluate relative liver weight and hepatocellular
hypertrophy in the context of evidence of hepatic necrosis, as measured by serum enzyme levels and
evidence of cellular necrosis.
c.	Please comment on whether the conclusions regarding adversity are scientifically
supported and clearly described.
Yes, the conclusions regarding adversity are scientifically supported and clearly described. There
were no human epidemiology studies for GenX to base adversity, so rodent studies were used as a
basis for the RfD. The conclusion is that 0.1 mg/kg/day causes liver effects that are observed as
single cell necrosis in males (DuPont-18405-1037 2010). Other studies presented in the document
(refer to Table 7) also support liver effects being considered the adverse effect for GenX at similar
NOAELS (Dupont-24459, DuPont-18405-1238). Because these studies evaluated necrosis and liver
weight and found evidence for cytotoxicity, they meet the concern for adversity as outlined by Hall
et al. 2012). In addition, because there is a lack of substantive information regarding the mechanism
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Response to Peer Review Comments-GenX Chemicals
November 2018
of action for GenX in rodent and cell-based studies, the role of PPARa as being the cause for the
observed liver effects, such as liver weight and single-cell necrosis, cannot be concluded.
7.	The draft assessment concludes that there is suggestive evidence of carcinogenic potential
for GenX chemicals and that this descriptor applies to oral routes of human exposure
(USEPA 2005). Please comment on whether the available animal and mechanistic studies
support this conclusion.
The conclusion is based on evidence that the liver is the target organ for toxicity and primary organ
for tumor development. The lack of cancer bioassay data using mice, which are the more sensitive
species, limits the conclusion. The conclusion is based on findings from a study that meets the
review criteria as being of high consideration and is in line with the EPA's Guidelines for
Carcinogenic Potential for Carcinogen Risk Assessment (USEPA, 2005). Based on this document, is
appropriate to make this conclusion based on the literature collected and studies that met criteria for
consideration. Moreover, the lack of substantive information regarding PPARa activation does not
allow one to rule out the potential for PPARa-independent activation contributing to the observed
liver effects.
8.	Editorial or Additional Comments: Please provide any editorial or additional comments
you would like to make here. These should be any comments that are not in direct response
to the technical charge questions above.
The document reads well and summarizes the findings appropriately.
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Response to Peer Review Comments-GenX Chemicals
November 2018
COMMENTS SUBMITTED BY
David Alan Warren, MPH, PhD
Program Director, Environmental Health Science
University of South Carolina Beaufort
Beaufort, South Carolina
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Response to Peer Review Comments-GenX Chemicals
November 2018
External Peer Review of EPA's Draft Human Health Toxicity Values
for Hexafluoropropylene Oxide (HFPO) Dimer Acid
and its Ammonium Salt (GenX Chemicals)
1.	The document describes the process for identifying and selecting pertinent studies. Please
comment on whether the literature search strategy, study selection considerations, and
study evaluation considerations are appropriate and clearly described. Please identify
additional peer-reviewed studies that the assessment should consider.
Sections 3.3.1 (Literature Search Strategy and Results) and 3.3.2 (Study Screening Process and
Study Evaluation) succinctly describe a laborious task that requires considerable skill if done
well. I have refrained from using the phrase "done correctly" in recognition of the subjective
judgments inherent to the process. The search of public literature is clearly comprehensive, as I
was able to locate only one additional study that might be worthy of inclusion in the toxicity
assessment (see below). Admittedly, I am unsure as to whether it meets the inclusion-exclusion
criteria in Table A-5. Based on its title and abstract, it might be appropriate to include in Section
1.3 (Occurrence). As for the screening process and evaluation of manufacturer-submitted studies,
like the toxicity assessment, I too acknowledge the importance of adherence to OECD/EPA TGs
and GLP. And while I find the scoring system and qualitative rating process a bit arbitrary, the
evaluation domains and metrics within them make for a transparent means in the pursuit of
consistency and ultimately, validity in toxicity values. Therefore, I support the study evaluation
process while encouraging its refinement over time.
Additional Peer-Reviewed Study
1. WA Gebbink, L van Asseldonk, and SPJ van Leeuwen. Presence of Emerging Per- and
Polyfluoroalkyl Substances (PFASs) in River and Drinking Water near a Fluorochemical
Production Plant in the Netherlands. Environ. Sci. Technol.. 51(19): 1 1057-1 1065. October 3.
2017.
The above study investigated the presence of legacy and emerging PFAS (including GenX) in
river water collected in 2016 up- and downstream from a fluorochemical production plant in The
Netherlands. Additionally, drinking water samples were collected from municipalities in the
vicinity of the production plant, and like the river water, were positive for GenX.
2.	For GenX chemicals the critical study chosen for determining the subchronic and chronic
RfDs is the oral reproductive/developmental toxicity screening study in adult mice (DuPont
18405-1037, 2010) and the critical effect is liver effects (single cell necrosis) in adult males.
Is the selection of the critical study and critical effect for the derivation of the subchronic
and chronic RfDs for GenX chemicals scientifically justified and defensible?
a.	If so, please explain your justification.
b.	If not, please provide your rationale and detail an alternative critical study and/or
critical effect you would select to support the derivation of the subchronic and
chronic RfDs.
Selection of the gavage study of reproduction/developmental toxicity in mice (DuPont 18405-
1037, 2010) and single cell necrosis for toxicity value derivation are scientifically justified and
well defended in the toxicity assessment. However, the dismissal of studies from further
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Response to Peer Review Comments-GenX Chemicals
November 2018
consideration as the critical study on the basis of NOAEL alone (i.e., having a NOAEL >0.1
mg/kg/day) is a questionable practice. This is especially true when a dismissed study's NOAEL
is but an order of magnitude greater than that of the critical study (i.e., 1 mg/kg/day), a difference
dwarfed by the total UF applied to toxicity value derivation. Nonetheless, Section 6.1 makes a
convincing case for selection of critical study and effect, especially with regard to preference for
liver necrosis over a hematological or immunological effect and use of a subchronic study for
chronic RfD derivation in lieu of a chronic toxicity/oncogenicity study reporting the same critical
effect, albeit at a considerably higher dose in a less sensitive species.
3.	EPA employed benchmark dose modeling in the identification of a point-of-departure
(POD) for GenX chemicals (USEPA 2012). Is the modeling approach, selection of
benchmark response level, and the selected model used to identify the POD for derivation
of the RfD scientifically justified and defensible?
Application of BMD modeling to data from two of three studies having NOAELs of 0.1
mg/kg/day was appropriate for POD identification, as neither sex of rats in the third study
(DuPont-17751-1026 2009) exhibited liver necrosis. The modeling approach appears consistent
with USEPA's Benchmark Dose Technical Guidance document, including use of dichotomous
models, selection of BMR, and inclusion of data from all dose groups given an adequate model
fit when none are omitted. Criteria for model selection appears to be largely consistent with
Agency guidance, as well. For example, model selection considerations included those with
goodness of fit p-values >0.1, lowest Akaike's Information Criterion (provided BMDLs are
"sufficiently" close), sufficiently small BMD:BMDL ratios, and lowest scaled residuals for doses
near the BMD/BMDL. In addition, fitted curves of incidence rate as a function of dose allowed
for an assessment of visual fit. Finally, selection was made of the lowest BMDL (0.15
mg/kg/day), which was one-half that of the alternative derived from the 28-day gavage study in
mice. As such, the toxicity assessment's BMD modeling results were obtained using time-tested
and widely-accepted methods and model choice decision logic, making it scientifically justified
and defensible. It is noteworthy that such methods stand in stark contrast to the means by which
North Carolina derived a drinking water equivalent level on the basis of an RfD derived by
application of a total UF of 1,000 to the NOAEL of 0.1 mg/kg/day for single cell necrosis in the
liver.
4.	Given what is known and not known about the interspecies differences in toxicokinetics of
GenX chemicals, EPA applied body weight to the % allometric scaling to adjust the POD to
estimate a human equivalent dose (HED) in the derivation of the respective RfDs (USEPA
2011).
a.	Is applying the body weight to the 3A for GenX chemicals scientifically justified and
defensible? If not, please provide your rationale and detail the alternative approach
you would use.
b.	Do the methods used to derive the RfDs for GenX chemicals appropriately account
for uncertainties in evaluating the toxicokinetic differences between the
experimental animal data and humans?
Yes, use of the default dosimetric adjustment factor (DAF) of bw to the 3/4 is scientifically
justified and defensible given the lack of a PBPK model for GenX (possibly excluding that of
Gomis et al., 2018), paucity of toxicokinetic data in experimental animals and their absence in
humans, and little mechanistic information to inform the issue of how internal dose relates to the
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Response to Peer Review Comments-GenX Chemicals
November 2018
nature, magnitude, and time-course of biological effects. As noted in the toxicity assessment, its
use is also justified given GenX's lack of metabolism, relatively short clearance time compared
to longer-chain PFAS, and application to adult mice as opposed to those in earlier life stages.
Furthermore, the default approach is consistent with the hierarchy of approaches for
interspecies extrapolation clearly expressed by USEPA in multiple documents, including
Recommended Use of Body Weight3/4 as the Default Method in Derivation of the Oral Reference
Dose and Harmonization in Interspecies Extrapolation: Use of BW3/4 as Default Method in
Derivation of the Oral RfD. The toxicity assessment's use of a UF of 3 for interspecies
differences is also consistent with Agency guidance, as the default DAF appropriately addresses
some, but not all, of the considerable cross-species uncertainties in both GenX toxicokinetics and
toxicodynamics. Lastly, it is encouraging to see the use of an updated body weight for adult
humans in the DAF equation (i.e., 80 kg), a minor change, but one that increases confidence that
the toxicity assessment reflects the state-of-the-science.
5.	EPA has evaluated and applied where appropriate uncertainty factors to account for
intraspecies variability (UFH), interspecies differences (UFA), database limitations (UFD),
duration (UFS), and LOAEL-to-NOAEL extrapolation (UFL) for GenX chemicals.
a.	Has uncertainty been adequately accounted for in the derivation of the RfDs? Please
describe and provide suggestions, if needed.
b.	Does the provided scientific rationale support the application of the selected
uncertainty factors? Please explain.
Yes, the considerable uncertainty surrounding the risk of GenX exposure has been adequately
accounted for in the toxicity assessment. Section 6.4.2 does a good job of explaining the
rationale behind each individual UF value and I agree with the total UFs of 100 and 300 used for
RfD derivation.
6.	The draft assessment for GenX chemicals identifies liver effects as a potential human
hazard. EPA evaluated the available evidence for liver effects, including the potential role
of PPARa, using Hall et al. (2012) criteria for adversity.
a.	Please comment on whether the available data have been clearly and appropriately
synthesized for these toxicological effects.
b.	Please comment on whether the weight of evidence for hazard identification has
been clearly described and scientifically justified.
c.	Please comment on whether the conclusions regarding adversity are scientifically
supported and clearly described.
The toxicity assessment, particularly Section 5.1, does an admirable job of synthesizing the
available data on liver effects and making the case (using a weight-of-evidence approach) for
GenX exposure as a potential hazard to the human liver provided a threshold dose is met.
Concern that the liver may not be the most appropriate target organ for RfD derivation is
minimal at best, as four manufacturer-submitted studies reported liver effects at the LOAEL. In
these studies, effects were seen in both sexes of mice and rats under conditions of varying
exposure magnitude and duration. Furthermore, the critical effect of single-cell necrosis typically
co-occurred with liver hypertrophy, increased relative liver weight, and/or elevated liver
enzymes, not to mention liver tumors in chronically-treated, high dose, female rats. As for the
issue of whether hepatic hypertrophy and increased relative liver weight are "adverse", the
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Response to Peer Review Comments-GenX Chemicals
November 2018
toxicity assessment clearly warns against the use of such an unqualified label in the event such
effects are PPARa-mediated. This is consistent with the consensus opinion of Hall and
colleagues (an expert panel of workshop attendees) that hepatic hypertrophy, in the absence of
histologic or clinical pathology, should be considered adaptive or non-adverse. Given the weight
ascribed to the Hall et al. (2012) publication by the toxicology community, and deservedly so, it
is appropriate that USEPA share the same opinion in the absence of evidence to the contrary.
7.	The draft assessment concludes that there is suggestive evidence of carcinogenic potential
for GenX chemicals and that this descriptor applies to oral routes of human exposure
(USEPA 2005). Please comment on whether the available animal and mechanistic studies
support this conclusion.
I agree that the one chronic toxicity/oncogenicity study is suggestive of carcinogenic potential
for GenX, and in the absence of information that the observed tumors were rat-specific, believe
the weight-of-evidence descriptor should apply to humans exposed via the oral route. Sections
4.4 and to a greater extent, 5.6, speak to the considerable weaknesses in the cancer bioassay data.
Nonetheless, liver and pancreatic tumors in GenX-exposed female and male rats, respectively,
were significantly elevated over controls. As rats have been shown to be considerably less
sensitive than mice to many non-cancer effects of GenX, a chronic bioassay in the more sensitive
species would be a logical next step. While the toxicity assessment provides an informative
overview of mode of action possibilities (e.g., cytotoxicity followed by reparative proliferation,
genotoxicity though the data are mixed, and promotion mediated by PPARa), data are
insufficient to select one over the others. Obviously, if the observed liver tumors in rats were
PPARa-mediated, humans would be resistant to tumor induction via this mechanism.
8.	Editorial or Additional Comments: Please provide any editorial or additional comments
you would like to make here. These should be any comments that are not in direct response
to the technical charge questions above.
The toxicity assessment is well written, though there are numerous minor errors in syntax,
subject-verb agreement, and punctuation, none of which detract significantly from the effort.
Overall, the toxicity assessment should be characterized as a high-quality work product typical of
USEPA. See several recommendations for minor editorial changes below.
1.	the toxicity assessment might want to note that Pan et al. (2017) not only examined blood,
liver and muscle of common carp, but also found detectable levels in the sera of Chinese
residents residing near the fluoropolymer production plant
2.	on p. 13, "fetus mice" might be better expressed as "fetal mice"
3.	Table 2 at the end of the 1st two paragraphs on p. 16 should be Table 3
4.	the last sentence on p. 19 should read 28 and 95, not 28 and 90
5.	change lines 6 and 7 on p. 20 to read .. .(e.g., effects such as liver toxicity), and populations
at risk of exposure to HFPO....;
6.	change "undermined" to "undetermined" toward the bottom of p. 31
7.	place a period after (0%-8.3%) on p. 36 and begin a new sentence
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Response to Peer Review Comments-GenX Chemicals
November 2018
8.	insert the word "study" after toxicity in the 1st line of the last paragraph on p. 38
9.	consider rewriting the paragraph immediately before section 4.6 to read as follows: The
NOAEL for this prenatal and developmental toxicity study is 10 mg/kg-day based on an
increase in early deliveries, decreases in gravid uterine weight, and decreased fetal weights
for both sexes, all having a LOAEL of 100 mg/kg-day
10.	should the "to" in the fourth sentence on p. 41 be changed to "did"
11.	delete the word "increasing" from the 8th line of paragraph 2 on p. 43
12.	consider an alternative to the phrase "suggestive of hazard" on p. 45
13.	delete the word "female" in the 2nd line of the 2nd paragraph of Section 5.5 on p. 46
14.	insert the word "consider" or "select" after the word "not" in line 7 of p. 51
15.	consider changing the first sentence on p. 52 to read as follows: Additionally, there were
increases in serum liver proteins at 0.5 mg/kg-day in males, though they did not statistically
significantly differ from control
16.	delete "by" or "via" from the last sentence of the 1st paragraph on p. 53
17.	consider changing the phrase "liver as a hazard" at the end of the 1st paragraph on p. 58
18.	insert the word "studies" after "other" in line 4 of the 2nd paragraph on p. B-l
19.	change nominator to numerator on p. B-l 1
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